The Wavemakers Podcast

FuelEU Maritime Masterclass by BetterSea

• BetterSea • Season 2 • Episode 1

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If you’re looking for actionable insights on FuelEU Maritime, this episode is a must-listen!

In an informative discussion, BetterSea co-founders Gordana Ilic and Maximilian Schroer explain the key aspects and mechanisms of the FuelEU Maritime regulation entering into force in Jan 2025. 

They address the topics such as the use of alternative fuels, penalties, pooling, banking and borrowing, as well as regulation implications on different maritime stakeholders: ship owners, ship managers, alternative fuel suppliers, fuel brokers, commodity traders. 

BetterSea brings unique market insights on how different parties plan to address the topic, what to keep in mind when considering trading compliance surplus, and why strategies such as creating a superpool may seem like a good low hanging fruit solution, but not necessarily the best one.

The conversation also highlights how BetterSea’s end-to-end platform addresses the challenge and simplifies compliance by providing an integrated FuelEU pooling marketplace that ensures transparency, fair pricing, and strategic decision-making.

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🔗 Related Resources and Links:
• Follow Gordana Ilic on Linkedin: https://www.linkedin.com/in/gordanailicphd/
• Follow us on Youtube: https://www.youtube.com/@BetterSea

📩 Have questions or comments? Feel free to reach out via email at gordana.ilic@bettersea.tech

Hello and welcome to the FuelEU Maritime masterclass! As you know, we are counting down towards FuelEU Maritime, beginning in January 2025, so we thought it could be timely to go over some of the basics, but also bring some of the market insights that we as BetterSea have. As you know, BetterSea provides an

