The escalation of conflict across the Middle East and the disruption to energy flows through the Strait of Hormuz have introduced a variable into the maritime energy transition that regulatory frameworks were never designed to handle: the possibility that conventional marine fuel becomes unavailable because competing domestic priorities absorb the available supply. This changes the analytical framing for clean shipping in a big way.
Steeper decline than FuelEU Maritime, similar architecture
The regulation applies to operators rather than shipowners and covers the combined energy use of all ships providing transport of provisions, materials, personnel and equipment, anchor handling, towing, pipe and cable laying, installation, operational and cessation activities, and emergency preparedness around facilities. Vessels engaged for fewer than 30 days in a compliance period are exempt.
The intensity reduction schedule works against the same 91.16 gCO2eq/MJ reference value used in FuelEU Maritime, applied over four three-year windows: 10% from 2029 to 2031, 15% from 2032 to 2034, 20% from 2035 to 2037, and 40% from 2038 to 2040. Figure 1 places this trajectory alongside FuelEU Maritime and the well-to-wake intensity of the fuels currently in use on the Norwegian Continental Shelf. The Norwegian target sits below FuelEU throughout the window, with the gap widest in the final period.
Familiar features carry over so that operators can pool compliance with each other, and over-compliance can be banked into the next three-year period. A multiplier of two applies to electricity, RFNBOs, low-carbon hydrogen and fuels derived from it through 2033, providing accelerated credit for early adoption. Enforcement is by administrative penalty under Section 80 of the Pollution Control Act, with the size of the penalty left to the Norwegian Environment Agency's discretion. For cost modeling, this remains a material unknown.
Conventional-engine fleet insufficient to comply
Figure 2 shows offshore vessels operated in Norway in 2026, grouped by licensee operator and engine type. Equinor accounts for almost 100 vessels, followed by Aker BP with around 65 and Vaar Energi with around 40. The long tail of smaller operators brings the total close to 300 vessels potentially in scope.
The engine mix is a significant obstacle to compliance. The clear majority of these vessels run conventional engines. Where alternative fuel capability exists, it is almost entirely LNG dual fuel, dominated by LNG Otto medium speed. Under the default values in Appendix II of the regulation, LNG Otto DF MS carries a methane slip of 3.1% and a well-to-wake intensity of about 89 gCO2eq/MJ when run on fossil LNG. That sits just below the VLSFO baseline and well above the Norwegian trajectory from 2029 onwards, making fossil LNG burned in the most common dual-fuel engine not a compliance fuel.
A narrow menu of pathways shifts burden to shipowners
The compliance challenge is sharpened by how the regulation handles liquid biofuels. Section 6 states that biofuels and recycled carbon fuels are deemed to have the same emission factor as the least favorable production process for the corresponding fossil fuel, while biogas in the following paragraph receives a conditional Renewable Energy Directive (RED) pathway. Biodiesel and renewable diesel, the workhorses of drop-in decarbonization under FuelEU Maritime, are therefore not a compliance pathway under the Norwegian rule regardless of certification.
Bio-LNG can contribute provided the underlying biogas meets RED sustainability and emission reduction requirements, with documentation following a Commission-approved voluntary scheme using mass balance under Article 30(1). RFNBOs sit on the favorable side of the regulation and benefit from the multiplier of two through 2033, although availability and cost remain binding constraints. Shore power and direct electrification count as zero emission, but the operational profile of most offshore vessels limits how much energy can realistically be drawn from a grid connection.
For the conventional vessel owners that make up the bulk of the fleet, operators will become more selective on decarbonization specifications when awarding charters, favoring vessels with bio-LNG, e-fuel or shore power capability. This pressure compounds with offshore vessels entering the EU Emissions Trading System from 2027 and a potential FuelEU Maritime extension to offshore activities thereafter.
Author:
Junlin Yu
Vice President, Head of Clean Shipping Solution
junlin.yu@rystadenergy.com
This article draws on insights from our latest commentary, "Norway’s GHG rule outpaces FuelEU, leaving most of the fleet non-compliant". The full analysis is available to clients via the Client Portal.
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