Q3/2026 Europe-Bound Environmental Surcharges: Maersk and ONE Differ by $49/FEU, While MSC Quotes by TEU

A 40ft dry container shipped from Vietnam to Northern Europe in Q3/2026 could incur an environmental surcharge of $155/FEU with Maersk and $204/FEU with ONE, even though both charges are linked to the cost of complying with Europe’s environmental regulations. MSC uses a different charging structure, separating the cost into two TEU-based surcharges outside its published freight rates. The Q3 schedules remain valid through September 30, 2026, while EU Allowance (EUA) prices in the market are currently well above the reference level Maersk used to calculate its Q3 surcharge.

Key points

●    Maersk charges a $155/FEU emissions surcharge (EMS/ESS) on Far East–Northern Europe services, effective from July 1 to September 30, 2026. ONE charges a $204/FEU Europe Environment Surcharge (EES) over the same period, a difference of $49/FEU.

●    On Mediterranean services, the ranking is reversed: Maersk charges $117/FEU, while ONE charges $86/FEU. Neither carrier has the lowest surcharge across all services.

●    MSC separately lists two TEU-based charges: a $20/TEU Carbon Limitation Surcharge (CLS) and a $81/TEU Carbon Review Surcharge (CRS) for Northern Europe, or $120/TEU for the Mediterranean. The schedule takes effect from August 15, 2026 and runs no later than August 31, 2026.

●    Maersk reduced its Q3 surcharge by approximately 14.4% from Q2, broadly in line with the decline in its reference EUA price from €83.19 to €71.07. The carrier says the surcharge is calculated using the average EUA price during the relevant reference period.

●    ONE has incorporated UK ETS compliance costs into its EES structure from Q3/2026, while Maersk says UK ETS compliance costs are currently minimal and has decided not to pass them on to customers in Q3.

Environmental surcharges: three carriers, three charging methods

Three major carriers are applying environmental surcharges under different names, scopes and pricing structures. On Vietnam–Northern Europe services in Q3/2026, Maersk has published a rate of $155/FEU, compared with $204/FEU for ONE, a difference of $49/FEU.

These surcharges are linked to the cost of complying with European environmental regulations, including the EU Emissions Trading System (EU ETS) and FuelEU Maritime. For ONE, EES also incorporates costs related to the UK ETS from Q3/2026, within the scope defined by the carrier.

Maersk: EMS/ESS

Maersk refers to the surcharge as EMS/ESS – Emissions Surcharge. Under its Q3/2026 schedule, Far East–Northern Europe services are subject to $78/20ft dry and $155/40ft dry, while Far East–Mediterranean services are charged $59/20ft and $117/40ft. For reefer containers, the corresponding charges are $231/FEU for Northern Europe and $177/FEU for the Mediterranean.

According to Maersk, EMS/ESS covers costs associated with EU ETS and FuelEU Maritime. The surcharge applies to bookings where the port of loading and/or discharge is located within the EU/EEA.

For Q3/2026, Maersk uses an average EUA price of €71.07 for the reference period from February 16 to May 15, 2026, to calculate the surcharge.

ONE: EES

ONE uses the term EES – Europe Environment Surcharge. Under the schedule effective from July 1 to September 30, 2026, dry cargo from Asia/Oceania to Europe is subject to $102/20ft and $204/40ft, while Mediterranean services are charged $43/20ft and $86/40ft. For reefer containers to Europe, the charge is $392/FEU.

ONE states that, from July 1, 2026, EES has been revised to include additional UK ETS compliance costs within the same surcharge.

On Northern European services, ONE's EES is $49/FEU higher than Maersk's EMS/ESS, equivalent to approximately 31.6%. Conversely, on Mediterranean services, Maersk's surcharge is $31/FEU higher than ONE's.

This difference shows why surcharges should be compared by trade lane and container type, rather than simply determining which carrier is cheaper overall.

MSC: carbon charges listed separately

MSC uses a different pricing structure, with carbon-related costs split into two separate charges. According to the schedule published on July 30, 2026:

●    CLS – Carbon Limitation Surcharge: $20/TEU;

●    CRS – Carbon Review Surcharge: $81/TEU to Northern Europe and $120/TEU to the Mediterranean.

MSC identifies these charges as “subject to”, meaning they are applied in addition to the amounts already included in the published FAK rates. In the same schedule, MSC states that GFS of $271/TEU and ECA charges of $15 or $52/TEU are already included in the FAK.

Therefore, when comparing quotations, it is important to establish which surcharges are already included in the FAK and which are charged separately. A lower FAK rate does not necessarily mean a lower total cost if CLS and CRS have not yet been included in the quotation.

Another point to note is that MSC quotes CLS and CRS per TEU, whereas Maersk and ONE publish their surcharges by container type. These figures should therefore not be directly converted into a common unit for comparison without first establishing the full scope and application of each charge.

When comparing carriers, shippers should consider the charging unit, container type, trade lane and scope of application to determine the actual total cost.