end-to-end platform with an integrated Marketplace [for pooling] 
to help shipping companies address FuelEU compliance. And naturally, today with me is my co-founder Max. Welcome, Max! Hi Gordana and I'm happy to contribute to the FuelEU Masterclass. First things first, we cover the basics. So can you perhaps help me introduce FuelEU Martime to our viewers; and if they don't know, if they are starting, perhaps we can slowly guide them through what it is, what are some of the most important things to keep in mind, and then we can switch to addressing some of the user needs? So, we can pretend that I am one of the users and we can maybe role shift to help the users adjust this topic. Sure. Let's start with what it is. Yes. So basically, FuelEU is the newest regulation that comes out of the EU after the EU ETS, that started in January 2024, and now FuelEU Maritime tackles again the shipping emissions. This time, however, it is based on the well-to-wake (WtW) so full life cycle of the fuel greenhouse gas emissions. So it not only covers carbon emissions as EU ETS, but it also covers the greenhouse gas emissions so methane and nitrous oxides. Some may say that FuelEU is the one moving the industry a bit further togreen shipping, compared to EU ETS, what is your comment on this? Yes, that's totally true. Because, for example, methane is a way larger contributor to climate change and the global warming compared to just the carbon emissions, and therefore, FuelEU covers a way larger scope in that sense, and also for example, tackles contributors that have more methane emissions, compared to carbon emissions, and those would not be covered by EU ETS solely. So as we know, most of the companies are not using alternative fuels, right? So what are the ways and mechanisms of compliance for these companies? So first and foremost, in order to comply with FuelEU, you can either pay a penalty, which would be €2,400 per ton of VLSFO equivalent that you are above the target, you can then... The second option will be to use alternative fuels, that you have already said, the companies might not want to use, or definitely it is scarce and expensive. The third option would be to use this new [FuelEU] pooling mechanism that the regulation came up with. Can you share more about it? Yes, so the pooling mechanism is very individual to FuelEU and the idea is that companies who usually would invest into retrofitting older vessels in order to make them compliant, now don't need to invest in these old ships that anyways will leave the fleet soon, but instead, they would invest in new buildings and this can be utilised by using this [FuelEU] pooling mechanism. Where, instead of a single vessel compliance, we have a compliance on a group- or what they also call "Fleet-level". This Fleet level compliance is essentially creating a pool; so several ships together in a group create this pool and then sort of on an average, 
in fact it's the sum of the compliance balances, they comply with the regulation, so a single, for example, an older vessel that would not be eligible to use alternative fuels or where the retrofit doesn't make sense economically, would then not be compliant individually, but when teamed up with for example newbuild that uses alternative fuels it would be compliant together. And that's how we use the [FuelEU] pooling mechanism. And very interesting here is that the [FuelEU] pooling mechanism can be used both internally, so within the company's fleet but also externally, so between different companies. Mhm, and before we touch deeper upon the pooling mechanisms... Why would someone be incentivised to pool? On the one hand, of course, as I said, there are not that many compliance options that one can use. The penalty is quite high and then on top, you have the biofuels, for example, or any other alternative fuels like e-fuels that are scarcely available and expensive. So pooling is kind of straightforward, because it is easily accessible if you have the right setup, and it promises to be cheaper than, for example, using alternative fuels. And in that case, it's quite a good option to comply with FuelEU. So if a company is using alternative fuels, what would their options be? So if a company already uses alternative fuels, then the suggestion would be that first they would offset their internal ships, so those that they own or maybe even charter and then using basically the alternative fuel that they have. They would create an internal pool that is compliant with those vessels that individually would not be compliant and then afterward we would suggest to, for example, use the pooling mechanism with other companies to, for example, trade the [FuelEUCompliance] 
Surplus that they have created. 'Surplus.' When I say 'Surplus' that basically means that it is over compliance with the regulation, achieved through using, alternative fuels and this comes with a value because other companies who are non-compliant and maybe do not use alternative fields, are of course, interested to get into this pool and to profit from the Surplus that the other company has, and then if you have created your internal pool, you still have over-compliance ,you could trade this over-compliance to a different company and open this pool up externally. And which companies are more likely to be compliant and 
over-compliant? Which are those that are likely to generate Surplus? So from our own experiences at BetterSea, we see that, for example, mostly the bigger companies, usually in Northern Europe, that have already investigated the use of alternative fuels, that are may be known as decarbonization leaders in their space, those usually have created Surplus or plan to create Surplus and have used FuelEU as an option to improve their business cases of decarbonization. What we see is also that many who are using biofuel, or intending to use biofuel, are the ones incentivized to generate Surplus and plan to sell it on a Marketplace. However, for example LNG vessels are also over-compliant. Can you comment a bit on different types of fuels that vessels can use and how that relates to their compliance, over-compliance, the ability to form pools? So, in general, one can say that fossil fuels other than LNG are non-compliant. So every ship that usually uses HFO, MDO, LFO, etc. will not be compliant with the regulation and therefore needs to find a different way to comply. And that goes back to the options that we already discussed and then we have, for example: LNG or LPG that is compliant with the regulation, that creates actually a surplus on top. We have all kinds of alternative fuels, so we have: biofuels - here it is important to