Maersk’s €60,000-Per-Voyage Surcharge: What Every Logistics Company Must Know About ESG Compliance in 2026

On January 1, 2024, maritime shipping entered the EU Emissions Trading System. Ships of 5,000 gross tonnage or more calling at EU ports became liable for carbon costs on every voyage. The industry knew it was coming. Maersk, MSC, CMA CGM, and Hapag-Lloyd all introduced emissions surcharges to pass on the costs to customers.

What the industry didn’t expect was how profitable those surcharges would be. Moreover, in February 2024, Transport & Environment published an investigation. It covered 565 voyages from 20 different ships. Furthermore, these ships were operated by Europe’s four largest shipping companies. They calculated the actual EU ETS cost per voyage based on verified emissions, route distance, and the prevailing EUA price. Then they compared it to the emissions surcharge each carrier was actually billing customers.

Nearly 90% of voyages showed overcharges. Maersk averaged a profit of €60,000 per voyage, while MSC, Hapag-Lloyd, and CMA CGM averaged €25,000, €23,000, and €14,000, respectively. On one China-to-Germany route, Maersk charged a surcharge netting an estimated €325,000 more than the EU ETS compliance cost. Jacob Armstrong from Transport & Environment noted that shipping companies profit from the ETS. This highlights the reality of ESG compliance for logistics companies in 2026, where the EU ETS creates carbon costs and commercial leverage, extending beyond just buying allowances. Maersk’s surcharge strategy reveals the complex ESG landscape logistics businesses must navigate.

How the EU ETS Actually Works for Maritime Logistics

The EU ETS for maritime shipping launched with a phased implementation. In 2024, shipping companies must surrender allowances for 40% of their verified emissions. Furthermore, that increases to 70% in 2025 and reaches 100% from January 1, 2026. In addition, the coverage is comprehensive. For voyages between two EU ports, 100% of emissions are in scope. Conversely, for voyages between an EU port and a non-EU port, 50% of emissions from that leg are in scope. Ships calling at EU ports must also surrender allowances for 100% of emissions while at berth.

Shipping companies must purchase one European Union Allowance (EUA) for each tonne of CO2 emitted. EUA prices fluctuate on various exchanges. Maersk used an average EUA price of €81.54 in Q1 2024, which decreased to €72.37 by Q2 2025. Forecasts for 2026 predict EUA prices between €60 and €150 per tonne, influenced by supply and demand. Starting from 2026, the emissions trading system (ETS) will include methane and nitrous oxide. This change will increase regulatory burdens for ships using traditional fuels.

Maersk publishes its emissions surcharge quarterly, calculated on a trade-route basis. For example, a 40-foot container from the US East Coast to Rotterdam carried a surcharge of approximately €59 in Q2 2025. Similarly, the same container from Houston, with longer voyage distance and higher emissions, carried approximately €75. Furthermore, the surcharge structure is transparent. However, the calculation methodology is not. This is where the profit opportunity emerged.

What Transport & Environment Actually Found

The investigation used publicly available data. Ship positions and routes came from AIS tracking. Emissions calculations used the IMO Data Collection System methodology. EUA prices came from market data. Surcharges came from published carrier tariffs. The findings were systematic, not isolated.

Maersk led in average overcharge, with surcharges exceeding actual EU ETS costs by €60,000 per voyage. The highest overcharge was €325,000 on a single China-to-Germany route. Transport & Environment used a conservative EUA price of €90 for calculations, suggesting actual profits could be higher. Other carriers, MSC, Hapag-Lloyd, and CMA CGM, also overcharged, with profits averaging €25,000, €23,000, and €14,000 per voyage, respectively. These overcharges were systematically applied to every booking within the EU ETS, totaling millions in additional revenue annually.

Transport & Environment reached out to these companies regarding their methodologies; only Hapag-Lloyd responded. Despite their surcharges, Maersk has ambitious decarbonization goals. These goals include launching the first green methanol container ship in 2023. This launch highlights the revenue opportunities created by carbon compliance regulations.

What Your Customers Actually Require From You in 2026

The EU ETS surcharge controversy matters beyond Maersk’s pricing strategy. Your customers need your verified tonne-kilometre emissions figures, not surcharges. Under EU CSRD, large companies must disclose Scope 3 emissions, including upstream (Category 4) and downstream (Category 9) transportation and distribution. Your emissions are your customer’s Scope 3. This is what procurement and sustainability teams at CSRD-covered companies now request from logistics providers:

• Well-to-wheel emissions data per tonne-kilometre by transport mode. Road, rail, sea, and air require separate figures calculated using the GLEC Framework or EN 16258 standard
• Fleet composition data: age, fuel type, Euro emission standard for road vehicles, electrification percentage
• Fuel consumption records verified against actual invoices, not estimated from route distance
• Science-Based Targets alignment: whether your business has committed to validated SBTi targets and is on track
• ISO 14001 certification or equivalent environmental management system evidence
• Third-party verified emissions reports aligned with GLEC Framework v3 (2023) or equivalent

Logistics providers failing to produce essential data are losing contracts as major shippers in automotive, retail, and FMCG now require ESG data in freight agreements. Failure to deliver verified emissions data can trigger termination clauses. The Maersk case demonstrates that carriers can profit from EU ETS surcharges. However, a customer paying Maersk’s €60 surcharge per container still needs the CO2 per tonne-kilometre figure for their CSRD Scope 3 calculation, as the surcharge offers no insight into actual emissions.

