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List of neighbouring container transhipment ports for the purposes of the EU Emissions Trading System (ETS) Directive

Climate action

This Implementing Regulation establishes the list of neighbouring container transhipment ports where the share of transhipment of containers exceeds 65% of the total container traffic of that port, and located outside the Union but less than 300 nautical miles of a port under the jurisdiction of a Member State, as per Article [3g(2)] of Directive 2003/87/EC.

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Public consultation

ID: 13867

Lobbying Activity

8 responses

ESPO demands stricter rules to stop maritime ETS evasion

European Sea Ports Organisation, 18 Sept 2023

ESPO requests lowering the 65% threshold used to identify ports where ships might evade carbon taxes. They urge the Commission to monitor new port investments and infrastructure capacity to stop route changes.
These changes would protect the competitiveness of EU ports and prevent the loss of shipping traffic.
European maritime hubs risk losing jobs and strategic oversight of international supply chains.

FEPORT urges stricter monitoring of shipping evasion via non-EU ports

FEPORT, 18 Sept 2023

FEPORT calls for robust monitoring using early warning indicators like new investments in non-EU port capacity. They also advocate for tracking diversion through ports below the current traffic threshold.
This would protect the competitive position of European terminals by preventing permanent cargo diversion.
Shipping companies would face higher costs as loopholes for avoiding emissions payments are closed.

Assarmatori Urges EU To Protect Ports From Carbon Leakage

Assarmatori, 18 Sept 2023

The group demands an urgent review of carbon trading rules for shipping. They propose temporarily exempting high-traffic EU transhipment ports from emission calculations. This would prevent vessels from rerouting to North African ports to save money.
This would reduce their regulatory compliance costs and prevent their clients from leaving.
Non-EU ports would lose the competitive advantage provided by the current regulatory loophole.

CLECAT seeks annual updates to prevent shipping carbon evasion

CLECAT - European association for forwarding, transport, logistic and Customs services, 18 Sept 2023

CLECAT calls on the Commission to closely monitor non-EU ports and revise the list annually. They warn more ports will soon meet the criteria for inclusion.
Frequent updates would help freight forwarders maintain connectivity and avoid operational delays.
Mediterranean ports lose business to non-EU rivals that aren't subject to carbon pricing.

Consultation response

MSC Mediterranean Shipping Company S.A., 18 Sept 2023

Please see the uploaded file.

Malta Business Bureau warns ETS threatens Mediterranean shipping competitiveness

Malta Business Foundation, 18 Sept 2023

The organization warns that operators may shift activities to North African ports to bypass emissions costs. They stress that avoiding EU ports would cause severe economic damage to local shipping hubs.
This would protect Malta's position as a manufacturing hub and secure its supply chains.
EU port regions lose economic activity and environmental goals suffer from carbon leakage.

Consultation response

Autoridad Portuaria de la Bahía de Algeciras, 18 Sept 2023

Por parte de la Autoridad Portuaria de la Bahía de Algeciras, se adjunta propuesta a considerar para la mejora de la efectividad de la directiva. Estamos de acuerdo con los puertos incluidos en el listado, y aportamos información para considerar la inclusión de otros puertos, así como la…

Consultation response

Organismo Publico Puertos del Estado, 18 Sept 2023

Regarding the draft implementation act identifying neighbouring container transhipment ports pursuant to Article 3ga(2) of Directive 2003/87/EC of the European Parliament and of the Council and its Annex, published in portal Have Your Say1 webpage, Puertos del Estado, public body attached to the…