Commission Implementing Regulation (EU) 2025/1127 of 6 June 2025 laying down rules for the application of Regulation (EU) 2023/1805 of the European Parliament and of the Council as regards of identifying neighbouring container transhipment ports

## Policy Analysis Report: Commission Implementing Regulation (EU) 2025/1127 - Identifying Neighbouring Container Transhipment Ports **1. Executive Summary:** This report analyzes Commission Implementing Regulation (EU) 2025/1127, which lays down rules for identifying neighbouring container transhipment ports, as per Article 22 of Regulation (EU) 2023/1805 on the use of renewable and low-carbon fuels in maritime transport. This regulation lists East Port Said (Egypt) and Tanger Med (Morocco) as neighbouring container transhipment ports. This designation impacts shipping companies operating in the region by influencing the definition of "port of call" under Regulation (EU) 2023/1805. The key finding is that stops in these listed ports are excluded from the definition of a port of call under the parent regulation, potentially affecting obligations related to fuel usage reporting. **2. Introduction:** This report aims to provide an informative analysis of Commission Implementing Regulation (EU) 2025/1127 based solely on the provided text from the Official Journal of the European Union. The report will outline the regulation's purpose, background, key provisions, affected parties, implementation aspects, and expected outcomes. **3. Policy Overview:** * This regulation implements Article 22 of Regulation (EU) 2023/1805 of the European Parliament and of the Council. * **Core Objective:** To identify neighbouring container transhipment ports for the purpose of applying the rules in Regulation (EU) 2023/1805 regarding the definition of a port of call. **4. Background and Rationale:** Regulation (EU) 2023/1805 likely establishes obligations related to the use of renewable and low-carbon fuels in maritime transport. Article 22 allows for the exclusion of stops at certain neighbouring container transhipment ports from the definition of a "port of call." This Implementing Regulation identifies *which* ports qualify for this exclusion. The rationale, as inferred from the text, is to avoid unintended consequences or competitive disadvantages that might arise from including brief transhipment stops in ports outside the EU within the scope of the fuel usage regulations. **5. Key Provisions / Changes:** This is a *New Policy* that specifies implementing rules. The key provisions are: * **Identification Criteria:** A port is listed as a neighbouring container transhipment port if: * Its transhipment of containers exceeds 65% of its total container traffic (measured in 20-foot equivalent units). * It is located outside the Union but less than 300 nautical miles from a port under the jurisdiction of a Member State. * It is *not* located in a third country that effectively applies measures equivalent to Regulation EU 2023/1805. * **Specific Ports Listed:** The Annex to the Regulation lists the following ports as neighbouring container transhipment ports: * East Port Said (Egypt) * Tanger Med (Morocco) * **Reliance on Previous Data:** The regulation uses the same data and analyses as Commission Implementing Regulation EU 2023/2297 for coherence. **6. Target Audience and Stakeholders:** The target audience and stakeholders directly affected by this regulation include: * **Shipping companies:** As the definition of "port of call" influences their obligations under Regulation (EU) 2023/1805 regarding fuel usage and reporting. * **Verifiers:** Entities responsible for verifying compliance with Regulation (EU) 2023/1805. * **Member State authorities:** Responsible for enforcing Regulation (EU) 2023/1805. **7. Implementation Aspects (Inferred):** * **Responsible agency:** The European Commission is responsible for implementing the regulation. * **Timelines:** The regulation enters into force on the third day following its publication in the Official Journal of the European Union (i.e., June 13, 2025). * The "Committee on Safe Seas and the Prevention of Pollution from Ships" provided an opinion before adoption, suggesting this body has an oversight role. **8. Expected Outcomes / Impact of Changes:** The likely intended outcomes and impact include: * **Clarification of "Port of Call" Definition:** By listing specific ports, the regulation provides clarity for shipping companies regarding whether stops at these ports will be considered "ports of call" under Regulation (EU) 2023/1805. * **Potential Reduction in Regulatory Burden:** Excluding transhipment stops at these ports may reduce the regulatory burden on shipping companies, as they may not be required to report fuel usage for these stops. * **Impact on Fuel Consumption Reporting:** Shipping companies may need to adjust their fuel consumption reporting practices based on the new definition of "port of call." * **Promotion of Coherence:** Use of the same data as Implementing Regulation EU 2023/2297 is designed to promote coherence and streamline implementation. **9. Conclusion:** Commission Implementing Regulation (EU) 2025/1127 is a significant implementing act for Regulation (EU) 2023/1805. By specifically listing East Port Said and Tanger Med as neighbouring container transhipment ports, the regulation clarifies the definition of "port of call" and affects the obligations of shipping companies, verifiers, and Member State authorities under the parent regulation. The regulation aims to balance environmental objectives with practical considerations regarding transhipment activities in nearby non-EU ports.

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