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MORUs and Maritime Law: A New Legal Challenge from a Spanish and International Perspective

Mikel Garteiz-goxeaskoa, partner of AIYON Abogados S.L.P.

In recent years, the shipbuilding and energy industry has witnessed a profound transformation driven by the transition to sustainable energy sources. In this context, MORUs (Mobile Offshore Renewable Units) emerge as one of the key elements for the exploitation of renewable resources in the sea. These floating structures, designed to generate wind, solar, wave or tidal energy, represent a considerable technical advance, a challenge for the shipbuilding industry, but also, without doubt, a major legal challenge.

The Comité Maritime International (CMI), a non-governmental organisation in consultative status with the United Nations, has positioned itself as one of the main forums for the development of a uniform international legal framework for maritime affairs. Founded in 1897, the CMI’s main objective is the progressive harmonisation and unification of maritime law. In 2023, in view of the growth in the navigation of our seas by these new offshore structures, the CMI set up an international working group to study the legal status of MORUs and, in order to gather information on how these units are treated in different legal systems as part of this process, launched a questionnaire addressed to national maritime law associations.

The Spanish Maritime Law Association actively participated in this initiative, constituting a group of legal experts coordinated by Jose Sánchez-Fayos and myself. Its aim was to analyse the legal treatment of MORUs within the Spanish regulatory framework, the conclusions of which were presented at the Spanish Maritime Law Association National Congress held in Madrid in June 2025.

One of the central questions that arises when dealing with the MORU phenomenon is their legal status: are they legally ships or not? This is not a purely technical question as the answer will depend on whether or not essential maritime law regimes apply to them, such as the Convention on the Arrest of Ships, the LLMC maritime claims limitation regime, the rules on nationality and flag, maritime privileges or the possibility of being registered and mortgaged as a ship – essential for financing their construction. Ultimately, their legal qualification determines not only their administrative treatment, but also the legal architecture that guarantees their operation, financing, insurance and conflict resolution.

In the Spanish case, Law 14/2014 on Maritime Navigation establishes a typology of shipping vehicles that distinguishes between ships, vessels, naval artefacts and fixed installations. Most MORUs, not being self-propelled and not intended for navigation in the strict sense of the word, cannot be considered as ships. They do not easily qualify as vessels either. Thus, it can be concluded that most MORUs should be classified as naval craft, defined as floating structures not intended to sail, but capable of being towed and of accommodating persons or equipment.

This classification has important practical consequences as MORUs, identified as naval artefacts, can be entered in the Register – although this will require adjustment to accommodate them – and can benefit directly from the ship mortgage regime foreseen for ships. However, the 1999 Convention on Arrest of Ships does not apply to them, which prevents them from being arrested according to the procedures established for ships, something that we believe should be changed given the mobility of these artefacts.

On the other hand, as far as insurance is concerned, Article 406 of the Maritime Navigation Act admits the application of marine insurance to naval artefacts if they are subject to risks inherent to navigation, which opens the door to coverage during phases such as towing, installation or operation at sea.

Looking at the responses from other countries, France, for example, has recently passed the APER Law (2023), which explicitly excludes these structures from the concept of ship and creates a specific legal framework for them, recognising their stationary nature. Denmark, on the other hand, adopts a broader interpretation of the concept of ship, allowing MORUs to be registered as such in the Danish maritime register, which facilitates their insurance and financing. In the United States, the case law of the Supreme Court in Lozman v. City of Riviera Beach has set a standard by considering any structure that is reasonably capable of being used as a means of maritime transport to be a vessel, which has allowed some MORUs to be classified as such. In China, although the legal concept of ‘maritime mobile unit’ could be applied to MORUs, in practice there is still no possibility to register them as property in a public register. Brazil, on the other hand, allows their registration only if they are construed as vessels under the guidelines of the maritime authority.

As far as the registration aspects in Spain are concerned, it is noted that, for the time being, there is no specific framework in Spain that allows the registration of MORUs in the ship register of the Directorate General of the Merchant Navy as a category of its own, except by means of an analogue application. This is a major constraint that the DGMN should address as soon as possible so as not to prevent them from accessing financing through ship mortgages and using them as collateral in transactions. Furthermore, the absence of express recognition as ships limits their access to limited liability regimes, but not to the rights of innocent passage or transit through the sea, which are regulated by conventions such as the United Nations Convention on the Law of the Sea (UNCLOS).

