The UK ETS Authority Interim Response: Scope Expansion to Maritime.

The UK ETS Authority recently published a number of responses to consultations covering scheme scope expansion to waste and maritime, and the integration of greenhouse gas removals. This update is the second of three and will summarise the interim response regarding the expansion of the UK ETS to maritime.


 

In 2023, the UK ETS Authority confirmed emissions from domestic maritime will be  captured in the UK ETS from 2026. The 2024 consultation discussed the technical implications, such as, inclusion thresholds, exemptions and the monitoring, reporting and verification (MRV) requirements. The consultation also considered maritime in UK ETS post 2028 and whether international emissions could be brought into scope.

The interim response outlines the following decisions made by the Authority:

1 – Domestic maritime compliance with the UK ETS will begin on 1st July 2026.

The first scheme year will run from 1st July 2026 to 31st December 2026. Future scheme years will run from 1st January to 31st December.

2 – The existing UK MRV regime will form the basis for the MRV requirements.

The Authority confirms the UK ETS MRV requirements will include the monitoring and reporting of in port emissions, whether travelling domestically or internationally, as well as the monitoring of emissions of methane and nitrous oxide.

Each operator is required to have an emission monitoring plan (EMP) approved by the UK ETS regulator and must submit one annual emission report (AER). Please note it is one AER per operator, not per ship. The AER must be submitted by the 31st March of each scheme matching the deadlines for current UK ETS operators.

Much like for existing UK ETS sectors, the Authority wishes to incentivise the use of sustainable fuels and intends to allow zero-rating of sustainable fuels of both biological and non-biological origin from 2026 for maritime. Further details still to be announced.

3 – Emissions in scope are those from domestic voyages (defined as those between UK ports, including those which start and end at the same port) and within UK ports for ships of 5 000GT or more.

This will include all emissions within a voyage, including while at anchor and while moored. Further guidance will be released to help define start and end of voyage.

Voyages to and from Crown Dependencies and Overseas Territories (CDs & OTs) will not be included in 2026, however may be considered in the future.

4 – Government non-commercial maritime activity will be exempt.

The exemption covers the following activities:

* Military activities

* Customs / Border Force activities

* Police activities

* Coastguard and other government search & rescue activity

* Emergency/medical ships

* Government research activities

* General Lighthouse Authority activity

5 – Methane and nitrous oxide emissions will be included alongside carbon dioxide.

Emissions from both combustion and slippage will be accounted for and will be calculated on a carbon dioxide equivalent basis, based on their Global Warming Potential.

6 – The entity responsible for compliance with the UK ETS is the Registered Owner of a ship, except where the ISM Company has duly assumed responsibility instead.

Where an ISM Company is responsible for compliance with UK ETS in respect of one or more ships, evidence must be provided of the agreement between the two entities.


 

The Authority will issue a full response to all questions included in the UK Emissions Trading Scheme Scope Expansion: Maritime consultation in due course.

 

If you would like to discuss this in more detail with a Swan Energy ETS Consultant, please get in touch.

Rebecca Scarratt

Carbon Consultant

Rebecca Scarratt

Carbon Consultant

Rebecca joined the Swan Energy team in 2021, after graduating from the University of Hull with a MSc in Renewable Energy.

In her role at Swan Energy, Rebecca supports the consultancy work the team does with clients across the UK. She has gained experience in the various compliance services we offer. Within the core team, Rebecca is account manager for over 40 UK ETS installations across the healthcare, food manufacturing and energy industry sectors.

Rebecca has managed SECR reporting and ESOS energy auditing for a selection of food manufacturing and retail clients. She has also produced a TCFD report for a large gas and oil company and managed CHPQA applications for NHS clients.

Click here to watch Rebecca’s introduction video.