FuelEU Maritime pooling is no silver bullet, ZERO44 warns

September 10, 2025, by Ajsa Habibic

While often presented as the simplest solution to meet the requirements of the FuelEU Maritime regulation, pooling can become a long-term cost trap for shipowners, Berlin-based platform ZERO44 warned in its new whitepaper.

Since the beginning of 2025, when the FuelEU Maritime regulation entered into force, ship operators in the European Union (EU) have been required to report their fuel consumption and greenhouse gas (GHG) intensity, and face penalties of several hundred thousand euros per vessel annually if the permitted threshold is exceeded.

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One of the compliance options includes pooling, which allows deficits to be offset by the surpluses of more efficient vessels. However, these surpluses do not arise automatically and are typically the result of costly measures such as the use of biofuels, onshore power, or investments in wind propulsion – costs that are ultimately reflected in the price of pooling, ZERO44 explains.

In its new whitepaper titled ‘FuelEU Maritime: Beyond the Pooling Hype’, ZERO44 analyzes four pooling provider models and their services with respect to managing compliance, price and counterparty risks, and highlights alternatives to pooling.

The whitepaper warns that, even though pooling promises quick relief, the reality is more complex, suggesting that alternative strategies are cheaper in the long term.

As explained, strategies such as biofuel blending, internal pooling, or technical measures can achieve the same compliance goals at significantly lower cost than pooling.

The paper points out that the key for companies is to clearly define their own willingness to pay for external pooling and realistically evaluate 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,” said Friederike Hesse, Co-Founder and Managing Director of ZERO44.

“With our whitepaper, we aim to provide more transparency and clarity, and give shipping companies a fact-based foundation for their decisions.”

Founded in Berlin in 2022, ZERO44 aims to help shipowners, ship managers, and charterers plan and optimize their CO2 emissions by combining the management of CII, EU ETS, and FuelEU Maritime in one solution.