As of 1 July 2026, if your vessels call UK ports, you’re accruing carbon costs. Here’s what to do about it.
The most common misread we’re seeing: operators assuming an international voyage sits outside the scheme entirely. It doesn’t.
Port emissions in the UK are covered regardless of where the voyage originates or terminates. A vessel loading in the UK and discharging in Turkey generates zero UK ETS liability on the sea passage, but every hour at berth in the UK port is priced. Two segments of the same voyage, two different treatments. Get this wrong at the reporting stage and your Annual Emissions Report understates exposure, which is a verifier finding waiting to happen.
Domestic UK-to-UK voyages carry no such split. The full voyage, sea and port, is in scope from the first mile.
What’s currently covered?
The scheme applies to cargo and passenger vessels of 5,000 GT and above. Government vessels, ferry services to Scottish islands, and fish-catching or fish-processing vessels remain outside scope. The threshold is scheduled for review in 2028.
Payment timeline ≠ reporting timeline
This is one of the biggest misconceptions.
Although the first UK ETS allowance surrender is not due until 30 April 2028, emissions must still be reported every year. Your 2026 Annual Emissions Report is due by 31 March 2027.
The reporting clock started on 1 July 2026. The payment deadline comes later, but that does not mean you can wait until 2028. If you do, you’ll be trying to reconstruct months of voyage and fuel data after the fact.
Who’s responsible?
From a regulatory perspective, ultimate responsibility rests with the registered owner of the vessel.
However, responsibility can be delegated from the registered owner to a management company (for example, an ISM, technical, or operational manager) through formal agreements. Where responsibility has been delegated, it must also be declared through the UK ETS online platform.
Importantly, acting as an ISM, technical, or operational manager does not automatically transfer responsibility. The transfer must be formally agreed and appropriately declared.
Who bears the cost?
Responsibility and cost allocation are not always the same thing.
Much like under the EU ETS, the party that ultimately bears UK ETS costs will often depend on how the vessel is employed. For vessels operating under voyage charters, the owner or responsible manager typically bears the costs. For vessels employed under time charter arrangements (TC/TCT), the charterer would generally be expected to bear these costs.
In practice, this should be clearly addressed through charter party clauses that specify how ETS-related costs will be allocated and how owners will be reimbursed by charterers where applicable.
Waiting until the first surrender deadline approaches may leave little room to resolve contractual gaps. Reviewing charter parties now can help avoid disputes later.
Want your fleet’s exposure mapped against your actual routes and contracts? Talk to your trader or email newfuels@gibunkering.com
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