EU Commission published list of shipping companies associated with country administering authorities under EU ETS

List of shipping companies associated with country administering authorities under the EU ETS published by EU Commission on 31 Jan 2024

The published list determines which administering authority each of the shipping companies must deliver their emission allowances to. 

All shipping companies are now obligated to open a maritime operator holding account („MOHA”) used to deliver and trade emission allowances within 40 days, counting from the publishing date of the list.

For shipping companies not included in the list, the deadline is 65 working days of the first port of call falling within the scope of the EU ETS Directive.


The regulation for implementation explicitly identifies the „shipowner” as the default party responsible for adhering to EU ETS obligations, including the surrender of allowances. However, an alternative entity may assume this responsibility if specific conditions outlined in the regulation are met.

To formally qualify for assuming responsibility, the entity must have taken over the ship’s operation from the shipowner and agreed to undertake all duties and obligations stipulated by the ISM Code. Essentially, the relevant entity must, at a minimum, hold the Document of Compliance (DOC). The transfer of compliance responsibility for EU ETS obligations to other entities is not allowed.

The regulation clarifies that being the DOC holder alone is inadequate. For responsibility transfer, the entity must also have taken on the obligations related to EU ETS, including the surrender of allowances. Additionally, documentation demonstrating that the shipowner has authorized the other entity to fulfill EU ETS obligations must be submitted to the relevant authorities. This documentation must be signed by both the shipowner and the entity assuming responsibility for EU ETS obligations.

The regulation provides further details on the required documentation for submission to authorities. It is explicitly stated that until such documentation is submitted, the authorities will consider the shipowner as the responsible entity. Consequently, an agreement between a shipowner and a technical manager or bareboat charterer alone is insufficient.

While there are restrictions on the entities eligible to establish a MOHA, it’s important to highlight that shipping companies are required to designate a minimum of two „authorized representatives” when initiating the account. In this context, an external 'service provider’ has the potential to be nominated, allowing them to act on behalf of the shipping company.

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