Does vessel size matter? : Policy instruments in maritime transport and their impact on the working and living conditions on board

This report examines the potential implications of size cut-offs in maritime regulation and legislation on seafarers’ working and living conditions. The primary focus is on the newly introduced European Union (EU) environmental regulations. While the EU's new policies aim to cut greenhouse gas emissions and bring the sector into the climate action fold, there are potential unintended consequences to ship design and crew working conditions. Central to this debate is the 5 000 GT (Gross Tonnage) threshold, which dictates whether ships fall under these new rules. Smaller vessels, designed to dodge regulatory costs, could mean shrinking crew accommodations and cutting corners on working conditions.The study explores two primary questions: (i) Do restrictions based on gross tonnage (GT) impact the working and onboard living conditions of seafarers? And (ii) Does the 5 000 GT threshold risk lowering the quality of seafarers' working and living conditions onboard? The report employs three primary methods to investigate this: a review of relevant regulations, semi-structured interviews with stakeholders, and an analysis of LinkedIn discussions on the topic. Additionally, a financial calculation illustrates the economic motivations driving compliance strategies. The results suggest revisiting the threshold and introducing incentives, like reduced port fees, for ships prioritizing crew welfare. Eleven stakeholders were interviewed, including representatives from trade unions, shipping companies, and industry organizations. Respondents expressed concerns that the 5 000 GT threshold could unintentionally promote ship designs with substandard accommodations and working conditions. They emphasized the need for balance between environmental objectives and social sustainability to avoid exacerbating the already demanding conditions faced by seafarers. The report further identifies historical and current examples of when vessel size has been limited and adapted to meet size restrictions to avoid costs with negative effects for crew welfare.The cost calculation example for general cargo vessels supports this further and highlights the financial incentives for designing ships below 5 000 GT. Avoiding the associated compliance costs will likely lead to large competitive advantages as stricter climate targets are introduced. The report identifies a risk of carbon leakage, in part as smaller vessels are not included in the legislation and over time likely will become cost competitive and as smaller vessels are less energy-efficient and may undermine broader environmental objectives. The emphasis on smaller vessels driven by the 5 000 GT threshold risks creating unintended negative consequences for seafarers. Policies such as port fee reductions or other economic incentives could encourage shipping companies to prioritize better onboard working conditions while meeting environmental goals. The study concludes that revisiting the 5 000 GT threshold as well as other GT based cut-offs and aligning it with policies that promote both environmental and social sustainability is essential. Current regulatory frameworks inadequately address the intersection of environmental compliance and social sustainability. Balancing environmental and social sustainability isn’t just a nice-to-have—it’s a must. After all, what’s a ship without its crew? Effective regulation must consider not only environmental impact but also the welfare of the workforce that sustains the industry. Future research should further explore the long-term implications of such thresholds and the potential for regulatory adjustments to mitigate adverse effects on seafarers.