For more on supply chain ESG requirements from the buyer’s perspective, see our post on ESG compliance for supply chains in 2026.

The Full ESG Compliance Framework for Logistics in 2026

The EU ETS is just one piece. Logistics companies operating in 2026 face a comprehensive ESG framework covering carbon costs, reporting obligations, and supply chain due diligence.

EU ETS for Maritime and Aviation

Maritime coverage will be 100% from January 2026. Ships must pay for CO2, methane, and nitrous oxide allowances. Beginning in 2026, failure to surrender these allowances will result in vessel detention at EU ports. The estimated annual cost increase is €1.3 million per average bulk vessel, making this a significant issue. Aviation has been part of the EU ETS since 2012, and from 2027, CORSIA coverage will apply to departing flights. Air freight operators need to include CORSIA costs in their plans now.

FuelEU Maritime Requirements

FuelEU Maritime entered force on January 1, 2025. Ships of 5,000+ gross tonnage using EU ports must cut the well-to-wake greenhouse gas intensity of fuel by 2% versus a 2020 baseline in 2025. This reduction will progressively increase to 80% by 2050. Non-compliance triggers financial penalties calculated per megajoule of non-compliant fuel used. A ship burning 1,000 gigajoules of heavy fuel oil while failing the 2% intensity cut faces approximately €58,500 in FuelEU fines. Carriers bundle this with EU ETS surcharges, so customers pay both.

CSRD and SECR Reporting Obligations

Large logistics companies with 250 or more employees, €40M+ in revenue, or €20M+ in assets must publish sustainability reports aligned with ESRS. These reports, due in 2026 for FY 2025, must cover GHG emissions, energy, water, waste, biodiversity, and social metrics. In the UK, logistics operators that meet SECR thresholds must report their energy consumption. They also need to include Scope 1 and 2 emissions in their annual directors’ reports. Fines for not complying with CSRD can reach up to 5% of global annual turnover, posing a significant risk for major logistics operators.

California SB 253 for US Market Operators

Logistics companies with $1 billion or more in annual revenue doing business in California must disclose Scope 1 and 2 emissions from 2026. Scope 3 disclosure follows in 2027. CARB enforcement carries penalties up to $500,000 per year for non-compliance.

Supply Chain Due Diligence Under CSDDD and LkSG

Germany’s LkSG applies now to logistics businesses with 1,000 or more employees operating in Germany. Moreover, BAFA enforcement reaches up to €8 million for systematic due diligence failures. Furthermore, the EU Corporate Sustainability Due Diligence Directive phases in from 2027. Large logistics operators must conduct mandatory environmental and human rights due diligence. This applies across their supply chains. Consequently, penalties for non-compliance could reach up to 5% of global turnover.

What Happens If Your Logistics Business Fails ESG Compliance

• EU ETS vessel detention: Starting in 2026, EU port authorities can detain ships that do not surrender allowances. A detained ship earns no revenue and quickly incurs port fees.
• CSRD fines for large operators: Logistics companies above CSRD thresholds that fail to publish compliant sustainability reports face fines up to 5% of global annual turnover under member state enforcement
• California SB 253 penalties: Logistics businesses with $1B+ California revenue that miss emissions disclosure deadlines face up to $500,000 per year from CARB
• Contract termination: Major shippers, including automotive, retail, and FMCG companies, now include ESG data provision as a contractual obligation. Failure to deliver verified emissions data triggers termination clauses
• Regulating Procurement: EU and UK procurement rules now require ESG credentials from logistics providers. Businesses without verified emissions data risk exclusion from public contracts.
• LkSG fines: Logistics businesses with 1,000+ employees operating in Germany face BAFA fines up to €8 million for supply chain due diligence failures

To fully understand ESG and environmental non-compliance penalties, check all sectors. See our guide to ESG non-compliance penalties in 2026.

How Logistics Companies Can Actually Comply in 2026

The Maersk surcharge case reveals a critical truth. Carbon regulations create costs. They also create commercial opportunities for businesses that understand the compliance landscape and can provide what customers actually need.