The conclusions reached underline the need to adapt part of the Spanish -and in general, the international- legal framework to this new technological reality. It is proposed to review the registration regime and clarify its status in relation to liability, seizure and navigation rules. In short, the aim is to provide these units – essential for the energy transition – with the necessary legal security to operate effectively in international waters and in the exclusive economic zone of coastal states, as well as to ensure that there are no obstacles to their constructive financing, which is essential for their acceptance by the shipbuilding sector.

The emergence of MORUs is an opportunity for maritime law to evolve in step with technology. The work of the CMI and national contributions, such as in this case that of the Spanish Maritime Law Association group, constitute a fundamental first step in building a clear, predictable and future-proof legal framework for the sea.

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Fair Competition in Sustainable Air Transport

Regulation (EU) 2023/2405 of the European Parliament and of the Council of 18 October 2023 on safeguarding a level playing field for sustainable air transport or ‘ReFuelEU Aviation’, on ensuring a level playing field for sustainable air transport, entered into force in 2023 with the aim of reducing emissions from the use of hydrocarbons in aviation. To this end, it establishes a plan that mandates the use of sustainable aviation fuels by 2050. With this legislation, the European Union (EU) is strengthening its strategy to achieve climate neutrality by 2050, as part of the so-called ‘European Green Pact’.

What is the ‘European Green Pact’? It is a growth strategy established by Europe based on the contribution of all policy areas to the fight against climate change, with the aim of achieving climate neutrality by 2050.

Air transport, together with maritime and land transport, plays an important role in our daily lives, both in passenger and freight transport. While it is true that this sector represents a smaller share of global emissions compared to shipping, it also requires attention due to its growing demand and intensive use of fossil fuels.

Specifically, the ‘ReFuelEU Aviation’ Regulation establishes rules for the use and supply of sustainable aviation fuels and, to this end, grants the European Aviation Safety Agency (EASA) the functions of promoting and monitoring the use of new sustainable aviation fuels (SAF) in civil aviation, monitoring the effects of these fuels and keeping informed users or travellers who choose to use air transport.

The goal is to make 70% of aviation fuels sustainable (SAF) by 2050. Within that percentage, 35% would be synthetic aviation fuels, out of all fuel supplied at EU airports. This makes it mandatory for a minimum percentage of 2% of sustainable aviation fuels to be applied from 1 January 2025.

EASA’s functions also include the publication of the annual technical report. This year, a report has been published with the aim of improving the level of environmental protection in the civil aviation sector and helping the EU to ensure that the aviation sector contributes to the objectives of the ‘European Green Pact’ through effective collaboration and continued commitment. The report provides an overview of the current situation and proposes recommendations for further progress in environmental protection, in cooperation with national aviation authorities, in the case of Spain, with AESA.

Regarding SAF, the report recommends reducing the price gap between SAF and fossil fuels, as the price of SAF is currently higher than the price of fossil fuels. It also highlights the allowances allocated in the Regulation and the measures needed to comply with the mandate. In addition, the promotion of less carbon-intensive SAFs is mentioned to maximise their contribution to the ‘European Green Pact’. The identification and optimisation of the composition of aviation fuels, both fossil and SAF, is also recommended to mitigate overall climate and air quality impacts.

In conclusion, through the different regulations addressed in the ‘European Green Plan’ for the year 2050, which includes this ‘ReFuelEU Aviation’ Regulation, not only aims at achieving climate neutrality, but also a more sustainable transport system. As mentioned by EASA in its report, this objective can only be achieved through real and effective international cooperation, with the involvement of all concerned operators.

The Role of the Spanish Ports in Today’s Global Landscape

In a context of geopolitical uncertainty marked by international conflicts and some crises inherited from 2024, Spanish ports have acquired a strategic role. Spain, with its consolidated maritime tradition, has become a key logistics hub within Europe, positioning itself as a global trade reference due to its geographical location and connectivity.

This is reflected in the growing economic impact of Spain’s general interest ports, which have significantly increased their contribution in recent years. According to a study on the economic impact of Spanish ports, they generate 24.3 billion euros and support 250,000 jobs, accounting for 2.2 percent of national GDP and 1.4 percent of total employment. Spain’s strategic position, at the crossroads of Europe, Africa and America, further reinforces its global logistics significance. The Strait of Gibraltar alone handles between 10 and 25 percent of global maritime trade, consolidating Spanish ports as critical infrastructures in international shipping routes.

