Ports and Shipping Regulation: Why Infrastructure and Emissions Legislation Must Develop Together

The success of ports has conventionally been framed in terms of cargo throughput, berth utilisation and ship turnaround, but the future success of ports will depend equally on their ability to evolve into integrated energy hubs. As regulatory frameworks such as the EU Emissions Trading System (ETS), FuelEU Maritime and the UK ETS increasingly incentivise and require the uptake of low-carbon fuels and zero-emission technologies by ships, ports are being called upon to provide the infrastructure needed to support this transition, from alternative fuel bunkering and shore power to hydrogen, ammonia and carbon-management services. Ensuring alignment between port development and shipping regulation will therefore be critical to the future success of ports. If regulation requires ships to adopt low-carbon fuels and technologies, ports must be able to provide, accommodate and service them, transitioning from traditional cargo gateways to energy hubs capable of supporting maritime decarbonisation at scale.

The Role of the EU and UK Regulations

I. AFIR: Transforming Ports into Energy Hubs

A key element of the regulatory framework impacting ports is Regulation (EU) 2023/1804 on the deployment of alternative fuels infrastructure (AFIR). While measures such as the EU ETS and FuelEU Maritime regulate ships, requiring and incentivising ships to adopt lower-carbon fuels and technologies, AFIR seeks to ensure that ports develop the infrastructure necessary to support that transition. In producing these complementary regulations, the European Commission recognises that emissions reductions at sea will be difficult to achieve unless corresponding investments are made onshore, positioning ports as critical enablers of the maritime energy transition. While at the same time, ensuring that investment in new port infrastructure will be met by sustained demand from ships.

The most significant maritime provision is Article 9, which requires Member States to ensure that qualifying Trans-European Transport Network (TEN-T) core and comprehensive maritime ports provide shore-side electricity supply (OPS) for large container and passenger ships. By 31 December 2029, affected ports must be equipped to supply shore power for at least 90% of relevant port calls by container ships and passenger ships above 5,000 GT. The provision reflects the growing importance of port electrification within the EU's decarbonisation strategy and requires substantial investment in grid connections, electrical infrastructure and berth-side facilities.

However, AFIR also extends beyond shore power into the realm of alternative fuels. Article 11 requires Member States to ensure the availability of an appropriate number of refuelling points for liquefied methane (LNG) in TEN-T core maritime ports. Although policy attention is increasingly focused on hydrogen-derived fuels and renewable electricity, this provision demonstrates that AFIR views ports as energy supply centres responsible for facilitating the uptake of alternative marine fuels.

Perhaps most importantly from a strategic perspective, Article 14 requires Member States to prepare national policy frameworks addressing the deployment of alternative fuels infrastructure in maritime ports. Those frameworks must include not only measures relating to shore-side electricity and LNG infrastructure, but also an assessment of future infrastructure requirements for emerging fuels such as hydrogen, ammonia, methanol and electricity. AFIR therefore looks beyond immediate compliance obligations and begins to establish a pathway for the development of the broader fuel ecosystem required to support the decarbonisation of shipping.

The Regulation is further supported by reporting, monitoring and interoperability provisions, including requirements for Member States to track deployment progress and for infrastructure to comply with common technical specifications. These measures are intended to provide certainty to infrastructure investors and support the creation of a coherent European network of alternative fuel facilities.

In its 2026 briefing, Transport & Environment argued that the forthcoming review of AFIR presents an opportunity to reinforce the role of ports as "green energy hubs" by accelerating the deployment of shore power and other alternative fuel infrastructure. The briefing notes that a significant proportion of maritime emissions occur within ports and contends that a more ambitious infrastructure framework is necessary not only to support shipping decarbonisation, but also to improve air quality, protect port communities and facilitate the development of emerging clean-energy technologies. In this respect, AFIR is increasingly viewed as a key mechanism for transforming ports from traditional logistics centres into multi-energy service providers.

II. EU ETS: Creating a Carbon Price with Indirect Port Impacts

The inclusion of maritime transport within the EU ETS from 1 January 2024 was a significant regulatory development for shipping, imposing for the first time a direct cost on greenhouse gas emissions produced by ships. The scheme requires shipping companies to surrender purchased emissions allowances for greenhouse gas emissions generated by ships during voyages to, from and within the EU.

While the EU ETS does not directly require ports to provide alternative fuels or shore power the carbon cost it imposes on greenhouse gases makes fossil fuel use more expensive, and indirectly improves the economic attractiveness of fuel-efficient technologies, alternative fuels and electrification. Furthermore, the EU ETS incentivises the use of biofuels and fuels of non-biological origin (RFNBOs) that meet certain criteria under the EU’s Renewable Energy Directive (RED III) by affording eligible fuels a zero-rating emission factor.

The extension of the EU ETS to maritime transport provides a carbon price signal that makes investments in energy efficiency and low-carbon solutions more financially attractive for shipping companies, while reducing the cost differential between conventional and alternative fuels. However, the effectiveness of this signal depends upon the existence of supporting infrastructure. A shipowner may be strongly incentived to reduce emissions exposure under the EU ETS, but the value of such incentives cannot be fully realised without a complementary port infrastructure capable of supplying compliant fuels and electrical connections. Meaning demand side requirements created by EU ETS need to correspond with supply side developments, such as those driven by AFIR.

III. FuelEU Maritime: Directly Linking Ships and Port Infrastructure

FuelEU Maritime, which governs from 1 January 2025 the greenhouse gas intensity of fuels and energy used by ships, establishes a much clearer connection between ship compliance and port infrastructure. The FuelEU Regulation (EU) 2023/1805 introduces progressively tightening limits on the greenhouse gas intensity of energy used on board ships over 5,000 GT calling at EU ports. The regulation seeks to reduce fuel lifecycle emissions (based on a well-to-wake methodology) by 2% from 2025, rising progressively to 80% by 2050.

