Expansion of UK Emissions Trading Scheme into the domestic maritime sector: Final Business and Regulatory Impact Assessment 2026

Footnotes

1 METS is the Manage your UK Emissions Trading Scheme reporting service, used by operators, regulators and verifiers who carry out activities covered by the UK ETS or the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA).

2 ISM companies are defined in the proposed Greenhouse Gas Emissions Trading Scheme (Amendment) (Extension to Maritime Activities) Order 2026 as a person who is not the registered owner of a ship who has agreed with the registered owner to take over all the duties and responsibilities imposed by the ISM Code. The ISM Code is the International Management Code for the Safe Operation of Ships and for Pollution Prevention, which provides an international standard for the safe management and operation of ships and for pollution prevention.

3 Developing the UK Emissions Trading Scheme (UK ETS) (publishing.service.gov.uk)

4 UK Emissions Trading Scheme: Business and Regulatory Impact Assessment

5 UK ETS scope expansion: maritime sector (publishing.service.gov.uk)

6 UK ETS scope expansion: maritime - interim response (publishing.service.gov.uk)

7 UK Emissions Trading Scheme: Main Authority response to the Scope Expansion: Maritime consultation

8 UK ETS scope expansion: domestic maritime - final stage impact assessment

9 UK Emissions Trading Scheme: Scope Expansion - Emissions from international maritime voyages consultation

10 UK Emissions Trading Scheme – Scope Expansion to Domestic Maritime - Island Communities Impact Assessment (ICIA) - gov.scot

11 Gross tonnage (GT) is a measure of the internal volume of a ship, used internationally to classify vessel size for regulatory purposes. It is not a measure of weight.

12 See UK Government Maritime Decarbonisation Strategy for more detail

13 UK Government Maritime Decarbonisation Strategy

14 UK ETS scope expansion: domestic maritime - final stage impact assessment

15 Tank-to-wake with zero rating measures direct operational emissions, excluding emissions relating to the production of the vessel. Zero rating refers to treating fuels that emit no greenhouse gases during combustion onboard as having zero emissions, regardless of their production emissions. Well-to-wake measures both the emissions from both the production and delivery of a maritime vessel in addition to direct operational emissions.

16 Letter: Advice on implementing the expansion of the UK ETS to include some maritime emissions - Climate Change Committee

17 All figures presented in tables 3B and 3C originate from UKG Department for Transport’s Maritime Emissions Model (MEM)

18 Figures may not sum to totals due to rounding.

19 5000GT refers to a ship with a gross tonnage (internal volume) of over 5000.

20 UK ETS scope expansion: domestic maritime - final stage impact assessment

21 Note: 2026 reflects half a year of emissions given the scope expansion to UK domestic maritime is planned from 1^st July 2026.

22 4 UK Emissions Trading Scheme – Scope Expansion to Domestic Maritime - Island Communities Impact Assessment (ICIA)

23 Traded carbon values used for modelling purposes, 2024 - GOV.UK

24 Developing the UK Emissions Trading Scheme: main government response

25 UK ETS scope expansion: domestic maritime - final stage impact assessment

26 Analysis of company address data for both International Safety Management (ISM) companies and Registered Owners (ROs) suggest approximately 4% of operators under the scope of the UK ETS scope expansion to domestic UK maritime are UK based, while 24% of these are based in Scotland.

27 As Scottish ferry operators are included within the data used to estimate the 24% Scottish share of UK operators, this £1.7m cost estimate should be treated as an upper estimate.

28 UK Emissions Trading Scheme Authorisations and Compliance - Scottish Environmental Protection Agency (SEPA)

29 Traded carbon values used for modelling purposes, 2024 - GOV.UK

30 More details provided in section C1.2. of the UK ETS Authority Impact Assessment: UK ETS scope expansion: domestic maritime - final stage impact assessment

31 More details on societal benefits can be found in section C4 of the UK ETS Authority Impact Assessment: UK ETS scope expansion: domestic maritime - final stage impact assessment

32 More details can be found in section D3 of the UK ETS Authority Impact Assessment: UK ETS scope expansion: domestic maritime - final stage impact assessment

33 Economic research on the impacts of carbon pricing on the UK Domestic Maritime sector

34 Evaluation of the UK Emissions Trading Scheme: Phase 1 report

35 Climate Change (Scotland) Act 2009

36 Economic research on the impacts of carbon pricing on the UK Domestic Maritime sector

37 Mean value: 11.96 tonnes CO₂. Median value: 2.3 tonnes CO₂. The mean value is inflated due to instances of vessels remaining at berth for particularly long periods of time (over 50 days). The mean value is used as a conservative upper value.

38 Net Zero Strategy Aligned value for 2026, £2024 prices. UKG traded carbon values used for modelling purposes, 2024

39 Clarksons’ Shipping Intelligence Network

40 See, for example, the World Bank evidence review on estimates of price elasticities of demand for transport Although this paper is from 1990, the fundamental economic theory has not changed. 0.5 central elasticity estimate for ocean shipping of general cargo (p27)

41 Clarksons’ Shipping Intelligence Network