EmissionLink warns against ‘bargain hunt’ approach to FuelEU Pooling

With the EU ETS reporting deadline passed and FuelEU Maritime enforcement fast approaching, EmissionLink Managing Director, Philippos Ioulianou (pictured), has cautioned shipowners against treating compliance pooling as a cost-cutting exercise, warning that a cheap pool that hides risk is worse than no pool at all.

Pooling has rapidly become one of the industry’s hottest topics as operators seek efficient pathways to meet FuelEU and ETS obligations. Yet according to Mr Ioulianou, a fixation on price risks undermining the very purpose of the regulation.

“FuelEU pooling isn’t a procurement exercise,” he said. “It’s a fundamental shift in regulatory responsibility. If shipowners view it simply as a budget line item, they risk stepping into the very pitfalls the regulation was designed to prevent.”

Pooling allows operators, particularly smaller fleets or those lacking access to alternative fuels, to aggregate carbon performance across vessels. When managed correctly, it can smooth compliance and lower costs. But mismanaged pooling can expose participants to significant liabilities.

Once in a pool, a vessel’s carbon intensity is tied to that of every other participant. If one underperforms, or if the pool manager fails to act, all members face penalties. That raises crucial governance questions around performance monitoring, mid-year corrective actions, and responsibility for penalties or surpluses.

Mr Ioulianou warns that many pooling schemes on offer today focus mainly on cost, often using market indexes as benchmarks, while ignoring governance, accountability, and risk management.

“Price references may guide cost but they don’t account for who’s responsible when things go wrong. Strong governance, continuous monitoring, and maritime expertise are what make pooling viable. Without them, the compliance risk multiplies.”

Drawing parallels with the IMO’s proposed Net-Zero Framework (NZF), Mr Ioulianou noted that similar governance challenges are emerging at a global level.

“The same dynamic is visible in the IMO debate. Ambition is outpacing accountability. Regulators are setting decarbonisation timelines that don’t fully reflect fuel availability or technological maturity. The lesson is clear,  without governance and industry alignment, frameworks don’t reduce risk—they redistribute it.”

As Columbia Group CEO Mark O’Neil observed during LISW, the gap is most evident with alternative fuels. Their potential is clear, but the challenges of adoption and the pace at which the industry can transition must be carefully managed.

Central to EmissionLink’s approach is the belief that pooling only works when built on transparency, continuous monitoring and maritime expertise. Participants must know how performance is tracked continuously, not just at reporting deadlines, and someone must carry responsibility if things go wrong.

Mr Ioulianou urged shipowners to ask critical questions before joining any pooling scheme:

- Who manages the data and reporting, and how accurate are they?

- What happens if performance dips?

- How are penalties and surpluses distributed?

- How do FuelEU, EU ETS, and IMO frameworks align—or conflict?

“In compliance, as in shipping, you get what you pay for,” Mr  Ioulianou concludes. “Don’t be seduced by the cheapest pool. Look for partners with the expertise, systems, and integrity to manage risk—because compliance doesn’t come cheap, and neither should your standards.”