note that we have a feed stock requirement by the RED and then on top we have e-fuels, so all kinds of hydrogen, methanol, etc. and here it is important that the fuel is also certified according to the international standards; so that will be an ISCC certification and always in relation to the RED Direct. If you have an LNG vessel, what would most likely be your strategy? So LNG is a bit tricky, because on the one hand, it's a fossil fuel, right, in that case? But it's still compliant. However, it is dependent on the engine type - so, for example, the Otto medium- speed LNG vessel is non-compliant with the regulation from 2030 onwards. whereas other engine types would still be compliant, for example to 2035. So usually what you would think is the LNG vessels and their owners would trade the Surplus, because they don't have any extra cost due to the fact that they anyways operate on LNG and they are happy having an additional revenue stream, but if they are forward-looking, then they would start banking the surplus, because in the future, all these requirements from FuelEU - they get more and more ambitious. Which essentially means, that in that case, if you Bank the Surplus, you can utilise it for the future years, where your vessel will not be compliant and you don't have the headache around: Oh, do I need to use alternative fuel? Do I need to pool? Because in that case everything is sorted out. This also depends slightly on what is your business model model, right, and whether you are having predictable routes, or you're trading on spot market? What do you think is the most prominent strategy here between different companies? Yes. So what we see here from the market is that companies that have a more predictable operations, like for example, liner shipping companies but also ferry lines, etc... They sort of know what will happen and they often prefer to have planning security and reliability in that sense. Which means that they usually look into buying the Surplus or selling the Surplus early, so that, for example, they can price it into their freight rates or charter rates ,or they simply have it within their budget for that year. However when we then look into tramp shipping and especially the spot market, then we see that companies will likely only buy surplus, or in that case pool, later in the year or even shortly before the compliance period ends, because they don't even know in most cases whether the ships will end up in Europe or not. So now that we have the Surplus owners who are likely to offer some of that extra to the market to be bought... Where can they put it and offer it to the market? Yes. So here we see different strategies in the industry. Of course, the initial idea would be that you as an owner who has Surplus go out and call maybe your friends or your connections in the industry and try to figure it out with them. That is a bit tricky, because it's not only just finding a price and deciding on it, you also need to set up all the intricacies around it. So you need to figure out whether, for example, the person that you called has the right requirement for your Surplus. Then, you would need to track the whole compliance going forward, once you have agreed on it whether you will actually end up with your pool that you have built - in Surplus or deficit, and whether this pool will be valid or not; and then of course you need to set up all these contractual agreements. Because even though it might be a friendship, in the end, you have a contractual liability around and it's a commercial value that you are trading, right, and then lastly, you need to do the pool verification around all these things, and in that case that might be the initial idea but it's not usually the best one. And then we have seen in the industry people are coming up with, for example, manual brokering -
which would sort of be a bit of an advancements of the first idea, but then you also have, what we call usually nowadays "a super pool" and the "super pool" will be run by a centrally managed party and that party basically tries to gather surplus, as well as deficit, and then create one big pool out of all these different parties that either provide surplus and deficit and this centrally managed function will then make sure that the pool is valid and that everything is in line with the regulation. This is, of course, on the one hand an easy solution because you directly get access to the Surplus or the deficit and you can set it up. However, you would need to trust this centrally managed party and this is especially tricky if you end up, for example, not bunkering the amount of biofuel that you intended to bunker if you are a surplus seller, or you need more deficit than you actually anticipate it and then it becomes tricky. Especially if you think that there are... that this is a multi-stakeholder environment, meaning that there are a lot of players with a lot of interests that are all managed by a single entity. And you wouldn't know what is the actual price of the surplus, right? Because you're leaving it up to that party
to determine the price? Yes, so that is a problem with all these that I've just discussed there -
you basically don't have a transparent visibility on the price of surplus or its value; whereas in the third option that has been created by the industry, there we talk about a Marketplace. So here you actually have an open and transparent sort of a platform, where you get on and you can offer your surplus to all kinds of different players that are in need for the Surplus, or vice versa, you could offer your demand - I need Surplus as a deficit company, and all kinds of different players that provide Surplus can actually bid on it; and with that you sort of derive transparent pricing around [FuelEU Compliance] surplus and deficit, as it is led by the market rather than by a centrally managed function that sets the price for, for example, the super pool or the manually brokerage deal. In choosing the right FuelEU Marketplace, one needs to pay attention to the trading scheme and how it is done and how that element is interpreted by different companies, whether it can be re-traded, which we are personally not fans of, or you lock it in. With BetterSea, you can achieve end-to-end compliance. As mentioned, BetterSea provides a platform with an integrated Marketplace that is open and transparent, so the solution helps you understand your compliance, strategize different options, on how to go about it, and also helps you achieve the compliance by exposing you to the marketplace that is fully open and transparent and we help you with the full bureaucratic process - 
