FuelEU Maritime’s pooling mechanism is supporting growing demand for liquefied biomethane (LBM/bio-LNG), while creating financial incentives for shipowners to exceed
FuelEU Maritime’s pooling mechanism is supporting growing demand for liquefied biomethane (LBM/bio-LNG), while creating financial incentives for shipowners to exceed greenhouse gas emissions requirements, according to a new analysis by Titan Clean Fuels.
In its white paper, “FuelEU Maritime: The Methane Pathway is the Way to Compliance”, Titan, examines how LNG, LBM and e-methane can contribute to regulatory compliance, with particular attention to the commercial opportunities created by pooling arrangements.
According to Titan, LBM increased from 6.5% to 19.1% of its total methane fuel deliveries between 2024 and 2025, largely supported by demand from operators seeking to generate surplus FuelEU compliance balances. The company also cites Port of Rotterdam figures indicating that LBM bunkering volumes increased sixfold in 2025 compared with the previous year.
The findings suggest that FuelEU Maritime is influencing fuel purchasing decisions as operators seek to balance regulatory compliance, fuel costs and potential revenues from exceeding emissions targets.
Pooling creates financial incentives for lower-emission fuels
Under FuelEU Maritime, vessels must meet progressively tighter limits on the greenhouse gas intensity of energy used onboard, calculated on a well-to-wake basis. The regulation allows operators to combine the compliance balances of different vessels through pooling, enabling ships exceeding their emissions requirements to offset deficits elsewhere in the pool.
This flexibility is available across different operators, allowing surplus compliance to be transferred under commercially negotiated arrangements.
Titan argues that pooling enables shipowners to concentrate investments in alternative fuels and newer vessels while managing compliance across existing fleets, rather than requiring every ship to achieve the same level of emissions performance individually.
The company has completed its first year managing a FuelEU Maritime pool involving several hundred vessels, with the pooling arrangements verified by DNV.
Containership model highlights potential compliance value
To illustrate the financial implications, Titan modeled an 8,000 TEU containership operating a Northern European route covering Rotterdam, Antwerp, Hamburg and Algeciras, with annual fuel consumption equivalent to approximately 18,000 metric tons of LNG within FuelEU Maritime’s scope.
The analysis compares three scenarios: conventional fuel oil, fossil LNG and LNG blended with 30% LBM.
Under the fuel oil scenario, the vessel would face an estimated FuelEU penalty of approximately €2.2 million in 2025, increasing to around €17 million by 2040 as emissions intensity requirements tighten.
By comparison, the LNG-fueled vessel would generate approximately 11,700 tonnes of CO₂-equivalent surplus compliance in 2025 and remain compliant through 2035 under the modeled assumptions.
From 2040, Titan estimates that blending approximately 15% LBM with LNG would restore compliance. Increasing the LBM share to 30% could generate more than 34,000 tonnes of CO₂-equivalent surplus compliance annually.
At indicative pooling-market values of €100–150 per tonne of CO₂-equivalent, that surplus could represent approximately €3.4 million–€5.1 million in annual gross transferable compliance value.
However, Titan acknowledges that the actual commercial benefit would depend on negotiated pooling prices and the additional cost of LBM compared with fossil LNG. The figures are modeled estimates and do not represent guaranteed returns.
Titan calls for revised LNG emissions factors
Beyond pooling, the white paper argues that FuelEU Maritime’s default emissions factors should better reflect improvements in LNG supply chains and engine technologies.
Titan cites Rystad Energy’s Well-To-Tank Emissions Assessment 2025, which estimated the average well-to-tank emissions intensity of LNG used as marine fuel in 2024 at 13.9 gCO₂eq/MJ, compared with FuelEU Maritime’s default value of 18.5 gCO₂eq/MJ.
According to Titan, the difference highlights the need to update default values more regularly or allow verified emissions factors reflecting the actual performance of individual supply chains.
The company also emphasizes ongoing efforts to reduce methane leakage during fuel production and distribution, as well as methane slip from ship engines.
It argues that more accurate recognition of verified emissions performance would strengthen incentives for operators to adopt lower-emission technologies and fuel supply arrangements.
Fuel availability and costs remain important considerations
The report identifies LBM as a near-term compliance option for LNG-fueled vessels because it can be blended with fossil LNG and used through established bunkering infrastructure.
Titan highlights examples involving Brittany Ferries and United European Car Carriers (UECC), which have used LBM to reduce lifecycle emissions and manage their FuelEU compliance positions.
For UECC, Titan estimates that the LBM it supplied during 2025 avoided more than 75,000 tonnes of CO₂-equivalent emissions.
Nevertheless, the white paper acknowledges uncertainty over the future availability of sustainable biomethane feedstocks, particularly as demand develops across shipping and other transport sectors.
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