EU ETS for maritime FAQ

EU ETS for maritime

Frequently asked questions

In this overview, we try to answer the most pressing questions on MOHA, Union Registry accounts, administering authorities, etc. – and yes, we will also touch on the famous list containing shipping companies and EU Member States.

If you're looking to register for MOHA, use the zero44 MOHA registration service below.

What types of accounts are relevant for maritime?

In the end, there is only one relevant Union Registry account for shipping: the maritime operator holding account (MOHA). It’s only available for companies affected by the regulation and is required to surrender EUA. But, as of today, it is currently not possible to open these accounts because the Union Registry needs to be adapted so that these new accounts can be set up. You can try it yourself by going to e.g. the German section of the Union Registry, selecting “Account Request” and the dropdown for “Type” where no MOHA is selectable.

Having said that, Spain does accept registrations for MOHA now through a separate form published on the website of the Spanish authorities.

I heard Malta is a good option for opening a trading account. Is this true?

Malta used to be less strict on Union Registry signup requirements, as no local entity or permanent residence was required. However, the Maltesian authorities have yet to accept new registrations due to increasing demand.

When can I open a maritime operator holding account?

That is hard to say as Germany, and Norway, for example, currently inform that before April 2024, the MOHA will not be ready to open. If you want to receive information from zero44 once the MOHA account can be opened, please drop us a line.

Having said that, Spain does accept registrations for MOHA now through a separate form published on the website of the Spanish authorities.

Where can I check in which EU member state I need to set up my MOHA account?

The European Commission published the „list of shipping companies specifying the administering authority“ in late January 2024; you can find the list here. This list informs shipping companies about their attributed member state (i.e., administering authority). If you find your company on that list, you will know in which national section of the Union Registry you need to open your MOHA account.

I’m seeing many reports online that say I must open a MOHA within 40 days of the list being published. Should I be worried?

No. As discussed above, while the European Commission set a 40-day timeline for MOHA setup after publishing the list, neither the Union Registry nor the respective administering authorities across EU member states can offer MOHA setup currently.

My company is not based in the EU and is not on the list. What now?

Generally, the European Commission refers to Article 3gf “Administering authority in respect of a shipping company” of the EU ETS directive. Three scenarios are possible:

Your company is registered in an EU Member State: This Member State will be the administering authority and your need to apply for a MOHA there

Your company is not registered in an EU Member State: Your administering authority will be the Member State your fleet called the most during the last four years.

Your company is not registered in the EU and your fleet did not call at an EU port during the last four years: Your administering authority will be the EU Member state of your first EU port call in 2024.

The European Commission advises that companies should identify which is their administering authority via the THETIS-MRV system (source). We recommend reaching out to the THETIS-MRV help desk via thetis@emsa.europa.eu.

I need to start collecting EUA from counterparties. How can I do that now?

Currently, the only option to physically receive EUA from Charterers or to transfer EUA to owners is to open a Trading Account in the Union Registry. Trading accounts can be opened by everyone in all EU member states, and we highly recommend setting one up to bridge the gap until MOHA is available. Once the MOHA is available, you can quickly transfer all EUA from your trading account to your new MOHA and close down the trading account. Or you could keep it as a means to handle all transactions via one account and surrender from there to different MOHAs you might require.

Essential details on trading accounts:
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1. Trading accounts in the Union Registry require at least two authorized natural persons to be listed during the application process.

2. No compliance-related transactions (i.e., surrendering, verifying, entering CO2 emission) can be executed from trading accounts.

While specific requirements can vary across EU member states, almost all require a legal entity registered in the country where the account should be set up. At least one authorized natural person with access to the account must have permanent residence there. Please reach out if you need guidance on these requirements; we can help you with an overview.

My company does not have a presence in the EU, so I can’t open a trading account – what should I do?

In cases where there is no option to open a trading account in any of the EU member states’ sections in the Union Registry, we recommend reaching out to service providers who offer EUA storage solutions, e.g., Berenberg Bank, CFP Energy (offering EUA depot solutions), or ACT Commodities and Aither (offering custody foundation allowing to store, receive, and transfer EUA without requiring an own trading account). Please reach out to us if you need further information.

Why am I not on the list published by the European Commission?

The list is based on the THETIS-MRV database and covers all entities with a company account with at least one vessel registered under that account in THETIS-MRV on 20 November 2023. If you are a shipowner and your DOC holder usually takes care of everything EU-MRV-related, you might not be on the list.

I’m not on the list. Does EU ETS not apply to me?

No. Including a shipping company in the EU ETS is not dependent on being included in the list.

How do I surrender EUA?

You surrender EUA via your MOHA in the Union Registry. Surrendering from trading accounts is not possible.

When can I start surrendering EUA?

As soon as your MOHA is ready. You do not need to wait until September 2025 to surrender EUA but can start right away. Surrendering needs to be completed by September 2025, not in September 2025. We can walk you through the process in detail, please reach out in case you have any questions.

Do I have to open one MOHA per vessel?

That depends on your specific company structure, so a general answer or advice on this question is tricky without knowing your setup. Please reach out to us if you have questions on this topic. We’re happy to help and will walk you through the regulatory landscape.

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