Nippon Yusen Kaisha

NYK Line

NYK Line is a global shipping company, established in 1885.

Lobbying Activity

Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

7 Jul 2025

We would like to express our sincere appreciation for the opportunity to contribute to the European Commissions call for evidence of the impact. We welcome this important review process and are grateful for the chance to share our perspective. NYK Line (Nippon Yusen Kabushiki Kaisha) : The NYK Group is a global shipping company founded in 1885 and headquartered in Japan, currently operating a fleet of over 800 vessels. We are firmly committed to decarbonization, as outlined in our NYK Decarbonization Story, with targets to achieve net-zero by 2050. Leveraging both our technical expertise and extensive business experience, the NYK Group is advancing innovative projects such as alternative-fueled and autonomous vessels. We are actively engaged in ship recycling initiatives aligned with circular economy principles and are developing digital solutions to enhance seafarer welfare. We believe these initiatives support the European Commissions goals related to sustainability. Position on the review of EUETS for maritime : The NYK Group strongly hopes that the EU ETS will be replaced by the IMO Net-Zero Framework. We appreciate the European Unions continued leadership in environmental regulation, exemplified over the past two decades through initiatives such as the EU Emissions Trading System (EU ETS). We also commend the foresight shown in implementing both the EU ETS and FuelEU Maritime, which demonstrate a strong commitment to an economic approach for driving decarbonization in the maritime sector. It is clear that the EUs early action and leadership within the IMO have played a significant role in advancing the development of the IMO Net Zero Framework. The EUs efforts have helped shape the global discourse and laid a strong foundation for international progress. Looking ahead, we hope the IMO will build on this momentum and take over the leadership role from the EU establishing itself as the primary forum for coordinating a globally consistent and effective approach to maritime decarbonization. The IMO Net Zero Framework reflects many of the principles pioneered by the EU. We believe that the IMO Net Zero Framework will contribute more effectively to promoting the decarbonization of the maritime sector, as it takes a global rather than regional approach, covers the full well-to-wake lifecycle, and allocates its revenues to measures that support this transition. At the same time, we would like to highlight the potential challenges arising from overlapping regulatory frameworks. If the IMO Net Zero Framework enters into force while the EU ETS and FuelEU Maritime remain unchanged, the maritime sector would face a double burden - both financially and administratively. This concern is further amplified by the momentum not only within the EU but also in other regions, which are developing or considering their own emissions trading schemes that include international shipping. Multiple regional and national ETS obligations could place significant administrative strain and compliance risk on international shipping companies, especially those calling at numerous ports worldwide. This could potentially divert resources away from actual decarbonization efforts. Finally, consistent with the polluter pays principle, the economic impact of these costs is ultimately borne by charterers and, eventually, consumers, including European citizens. At this crucial juncture, it is essential for the EU to take the initiative and demonstrate leadership by consistently working towards the harmonization of regional and international regulatory approaches. This ongoing effort is vital to ensure a fair, effective, and efficient decarbonization of the maritime sector.
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