UK Emissions Trading Scheme

The Interim Authority response[1] focused on the feedback on the sampling and analysis issues associated with measuring and monitoring of carbon from non-biogenic sources[8] (the 'fossil' carbon which creates the liabiliy for the large majority of the tax, with relatively little impact from process emissions), the level of accuracy possible in heterogeneous waste and the casacade of the carbon libaility back through the 'supply chain'.

A voluntary period of Monitoring, Reporting and Verification (MRV) started from 1st Jan 2026 and the scope of facilities it applies to includes combustion and process emissions from incinerators of waste, including those focused on clinical waste incineration, but excluding those focused on high-temperature hazardous waste incineration.

The ESA, representing busineses in the sector, have lobbied strongly for a emissions factor approach and an alignment between the ETS and the pEPR to allow local authorities to offset the cost of the incineration of packaging waste[4].

The MRV period is intended to inform an emissions factor approach, taking compositional analysis for waste from different sources and emissions from the stack of incinerators from a variety of plants and aggregating them on an aggregated confidential basis.

MSW waste is broadly around 50% non-biogenic or 'fossil' carbon, and at a carbon tax of £70 per tonne would have an impact of around £35 per tonne on gate fees. Local Authorities have set out clearly the potential impact to budgets (even after the potential offset from pEPR payments) with many suggesting negative impacts to wider service delivery[5].

As a result the exact ramiciations and approach to implimentation are still unclear, and are unlikley to become clear until late into the MRV period, leading many commentators to suggest that the implimentation in 2028 is unlikley to be possible.