Among the Spain’s main ports, the following stand out:

  • Santander/Bilbao: Essential for trade with the UK and Northern Europe.
  • A Coruña/Vigo: Key connections with the Americas, while facilitating north-south trade between Europe and Africa.
  • Algeciras: Spain’s largest port and one of Europe’s top transshipment hubs, maintaining critical links with Africa, the Americas and Asia.
  • Valencia: A leading container port, with strong commercial ties to China and Southeast Asia.
  • Barcelona: A crucial gateway to the Mediterranean and North Africa, with historically high cargo volumes.

This being so, recent geopolitical changes have significantly impacted Spanish ports, compelling them to redefine strategies and adjust priorities in response to new global challenges.

  1. US-China tensions. The expansion of China’s Maritime Silk Road has reinforced Beijing’s presence in the Mediterranean, reshaping trade dynamics. In 2025, new sanctions and ongoing technological disputes could disrupt trade flows, potentially affecting Spanish exports to Asia.
  1. The war in Ukraine and NATO expansion. The energy crisis has shifted trade benefits toward Mediterranean ports, often at the expense of Northern European hubs. Spain has capitalized on this shift by positioning itself as a key LNG importer from the Americas and Africa, leveraging agreements such as the EU-Egypt-Israel trilateral memorandum on natural gas exports to Europe.
  1. The Panama Canal crisis. A potential political crisis or rising transit costs through the Panama Canal could pose challenges for Valencia, Barcelona and Algeciras, which rely heavily on the canal for trade with South America’s Pacific coast. Any disruption could affect rout viability and overall trade volumes.
  1. Decarbonisation and the EU Green Deal. The shift towards a more sustainable maritime transport presents challenges. Spanish ports must adapt to stricter CO₂ regulations while ensuring they remain competitive in global trade.

In order to maintain their global position, Spanish ports must focus on key strategic areas.  Investing in modern infrastructure and digitalisation will be essential for adapting to evolving technological and environmental regulations. Strengthening rail and logistics connectivity will enhance landside efficiency and improve cargo distribution. Additionally, expanding the Green Maritime Corridor in 2025 will further consolidate Spain’s role in sustainable global trade.

Spanish ports must continue evolving towards a more sustainable, technologically advanced mode, fully integrated into international logistics networks.

Only by doing so will they successfully face current and future geopolitical and economic challenges, consolidating their position as key players in global trade.

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The CJEU Allows Advance Complaints for Delayed Baggage (Article 31.2 of the Montreal Convention)

On 5 June 2025, the Court of Justice of the European Union (CJEU) ruled on case C-292/24 (AD vs. Iberia Líneas Aéreas de España, S.A. – Operadora Unipersonal), addressing a key point of the Montreal Convention, namely: can a complaint be lodged for delayed delivery of baggage before it is made available to the passenger?

The context of the dispute is based on a claim filed by AD, an air passenger, against the airline Iberia Líneas Aéreas de España, S.A.- Operadora Unipersonal (hereinafter, ‘Iberia’), in relation to the latter’s liability for the damage caused by the delay in the air transport of AD’s luggage. The passenger reported the incident on the same day, requesting contact from the airline. When he did not receive a response, he made the purchases he deemed necessary to cover his needs. A few days later, his luggage was delivered to him. Iberia, for its part, refused to compensate the expenses related to the replacement purchases made, as well as the travel expenses and the price of the tickets corresponding to a replacement flight, arguing that the complaint did not comply with the 21-day deadline set forth in Article 31.2 of the 1999 Montreal Convention.

The preliminary ruling referred to the CJEU concerned the interpretation of the second sentence of Article 31.2 of the Montreal Convention, approved by Decision 2001/539/EC and in force for the Union since 28 June 2004. Article 31.2 of the aforementioned Convention states: “[…] In the event of delay, the complaint must be made no later than twenty-one days from the date on which the baggage or cargo was made available to you.”

The CJEU ruled that the aforementioned provision does not impose a strict time limit on when the complaint must be lodged, provided that the maximum period of twenty-one days from the date on which the luggage was finally made available to the recipient has not been exceeded. Therefore, the Court made a literal and final interpretation of the article, emphasising that its wording sets a limitation period but does not expressly prohibit early protest.

Consequently, this interpretation avoids unnecessary formalities and promotes greater legal certainty and effectiveness in protecting the rights of passengers affected by unjustified delays in the delivery of their luggage.

Algeciras Hosts the First Celebration of the 10th Anniversary of AIYON Lawyers

On Thursday, 29 May, the entire AIYON Abogados team celebrated the firm’s 10th anniversary at an event held at the Hotel Alborán in Algeciras, attended by our clients and friends, as well as our regular collaborators, with whom we form a solid team of lawyers and experts.

