• FuelEU Maritime can result in penalties of hundreds of thousands of euros per vessel.

• Pooling promises quick relief but often turns into a cost trap.

• ZERO44’s new whitepaper analyzes four pooling provider models and their services with respect to managing compliance, price and counterparty risks, and highlights alternatives to pooling.

Pooling is often presented as the simplest answer to the requirements of the FuelEU Maritime regulation. But the reality is more complex: in many cases, other strategies such as biofuel blending, internal pooling, or technical measures are cheaper in the long term. This is the conclusion of a new whitepaper from ZERO44. Published under the title “FuelEU Maritime: Beyond the Pooling Hype”, it provides shipping companies with an in-depth analysis and concrete recommendations for action.

Pooling is no silver bullet

Since January 2025, ships operating in the EU have been required to report their fuel consumption and greenhouse gas intensity. If the permitted threshold is exceeded, penalties of several hundred thousand euros per vessel per year can apply. Pooling allows deficits to be offset by the surpluses of more efficient vessels. However, these surpluses do not arise automatically. They 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.

The ZERO44 whitepaper shows through practical examples that pooling is often more expensive than the alternatives. Strategies such as biofuel blending or internal pooling can achieve the same compliance goals at significantly lower cost. The key, the paper stresses, is for companies to clearly define their own willingness to pay for external pooling and realistically evaluate alternatives.

In addition, ZERO44 analyzes four current pooling provider models – brokers (‘matchmakers’), organisers, traders and platforms – and assesses their advantages and drawbacks with regard to pricing, compliance assurance and counterparty risks. The conclusion: there is no one-size-fits-all solution. The right choice always depends on the specific situation and strategy of a company.

“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,” says 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.”

The whitepaper “FuelEU Maritime: Beyond the Pooling Hype” is now available for download on the ZERO44 website. It provides detailed analyses of pricing, market models and strategic alternatives for shipowners, charterers and ship managers.