UK ETS Maritime · Technical reference
UK ETS vs EU ETS for shipping: scope and surrender
UK ETS starts 1 July 2026 and is built the opposite way to EU ETS: scope attaches per activity, so an international call owes nothing at sea, all at berth.
Both schemes price the same gas from the same ships. Both apply from 5 000 gross tonnage UK ETS Order 2026 · Para. 5 Dir. 2003/87/EC · Art. 3ga , both measure emissions at the funnel rather than across the fuel's life, and both settle in allowances a company has to buy. From there they are built in opposite directions, and the difference is not a percentage — it is where the obligation attaches.
The UK scheme came into force on 1 July 2026, through an Order that inserts a new Part 4ZA and Schedule 2A into the Greenhouse Gas Emissions Trading Scheme Order 2020 UK ETS Order 2026 · Para. 5 .
EU ETS attaches to the voyage
Article 3ga decides how much of a voyage counts Dir. 2003/87/EC · Art. 3ga : a voyage between two EEA ports counts in full, time at berth in an EEA port counts in full, and a voyage with one end outside the EEA counts for half. Every leg a ship sails is measured, and the question asked of it is what fraction. The surrender obligation then phased in across 2024 and 2025 and reached the full amount from 2026 Dir. 2003/87/EC · Art. 3gb .
| Year | Chargeable fraction |
|---|---|
| 2024 | 0.4 |
| 2025 | 0.7 |
| 2026 | 1 |
UK ETS attaches to the activity
The UK Order asks a different question first. It defines a maritime activity as either a voyage or an in-port activity, and a voyage only counts as one if it begins at the last berth at a port of call within the United Kingdom's jurisdiction, ends at a port of call within that jurisdiction, and does not arrive at a port of call outside it UK ETS Order 2026 · Para. 7 .
Read that carefully and there is no fraction for international sailing, because international sailing never becomes a voyage in the first place. An in-port activity, by contrast, is a maritime activity on its own terms — it does not inherit anything from the voyage that brought the ship there.
Only then does the surrender rule apply: 50 % of emissions from voyages between Great Britain and Northern Ireland in either direction, and 100 % from any other maritime activity in scope UK ETS Order 2026 · Para. 15 . There is no phase-in. The scheme starts at its full share.
Two markets, two calendars
The allowances are not interchangeable. A UK obligation is settled in UK allowances, bought in a UK auction at a UK price; an EU obligation is settled in EUAs. The two prices move independently, and a company exposed to both carries two positions, not one.
The calendars differ too, and by more than a date. EU allowances for a reporting year are surrendered by 30 September of the following year Dir. 2003/87/EC · Art. 12 . The UK deadline is 30 April — but the first one is 30 April 2028, and it covers the 2026 scheme year and the 2027 one UK ETS Order 2026 · Para. 15 . Two years of UK allowances are bought and surrendered together, on a date when the EU obligation for 2027 is still five months away. That is a cash-flow event with a known date, and it is the kind of thing a treasury function would rather learn about in 2026 than in 2028.
What UK MRV left behind
The UK's own monitoring and reporting regime is gone: it was revoked by the Merchant Shipping (Monitoring, Reporting and Verification of Carbon Dioxide Emissions) (Revocation) Regulations 2026 UK MRV Revocation Regulations 2026 . Those Regulations commence on the twenty-second day after the day they were laid and name no calendar date in their own text, so any specific day quoted for the withdrawal comes from a secondary source rather than the instrument.
What that removes is a UK reporting duty. What it does not remove is EU MRV, which is a separate instrument with its own scope and its own deadlines — a company that files EU MRV for the same ships still files it, unchanged. The EU MRV pillar covers that cycle.
One call, both schemes
Take a single voyage from Rotterdam to Felixstowe and hold both rulebooks against it. For the EU it is a voyage from an EEA port to a third-country port, so half of its emissions count Dir. 2003/87/EC · Art. 3ga . For the UK it is not a voyage at all — it did not begin in UK jurisdiction — so the crossing contributes nothing UK ETS Order 2026 · Para. 7 . Then the ship berths, and those hours are a UK maritime activity in full UK ETS Order 2026 · Para. 15 .
One call, two schemes, two allowances, neither one substituting for the other. The schemes do not overlap on the same tonne and they do not leave a gap either; they divide the ship's day between them along a line that no single voyage-share model can express. Any system that resolves scope once per voyage will get the UK side wrong — the classification has to run per activity, with port time carried separately from the legs.
Last reviewed · Carbonlogy Compliance Team
Calculators
Frequently asked questions
- Does a ship arriving in the UK from outside the UK owe UK allowances?
For the crossing, no. A voyage counts only if it begins and ends at a port of call within the United Kingdom's jurisdiction and does not arrive at a port of call outside it, so an inbound international leg is not a voyage under the Order at all. For the time the ship then spends in the UK port, yes, in full — in-port activity is a maritime activity in its own right.
- What share applies to a Great Britain to Northern Ireland voyage?
Half. Paragraph 15 requires surrender of 50 % of emissions from voyages between a port of call in Northern Ireland and one in Great Britain, in either direction, and 100 % from any other maritime activity in scope.
- When is the first UK ETS surrender due?
30 April 2028 — and it is a double. The 2026 scheme year is not due until that date, which is also the deadline for the 2027 year, so two years of allowances are surrendered together. Later years follow the ordinary 30 April deadline.
- Can UK allowances be used for EU ETS, or the other way round?
No. They are separate schemes with separate registries, separate auctions and separate prices. A UK allowance settles a UK obligation and an EU allowance settles an EU one; neither is fungible with the other, and the two prices move independently.
- Is UK MRV still in force?
No. It was revoked by the Merchant Shipping (Monitoring, Reporting and Verification of Carbon Dioxide Emissions) (Revocation) Regulations 2026. The Regulations commence on the 22nd day after the day they were laid, and name no calendar date in their own text.
Sources cited
- [1]UK ETS Order 2026 (SI 2026/392) — Paragraph 5, Schedule 2A — applies to a ship of gross tonnage 5000 or more (ITC 1969 Annex I), excluding armed-services and law-enforcement ships among othersUK
- [2]UK ETS Order 2026 (SI 2026/392) — Paragraph 7, Schedule 2A — a maritime activity is a voyage or an in-port activity; a voyage must begin and end at a port of call within the United Kingdom's jurisdiction and must not arrive at a port of call outside itUK
- [3]UK ETS Order 2026 (SI 2026/392) — Paragraph 15, Schedule 2A — surrender 50 % of emissions from Great Britain–Northern Ireland voyages and 100 % from any other maritime activity; 2026 scheme year due 30 April 2028, later years 30 AprilUK
- [4]UK MRV Revocation Regulations 2026 (SI 2026/245)UK
- [5]Directive 2003/87/EC (EU ETS), as amended by Directive (EU) 2023/959 — Article 3ga — scope of application to maritime transport (voyage shares: 100 % intra-EEA and at berth, 50 % to/from third countries)EUR-Lex
- [6]Directive 2003/87/EC (EU ETS), as amended by Directive (EU) 2023/959 — Article 3gb — phase-in of surrender requirements (40 % of 2024, 70 % of 2025, 100 % from 2026)EUR-Lex
- [7]Directive 2003/87/EC (EU ETS), as amended by Directive (EU) 2023/959 — Article 12(3) — surrender of allowances for the previous year's verified maritime emissions by 30 SeptemberEUR-Lex
All citations checked automatically · updated 2026-10-21