Most importantly from a port perspective, FuelEU contains specific requirements regarding OPS. FuelEU provides that the obligation for ports to provide OPS as set out in the AFIR, is matched by a corresponding obligation for ships to utilise available OPS facilities while berthed, thereby ensuring that the infrastructure delivers its intended environmental benefits and avoiding underutilisation of significant port investments.

From 1 January 2030, container ships and passenger ships at berth in designated EU ports must connect to OPS or use alternative zero-emission technologies. By 2035, the obligation expands to all EU ports that have installed OPS infrastructure. Under FuelEU, an ‘on-shore power supply’ means a system that allows a ship at berth to connect to electricity supplied from the shore, rather than running its onboard engines, using either low or high voltage and alternating or direct current. to power for onboard, hotel loads, service loads and battery charging while the ship is in port.

FuelEU is a significant development in the connection between maritime decarbonisation and ports as it directly links ship compliance to infrastructure availability within ports and therefore provides stronger long-term investment signals than the EU ETS alone.

IV. The UK Approach: Carbon Pricing Ahead of Infrastructure Mandates

The extension of the UK ETS to maritime transport from 1 July 2026 introduces a carbon price for emissions generated during domestic voyages and while ships are at berth in UK ports, thereby creating incentives for ship operators to reduce emissions. However, there is currently no direct equivalent to the EU's Alternative Fuels Infrastructure Regulation (AFIR), which mandates the deployment of shore-side electricity infrastructure in qualifying ports, or of FuelEU, which mandates reduction in the greenhouse gas intensity of energy used by ships.

Nevertheless, UK policy increasingly recognises the strategic role of ports in the energy transition. The National Policy Statement for Ports identifies ports as critical national infrastructure that support economic growth, trade and energy security, while the government's Maritime Decarbonisation Strategy emphasises the importance of developing "net zero ports" capable of supporting the decarbonisation of maritime transport. This policy direction has been reinforced through the UK's Net Zero Ports programme, which envisages ports evolving beyond their traditional logistics function to become hubs for clean energy production, storage and distribution. In particular, ports are expected to play a key role in supporting shore power, electrification, hydrogen, ammonia and other alternative fuel supply chains that will be required by a decarbonising shipping sector.

Significantly, UK policy is increasingly recognising ports as critical enablers of maritime decarbonisation. Alongside proposals for ships to achieve zero or near-zero emissions while at berth, the UK Government's wider net-zero ports agenda emphasises the need for infrastructure capable of supporting shore power, alternative fuel bunkering and other zero-emission technologies. The approach remains technology-neutral, allowing ports and operators flexibility in how those outcomes are achieved. The direction of travel is reinforced by the proposed UK Maritime Fuel Standard, which the Government intends to consult on in late 2026 and which will, presumably, perform a role similar to FuelEU in driving shipping's demand for low-carbon fuels, and meaning that ports will increasingly be expected to provide the storage, bunkering and energy infrastructure needed to support compliance.

Although legislative proposals may be some way off, the policy direction signals a recognition that effective decarbonisation requires a basket of interconnected measures, placing obligations on ships and supporting infrastructure within ports.

What does this mean for ports outside the EU and UK?

While it is obvious that ports within and EU and UK are entering a time of transition, ports not directly subject to the impacts of the EU ETS, UK ETS, FuelEU Maritime or AFIR regulations are still affected. Ships trading internationally will require access to low-carbon fuels outside the EU and UK if they regularly call at EU ports. Furthermore, if they are equipped to utilise shore power and other decarbonisation infrastructure such ships will likely seek connection points and servicing at ports outside the EU as well as within, increasingly favouring ports capable of supplying alternative fuels and supporting lower-emission operations across their trading routes.

This trend is likely to accelerate as the decarbonisation agenda becomes increasingly global. The International Maritime Organization (IMO)'s 2023 GHG Strategy established an ambition for zero- or near-zero GHG emission technologies, fuels and/or energy sources to account for at least 5%, striving for 10%, of the energy used by international shipping by 2030. Likewise, the proposed IMO Net-Zero Framework is intended to accelerate the uptake of zero or near-zero GHG fuels, technologies and energy sources through a global fuel standard based on lifecycle greenhouse gas intensity.

At the same time, it would be excessively narrow to view port decarbonisation solely through a European and UK lens. Many jurisdictions are developing their own maritime and port decarbonisation policies, whether through emissions pricing, shore power requirements, clean fuel strategies or broader energy-transition initiatives. The commercial case for investing in low-carbon port infrastructure may therefore arise not only from the need to serve ships trading with Europe, but also from domestic regulatory requirements, national net-zero policies and energy security objectives. Consequently, ports outside the EU and UK are likely to face a combination of international and domestic pressures to enhance their decarbonisation capabilities both directly and indirectly through the changing needs of the ships they service.

Final Remarks

Ultimately, future port viability will depend in part on maintaining alignment between the obligations imposed on ships and the infrastructure available to support them. The EU ETS, UK ETS, FuelEU Maritime and AFIR each address different parts of this challenge, but collectively they point towards the same outcome: a shipping sector that increasingly relies on ports not only for cargo handling, but also for the provision of clean energy services. As demand grows for shore power, alternative fuels and other decarbonisation solutions, ports will be required to adapt their business models accordingly. The ports of the future will therefore need to offer very different services from those of today if they are to remain commercially relevant and competitive, positioning themselves not merely as gateways for trade, but as energy hubs crucial to the global energy transition.