At this pleasant event, we brought together leading operators and various stakeholders from the logistics and transport sector in Algeciras and the rest of the province of Cádiz, as well as some local authorities, to commemorate a significant milestone in our professional career.

Multiple local media outlets reported this news, which undoubtedly fills us with pride for the effort and dedication that the team has put into achieving this goal, but above all for its five partners, Enrique Ortiz (head of the Cadiz office), Verónica Meana (head of the Madrid office), Mikel Garteiz-goxeaskoa and Zuberoa Elorriaga (heads of the Bilbao office) and José Antonio Domínguez (head of the Algeciras office); partners who work side by side with the rest of the team in handling all kinds of matters related to their specialities.

Founded in 2015 in the city of Bilbao, AIYON Abogados is one of the few specialist law firms currently operating in Spain that provides advice in the areas of maritime law, transport law (both land and air), insurance law and international trade, addressing all of its clients’ legal needs thanks to a highly qualified and multidisciplinary team of lawyers and a network of trusted collaborators in other areas of law (criminal, tax, commercial, and labour), enabling them to offer a 360º legal service. In fact, last March, we were once again highlighted by the prestigious British legal guide Chambers & Partners in the category of ‘Shipping – Maritime Law’ for Spain, and we also contributed to the chapter on Maritime Law in Spain for the guide The International Comparative Legal Guides, 2025 (ICLG).

This is the firm’s first celebration in this momentous year 2025, which will be followed by a second celebration in Bilbao after the summer, serving as the grand finale to commemorate a decade of work and joint effort, with all eyes set on the next 10 years. Congratulations, AIYON Abogados!

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How is the Arrival of Stowaways in Spanish Ports Managed?

We would like to thank the Catalan newspaper El Nacional.cat  for the collaboration of our colleagues Jose Antonio Dominguez Castro and Zuberoa Elorriaga for their article on stowaways.

Specifically, the Catalan newspaper reports on the arrival of stowaways in the Port of Barcelona on different ships, which poses a challenge for the different actors affected by this eventuality. Although the newspaper points out that the arrival of stowaways in the Port of Barcelona is scarce, it confirms that this does not mean that this phenomenon does not exist, but that it generally does not transcend despite the fact that it is a reality which, in the 21st century, is still present in maritime life and in the different Spanish and European ports. According to data from the Ministry of the Interior to which the publication had access, between 2016 and 2024 a total of 137 stowaways arrived at the Port of Barcelona: 11 (2016); 20 (2017); 15 (2018); 47 (2019); 15 (2020); 13 (2021); 9 (2022); 3 (2023), and 4 (2024). The authorities state that their provenance is unknown and point out that ‘they have embarked through unregulated procedures unknown to the ship’s captain’.

As El Nacional.cat points out, our firm, in collaboration with the shipowners involved, the responsible authorities, shipping agents and P/I clubs, has managed complex situations arising from this reality in Europe, which undoubtedly always pose a challenge for our team. In this sense, our partner José Antonio Domínguez , a lawyer from the Algeciras office with accredited experience in cases of management of stowaways arriving at the Port of Algeciras, explained in detail to the newspaper the multiple steps and actions that must be taken with all the agents affected once stowaways are detained on a ship on its arrival at a Spanish port, without forgetting the human factor that all this entails, as we are talking about people in an irregular and precarious situation who must be treated with respect and humanity.

Enrique Ortiz, Partner of AIYON Cadiz, Participates in the Round Table Organised by the Propeller Club of Algeciras

On the 29th of April, an interesting meeting took place in Algeciras, organised by the Propeller Club of Algeciras, which brought together many of the most relevant members of the maritime and transport sector in the Bay of Algeciras, including Enrique Ortiz), our partner responsible for the Cadiz office.

The round table was attended by the presidents of the three major associations of companies operating in the Port of Algeciras, such as the Association of Service Companies of the Bay of Algeciras (AESBA), the Association of Freight Forwarders, International Forwarders and Similar of the Bay of Algeciras (ATEIA-OLTRA) and the Port Community of the Bay of Algeciras (Comport), and was moderated by Mr. Manuel Piedra.

During the meeting, José Antonio Fernández, Manuel Cózar and José Manuel Tejedor analysed the current situation, as well as the future of the logistics-port community of the Port of Algeciras. In general, the participants agreed in demanding better tools for the port facilities and the region in the form of better infrastructures, more space for the activity of the companies in the sector, as well as adequate and up-to-date training to improve the service provided.

