Kystrederiene
The Norwegian Coastal Shipowners Association (NCSA) is a trade organization representing companies that operate passenger and cargo vessels along the coast of Norway.
ID: 548547549073-85
Lobbying Activity
Response to European Climate Law amendment
12 Sept 2025
Consultation Response from Kystrederiene The Norwegian Coastal Shipowners Association Kystrederiene, representing a large share of the Norwegian short sea and coastal shipping sector, welcomes the European Commissions proposal to amend the European Climate Law and set a binding Union-wide 2040 climate target. We acknowledge the importance of clear long-term objectives for emissions reductions, both for climate and for industrial competitiveness. At the same time, we urge caution when designing the post-2030 policy framework for maritime transport. Shipping is a global industry, and unilateral or overly stringent EU requirements risk creating fragmentation and undermining competitiveness. It is essential that EU measures remain fully aligned with international processes at the International Maritime Organization (IMO). A strong EU contribution at IMO level is the most effective way to reduce global maritime emissions while maintaining a level playing field. For the maritime sector, several concerns should be highlighted: Avoiding double regulation: The extension of the EU ETS, the introduction of FuelEU Maritime, and upcoming sustainability requirements for fuels already place heavy burdens on shipowners. Additional, separate obligations linked to the 2040 target would create overlapping systems and increase compliance costs without corresponding climate benefits. Access to clean fuels and infrastructure: Short sea shipping operators face limited access to alternative fuels such as advanced biofuels, e-fuels, hydrogen and ammonia, as well as charging facilities for electrified vessels. EU policy should focus on enabling investments in port infrastructure, supply chains, and bunkering solutions rather than primarily tightening compliance mechanisms. Competitiveness and modal shift: Coastal and short sea shipping is a key enabler of sustainable logistics in Europe, offering lower emissions per tonne-kilometre compared to road transport. If policy design drives costs disproportionately higher for maritime operators, it risks shifting freight back to trucks, undermining climate goals. Safeguarding maritime competitiveness is therefore critical to achieve the overall EU decarbonisation pathway. Technology neutrality and realistic timelines: Full decarbonisation requires a portfolio approach, including efficiency measures, electrification where feasible, use of sustainable fuels, and carbon capture solutions for hard-to-abate segments. Regulatory frameworks must remain technology neutral and provide realistic transition timelines, recognising the capital-intensive nature of shipping. International cooperation: The proposal refers to the possible limited use of high-quality international credits after 2036. For shipping, international flexibility mechanisms under the IMO could play an important role, ensuring that efforts are coordinated globally while avoiding carbon leakage. In conclusion, we support the EUs ambition but stress that maritime decarbonisation must be addressed through global cooperation at the IMO, complemented by EU policies that focus on enabling conditions rather than excessive additional requirements. A fair, proportionate and technology-neutral framework will ensure that shipping continues to be a cornerstone of Europes sustainable transport system. Kystrederiene Norwegian Coastal Shipowners Association
Read full responseResponse to Technical updates of the Emissions Trading Scheme (ETS) State aid guidelines
21 Aug 2025
Consultation Response from Kystrederiene Call for Evidence Technical updates of the ETS State Aid Guidelines Kystrederiene, the Norwegian association of short sea shipping companies, welcomes the European Commissions initiative to update the ETS State Aid Guidelines in light of the significantly changed market conditions since their adoption in 2020. We recognize the need to ensure that support measures remain aligned with current CO price levels, thereby reducing the risk of carbon leakage and safeguarding industrial competitiveness. Acknowledgement of the Commissions initiative We agree that the substantial increase in CO prices since 2020 has affected a broader range of sectors than initially foreseen. Updating benchmarks, CO emission factors, and geographical parameters is crucial to ensuring that aid is based on accurate and verifiable data. Extending eligibility to newly affected sectors is consistent with the original intent of the guidelines and essential to maintaining a level playing field. Relevance to maritime transport Although the current update primarily addresses energy-intensive land-based industries, it also has important implications for the maritime transport sector: Indirect cost exposure Shipping companies, particularly in short sea shipping, are significantly affected by rising energy and fuel prices resulting from the EU ETS. These costs directly impact competitiveness against land-based modes of transport, particularly road transport, which continues to receive substantial public support through infrastructure investments and, in many cases, tax exemptions. Risk of carbon leakage in transport Just as in heavy industry, maritime transport faces a real risk of carbon leakage. If operating costs under the ETS framework continue to rise without corresponding support measures, transport work may shift from sea to road. This would undermine the EUs modal shift ambitions, increase