The EU Emissions Trading System comes into full force — and permanently changes the conversation between Ecuador and its shipping lines
For years, Ecuadorian exporters negotiated with shipping lines on essentially two variables: the base rate and the seasonal surcharge. That conversation has changed. Since January 2026, there is a third line on every quote that is non-negotiable, non-seasonal, and does not disappear when freight rates fall: the carbon emissions surcharge.
This is not a future threat. It is a reality that Maersk and Hapag-Lloyd have already published in their first-quarter 2026 tariffs, and it reflects a structural decision by Brussels that has been rolling out in phases for three years.
What the Emissions Trading System Is — and Why 2026 Is the Year That Matters
The European Union Emissions Trading System (EU ETS) incorporated maritime shipping on a precise escalation schedule: carriers covered 40% of their reported 2024 emissions during 2025; in 2026 they must cover 70% of reported 2025 emissions; and 100% applies from 2027 onward for reported 2026 emissions. Several carriers — Hapag-Lloyd among them — communicate 2026 as the year of “full implementation” in their surcharge adjustments, because it is the first year in which the obligation exceeds the halfway mark and the cost becomes materially significant on the client’s invoice.
One scope detail that matters for Ecuadorian exporters: the EU ETS does not apply equally to all routes. Voyages within the European Union and calls at European ports are subject to 100% of the obligation; legs between Europe and ports outside the EU — such as Ecuador’s — apply to 50% of the corresponding journey. The partial rate does not eliminate the cost; it moderates it, but it does not make it optional.
Alongside this, the FuelEU Maritime Regulation came into force in 2025, requiring vessels operating with the EU to reduce the carbon intensity of their fuel by 2% relative to the 2020 baseline. The next mandatory reduction is 6% by 2030. Both regulations operate simultaneously, and in most cases shipping lines consolidate them into a single surcharge on the invoice.
Hapag-Lloyd announced that its EU ETS surcharge will increase approximately 45% in 2026 compared to the prior year, as a direct result of the escalating emissions coverage requirement and rising carbon permit prices. Maersk calculated its first-quarter 2026 surcharge using the average European emission allowance price, which stood at €76.75 per tonne between August and November 2025. Analyst surveys compiled by Reuters place the projected average price for 2026 at around €92 to €93 per tonne. The volatility is not a minor detail — it means that a surcharge locked in today through a long-term contract may not reflect the actual cost six months from now.
Why This Hits Ecuador Harder Than Other Exporters
The European Union was the top destination for Ecuador’s non-oil exports in 2025, at $7.237 billion — 23% of total exports. The two flagship products in that relationship are precisely the most exposed to the EU ETS impact: bananas and shrimp, both shipped in refrigerated containers, which carry higher energy consumption and therefore a larger carbon footprint per box moved.
In January 2026, the EU accounted for 34.36% of Ecuador’s total banana exports, with growth of 15.57% compared to the same month the previous year. Shrimp generated $8.401 billion in exports during 2025, with 20.2% growth, cementing Ecuador’s position as the world’s leading exporter of the product. Both sectors are entering this new regulatory regime at their highest historical volumes — which amplifies both the opportunity and the exposure.
The impact mechanism is straightforward: the EU ETS surcharge varies by route, container type, and size. Maersk publishes differentiated tables by trade, box size, and container type — dry or reefer — and surcharges have increased substantially compared to 2025. For Ecuadorian exporters, this means that logistics costs to Europe can no longer be modeled with a fixed figure. They depend on the quarter, the cargo type, and the spot price of carbon permits on the European market.
Who Wins, Who Loses
Shipping lines that invest in efficiency and alternative fuels hold a growing competitive advantage. Some operators use transshipment hubs such as Tanger Med in Morocco or Port Said in Egypt as part of their routing architecture — though the European Commission has explicitly identified these as neighboring transshipment ports subject to monitoring, precisely to prevent them from becoming regulatory evasion mechanisms. Using them may make operational sense, but it does not automatically eliminate EU ETS exposure.
The Ecuadorian exporter who negotiates from a position of knowledge gains leverage at the table: they can request itemized surcharge breakdowns to verify that amounts charged correspond to actual costs, and structure contracts with adjustment clauses tied to carbon permit price fluctuations. Those who don’t will simply pay whatever rate they are presented with, with no basis to question it.
Two Scenarios
The likely scenario — surcharge normalization as a structural cost. The European carbon permit price holds within the range projected by analysts, and shipping lines consolidate their surcharges in a transparent, predictable manner each quarter. The additional cost is real but manageable for exporters who incorporate it into their pricing structure in advance. Trigger: advance publication of quarterly tariffs with at least 60 days’ notice.
The dangerous scenario — margin pressure with no pass-through. The carbon permit price climbs above projected ranges, surcharges become unpredictable, and Ecuadorian exporters who signed fixed-price contracts with European buyers cannot pass on the additional cost. In bananas, where the minimum box price is set at $7.50 for 2026, the absorption margin is limited. Trigger: carbon permit price sustainably exceeding €100 per tonne for a full quarter.
What Cannot Wait
The green surcharge is not a temporary line on a freight quote. It is the new cost architecture of trade with Europe. The Ecuadorian exporter who still treats the EU ETS as their shipping line’s problem — rather than as a variable in their own business model — is making pricing decisions with incomplete information. The conversation with Brussels is no longer just about tariffs and quotas. It is also about how much carbon is embedded in every box that arrives in Rotterdam.
Sources: Comisión Europea (EU ETS, FuelEU Maritime); Hapag-Lloyd (comunicado noviembre 2025); Maersk (tarifas Q1 2026); Reuters (proyección precio permisos carbono 2026); Portal Frutícola (ACORBANEC, datos enero 2026); Infobae (exportaciones no petroleras Ecuador 2025).