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

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 are 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 1 July 2026. Ships of 5,000 GT and above must now surrender one UK allowance (UKA) for every tonne of CO2e emitted on covered voyages. The 2025 average UKA price was £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 the gap. Below is her seven-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 evidence is already telling. Take one voyage we modelled bottom-up: the Elly Maersk from Rotterdam to Singapore. The actual EU ETS cost, built from fuel consumption, transit days, emissions and EUA market price, lands at 43.30 USD per TEU. The carrier's published surcharge on that trade is 61 USD per TEU. On the same lane, published carrier EU ETS surcharges range 66 percent from lowest to highest for the exact same box. And zoomed out, 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. Key numbers:

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  66% · spread between the highest and lowest published carrier EU ETS surcharges on one lane, for the exact same box.
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  43.30 USD vs 61 USD per TEU · actual EU ETS cost (Elly Maersk, Rotterdam to Singapore) vs the carrier's published surcharge on the same trade.
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  Up to 2.3M USD · modelled recoverable gap on one BCO's Europe to North America EU ETS exposure. The same audit mechanic applies to UK ETS.

The seven moves at a glance

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  Move 1: Map your UK exposure lane by lane.
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  Move 2: Pin down what your carriers publish, then benchmark.
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  Move 3: Check the scope, audit the amount, then pass through.
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  Move 4: Brief your customers on UK ETS vs EU ETS.
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  Move 5: Avoid double-charging on UK-EU legs.
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  Move 6: Bring the gap into every quarterly carrier review.
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  Move 7: Know your four recovery routes.

The seven 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. Want a printable version to share with your team? Download the UK ETS Exposure Checklist (PDF).

Watch the full session

Jocelyn Hansen on UK ETS at the BIFA member webinar, 30-minute on-demand replay. Watch on Searoutes.

Move 1: Map your UK exposure

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

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  Services on UK-domestic voyages (two UK ports).
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  Services on GB to Northern Ireland legs.
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  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.

Move 2: 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.

Move 3: Check the scope, audit the amount, then pass through

Before you audit the amount, check what the surcharge can legally contain. UK ETS covers three things: voyages between UK ports at 100 percent, GB to Northern Ireland legs at 50 percent, and in-port activities at UK ports at 100 percent, for every ship in scope regardless of where it sailed from. What it does not cover, yet, is the international voyage itself. A vessel arriving from Shanghai owes UK allowances for its time in port, hoteling, cargo operations and movements within the harbour, and nothing for the ocean leg. Read that back against your invoices. On a deep-sea service into Felixstowe or Southampton, the only legitimate UK ETS cost is the port call, a small fraction of any voyage-level figure. A UK ETS surcharge on an international service that is sized like a voyage charge is mostly buffer by construction. You do not even need vessel data to see it. The scope rules alone put a ceiling on what the line can contain. In the early months of any new scheme, surcharge tables get applied broadly first and corrected later. Do not wait for the correction. Check every UK ETS line against the scope, then audit the amount on the lines that survive. Full scheme guidance is on gov.uk. Once the line survives the scope check, 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:

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  What is the carrier billing per TEU on this service?
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  What did the actual voyage emit, on a vessel-specific and route-specific basis?
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  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 is the number you can defend to your customer, and the leverage you carry back to your carrier at your next tender. 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.

Move 4: 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: Interchangeability: The schemes are separate markets with no automatic offset. For a deeper dive on how EU ETS mechanics work today, see our Complete Guide to EU ETS.

Move 5: 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:

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  How do you reconcile UK ETS and EU ETS on multi-port voyages?
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  Which allowances apply to which segment of the journey?
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  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.

Move 6: 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:

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  How carrier surcharges compare to actual voyage emissions on your specific services.
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  Where you have been over-charged relative to what your voyages emit, quantified per TEU and per lane.
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  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.

Move 7: Know your four recovery routes

Finding the gap is the audit. Recovering it happens through four routes, and knowing which one fits which situation is most of the work. This is the move the first six build toward. Dispute before payment. The cheapest recovery is the one you never pay. Most carrier invoices carry a dispute window. An audited emissions number filed inside that window, against the surcharge line only, keeps the freight moving while the carbon line gets corrected. This is where vessel-specific data earns its keep: a dispute backed by "your own vessel, this voyage, this fuel burn" gets a different reception than a dispute backed by "this feels high." Next tender leverage. This is often the biggest recovery route, and it turns the audit into a permanent pricing advantage. Some of the gap will not come back as cash. It comes back as rate. A quantified overcharge per TEU, per lane, per quarter is negotiating currency at your next tender, and unlike most negotiating currency, the carrier cannot dispute the denominator. Forwarders who bring vessel-level audit data into tender conversations set the terms; forwarders who arrive with carrier averages take what they are offered. The scope claim. Where a surcharge on an international service exceeds any plausible port-call cost, you are not negotiating a fleet-average gap. You are pointing at a charge the scope rules cannot support. These claims settle fast, because the carrier's alternative is explaining the line item. The year-end true-up. Carriers surrender allowances for the 2026 period on a set compliance calendar: emissions reported by 31 March 2027, first allowances surrendered by 30 April 2028. That means every surcharge collected this year is, from the carrier's side, a provision against a bill that has not landed yet. When the actual surrender numbers come in below the fleet-average provision, that difference exists on the carrier's books. Forwarders who have audited their lanes are the ones positioned to claim their share of it. Forwarders who have not will never know it was there. One honest caveat. If you pass through the audited number to your customer while the carrier still bills you the full surcharge, you are carrying the delta until one of the four routes above closes it. That is a deliberate working-capital position, not free margin. Forwarders who take it knowingly, with the audit behind them, turn it into a differentiator. Forwarders who take it accidentally just gave away margin. The audit is what makes the difference.

The gap is only getting bigger

The UK ETS launch on 1 July 2026 is only the start. UKA prices are expected to rise as the UK accelerates maritime decarbonisation targets. The UK government has consulted on extending the scheme to other transport modes. 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.

Start with one lane

You do not need a program to test the thesis. Pick one lane with UK ETS exposure, send us the carrier surcharge you were billed, and we will show you the vessel-specific number next to it. The gap, or the absence of one, will tell you whether this is worth your quarter. Sources: BIFA member webinar with Jocelyn Hansen (Searoutes, July 2026); UK Government participating-in-the-uk-ets guidance; Searoutes internal modelling covering the Elly Maersk Rotterdam-to-Singapore voyage, published carrier surcharge comparisons, and an EU ETS BCO profile from Europe to North America.