congestion, and lead to higher overall emissions. Consistency and fairness By expanding support for selected industries, the Commission rightly acknowledges that the original assumptions no longer reflect market realities. However, leaving the maritime sector outside the scope of compensation mechanisms risks creating further distortions in competition. Maritime transport is already disproportionately exposed to multiple overlapping regulatory and fiscal measures (ETS, FuelEU Maritime, national CO taxation), which cumulatively undermine its role as the most energy-efficient mode of freight transport. Recommendations We encourage the Commission to consider the maritime sector in future revisions of the ETS State Aid Guidelines. Shipping, particularly short sea shipping, is exposed to similar risks of cost escalation and carbon leakage as the energy-intensive industries currently covered. Member States should be allowed flexibility to design aid schemes that can address these risks in maritime transport, particularly where increased costs threaten modal shift objectives and EU climate goals. In line with the principles of technological neutrality and fair competition, support should not be limited to land-based industries but extended to other sectors where ETS-related costs have systemic impacts on competitiveness and decarbonisation. Conclusion Kystrederiene supports the Commissions technical update of the ETS State Aid Guidelines as a necessary adjustment to current market conditions. At the same time, we strongly urge that the maritime transport sector be considered in future updates to ensure that EU climate policy remains coherent, cost-effective, and fair across sectors. Without such consideration, there is a significant risk that the intended benefits of the ETS and related climate measures will be undermined by shifts in transport patterns and loss of competitiveness in short sea shipping.
Read full responseResponse to European climate resilience and risk management law
8 Aug 2025
Consultation Response Kystrederiene European climate resilience and risk management integrated framework Kystrederiene The Norwegian Short Sea Shipowners Association welcomes the Commissions initiative to develop a comprehensive framework for climate resilience and risk management. Our members operate coastal shipping services for bulk cargo, general cargo, passenger transport, and specialised maritime operations along the Norwegian coast and across European waters. Though Norway is not an EU Member State, the maritime sector is deeply integrated with the EU through the EEA Agreement. Coastal shipping is an essential part of Europes transport network and plays a strategic role in climate adaptation, disaster preparedness, and supply chain resilience. Coastal shipping as critical resilience infrastructure Coastal shipping offers an energy-efficient and climate-resilient alternative to road and rail. During extreme weather events that disrupt land transport, shipping can maintain flows of essential goods, fuel, construction materials, and food. The framework should explicitly recognise maritime transport, including short sea shipping, as part of Europes core resilience infrastructure and integrate it into climate risk assessments and emergency preparedness planning. Climate risks to maritime operations and infrastructure Shipping is itself vulnerable to climate change impacts including more frequent storms, rough seas, sea level rise, and strain on navigational safety systems. The resilience by design approach must account for operational realities at sea and for the diversity of coastal environments across Europe. Ports and infrastructure Many ports, particularly small and medium-sized ones, are critical for regional supply chains yet face resource constraints. Climate-proofing port infrastructure is essential but should be supported by EU co-financing and technical assistance. Targeted funding should be available to SMEs and smaller ports for adaptation measures, digitalisation, and resilience-enhancing technologies. Innovation opportunities The initiatives emphasis on developing markets for climate resilience solutions is an opportunity for the maritime sector: climate-resilient vessel designs, advanced routing/weather prediction systems, and digital tools for supply chain resilience. EU funding and innovation programmes should be accessible to SMEs and to EEA/EFTA operators. Governance and reporting Harmonised risk assessments are welcome, but administrative requirements must be proportionate. Reporting obligations on climate adaptation should be streamlined and avoid duplication with other environmental and safety regulations. Recommendations Recognise maritime transport including coastal and short sea shipping as critical resilience infrastructure. Integrate maritime transport and port infrastructure into EU-wide climate risk assessments and adaptation strategies. Provide financial incentives and co-funding for SMEs to implement adaptation measures. Ensure EEA/EFTA countries have fair access to EU funding and innovation programmes. Promote innovation in maritime climate adaptation solutions. Apply proportionality in reporting and compliance obligations. Conclusion Maritime transport is both vulnerable to climate change and an enabler of resilience. By fully integrating coastal shipping and ports into the framework, the EU can strengthen supply chain security, protect communities, and promote sustainable transport under changing climate conditions. Kystrederiene is ready to contribute expertise and practical experience to support a robust, effective, and implementable European climate resilience and risk management framework.
