The European Shippers’ Council together with other associations representing EU terminal operators, tugowners, maritime pilots, agents, and freight forwarders (FEPORT, ETA, EMPA, ECASBA, and CLECAT) support the spirit of the ETS Maritime. They welcome initiatives that stimulate the decarbonization of maritime shipping and the greening of the fleets. The way that ETS Maritime is currently envisaged, however, raises grave concerns about the extra-EU application of ETS Maritime in view of the serious risk of carbon leakage and business leakage at the expense of EU ports. ETS costs related to extra-EU voyages can be easily avoided or reduced by calling at ports outside the EU or through transhipment.
The associations are well aware of the EU Commission’s efforts to address the risks of carbon and business leakage by including a definition of “port of call” in the revised ETS Directive which only incorporates ports where ships stop to load or unload cargo, or embark or disembark passengers while excluding calls in “neighbouring container transhipment ports” which are located less than 300 nautical miles from the EU and have a transhipment incidence exceeding 65%.
It is reassuring that the revised ETS Directive contains a review clause which requires the Commission to monitor changes in port traffic such as shifts to non-EU ports as a consequence of the extra-EU application of ETS maritime and to report on this biennially, while obliging the Commission to propose measures to address this if evasion is indeed established.
The above-described measures are unfortunately not sufficient with regards to the loopholes that have been identified, and which provide evidence that costs associated with the extra-EU application of EU ETS can still be avoided.
The associations addressed the European Commission and explained the risks associated with the provisions of the revised ETS directive.
For more information, please see the Joint Letter sent to the EC by the European Shippers’ Council (ESC), Federation of European Private Port Operators (FEPORT), European Tug owners’ Association (ETA), European Maritime Pilots’ Association (EMPA), European Association for Forwarding, Transport, Logistics and Customs Services (CLECAT), and the European Community Association of Ship, Brokers and Agents (ECASBA).