What Norwegian Cruise Line Holdings Ltd. told the SEC could break it.

Norwegian's ships are subject to tightening U.S. discharge regulation — the Clean Water Act Vessel General Permit and the Vessel Incidental Discharge Act (VIDA), under which the EPA published final national performance standards in October 2024.

“In 2018, the Vessel Incidental Discharge Act (“VIDA”), which will eventually replace the VGP, was signed into law, and the EPA published a final rule in October 2024 establishing national standards of performance under the VIDA that apply to 20 different types of vessel equipment and systems, as well as general discharge standards that apply to all types of vessel incidental discharges within 12 nautical miles of the United States.”

If Norwegian lacks a U.S. fixed place of business or its income is not from regularly scheduled transportation, its U.S.-source shipping income could fall outside the favorable regime and be subject to a special 4% gross-basis tax.

“If we do not have a fixed place of business in the U.S. or substantially all of our income is not derived from regularly scheduled transportation, the income will generally not be considered to be effectively connected income. In that case, we would be subject to a special 4% tax on our gross U.S.-source shipping income (the “4% Tax Regime”).”

Norwegian has ~€18.3 billion ($21.5B) of euro-denominated ship contracts on order; a 10% move in the euro would change the USD value of remaining payments by ~$1.9 billion.

“We estimate that a 10% change in the euro as of December 31, 2025 would result in a $1.9 billion change in the U.S. dollar value of the foreign currency denominated remaining payments.”

Norwegian's passenger ticket revenue is concentrated in U.S.-sourced guests — 84% in each of 2023–2025 — leaving it exposed to U.S. consumer demand, with no other single country above 10%.

“Although we sell cruises on an international basis, our passenger ticket revenue is primarily attributed to U.S.-sourced guests who make reservations through the U.S. Revenue attributable to U.S.-sourced guests was 84 % for each of the years ended December 31, 2025, 2024 and 2023. No other individual country's revenues exceeded 10% in any of our last three years.”