A time charterer can demand the calculation behind a carbon cost. A cargo owner paying the same cost has no such right. That gap is a product.
Written from public sources as a work sample for the Product Strategist application. I have no visibility into the Searoutes roadmap. Read it as a demonstration of the format and the reasoning. Every figure below is linked to its source.
Problem
BIMCO's ETS clause for time charter parties obliges the owner to give the charterer the relevant calculations and the data used to establish the quantities
. The 2024 FuelEU clause repeats the obligation for compliance-balance surcharges. A charterer who receives a carbon bill can ask for the working and is entitled to get it.
A cargo owner pays the same cost one layer further down. BIMCO's COA surcharge clause contains no verification, audit or evidence right at all, and for container liner service contracts there is no standard clause of any kind. The surcharge is a tariff item: set unilaterally, revised quarterly, payable as freight.
What lands on the invoice varies more than the underlying emissions plausibly do. Searoutes' own January 2026 analysis put four carriers on the same intra-North-Europe lane at very different numbers.
| Carrier | Charge | Index vs lowest |
|---|---|---|
| Maersk | $16 | 1.0× |
| Hapag-Lloyd | $49 | 3.1× |
| CMA CGM | $55 | 3.4× |
| ONE | $83 | 5.2× |
Disclosure varies as much as price. Maersk publishes the EUA reference price behind its Q3 2026 surcharge, €71.07, and the window it was averaged over, 16 February to 15 May 2026. It stops there: no emission factor, no account of how a vessel-level obligation becomes a per-container charge. Hapag-Lloyd announced a 45% increase for 2026 and described its method as recognized emission factors and market indices
, with no figures at all.
Each carrier also picks its own lookback window and none of them true up afterwards. Maersk's Q1 2026 surcharge was priced off an August-to-November 2025 average of €76.75; its Q3 surcharge off €71.07. A shipper on a fixed contract absorbs the difference in both directions and sees neither.
The last independent audit is two years old. Transport & Environment examined 565 voyages in early 2024 and estimated that 486 of them, 86%, produced a windfall for the carrier, averaging €59,909 per journey at Maersk and €15.2m across the sample. That was at 40% phase-in with EUAs near €60. Nobody has repeated it at higher scope and higher prices, and I can find no case of a shipper recovering money, no arbitration award, and no competition-authority action on ETS surcharges.
The sums are now large enough to be worth the argument. Drewry put the first bill at USD 2.9bn for the October 2025 surrender, covering 40% of 2024 emissions, and expects roughly USD 7.5bn once the phase-in completes and methane and nitrous oxide are inside the obligation.
Even the headline percentage is ambiguous. 100% from 2026
describes emissions incurred in 2026 and surrendered in 2027. The obligation actually falling due during 2026 is 70%, on 2025 emissions. Two clocks, both correct, and a shipper reading a surcharge notice cannot tell which one the carrier priced against.
Meanwhile the reason a sustainability team gets budget has shifted. Omnibus I entered into force on 18 March 2026 and lifted the CSRD threshold to 1,000 employees and €450m turnover, moving most in-scope companies to FY2027. Freight emissions data sold as a reporting obligation now reaches fewer buyers each year, while the invoice that same data can be checked against grows.
Several vendors already hand shippers an independent number. Searoutes does it through the Freight Emissions Reporter; OceanScore Cargo markets the same capability as surcharge verification
; VesselBot benchmarks pass-throughs against an execution-based reference; Lune published a comparison tool that still runs on 2023 prices. All of them produce a counter-number. None of them takes the specific line on the specific invoice, resolves it to the specific voyage, and returns something a buyer can send back.
Searoutes already computes voyage-level emissions on these lanes, holds engine and capacity data on more than 6,000 vessels, and is GLEC-accredited. The missing piece sits at the end of the pipeline.
Appetite
One Big Batch cycle. Three weeks buys a single reconciliation good enough that a sustainability manager forwards it without editing it first. If it needs a fourth week, the shape was wrong and we drop it.
Solution
The shipper exports the invoice from the carrier portal and maps three columns: container, lane, charge. No integration, no TMS project, no procurement cycle before anyone can try it.
Resolve each line to its actual voyage from vessel and schedule data already held. Compute ETS-eligible tonnage at the applicable scope percentage. Price it at the carrier's own published reference window where one exists, and at a stated market average where none does. Separate an estimated FuelEU component. Show the delta per container.
One PDF per invoice: total charged, total explainable, variance, per-container detail, and a method note naming GLEC v3.2 and the specific vessel used.
The output is a document a sustainability manager can forward to whoever owns the carrier contract. Forwarding is the behaviour the whole thing is designed around, and a dashboard does not get forwarded.
Rabbit holes
No-gos
Kill criteria
Ten discovery calls in the cooldown week: five sustainability managers at shippers with EEA container volume, three logistics buyers who own the carrier contract, two forwarders billing ETS onward.
One question settles the bet. When the surcharge line arrives, who checks it, against what, and what happens when they think it is wrong?
James Hookham of the Global Shippers Forum has been asking carriers to show their working since 2024, and Xeneta's Peter Sand was still telling shippers to demand separate line items in August 2026. Complaint is well established. Mechanism is not, and no money has moved.
If the honest answer to that question is that nobody checks because nobody believes a challenge would succeed, the artefact has no receiving behaviour and the bet is dead. Week one is when to find that out.
Sources
Daniil Cherpakov · Work sample for the Product Strategist application