• Step 1: Calculate your Scope 1 emissions baseline. Use actual fuel consumption records and GLEC Framework v3 modal emission factors. This is the data your customers need and your regulatory baseline
• Step 2: Calculate Scope 2 emissions. Measure purchased electricity across warehousing, depots, and offices. Apply market-based or location-based emission factors as appropriate for your reporting framework
• Step 3: Assess EU ETS exposure. If you operate maritime or aviation assets on EU routes, calculate your annual CO2 liability and EUA costs. Build ETS costs into freight rate models for 2026 and beyond. Be transparent about actual costs versus surcharge pricing
• Step 4: Prepare customer-facing emissions reporting. Build capability to provide verified tonne-kilometre emission figures to customers’ sustainability teams. Align data format with GLEC Framework v3 and EN 16258 for compatibility with customer reporting systems
• Step 5: Assess CSRD and SECR reporting obligations. Determine whether your logistics business meets direct reporting thresholds. If so, begin preparing an ESRS- or SECR-aligned sustainability report. See our full guide to ESG compliance requirements for businesses
• Step 6: Develop a fleet decarbonization roadmap. Customers and regulators expect credible plans. EV transition targets for last-mile fleets, LNG or methanol transition for maritime, and SAF commitments for air freight are now standard expectations in large shipper RFP processes
• Step 7: Assess LkSG and CSDDD obligations. Large logistics businesses operating in Germany must now comply with LkSG. All large EU logistics operators must comply with CSDDD from 2027. Begin supply chain mapping and due diligence programme development

ESG Compliance Checklist for Logistics Companies (2026)

• Calculate fleet Scope 1 emissions using actual fuel consumption and GLEC Framework v3
• Calculate Scope 2 emissions for all warehousing, depot, and office energy consumption
• Determine EU ETS maritime participation status and calculate annual surrender obligation
• Assess FuelEU Maritime compliance for vessels operating EU routes
• Prepare tonne-kilometre emissions intensity data by transport mode for customer provision
• Assess CSRD and SECR reporting thresholds and begin sustainability report preparation if in scope
• Assess California SB 253 compliance if operating in California above revenue threshold
• Determine LkSG applicability based on employee count in Germany
• Begin CSDDD readiness assessment for compliance from 2027
• Obtain or renew ISO 14001 environmental management certification
• Build or update fleet decarbonization roadmap with specific EV, LNG, or SAF targets
• Review freight customer contracts for ESG data provision obligations and compliance timelines
• Implement transparent EU ETS surcharge methodology and customer verification process

In February 2024, Transport & Environment revealed that Maersk was earning substantial profits from EU ETS surcharges, with one route generating €325,000. While this practice is legal and common in shipping, logistics companies in 2026 face two levels of ESG compliance: regulatory obligations and the need to provide verified emissions data to customers for their Scope 3 reporting. Companies that prioritize credible emissions measurement and transparent reporting will gain a competitive edge, while those focusing solely on profits from surcharges risk losing contracts to more compliant providers.

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Frequently Asked Questions

What ESG requirements apply specifically to logistics and transport companies?

Logistics companies face several direct obligations. These include the EU ETS for maritime and aviation operations (100% coverage from 2026). They also include FuelEU Maritime GHG intensity targets and CSRD sustainability reporting for large operators. Additionally, there are UK SECR energy and carbon reporting and California SB 253 for high-revenue US-market operators. Indirect obligations come from customers who need logistics emissions data for their own Scope 3 CSRD and SB 253 reporting. Commercial pressure from major shippers requires verified emissions data, SBTi alignment, and fleet decarbonization roadmaps as contract conditions.

What is the GLEC Framework, and why do logistics companies need it?

The GLEC Framework (Global Logistics Emissions Council) is the industry standard methodology for calculating and reporting greenhouse gas emissions from freight transport across all modes. Furthermore, it provides modal emission factors and calculation guidance for road, rail, sea, air, and inland waterway freight. Additionally, major shippers expect logistics providers to calculate and report emissions using GLEC Framework v3 (2023). Without GLEC-aligned reporting, your emissions data will not be compatible with customers’ CSRD Scope 3 calculations.

How does the EU ETS affect freight shipping companies?

The EU ETS extended to maritime shipping from January 2024. Ships of 5,000 gross tonnes or more on EU routes must monitor, report, and surrender EU allowances for 40% of emissions in 2024, 70% in 2025, and 100% from 2026. Coverage includes 100% of intra-EU voyage emissions and 50% of extra-EU voyage emissions. From 2026, persistent failure to surrender allowances results in vessel detention at EU ports. Financial exposure depends on fleet size and route network but can reach millions of euros annually for large maritime operators. Carriers pass costs through via emissions surcharges. However, a February 2024 Transport & Environment investigation found systematic overcharging. Maersk averaged €60,000 profit per voyage in these cases.

Do small logistics and courier businesses need to comply with ESG standards?

Small logistics and courier businesses below direct CSRD and SECR reporting thresholds still face ESG compliance pressure through two routes. First, if they supply large companies within CSRD scope, those customers require verified emissions data for their Scope 3 Category 4 and 9 calculations. Inability to provide this data risks losing the contract. Second, greenwashing rules apply to all logistics businesses regardless of size. Any sustainability claim about fleet, operations, or carbon footprint must be substantiated. The FTC Green Guides, EU Green Claims Directive, and UK CMA enforcement apply regardless of company size.