In 2026-27 who in the charterparty chain will capture the value of surplus FEM compliance gains?

The honest answer is whoever drafted the contract better.

Under the BIMCO FuelEU clause framework, a full-year time charterer who blends biofuels past the GHG intensity threshold can generate a compliance surplus. That surplus is a tradeable asset. But that value only flows to the charterer if the contract is drafted to allow it. Without the right clause architecture, the charterer has paid for the biofuels and handed the upside to the owner.

For charterers fixing tonnage right now without a proper biofuels clause — i.e. one that covers tank preparation, fuel certification, testing, handling, and vessel performance with new fuel grades — the risk runs the other way too. Compliance failure that the charterer has already funded is a painful outcome. A good clause protects both sides.

Procurement Possibilities

Charterers who have built the relationships and infrastructure to lock in biofuel offtake agreements have a big cost advantage over those buying on spot. For commodity traders chartering tonnage, this is familiar logic. It’s a forward fuel position. For pure tonnage providers stepping into the operator role, it’s probably a new muscle, and one that takes time to build.

This is also where pooling matters most for those who haven’t yet built that muscle. If you’re exposed to spot biofuel pricing — volatile, often illiquid, subject to ISCC certification complexity — a managed pool position provides cost certainty and flexibility that spot biofuel procurement can’t.

The cost difference between a strategic compliance position and a reactive one, measured across an EU-exposed fleet, will quickly run into the millions per year. And it compounds as the curve tightens every five years to 2050.

Susbcribe to The Ahti Currents monthly newsletter on LinkedIn.