One Panamax fixture, two carbon bills: what December's IMO vote does to dry bulk pricing

A 76,000 dwt Panamax fixed at $35,000 a day on a transatlantic grain trip already carries a €66,000 carbon bill in Europe — and the IMO's December vote decides whether that cost follows the ship to every trade lane, not just those touching an EU port.

The worked example comes from Argyris Zafeiropoulos of Resilience & Compliance Advisory, built on a trip reported in the Baltic Exchange's weekly round-up on 9 October: delivery East Coast South America, 66,000 tonnes of grain from Santos to Rotterdam, 12.5 knots, about 21 tonnes of fuel a day. That works out to roughly 26 days on hire and 400 tonnes of fuel burned.

At today's rules, the European charges on that single fixture total around €55,000 of EU allowances — priced at about €88, the mid-October level — plus €11,000 of FuelEU penalty. Some €66,000 in total. That equals €1.01 per tonne of cargo, roughly €2,600 a day, or 8% of the hire. On a time charter, the charterer normally pays both through the BIMCO clauses, so the cost sits on top of the $35,000 daily rate.

When does the IMO actually vote?

MEPC 85 meets at the end of November, with the resumed extraordinary session on the Net-Zero Framework pencilled in for 4 December. The framework was approved in April 2025, its adoption was adjourned for a year last October, and it was debated again at MEPC 84 in the spring. Both adoption and another delay remain possible, Zafeiropoulos notes.

What happens if the framework is not adopted?

Nothing changes the morning after. The trip carries the same €66,000, and the bill keeps growing on Europe's timetable. When the FuelEU target tightens from 2% to 6% in 2030, the same Santos–Rotterdam trip costs about €85,000, or €1.29 a tonne, at today's allowance price.

There is a second effect, on the other side of the ocean. The same ship on a fronthaul from Santos to Qingdao — twice the distance, twice the fuel — pays nothing in Europe and keeps paying nothing. Between a Continent discharge and a Far East discharge, one carries a carbon bill and the other does not.

What changes if it is adopted?

The framework prices fuel intensity, not location. From 2028, every tonne of fuel burned on international voyages counts, wherever the ship trades, against two targets:

• $100 for each tonne of CO2-equivalent between the direct-compliance line and the base line
• $380 for each tonne of CO2-equivalent above the base line

On the Rotterdam trip, assuming no change to the European rules, that adds roughly €29,000 in 2028, taking the total carbon on the fixture to about €96,000 — €1.45 a tonne and 12% of the hire. By 2030, the two systems together come to about €136,000: some €2.06 a tonne and 16% of the hire.

The biggest shift is on the Qingdao fronthaul. From zero, it would carry about €61,000 in 2028 — close to what the Rotterdam trip pays in Europe today — and €106,000 in 2030. The carbon difference between the two discharge ranges narrows from €1.01 to about €0.52 a tonne in 2028.

Three cautions on the numbers

• The IMO charge is assessed per ship per year, not per voyage, so a trip's share is an allocation, not a levy on the fixture itself
• EU law requires the Commission to review the maritime ETS in light of a global measure, so the two systems may not simply add up for long
• A ship that over-complies can sell surplus units, so the real cost depends on the rest of the owner's fleet

What does the vote change on the desk?

For the broker, the practical point is less the price of a tonne of carbon than its allocation. If the framework is adopted, every fixture acquires a carbon line — not only those touching Europe — and the charter party has to say who carries it.

On a time-charter trip, the BIMCO clauses written for the EU ETS and FuelEU do not by themselves cover an IMO remedial unit. On a voyage charter, the cost stays with the owner, who will price it into the freight.

The morning after the vote, the question at the desk will be the same one Europe has asked since 2024: who pays the carbon on this fixture? If the framework is adopted, that question moves to every route, not only those that touch Europe.