Why did environmental surcharges fall in Q3, and could they rise again in Q4?

Maersk's surcharge fell by approximately 14.4% in Q3/2026, while the EUA price used as its reference also declined significantly from the previous quarter. This indicates that the reference carbon price is an important factor in the carrier's surcharge-setting mechanism.

The Q2 schedule was based on an average EUA price of €83.19, compared with €71.07 for Q3. Together with an exchange rate of €1 = $1.1672, the surcharge on the Far East–Northern Europe trade fell from $181/FEU to $155/FEU.

The reference EUA price declined by approximately 14.6%, broadly in line with the 14.4% reduction in Maersk's Northern Europe surcharge. This correlation suggests that carbon prices are an important variable to monitor when assessing surcharge trends, alongside the official surcharge schedules issued by carriers.

By contrast, market EUA prices in mid-August 2026 were already significantly above the €71.07 reference level used for Q3. If these higher prices are sustained during the next reference period, upward pressure on environmental surcharges in Q4 is a scenario that businesses should factor into their planning.

However, the market EUA price at any given point does not necessarily correspond to the official reference price used by a carrier. Each carrier may use a different reference period, calculation formula and conversion mechanism. EUA prices should therefore be viewed as a trend indicator rather than a basis for precisely forecasting future surcharges.

Could Q4/2026 mark a turning point?

The movement in Maersk's surcharge between Q2 and Q3 shows that the charge is relatively sensitive to the reference EUA price. If carbon prices remain elevated during the next reference period, environmental surcharges could rise again in Q4.

This remains a forecast scenario rather than a rate confirmed by the carriers. Businesses should not use the current EUA price to calculate a specific Q4 surcharge themselves.

In terms of publication timing, Maersk issued its Q2 schedule on March 1 and its Q3 schedule on June 1, approximately one month before each became effective. ONE also published its Q3 schedule on June 1.

Based on this publication pattern, early September 2026 will be an important period to monitor for the release of Q4 environmental surcharge schedules.

UK ETS: two carriers, two approaches to passing through the cost

From July 1, 2026, the UK ETS expanded its scope for maritime activities in the UK, applying to vessels of 5,000 GT or above, including voyages between UK ports and emissions generated while vessels are operating at UK ports.

ONE has chosen to incorporate UK ETS costs into its EES. According to information published by the carrier, from July 1, 2026, ONE applies a 100% surrender obligation to emissions falling within the scope of the UK ETS and incorporates the associated cost into EES for cargo moving to and from the UK.

Maersk has taken a different approach. The carrier says that, following its assessment, UK ETS compliance costs are currently minimal and has decided not to pass these costs on to customers in Q3/2026.

Hapag-Lloyd has also stated that its Q3 schedule has been adjusted to include UK ETS costs. However, the carrier does not publish specific charges by trade lane on its information page, so businesses need to check Hapag-Lloyd's surcharge tool directly before preparing quotations.

EU ETS maritime compliance in 2026: distinguishing the emissions year from the allowance surrender timeline

This distinction is important when assessing EU ETS compliance costs because the year in which emissions occur and the time when the corresponding allowance surrender obligation is fulfilled do not fully coincide.

According to the European Commission, the surrender requirement is being phased in at 40% for emissions generated in 2024, 70% for emissions generated in 2025, and 100% for emissions generated from 2026 onward. Therefore, emissions generated during 2026 are subject to a 100% surrender requirement.

Saying that “the allowance surrender rate is 100% from January 1, 2026” can therefore be misleading unless the distinction between the year in which emissions are generated and the time when the allowance surrender obligation is fulfilled is made clear.

From 2026, the scope of the EU ETS also expands to include methane (CH₄) and nitrous oxide (N₂O) alongside CO₂.

For maritime transport, the EU ETS currently applies to cargo and passenger vessels of 5,000 GT or above. The scope covers 100% of emissions from voyages between two EU ports and emissions generated while vessels are operating at EU ports. For voyages between the EU and non-EU destinations, 50% of emissions fall within the EU ETS scope.

Therefore, the environmental costs appearing in shipping quotations in 2026 depend not only on carbon prices, but also on the regulatory scope, type of emissions, vessel type, trade lane and the way each carrier allocates compliance costs.

Environmental costs are becoming a core component of shipping rates

Carbon-related costs are becoming increasingly visible in the structure of ocean freight costs as carriers pass part of their environmental compliance expenses on to shippers through various surcharges.

Maersk and ONE both apply environmental surcharges, but use different names and calculation methods. MSC has chosen to separate CLS and CRS from its published FAK rates. These differences mean that carrier quotations should be compared based on total transportation costs, rather than simply the base freight rate.

For Vietnamese businesses, particularly shippers moving significant volumes to Europe, movements in EUA prices during subsequent reference periods could affect logistics costs.

