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EU ETS – Who is liable to the authorities: Shipowners or managers?

A hotly debated topic regarding the extension of the EU Emission Trading Scheme (EU ETS) to include maritime emissions, is who should be responsible for submitting emissions allowances on the relevant submission date to the relevant administering authority (ETS obligations), in particular in instances where a shipowner has delegated the responsibility to comply with the ISM Code to a manager, highlights Dr. Clemens Hillmer LL.M., WFW Hamburg Partner.

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