all the way till the end! We have talked about the offering, but we need to have a demand for a Marketplace to be successful. So who is in demand and how can companies understand whether they are in demand or not? So as we said earlier, basically every company that uses fossil fuels, except LNG, will have a demand because it will end up being non-compliant. It will end up facing the penalties of the regulation which can be up to 10% of the OPEX cost of a single vessel, so that's quite substantial. So all these companies that use these fossil fuels will be non-compliant and therefore have a demand for pooling if they do not use, for example, alternative fuels. Between different mixes that they can Implement... they can Implement mixes of biofuels, for example, to top it up. Which ones are your recommendations? Personally, I would choose to implement B30 fuel and then use it in order to be compliant with the regulation. If I don't have further customer demand from my own customers as a company to provide, for example, Green Solutions. Let's say that the biofuel is not available to be bunkered in the port, we didn't secure the amounts... How can we understand the exposure and calculate our exposure? Yes. So you would basically use a calculator that calculates the FuelEU compliance balance based on the fuel consumption of the different fuel types that you have. It is important that you simulate not only end-of-year compliance, but for example, depending on your charter agreements etc, also that you are able to calculate the effect of an upcoming voyage only. All this, by the way, you can do within the BetterSea FuelEU  platform where we have a simulator both for on a single vessel level, as well as on a fleet level. So for different pools etc. you can calculate what would be the requirement of any alternative fuel in order to make the pool compliant, or you can see what will be the future compliance status of one of my vessels, depending on, for example, using a different alternative fuel or shore power. If a person, let's say, uses our calculator they can choose different fuel types, but then, there's an option AR4 or AR5.What does that mean? Yes, so that refers to different values for global warming potentials, coming from the IPCC. Currently the regulation is based on AR4 values, but it has been indicated by EMSA, the European Maritime Safety Agency, that the regulation by January 2025 when it enters into force will be changed to AR5 values. What that essentially means is that everyone or every greenhouse gas type, let's say carbon, methane and nitrous oxide is assigned the global warming potential, so this global warming potential refers to how much effect does this gas have on the global warming. And carbon usually has one, and then we have methane, which locates around 25, and then we have nitrous oxides. So of course, in that case, for example, methane has a larger potential to contribute to global warming, compared to carbon, and these values change. So if you would base it on AR4 your values would be different than if you base it on AR5 and this is where the discrepancy may come if people are, for example, using some of their own internal tools that took AR4 values into account versus a calculator that uses AR5 values into the account. What we see is that, most likely, companies would calculate some of these values internally, they would maybe use a calculator and also there are other vessel performance tools, data analytics tools, that help them understand the exposure, right? So from that step, they also need to make sure that they are going into EU Waters in order to be exposed, and then the next step for them would be to put their demands on a Marketplace. I did remember one question from one of the customers, whether any of the Energy Efficiency Technologies change their exposure? That's an interesting question, because the customers are usually used to the fact that both, under CII, as well as EU ETS the exposure would be changed if they use any Energy Efficiency technology, or for example slow steaming. In fact under FuelEU this will not have a major effect because the way that the FuelEU indicator is calculated is based on the greenhouse gas emissions that are happening on board, based on the consumption, as well as based on the energy consumption on board of the vessel. So if I, for example, slow steam or use any Energy Efficiency technology, I have a reduced energy consumption, but also a reduced greenhouse gas emissions; so there's no effect on the indicator whatsoever. And how about the connection of EU ETS, wind assisted propulsion technologies to FuelEU exposure? So the wind assisted propulsion technology can be used in order to reduce your FuelEU exposure, therefore the regulation actually implemented a reward factor that is based on the wind power that is created, as well as the propulsion power vessels having, for example, rotor sale installed. Would they be able to form a pool or would they have reduced exposure, how does that work? Yes, so dependent on this ratio of the wind power and the propulsion power, they would either be able to form their pool or to have reduced penalties. It's strongly dependent on how this ratio plays out. In the calculator, as well, there is an ice class section - 
can you comment briefly about that? Yes because vessels sailing on the ice class, of course, have higher fuel consumption, compared to other vessels. That is on the one hand because of the preparation of the hull etc, to be able to sail under ice conditions, but then on the other hand, also because of the operational circumstances of sailing under Ice. The nice thing about FuelEU is that it takes both of these into account; so on the one hand, you have a sort of reduction factor that takes into account the fact that the vessel has hull preparations to be allowed to sail under ice and then, on the other hand, you can also report distance sailed in ice conditions, which will further reduce your greenhouse gas emission indicator in that case. So I did my calculations, I'm still under-compliant, what should be my strategy? Well if you are still under-compliant... so you calculated, you figured out you are under-compliant, then in that case you would need to think - okay now I have a few options: one option will be alternative fuels, another option would be winter assisted propulsion and the next option would be pooling. I cannot get alternative fuels, I haven't prepared my vessel to install anything wind assisted propulsion-related, pooling? Well, that's then the only option that remains if you don't want to pay the penalty! So what should I do now? Should I try to find my pooling