Phaata's assessment: In Q4/2026, businesses should monitor not only base freight rates but also how individual carriers incorporate carbon-related costs into their quotations and which EUA price levels they use as reference points. If EUA prices remain significantly above the Q3 reference level, a renewed increase in environmental surcharges is a scenario worth considering. However, the actual adjustment can only be determined once each carrier publishes its official Q4 surcharge schedule.

Recommendations for importers and exporters

●    Compare surcharges by trade lane and container type. On Northern European services, Maersk is $49/FEU cheaper than ONE, while on Mediterranean services, ONE is $31/FEU cheaper than Maersk. Surcharges should therefore be assessed within the specific trade lane and container type rather than used to determine which carrier is cheaper across its entire network.

●    Include environmental surcharges in the total cost when comparing quotations. Maersk and ONE quote these charges by container type. For MSC, businesses need to identify and add CLS and CRS on a TEU basis if these charges are not already included in the final quotation.

●    For MSC quotations, confirm whether CLS and CRS apply. MSC identifies these two charges as “subject to”, meaning they are outside the amounts already included in its published FAK rates. Confirming this in advance can help prevent discrepancies between the reference freight rate and the actual total cost.

●    Monitor EUA prices during subsequent reference periods. EUA prices are one of the variables that can influence the environmental surcharges published by carriers. Tracking these movements can help businesses develop cost scenarios for the following quarter.

●    For contracts extending beyond September 30, 2026, clarify the surcharge adjustment mechanism. The Q3 surcharge schedules are valid only through September 30. For shipments moving in Q4, businesses should review the relevant contractual clauses and confirm the applicable surcharge under each carrier's new schedule once published.

Recommendations for logistics companies

●    Explain surcharges in terms of regulatory obligations and scope. EMS/ESS, EES, CLS and CRS are different names used by carriers for costs associated with environmental compliance. However, their cost components and calculation methods are not identical, so logistics providers should clearly explain what each charge covers when advising customers.

●    Separate base freight from environmental surcharges in quotations. This makes it easier for customers to compare carriers while clearly identifying charges that may change when surcharge schedules are updated.

●    Keep the original charging unit when comparing surcharges. MSC publishes CLS/CRS on a TEU basis, while Maersk and ONE quote surcharges by container type. When preparing quotation comparison tables, the original unit should be retained and the applicable scope, container type and conditions clearly stated.

●    Develop Q4 cost scenarios in advance for contracts extending beyond September 30. Changes in EUA prices could affect carriers' surcharge schedules in the next period. Preparing cost scenarios in advance can help logistics companies remain more proactive when quoting customers and negotiating adjustment clauses.

●    Keep the official surcharge schedules and carrier notices used at the time of quotation. For surcharges that are revised quarterly or may change according to market conditions, retaining the carrier's official notice or the surcharge lookup result at the time of quotation provides a reference point if discrepancies later arise between the quotation and the invoice.

Frequently Asked Questions

How much is the environmental surcharge for a 40ft container to Europe in Q3/2026?

The surcharge depends on the carrier and trade lane.

Maersk charges $155/FEU on Far East–Northern Europe services and $117/FEU on Far East–Mediterranean services.

ONE charges $204/FEU on Asia/Oceania–Europe services and $86/FEU on Mediterranean services.

MSC uses a different charging structure, with CLS at $20/TEU and CRS at $81/TEU for Northern Europe or $120/TEU for the Mediterranean, according to its schedule published on July 30, 2026.

Because the carriers use different units and surcharge structures, total costs need to be assessed based on the specific container type and trade lane before making a comparison.

Why do carriers charge different amounts even though the surcharges are all related to the EU ETS?

Each carrier's environmental surcharge does not reflect EU ETS costs alone.

Maersk says EMS/ESS covers compliance costs associated with EU ETS and FuelEU Maritime. ONE has incorporated UK ETS costs into EES from Q3/2026, while MSC separates its carbon-related costs into CLS and CRS.

In addition to differences in the regulatory obligations covered by each surcharge, carriers may use different calculation methods, reference periods and cost structures. This results in different surcharge levels even on the same trade lane.

Will environmental surcharges rise or fall in Q4/2026?

It is not yet possible to determine the Q4/2026 surcharge levels.

Maersk used an average EUA price of €71.07 as the reference for its Q3 schedule, while the market EUA price in mid-August 2026 was significantly higher than this reference level.

If EUA prices remain elevated during the next reference period, environmental surcharges could rise again. 

However, the final surcharge will only be known once each carrier publishes its official Q4 schedule.

Did the EU ETS reach a 100% allowance surrender requirement from January 1, 2026?

The emissions year should be distinguished from the timing of the allowance surrender obligation.

According to the European Commission's phase-in schedule, the surrender requirement rises from 70% for emissions generated in 2025 to 100% for emissions generated from 2026 onward.

From 2026, CH₄ and N₂O are also included in the scope of the maritime EU ETS.

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Source: Phaata -  Where Shippers & Logistics Providers Connect

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