Read full response2 Jul 2025
Subject: Feedback on the Extension of the Carbon Border Adjustment Mechanism (CBAM) to Downstream Products and Anti-Circumvention Measures Submitted by: Kystrederiene (The Association of Norwegian Coastal Shipping Companies) Date: 2-6-2025 Introduction Kystrederiene represents the interests of Norwegian short sea and coastal shipping companies that are vital to national supply chains, industrial logistics, and climate-friendly transport solutions. We appreciate the opportunity to comment on the Commissions call for evidence regarding the potential extension of the CBAM Regulation (EU 2023/956) to downstream products and anti-circumvention measures. While maritime transport is not directly included in the CBAM scope, this initiative may have significant indirect consequences for our sector and the industries we serve. General Support for Climate Objectives Kystrederiene supports the EUs efforts to combat carbon leakage and ensure that the carbon cost of imports reflects the EUs climate ambitions. A level playing field for decarbonised goods is essential, and we recognise the need to prevent circumvention and leakage through complex supply chains. Key Considerations for Coastal and Short Sea Shipping 1. Impact on Trade Patterns and Logistics The extension of CBAM to include downstream products such as processed steel and aluminium will influence global sourcing strategies. This will likely result in: A shift in trade routes and cargo composition, potentially affecting volume and route viability for shipping companies. Increased complexity in logistics chains, as suppliers and importers seek to avoid CBAM costs by re-routing or consolidating operations elsewhere. For coastal shipping, which depends on high cargo density and regular schedules, these changes can reduce efficiency, increase costs, or create sudden imbalances in demand. 2. Indirect Administrative Burden CBAMs expanded scope may require shipping companies to: Provide documentation or emissions-related data to support carbon footprint declarations for goods they transport. Align with reporting obligations in the supply chain, even if not directly regulated under CBAM. For small and medium-sized shipowners, this could impose administrative burdens that are disproportionate to their role in the value chain. 3. Opportunity: Shipping as a Low-Emission Transport Mode As the EU aims to promote decarbonised value chains, it is crucial to recognise that: Short sea shipping offers significantly lower emissions per tonne-kilometre than road transport. Coastal shipping should be highlighted as a climate-efficient transport solution within decarbonisation-oriented regulation. The CBAM revision should explicitly ensure that climate-friendly transport modes are not disadvantaged through increased indirect costs or administrative burdens. Recommendations Assess Trade Flow Impacts on Maritime Transport The impact assessment should include effects on trade flows and modal shifts that may affect maritime transport, particularly coastal and short sea shipping. Avoid Unintended Administrative Spillover Ensure that CBAMs implementation does not indirectly create reporting obligations for shipping companies, unless clearly justified and supported by harmonised tools and digital platforms. Recognise the Role of Green Shipping As decarbonisation of logistics becomes a priority across sectors, the Commission should recognise shipping as a key enabler of sustainable supply chains. Incentives or recognition mechanisms for low-emission maritime logistics should be considered. Coordinate With ETS and FuelEU Maritime The interaction between CBAM and existing maritime climate regulations (EU ETS for shipping, FuelEU Maritime) must be clarified, especially in cases where embedded emissions from transport are part of the carbon accounting for imported goods. Closing Remarks Kystrederiene welcomes the Commissions inclusive approach to stakeholder input and calls for con
Read full response2 Jul 2025
Summary of the Norwegian Coastal Shipowners consultation response on the review of the EU ETS and related climate regulations The Norwegian Coastal Shipowners, representing over 230 shipping companies with nearly 10,000 seafarers, support the EUs ambition to reduce greenhouse gas emissions from shipping. However, they emphasize that regulations must ensure fair, predictable, and practical conditions for short sea shipping, which is essential to societal resilience and emergency preparedness in Norway. 1. Avoid double taxation A central concern is the risk of double taxation on the same emissions, where shipping companies are subject both to the EU ETS and Norways national CO tax. This disadvantages Norwegian coastal shipping compared to foreign competitors. A refund mechanism is being considered by Norwegian authorities, but it requires clarification and ESA approval. More broadly, all overlapping climate mechanisms (e.g. IMO levies) must be coordinated under the principle: one emission one price. 2. Lowering ETS threshold to 400 GT The Shipowners support extending the ETS to vessels from 400 GT and up (down from the current 5,000 GT), to ensure more balanced competition and incentives for decarbonization. However, this must be implemented gradually and predictably, with support for smaller operators. 3. Clarify treatment of Norwegian-specific operations Particular attention is needed for the aquaculture sector and its service vessels, which operate under unique conditions along the Norwegian coast. These must be clearly defined and treated appropriately under the EU ETS and FuelEU Maritime frameworks. Dialogue between the EU and Norwegian authorities is needed before full implementation. 