partner early in the year, later in the year, should I go to a Marketplace? Should I call my friend? What should I do? Well if you intend to do pooling on a competitive price, then you would choose to go on a Marketplace and because then you can either find the Surplus or you can offer your demand and in that case you will then receive bids from different Surplus sellers, or you can compete with different deficit companies, in order to buy the Surplus that is offered. Should I start early, or should I wait? Well I would propose to start early, because from a market perspective, we can assume that usually the price would increase by the end of the compliance period, because then, as we said earlier, for example, people that work on a spot market in tram shipping etc, they will likely trade later, and then there will be a reshuffling around who has the right pool and who still needs something and maybe I did a wrong calculation so there will a lot of activity on the market at the end of the compliance period which will likely drive the price up. Whereas, if you start early, then you might be able to benefit from a lower price. Or have time to consider multiple options and perhaps bid to different parties and ensure that I secure some of that Surplus before it's too late? Okay, why would I just call my friend? Well, as we said before, if you just call your friend you have no idea about the actual value of the Surplus, so you might make a bad deal even though it's your friend and secondly, you would need to set up all these functions around it; so you would need to set up the contractual agreement around the liabilities, you would need to set up the tracking of the compliance together with your friends, so you need to align the data sources, you would need to do the decide on a pool verifier, which means you need to verify the pool separately in the end of the year right, you would need to figure out the financial transactions around it... So all these you would need to figure out on your own. Whereas, for example, if you use a marketplace like BetterSea, all this is already included because it provides a standardized process. So now we have talked about a relatively simple case where we have a ship owner with a surplus and a ship owner with a deficit, but things get a bit more complicated because we're talking about shipping. Let's reflect on the ship management companies. Yes, so ship management companies are in a tricky state, because the regulation actually sets the ISM company as the one that is responsible for compliance under FuelEU. So they kind of have the problem that they do not decide on the fuel therefore they can't influence the compliance status of the vessel, but in the end they are responsible. We saw the same problem with EU ETS. In EU ETS it was actually resolved with an implementing act, which moved the responsibility away from the ISM company - that is not possible on a FuelEU. So as a ISM company, you would need to track the compliance status of all the vessels that you manage, you would need to implement the right clauses in the shipman contract, together with your partners, and then the best thing that I will propose to do is that you actually help your clients be compliant with this regulation in the most cost-effective way. That can be, for example, by white-labeling a Marketplace, or by giving them advisory services on FuelEU. There are different options that you can do, but that would on the one hand reduce your own risk and on the other hand, create additional value for your clients, compared to competitors. For example, if I am a ship management company, I'm already tackling EU ETS for my ship owners - why wouldn't I just build a solution for FuelEU. EU ETS, compared to FuelEU is way more tricky. Under EU ETS, you just need to trade a certificate and then you need to align the data and share the certificates. It's quite straightforward. In FuelEU, it's way more tricky; because on the one hand, you would need to align the data sources between different parties, on the other hand, you have all these legal and financial things that you need to figure out on top of the normal stuff - 
let's say, adapting your shipman contract etc, which is already tricky enough, but now you have new legal contracts around pooling, for example that haven't been discussed in the industry before at all. And doing all this on your own is quite tricky. Also, if you would do it on your own you would limit your pool of available surplus and demand vessels to your own clients, which would naturally decrease the market size and therefore potentially influence the actual competitiveness of the price that your clients can achieve on your own solution. Perhaps... and we know that that is true, that certain ship management companies are considering creating their internal pools for the vessels that they manage, before going out. However, being able to access a Marketplace can be a great next step, because that helps them be reactive and respond to the market as things evolve and data arrives. Yeah. What do we do with the parties chartering their ships? Well, so the charter parties, they usually have the power over the fuel supply of the vessel, so they can actually influence the compliance status of the ship. However, they face a different problem than the ship managers who need to adapt their shipment contracts.They face the problem that they need to align the responsibility with the owner -
so here we need to have the right charter clauses in place, that aligns all these responsibilities related to FuelEU. The problem here is that, on the one hand, at the current moment in time, BIMCO doesn't have finalized their charter clause and this leaves the charter parties close to the end of the year with sort of "hanging in the air" because they don't know how to set it up properly, and they don't have the guidance from an independent body. However, let's say they agree on the charter clause, then the question is - who actually owns the surplus? If it's the charter party, then the charter party would need to start engaging in how to be compliant with the regulation and then potentially either buy or sell surplus. If it's on the contrary the owner that owns the Surplus, then the cherter party would need to figure out - how do I reimburse myself etc. for the cost that I faced, or the owner? So there will be some realignment of financials between the different stakeholders that need to be managed as well, and one of the very tricky things and that needs to be discussed under FuelEU is - what is actually the cost of compliance? Because straightforward, you would assess it as the price of the penalty, but you can also achieve compliance with, as we said, alternative fuel. So one could also argue it's the current price of UCOME based on any biofuel indices on the pricing, but then one can also say - well it might be the price of pooling, but it's totally unclear what the actual value of the Surplus will be. And dependent on how you trade your Surplus, if it's a friend, you can't really use that price, because it's not really an index. If it's a super pool, it's also a price that was set by a centrally managing function right so it's not something that the market came up with... So these are... This is the trickiness that you will face around what is the actual compliance cost related to FuelEU. You mentioned that, they might not be in control of the fuel supply, which brings me to my next question. The fuel suppliers.How can they get into the mix, and some of them did already, so - how can they address the topic or benefit from it, or perhaps help some of the other parties well? 