The dismissal of Mr. Álvaro Rodríguez Dapena as president of Puertos del Estado, considered a strategic ally for Algeciras, also had a place in the round table. The president of Comport regretted that it is a ‘huge loss for the Port’.

Another recurring theme that was also discussed, and which not only affects the Port of Algeciras but all areas of logistics and transport at national level, was the shortage of qualified personnel in sectors such as consignment, customs or port services. The lack of a maritime-port training centre in the region was highlighted, as well as the urgent need to promote dual training, improve technical training and provide companies with more customs representatives.

In relation to the so-called ‘Green Strategy’ followed by the Port of Algeciras, the speakers advocated the need to advance in compliance with European regulations, but pointed out that some of the measures should have a ‘more practical’ sense in order to be able to adapt better to the needs of the operators.

In general, it was a very complete and pleasant meeting in which Enrique Ortiz was able to take note of the different aspects discussed, as well as to reinforce the links that our firm has with the community of the Bay of Algeciras, and its different actors.

Royal Decree 205/2025 of 18 March Establishing the Criteria for the Determination of Vehicle Charges/Exemptions/Reductions for the Use of Certain Infrastructures

The aforementioned Royal Decree 205/2025, approved on 18 March 2025 and coming into force on 19 March 2025, aims to adapt the current regulations on criteria for determining the tolls to be applied to goods vehicles with a maximum authorised mass of more than 3.5 tonnes on motorways under concession on the State Road Network, in accordance with the provisions of Directive (EU) 2022/362 of the European Parliament and of the Council of 24 February 2022 amending Directives 1999/62/EC, 1999/37/EC and (EU) 2019/520 as regards the charging of vehicles for the use of certain infrastructures.

Therefore, this Royal Decree has as its precedent Directive (EU) 2022/362 of the European Parliament, and its purpose is to transpose the content of Article 1 of the aforementioned European regulation, adapting the criteria for the determination of tolls under concession and tolls for motorways operated in accordance with the provisions of the seventh additional provision of Law 37/2015, of 29 September, on roads. This, repealing the previous Royal Decree 286/2014, of 25 April, establishing the criteria for determining the tolls to be applied to certain goods transport vehicles on motorways under concession on the State Road Network.

Directive (EU) 2022/362 of the European Parliament and of the Council of 24 February 2022 amending Directives 1999/62/EC, 1999/37/EC and (EU) 2019/520/EC as regards the charging of vehicles for the use of certain infrastructures, whose approval introduces amendments to Directive 1999/62/EC, with the objectives of aligning it with the challenges of climate change, noise and congestion, making progress in the application of the ‘polluter pays’ and ‘user pays’ principles, promoting environmentally sustainable but also socially equitable road transport.

One of the main changes proposed in this new RD is that the term ‘heavy goods vehicle’ is deleted and replaced by the term ‘vehicles in general’, meaning motor vehicles, with four or more wheels, or a combination of articulated vehicles, intended for the carriage of passengers or goods by road or used for that purpose.

In addition, it includes six key annexes which: (i) specifies the main principles for cost allocation and toll calculation; (ii) classifies vehicles according to emission limits; (iii) classifies vehicles according to pavement damage; (iv/v) set out, respectively, the requirements for the determination of external cost tolls and the reference values for the corresponding tariffs; (vi) sets out pollutant emission performance criteria for light-duty vehicles.

This is on the basis that no category of vehicles may be required to pay tolls and any other charges for the use of the same road section at the same time. Similarly, any tolls will avoid discriminatory treatment of international traffic and distortions of competition between operators.

In addition, among other aspects, it establishes that, from 25 March 2026, for the determination of these charges, heavy goods vehicles will be charged for the external costs of atmospheric pollution caused by traffic. It also mentions that an additional cost for noise pollution may be added to this charge, depending on the stretch of road on which the heavy goods vehicle is travelling.

In short, Royal Decree 205/2025 introduces a series of modifications and adapts the European regulations, with which it coexists, in order to meet the objectives pursued by the European Parliament and the Council of the European Union, which is to introduce fair mechanisms for allocating the costs of infrastructure use in order to eliminate distortions of competition between transport companies in the Member States, promoting the proper functioning of the internal market and increasing competitiveness.

