We welcome the opportunity to contribute to the European Commissions review of the EU ETS as applied to maritime transport. We attach a document outlining Spanish Shipowners Associations (ANAVE) main positions. In summary, we respectfully highlight the following five key points: 1. A global regulatory framework: The EU should fully align with the IMOs forthcoming Net Zero Framework (NZF).
ANAVE
Industry association · Spain · EU Transparency Register 03008307807-49
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1518 trade and business associations on this site, they rank #995 by legislative files engaged, a count of participation, not a measure of influence.
Declares membership of
- ECSA: European Community Shipowners' Associations
- ICS: International Chamber of Shipping
- ISF: International Shipping Federation
- BIMCO: The Baltic and International Maritime Council
- INTERTANKO: International Association of Independent Tanker Owners
- INTERCARGO: International Association of Dry Cargo Shipowners
- CEOE: Confederación Española de Organizaciones Empresariales
- SPC - Spain: Spanish Short Sea Promotion Center
- GASNAM - Asociación Ibérica de Gas Natural y Gas Renovable para la Movilidad
- https://anave.es/en/anave/spanish-shipowners-association/
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade and business associations
- Registered as
- ASOCIACIÓN DE NAVIEROS ESPAÑOLES - SPANISH SHIPOWNERS ASSOCIATION (ANAVE)
- Head office
- MADRID, Spain
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
ANAVE filed 2 positions between 8 Jul 2025 and 14 Jan 2026, across 2 of the 665 legislative files tracked here, attaching a full position paper 2 times.
What they argued
In summary, we propose the following: - We support updating the Global Warming Potentials (GWPs) in line with the latest IPCC assessment, but we consider that their application should not take place during 2026.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
Showing 5 of 27.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.