Economic study for an assessment of potential carbon leakage in the aviation and maritime sectors and mitigating measures

This study assesses the risk of carbon leakage and loss of competitiveness linked to FuelEU Maritime and the extension of the EU ETS to maritime transport. It examines how these policies may affect operational and commercial decisions in shipping and ports, such as changes in route choice, port calls, transhipment patterns, fleet deployment and bunkering. The analysis combines desk research, stakeholder consultation, connectivity analysis and quantitative case studies focused on container liner shipping. Current evidence does not demonstrate carbon leakage or a system-wide loss of competitiveness linked to the EU ETS. For FuelEU Maritime, empirical evidence remains limited due to the relatively recent application of the Regulation. Observed changes in routing and connectivity are also influenced by wider market developments. Future risks of carbon leakage and loss of competitiveness appear concentrated in certain parts of the Mediterranean, rather than across the maritime sector as a whole. The most plausible risk is the relocation of transhipment activity to nearby non-EEA hubs, particularly where these hubs already combine scale, connectivity, feeder functions and short sailing distance from EEA competitors. Evasive port calls and port-call reordering may also reduce regulatory exposure but appear more conditional on route economics, schedule constraints, and the future evolution of compliance and fuel-related cost differentials. As the most suitable near-term mitigating measure, the study identifies continued monitoring as well as refining the existing anti-evasion measure, the neighbouring container transhipment port mechanism.