UK ETS Consultation: Biomass

Swan Energy has produced a guidance document to summarise the Developing the UK Emissions Trading Scheme – UK ETS consultation document under  a number of headlines – one being Biomass, which we summarise here.


At present only bioliquids are subject to a ‘sustainability criteria’. The Authority is proposing to apply a sustainability criterion to all solid, liquid, and gaseous biomass, for all installations. Only once the specified criteria are met will an emission factor of zero be applied. The Authority are seeking views on which sustainability criteria are suitable for the UK ETS.

For Hospital and Small Emitters (HSEs), an emissions factor of zero is currently applied to all biomass, including liquid biomass. The Authority are proposing that sustainability criteria are applied when assessing HSE eligibility, calculating emissions targets, and determining whether an installation’s reportable emissions exceed the emissions targets. An emissions factor of zero will only apply to biomass that meets the sustainability criteria.

The Authority also proposes that for installations and combustion units that generate energy solely through biomass combustion to be exempt from the UK ETS, they must exclusively burn biomass which adheres to the relevant sustainability criteria.

The Authority wishes to hear your thoughts on the following. This section relates to Questions 96 – 101 in the response survey.

  • Do you agree with the proposal that sustainability criteria are to be applied to all Biomass?
  • Which sustainability criteria should be used?
  • Do you agree that HSEs should be subject to sustainability criteria?


 If anyone would like to receive our full summary document , please call us on 01484 843867 or email and we’ll be in touch.


Swan Energy has been involved with the UK ETS (formerly EU ETS) since its conception and delivers 100% compliance for our clients. Click here to find out more about our service.

Rebecca Scarratt

Carbon Consultant

Rebecca Scarratt

Carbon Consultant

Rebecca has joined the Swan Energy team in 2021. She graduated from the University of Hull with a BSc in Geology with Physical Geography in 2020 and went on to do a MSc in Renewable Energy. Her Masters’ thesis focused on how future climate change may impact the Humber region’s wind energy sector and how adaptation strategies could be used to reduce vulnerability.

In her role at Swan Energy, Rebecca supports the consultancy work the team does with clients across the UK.