UK ETS Consultation Response

We welcome the UK’s ambition to strengthen the ETS and its overall aim to combat climate change and reduce greenhouse gas (GHG) emissions cost-effectively. The ETS will be a particularly important mechanism in achieving the UK’s legally binding pledge to reach net zero by 2050.

Members of the Group are involved in the export of UK WDF to recovery in incinerators in the EU. This trade in residual waste, in the form of WDF, is a vital part of the UK’s residual waste management as the UK does not have enough non-landfill residual waste capacity to treat all of its waste. Equally, there are countries in Europe which have excess EfW capacity and use this to generate energy from UK WDF. This results in the optimal overall outcome in carbon terms compared to landfilling. This is corroborated by the Prognos Study, which reveals the largest net emission savings are made by reducing landfilling, particularly of organic waste materials, which can achieve a reduction by up to 120 Mt CO₂eq. Moreover, in the last 10 years operational incinerator capacity in the UK has increased from 5 to 20Mt a year (an increase that is greater than in the rest of Europe combined). If control is not exercised in the granting of permits for new EfW facilities, it could result in a landscape of overcapacity. In this instance, facilities would be rendered redundant as recycling rates increase and waste reduction targets come into play. Exporting WDF therefore allows the UK the time and flexibility to transition from a landfill to a recycling-led waste system.

The Group is thus affected by ETS changes both in the UK and in the EU.

The attached response addresses specific points of interest highlighted by the Department for Energy Security and Net Zero in the consultation, which seeks to provide more detail on the inclusion of incineration and EfW in the UK ETS from 2026 for the Monitoring, Reporting and Verification only period, with full surrender obligations from 2028. We can confirm that this response does not need to be kept anonymous.