That's actually very interesting, because in the end, this whole FuelEU game is not somewhat regulated in how the industry would play it out, which means the industry can come up with their very own ideas on how to trade supplies who owns it Etc. And the fuel supplies are one of these examples where they came up with a very interesting idea around this whole game and, in that case, what we have experienced is that the few suppliers decided to own the surplus. So instead of a ship owning company or a charterer, they would own the surplus and they would give the alternative fuel that would create the surplus at a reduced rate, compared what they usually would sell it for to the company that provides them the Surplus and in that case actually the fuel supplier is the one who controls trading the Surplus and pooling the vessel. For the fuel supplier that might be interesting, because they can increase the margin that they might get on the alternative fuel, depending on how good they are with trading the Surplus; and for the shipping company it might be interesting because they have a reduced price on their alternative fuel, which gives them planning security going forward and they, sort of, can provide better services, cheaper services with alternative fuel for their customers. If I am a ship owner and I make a deal with a fuel supplier, I tell him - great, then here's the Surplus, figure it out. How comfortable, or not comfortable, should I feel if the fuel supplier goes to the marketplace and trades the Surplus? Well that's a good question, because in the end, again, we need to compare to EU ETS. At EU ETS you were just training certificates, but under FuelEU Maritime what you are doing when you trade surplus and when you are pooling is that you actually allocate your asset the ship into a compliance pool in the end. So if you, as the ship owner, give the trading power of the surplus of that particular vessel to your fuel supplier, you lose control over your asset in the perspective of compliance, which means that in that case you don't know with whom your vessel will be pulled up with. You have no control over the opposite party in the pool. On the other hand, you also have no option to control whether the vessel will end up in a valid pool, right, because you gave all this control to the fuel supplier. So at least what you need to do is to implement some sort of tracking function or control function so that you can see whether the fuel supplier actually makes a proper decision or not, that is in line with what you would do. Perhaps I wouldn't want to help my competitors achieve compliance? For example, yes. Yeah, and then... fuel suppliers work with fuel traders. Is there a spot for fuel traders in the mix? In general, one could say that there's a spot for commodity traders, may it be EUA Traders, fuel Traders, etc, right? What they usually do at the moment is that they provide help to the shipping companies and any other entity that is related to EU ETS by trading for example the EUAs, the certificates underlying the EU ETS Market, and of course, they will be interested in engaging in the same activities for FuelEU, which as I said before, is quite tricky because it's not just trading a certificate. It is trading the asset into a compliance pool. However, it might be that one gives the purpose to the fuel trader or to the EUA trader to actually be allowed to trade on behalf of the shipping company. If you trade on behalf then you sort of as a shipping company give out the control to the trader that you trust, but you don't need to think about the risk of trading, or do I trade at the right price... all this will be handled by the trader in the sense. We've showed that it can get quite messy and there are many stakeholders that can potentially benefit from it, will try to put that benefit into certain clauses when making already familiar contractual agreements for any of them or for the the shipping companies who are the first in that chain. We do provide an end-to-end solution FuelEU end-to-end platform with an integrated [ppooling] marketplace where we help with all these parts of the process and of course there is an access to an open and transparent Marketplace that helps companies connect globally, find the right match and right pool to join and benefit from a fair market. Is there anything else that we can cover? Yeah I think to like wrap it up from my side, what we see in the industry is that this whole FuelEU Maritime game is not regulated, it's not standardized, the surplus is not recognized as a commodity in any sense, which means anyone can trade it, there are no licensing issues around it etc, and that creates quite a...We call it a "wild west" and therefore as I see it as a shipping company or as anyone engaging in trading surplus there would be a huge benefit from a standardized process and from a transparent process that follows step by step a process that the industry understands and where everyone can see their spot and their place and can understand what is the next step in order to go forward and to be able to comply most cost effectively and that is something that we at at BetterSe - try to create by providing a transparent standardized process around pooling. Thank you for your insights and with this, I will invite the viewers to talk to us if this is a topic of their interest, opportunity, challenge... And with this, we will start our Fuel EU Maritime countdown series, basically counting down to January when the regulation starts, and hand-holding you along the way! Thank you for sticking around, till the next time!

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