Members may recall that earlier this year, the UK Government conducted a consultation on their proposed adoption of an Emissions Trading Scheme (ETS) for shipping. At that time, it was proposed that emissions at UK berths from international shipping should be included.

Within their response, the UK government has since confirmed the following elements of the scheme:
Scope:

· 5000 GT and above (review in 2028 planned);

· Covering:

o Domestic Voyages

o All In-port Emissions from International vessels

Start Date:

· First compliance year: July–Dec 2026; then annual cycles.

Double-surrender rule:

· Operators have until April 2028 to surrender allowances for both 2026 and 2027.

Offshore Vessels

· Offshore ships delayed until Jan 2027 to align with EU ETS

Compliance and Enforcement

Managed via METS system and UK ETS Registry.

New consultation

On 25th November 2025, the UK Government confirmed that it is now considering expanding its ETS scheme to include emissions from international voyages and is seeking stakeholder input through this consultation document.

In brief, the UK government’s proposal is for participants to:

“Monitor and report 100% of their greenhouse gas emissions on a voyage between a UK port and a port outside of the UK. However, operators would only be required to surrender allowances to cover 50% of their emissions. In addition to this, participants would be required to surrender allowances for 100% of their emissions while in port in the UK, as already confirmed in the interim Authority Response, published in July 2025”

The consultation document includes 14 questions. Stakeholders are invited to respond to these by 20thJanuary 2026, via this portal.

Alternatively, stakeholders can submit their responses via email to ukets.consultationresponses@energysecurity.gov.uk

Within Annex A to this circular, the ICS Secretariat has proposed a set of responses, and Members are invited to review these and forward any comments to Chris Waddington, ICS Technical Director. at chris.waddington@ics-shipping.org by 31st December 2025.

Alternatively or additionally, Members may submit their own responses to the consultation.

The ICS Secretariat extends our thanks to the UK Chamber of Shipping (UKCS) for forwarding the consultation information. UKCS has kindly offered to share it’s position on 12th January 2026, and at that point there will be an opportunity for UKCS and ICS to exchange views and to mutually strengthen responses.