Picture an Aframax operating in the Mediterranean. No scrubber, burning MGO.

In 2026 the FuelEU baseline is 89.34 gCO2e/MJ. As we all know by now, fuel used on EU/EEA voyages and port calls counts 100%; on mixed EU/non‑EU voyages it counts 50%.

Under FuelEU’s default factors MGO scores 90.77 gCO2e/MJ. Plug that into the penalty formula and you land at roughly €39.5 per tonne of FuelEU‑covered MGO. Or approximately €645 per tonne of compliance deficit CO2e.

Do the arithmetic for a typical Aframax in the Med with a fuel burn of 7,000–10,000 covered tonnes a year:

• Non‑scrubber MGO ship: roughly €0.28m–€0.40m per year in penalties.

• Scrubber/HFO ship: Much worse. HFO’s default intensity gives about €62.1/covered tonne, or ~€0.47m–€0.62m per year on the same burn.

Now pooling. The market for FuelEU surplus is trading well below the statutory penalty. Market commentary in May showed surplus around €150 per tCO2e – but that number is going to be at the mercy of the situation in the Hormuz Strait for the foreseeable. Against a statutory hit near €645/tCO2e for an MGO ship, that’s roughly a 70% saving if you can buy surplus at market rates.

Translated to ship-level cash:

• Without pooling (MGO profile): ~€276k–€395k/year.

• With pooling at current market rates: ~€65k–€93k/year.

• Rough saving: ~€185k–€305k per ship per year.

If you self‑pool within a fleet (using your own ships’ surplus), the cash outlay can be even lower, and you can avoid haggling for market prices altogether.

Bottom line: FuelEU penalties can bite hard, especially for HFO users. But an active pooling strategy - or managing fleet surplus internally - can cut your hit by roughly two‑thirds.

Ahti works with leading owners and operators including BBC Chartering, Van Weelde Group, Bore, Spliethoff, Stenersen, Avin International, and Neste. If you’d like to join them in the Ahti Pool, or learn more from our experts about how FuelEU pooling could benefit your fleet.