UK ETS is live. Audit your surcharges and recover the overpayments.

Searoutes team

21 July 2026 · Updated 22 July 2026

Based on Jocelyn Hansen's presentation to the BIFA member webinar.

Carriers price UK ETS on fleet averages with a safety buffer. Your vessels often emit less than the number you're billed. That gap between what you pay and what your voyages actually cause is recoverable, if you have the data to audit it.

The UK Emissions Trading Scheme extended to domestic maritime on July 1, 2026. Ships of 5,000 GT and above must now surrender one UK allowance (UKA) for every tonne of CO2e emitted on covered voyages. UKAs trade around £49 per tonne, and carriers pass the cost on via surcharges on your invoices.

At the recent BIFA member webinar, Jocelyn Hansen, VP Sales at Searoutes, walked members through what UK ETS covers, how it differs from EU ETS, and critically, how to audit that gap. Below is her six-move playbook, reframed around a simple thesis: the gap is recoverable if you measure it.

The recoverable gap

Every UK ETS surcharge on your invoice reflects a calculation the carrier made about a vessel, typically using a fleet average multiplied by a safety buffer. That number is designed to protect the carrier's margin under the scheme, not to reflect the true emissions of the specific voyage that carried your box. Fleet averages hide vessel efficiency differences, engine types, route optimisations, and service-level factors that push actual emissions down.

The mechanic is identical across every ETS scheme, and the modelling is already telling. On EU ETS, the larger and longer-running system, our analysis on a BCO profile shipping 80,000 TEU a year on Europe to North America shows the recoverable gap can reach 2.3 million USD once vessel-specific emissions replace the carrier's fleet-average surcharge. UK ETS runs on a smaller scope but the mechanic is the same. Wherever your carriers surcharge you on fleet averages, there is a gap to measure.

The six moves below walk you through how to spot that gap on your own book of UK ETS exposure, and how to turn the audit into a repeatable advisor value for your customers.

Map your UK exposure

Before any conversation with carriers or customers, know your own numbers. Look at your lanes and flag:

Services on UK-domestic voyages (two UK ports).
Services on GB to Northern Ireland legs.
Vessels above the 5,000 GT threshold on any covered voyage.

The volumes on domestic UK legs and short-sea feeder services are often more significant than teams realise. Every lane in scope now carries an additional cost line, and more importantly, a potential audit line.

At Searoutes, we help forwarders map their UK exposure at the lane and vessel level, using vessel-specific emissions data to quantify the actual UK ETS surcharge on each service.

Pin down what your carriers publish

Every major carrier publishes their EU ETS surcharges by trade lane on their website. UK ETS surcharges now follow the same pattern. Get the published rate, the calculation method, and the effective date in writing before you sign or renew.

A key detail Jocelyn highlighted: carriers in the same alliance, on the same service, sometimes charge different EU ETS surcharges per TEU. On Trans-Pacific services calling the UK before Europe, the published EU ETS rate should be significantly lower than the trade-lane average. It rarely is.

"Carriers on the same alliance are charging very different EU ETS charges for the exact same service." — Jocelyn Hansen, VP Sales at Searoutes, at the BIFA member webinar.

Reading the carrier surcharges is the first step. Benchmarking them against actual voyage emissions is the second, and it is where the real leverage lies.

Audit before you pass through

The temptation is to pass the full carrier surcharge straight to your customer. Resist it. The published surcharge is a starting number, not the final one. Run the audit first:

What is the carrier billing per TEU on this service?
What did the actual voyage emit, on a vessel-specific and route-specific basis?
Where is the gap, and how large is it?

Once you have the audited number, pass through only the amount that reflects the real emissions. The delta between the carrier's charge and the audited number becomes your advisor value. It's the number you can defend to your customer, and the leverage you carry back to your carrier at renewal.

BIFA members are already protected under Clause 20 of the Standard Trading Conditions for passing on charges. Update your quotes and contracts to make the audited-pass-through model explicit: state that UK ETS is passed at the audited rate, and specify how the audit is performed. That contractual clarity turns a compliance line into a differentiator.

Brief your customers

Explain the difference between UK ETS and EU ETS to your customers so they do not read a legitimate double surcharge as double-charging. On shipments touching both UK and EU ports, both surcharges may apply, and both are legitimate, but the amounts, allowances, and reconciliations are separate.

Provide accurate emissions data alongside the surcharge on every invoice. That transparency does two things: it gives your customer the reporting-grade data they need for their own carbon accounting, and it makes your audit visible. When customers can see the number behind the surcharge, they trust it, and they stop pushing back on the line item.

The two schemes compare as follows:

Live since. EU ETS: 2024, phased. UK ETS: July 1, 2026.
Allowance price. EU ETS: roughly €70 to €80 per tCO2e. UK ETS: roughly £49 per tCO2e.
Vessel threshold. Both schemes: 5,000 GT and above.
Maritime scope. EU ETS: 50% of international voyages to and from the EU, 100% intra-EU and at-berth. UK ETS: 100% of UK-domestic voyages and at-berth, 50% GB to Northern Ireland.
Interchangeable? No. They are separate markets with no automatic offset.

Avoid double-charging on UK-EU legs

On voyages that cross both UK and EU jurisdictions, EU ETS and UK ETS need to be reconciled carefully. The two schemes are not linked, and there is no automatic offset between UK allowances and EU allowances. If your carrier charges both without adjustment, you or your customer end up paying for the same emissions twice.

Ask your carriers explicitly:

How do you reconcile UK ETS and EU ETS on multi-port voyages?
Which allowances apply to which segment of the journey?
How is the split calculated when a voyage calls both a UK and an EU port?

If they cannot answer clearly, that is a red flag worth pressing on. It is also, potentially, another line on your audit and another gap to recover.

Bring the gap into every quarterly carrier review

ETS is no longer a footnote in your carrier relationship. It deserves a dedicated section in every quarterly business review. Cover three things:

How carrier surcharges compare to actual voyage emissions on your specific services.
Where you have been over-charged relative to what your voyages emit, quantified per TEU and per lane.
What alternatives exist (including green fuel programs) as ETS prices rise.

Freight forwarders who bring vessel-specific and route-specific data to these reviews are the ones who successfully push back on carrier pricing. Searoutes' GLEC-certified emissions data delivers the accuracy and auditability needed to challenge carrier surcharges with numbers, not intuition, and to build a track record of recovered overpayments that pays for itself.

The gap is only getting bigger

The UK ETS launch on July 1, 2026 is only the start. UKA prices are expected to rise as the UK accelerates maritime decarbonisation targets. Road and rail ETS are on the roadmap, likely from 2027 or 2028. Green fuel programs, currently more expensive than paying ETS surcharges, will become cost-competitive faster than most teams expect.

Every one of those shifts widens the same gap: the distance between what your carriers bill on fleet averages and what your specific voyages actually cause. Forwarders who treat ETS as a compliance box to tick will keep reacting to every change. Those who build the data infrastructure to audit their exposure will negotiate from strength, recover overpayments quarter after quarter, and give their customers the transparency they are increasingly demanding.