German technology firm ZERO44 is encouraging shipowners to reconsider heavy reliance on pooling models for FuelEU Maritime compliance, warning that such approaches may prove costlier than expected.
A new whitepaper, “FuelEU Maritime: Beyond the Pooling Hype”, analyses four pooling provider models and suggests that alternatives—such as biofuel blending, internal pooling, or technical upgrades—are often more cost-effective in the long run.
Since January 2025, FuelEU Maritime requires ships trading in the EU to report fuel consumption and keep greenhouse gas intensity under strict thresholds. Penalties for exceeding the allowed levels can amount to several hundred thousand euros per vessel annually.
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While pooling lets less-efficient vessels offset their deficits by borrowing surplus performance from cleaner vessels, the whitepaper notes that such surpluses typically result from expensive measures—including advanced fuels or wind propulsion—that drive up the costs of pooling itself.
ZERO44’s analysis finds that internal strategies to manage emissions—as opposed to joining external pools—can achieve regulatory targets at lower total cost, provided ship operators evaluate their willingness to pay and consider realistic alternatives.
“Pooling is no cure-all. Anyone using it should be clear about the price and the partners they engage with. In the long term, strategic fuel decisions often lead to lower costs and greater control,” commented Friederike Hesse, Co-Founder and Managing Director.
The whitepaper details the strengths and pitfalls of four popular pooling models: brokers, organisers, traders, and technology platforms. It concludes that there is no universal solution, and each choice depends on the operator’s operational model and risk preference.
The whitepaper is available for download on the ZERO44 website.