4. Protect vessels providing critical public services Many coastal ships operate vital supply, transport, and emergency preparedness services under public contracts. These should be eligible for exemptions, compensation, or support schemes to avoid disruptions or unfair competition from foreign vessels not subject to the same obligations. 5. Harmonize reporting systems Shipping companies face overlapping reporting under EU MRV, IMO DCS, and national systems. The EUs effort to harmonize MRV with IMO DCS is welcomed. The goal should be one unified, digital, and simple system to reduce administrative burdens, especially for small and mid-sized companies. 6. Reinvest ETS revenues into green shipping Norwegian ETS revenues currently go to the general state budget. Kystrederiene calls for earmarking these funds to support the green transition in the maritime sector through infrastructure, fleet renewal, and innovation mirroring EU countries' reinvestment rules. 7. Responsible implementation and reduced bureaucracy The complexity of climate rules (e.g. ETS, FuelEU Maritime, CII) requires phased, realistic implementation. The EU should involve industry in designing practical systems and allow advisory or transitional periods before enforcement to reduce risk of confusion and excessive administrative load. Conclusion The Norwegian Coastal Shipowners support the EUs climate goals and seek to be a constructive partner. They urge the EU to: Prevent double taxation Include smaller vessels thoughtfully Recognize the special nature of Norwegian coastal shipping Protect essential public maritime services Harmonize reporting systems Allocate ETS revenues to maritime climate measures Ensure feasible and coordinated implementation These steps will help achieve emissions reductions without undermining a resilient, competitive, and sustainable short sea shipping industry.
Read full responseMeeting with Andrea Gavinelli (Head of Unit Health and Food Safety)
24 Apr 2025 · Discussion on the Commission legislative proposal on the protection of animals during transport with a focus on the transport of aquatic animals by well-boats.
Response to Rules for the FuelEU database under Article 19(3) of the FuelEU Maritime Regulation
3 Mar 2025
Consultation Response to the Implementing Regulation for the FuelEU Database Bergen, March 3, 2025 On behalf of Kystrederiene, we would like to submit our input on the European Commission's proposed implementing regulation for the FuelEU database, related to Regulation (EU) 2023/1805 on the use of renewable and low-carbon fuels in maritime transport. Introduction Norway is part of the EEA, and Norwegian ports are consequently considered EU ports in connection with the FuelEU Maritime Regulation. This means that the requirements of the regulation will apply directly to Norwegian shipping and port operations. This has significant consequences for the industry, including increased infrastructure requirements, administrative burdens, and financial commitments. Delays in implementing EEA legal acts have meant that current EU regulations are not yet applicable in Norway, but we expect this to be implemented soon. Key Points in Our Consultation Response Access Rights and Administration of the FuelEU Database (Article 3) We support the introduction of a harmonized reporting system but emphasize the need for a smooth implementation for Norwegian stakeholders. Article 3 specifies different access levels for stakeholders such as administrative authorities, flag states, port authorities, and companies. It is crucial that Norwegian shipping companies have easy access to the FuelEU database and that training is provided to ensure proper use. We recommend simplifying data access for companies with multiple vessels to reduce the reporting burden. Requirements for Shore Power and Zero-Emission Technologies in Ports (Article 4) Article 4 mandates the use of On-Shore Power Supply (OPS) when ships are docked in EU ports. Since Norwegian ports are considered EU ports, this will require significant investments in OPS infrastructure. We urge the introduction of transitional arrangements or exemptions for ports that do not yet have the capacity to provide OPS to all visiting ships. Issuance of FuelEU Compliance Documents (Article 6) Article 6 requires verifiers and administrative authorities to issue compliance documents for ships. We propose automating this process to reduce delays and administrative burdens. Monitoring and Updating the System (Article 9) Article 9 mandates the European Maritime Safety Agency (EMSA) to update the FuelEU database. We emphasize the need for Norwegian stakeholders to be consulted in the development process, as the regulations also affect EEA countries. Final Remarks We recognize the need for a harmonized system for reporting and verifying fuel use in the maritime sector but stress the importance of smooth implementation for stakeholders in the EEA area. Clear guidelines are needed on how Norwegian ports and shipping companies should operate within this regulatory framework, as well as what support schemes and transition periods will apply. We appreciate the opportunity to provide input and look forward to further dialogue on how FuelEU Maritime can be implemented in a way that balances climate considerations with the economic and practical realities of Norwegian shipping. Best regards, Tor Arne Borge Chief Executive Officer (electronically signed) Karsten H. Sprenger Senior Advisor, Policy, Analysis, and Public Affairs (electronically signed)
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