‘Chambers & Partners’ Endorses Our Work

The British entity ‘Chambers & Partners’, one of the most prestigious directories worldwide in the classification of departments of law firms and individual lawyers in different jurisdictions and practice areas, has published its ranking for the year 2025 in which AIYON Abogados has been recognised, once again, as one of the leading firms in its sector, reaching the Band 3 ranking. In addition, at an individual level, our partners Mikel Garteiz-goxeascoa and Verónica Meana have also been distinguished in the ‘Chambers & Partners’ rankings, in Band 3 and Band 4, respectively.

This recognition, which has been consolidating in recent years, confirms the solid track record of our firm, as well as the deep specialisation of our lawyers in the areas of Maritime and Transport Law, strengthening our position in the market and making us a benchmark within the industry.

In this year of celebrations, in which we celebrate ten years since our foundation, we would like to thank all our clients and collaborators for the trust in our firm they have shown, which has allowed us to grow and obtain this much-appreciated recognition.

Regulation (EU) 2023/1805 on Renewable and Hypo-Carbon Fuels in Maritime Transport

Regulation (EU) 2023/1805 of the European Parliament and of the Council of 13 September 2023 on the use of renewable fuels and low-carbon fuels for maritime transport and amending Directive 2009/16/EC  represents a milestone in the transition towards more sustainable shipping in the European Union. In force since 12 October of the same year and applicable as of 1 January 2025, this regulation establishes new rules to promote the use of renewable and low-emission fuels in shipping within the EU. Its purpose is clear: to reduce greenhouse gas emissions and move towards the climate commitments of the ‘European Green Pact’ which aims to create a climate-neutral Europe by transforming the way we produce and consume.

Maritime transport, which plays a key role in the global and European economy as it handles 75% of the EU’s external trade and 31% of internal trade, has a very significant environmental impact, accounting for 3-4% of total CO2 emissions in the region.

Faced with this challenge, Regulation (EU) 2023/1805 outlines a roadmap for the decarbonisation of the sector, driving the transition to cleaner energy sources. This initiative will not only reduce pollution but also ensure the competitiveness and sustainability of maritime transport in Europe.

The Regulation lays down specific rules to reduce the greenhouse gas intensity of fuels used in maritime transport. One of its main features is that it applies to ships with a gross tonnage of more than 5,000 tonnes operating in EU ports, irrespective of their country of origin or destination. In addition, progressive emission reduction targets are set, starting at 2% from 01 January 2025 and gradually increasing to 80% by 2050 (1). To achieve this, it calls for the use of renewable and low-carbon fuels such as advanced biofuels, hydrogen, green ammonia and electricity. It also promotes the use of wind-assisted propulsion as a viable alternative.

That said, one of the key elements of the regulation is the obligation to use electricity in ports. From 2030, container and passenger ships will have to be connected to the electricity grid at the quayside to avoid the use of combustion engines while in port. This measure will significantly reduce air pollution in coastal cities and improve air quality for local residents.

The implementation of Regulation (EU) 2023/1805 will have a positive impact on the reduction of pollutant emissions in maritime transport. This legislation is expected to drive innovation in propulsion technologies and encourage the development of more sustainable fuels, consolidating Europe’s leadership in green solutions for the maritime sector.

However, it also presents challenges, especially in economic terms. Shipping companies will have to invest heavily to adapt their fleets to meet the new standards. In addition, the development of adequate port infrastructures to ensure the supply of alternative fuels and the implementation of efficient electrical systems will be crucial.

Sanctions and enforcement systems: To ensure compliance with the regulation, a penalty system known as FuelEU will be implemented, which will penalise ship operators that fail to meet emission reduction targets. In addition, compensation between vessels within the same company will be allowed to balance compliance levels and facilitate a more flexible transition to clean fuels.

In conclusion, Regulation (EU) 2023/1805 marks a turning point in the regulation of maritime transport in the European Union. With these measures, the EU reaffirms its commitment to the fight against climate change and its leadership in promoting sustainable solutions for global transport, a clear example of commitment to future generations and the planet.

The effective implementation of this regulation will undoubtedly depend on the joint efforts of authorities, companies and operators in the maritime sector, who will have to adapt to this new era of green and responsible shipping and, although the transition to a more sustainable maritime industry involves challenges in terms of costs and technological adaptation, the long-term environmental and economic benefits are unquestionable.

(1) The regulation sets concrete targets compared to 2020 levels: 2% less in 2025, 6% in 2030, 14.5% in 2035, 31% in 2040, 62% in 2045 and 80% in 2050.