Answer to a written question – Possible double counting of CO2 and distortions caused by unclear rules on the use of subsidised options such as biomethane to meet requirements – E-001494/2025(ASW)

Source: European Parliament

Under Directive (EU) 2018/2001 (Renewable Energy Directive — RED)[1], greenhouse gas (GHG) emission reductions are counted towards Member States’ renewable energy targets, while under Regulation (EU) 2023/1805 (FuelEU)[2] shipping companies are the obligated parties.

FuelEU does not exclude emissions reductions supported via other legal frameworks, such as the support schemes under RED, as doing so might lead to competitive disadvantages for the sector, and slow down investments in decarbonised marine fuels.

Support schemes under RED are specified as transposed by the Member States, taking in consideration the national energy policies’ features and priorities.

FuelEU enforcement relies on the well-established framework of the EU Monitoring, Reporting, and Verification Maritime Regulation[3] used by Member States’ Competent Authorities.

Shipping companies have to certify fuels’ sustainability using RED traceability rules and governance for all fuel batches claimed to count towards their obligation under FuelEU.

The traceability system of the Union database, deployed under Article 31a of RED, will be applied. Thus, fuel volumes and emissions reductions reported under FuelEU and RED can be tracked and verified.

Beyond dedicated webinars, updated THETIS-MRV[4] tutorials, and dedicated helpdesk support, the Commission will adopt its guidance document for FuelEU Implementation in the second semester of 2025.

The provision in the EU emission trading system (ETS) Directive 2003/87/EC[5] on avoiding double counting of emissions applies to the reporting and surrendering of allowances within the ETS compliance framework.

It does not apply — but rather exerts synergetic effects — to emission reductions in sectoral regulations with which it is complementary, FuelEU being one such case.

  • [1] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02018L2001-20240716.
  • [2] https://eur-lex.europa.eu/eli/reg/2023/1805/oj/eng.
  • [3]  Regulation (EU) 2015/757: https://eur-lex.europa.eu/eli/reg/2015/757/oj/eng.
  • [4] https://mrv.emsa.europa.eu/.
  • [5] https://eur-lex.europa.eu/eli/dir/2003/87/oj/eng.