Emissions Trading Scheme Misalignment
Lack of alignment between UK and EU Emissions Trading Schemes, potentially creating trade barriers and hindering climate goals.
Source spread
Where this theme appears
This theme appears across 3 independent accountability sources, so the source mix matters as much as the headline total.
77 committee recs
18 LGO/SPSO decisions
Browse by source
Source-grouped records are useful for tracing where a concern came from. Large sections show the 50 strongest matches for that source; counts still show the full theme total.
Select committee recommendations(77)— showing 50 strongest matches
#7 —
Recommendation: We welcome the ambition to conclude talks on an Emissions Trading Scheme agreement by the time of the 2026 UK-EU summit. Linking UK-EU Emissions Trading Schemes will deliver mutual benefits to businesses. Mutual Carbon Border Adjustment Mechanism (CBAM) waivers will …
Response status not verified
#8 —
Recommendation: We recommend that the Government move as quickly as possible to conclude the ETS linkage agreement. Once negotiations have concluded, it should seek provisional application of the agreement before its formal ratification. This would allow industry to feel its benefits, …
Response status not verified
#12 —
Recommendation: The UK and EU have agreed to consider linking the UK and EU ETS systems, which would exempt UK producers from the EU’s CBAM (and vice versa), simplifying administrative processes for UK-EU trade; as linking can be a lengthy process, …
Response attribution not verified
#5 —
Recommendation: We recommend that the Government commence work immediately on developing a comprehensive UK carbon border approach, in order that this might be implemented during the 2020s. We recommend that this include a CBAM as part of a co-ordinated set of …
Response attribution not verified
#3 —
Recommendation: While net zero policies address the UK’s territorial production emissions, 43% of the UK’s consumption emissions arise from imports. The UK’s principal carbon pricing mechanism, the ETS, applies to domestic production, but no carbon price is currently applied to imports …
Response attribution not verified
#1 —
Recommendation: Effective carbon pricing is crucial to decarbonisation, but cannot be achieved without effective anti-carbon leakage policies in place. The Government’s current approach to addressing the risks of carbon leakage, including free allocation of Emissions Trading Scheme (ETS) allowances, is insufficient …
Response attribution not verified
#22 — New Drax agreement offers limited impact on emissions and lacks BECCS investment incentives.
Recommendation: There are other factors which cast doubt on whether the government has reached a good deal. The new support agreement with Drax reduces the level of allowed supply chain emissions for the fuel it burns, from 55.6 grams of CO2 …
Response attribution not verified
#7 — Current Bus Service Operators Grant disadvantages rural areas and conflicts with decarbonisation goals.
Recommendation: The current Bus Service Operators Grant structure appears to disadvantage rural and low-demand areas, where lower fuel consumption per kilometre and longer average journey lengths can reduce the level of support received. This funding model does little to reflect the …
Response attribution not verified
#25 — Ensure aviation sector pays fair share and include Sustainable Aviation Fuels in ETS.
Recommendation: The Government should ensure that the aviation sector pays its fair share towards mitigating its carbon emissions and the benefits it receives in comparison to other sectors. Aviation should be included in Emissions Trading Schemes and the government should include …
Response attribution not verified
#24 — Aviation sector's carbon emissions are not fully paid for, creating artificial cheapness.
Recommendation: The aviation sector does not fully pay for its carbon emissions, whether this is through the lack of a direct carbon tax, VAT on its fuel, or the greater benefits it receives through the Emissions Trading Scheme compared to other …
Response attribution not verified
#18 — Legislate to formally include international aviation emissions within Carbon Budgets and Net Zero targets
Recommendation: We reiterate the recommendation made by the Climate Change Committee, our predecessor Committee and others that the Government makes Parliamentary time available to introduce the necessary legislation to formally include international aviation emissions within Carbon Budgets and its Net Zero …
Response attribution not verified
#17 — International aviation emissions not formally legislated within UK Carbon Budgets
Recommendation: Whilst the Committee understands the Government position that it includes international aviation emissions within its carbon calculations, the UK is yet to formally legislate to include international aviation emissions within the Carbon Budgets, despite it agreeing to do so previously. …
Response attribution not verified
#10 — National Policy Statement for Ports critically enables maritime decarbonisation through planning decisions
Recommendation: Decarbonising the maritime sector is a complex and long-term challenge that requires coordinated action across government, industry and planning frameworks. While the National Policy Statement for Ports is not the vehicle for setting decarbonisation policy, it plays a critical enabling …
Response attribution not verified
#9 — Revise National Policy Statement for Ports to clarify port freight interface and promote modal shift
Recommendation: The Government should revise the draft National Policy Statement for Ports to articulate more clearly how ports interface with other freight modes, ensuring that planning authorities actively consider modal shift in their decision-making. This should reflect the strategic role of …
Response attribution not verified
#20 —
Recommendation: We recommend that the Government: a) Ensure, through the oversight of both Cabinet Committees on Climate Action, that the UK’s carbon border approach is aligned with existing environmental, trade, development and fiscal policy, through both its design and implementation stages. …
Response attribution not verified
#19 —
Recommendation: The UK’s carbon border approach needs to be aligned with the Government’s wider environmental policies, and integrated into trade, development and fiscal policy. The context for carbon border measures is not fixed, and CBAM in particular represents a new policy …
Response attribution not verified
#17 —
Recommendation: Pricing the carbon element, so low-carbon products become less expensive than high-carbon ones, is a powerful lever to reduce consumption emissions, to support the development of low-carbon products and increase access to such products. Currently, high energy prices and rises …
Response attribution not verified
#13 —
Recommendation: We recommend that the Government: a) Set out in its response to this report: b) how it intends to work with stakeholders in the EU and UK to understand how the proposed EU CBAM, would affect the UK, including in …
Response attribution not verified
#10 —
Recommendation: It is at present unclear how the proposed EU CBAM might impact the UK, particularly Northern Ireland, where electricity generators are currently under the scope of the EU’s ETS. We understand that this is a dynamic discussion which depends on …
Response attribution not verified
#7 —
Recommendation: As the UK continues to negotiate its own trade agreements following exit from the European Union, there is an opportunity to align trade policy with the UK’s role as a leader in climate change action; further analysis is required to …
Response attribution not verified
#6 —
Recommendation: The UK is an open, trading economy, and trade can be a powerful lever to drive environmental outcomes. Careful design, alongside inclusive engagement with trading partners, is needed to ensure that any CBAM and wider carbon border approach are aligned …
Response attribution not verified
#4 —
Recommendation: Alongside CBAM, the UK’s carbon border approach needs to comprise a set of complementary policies, including product standards, to tackle consumption emissions beyond those covered by explicit carbon pricing, and support decarbonisation across the economy. Careful design is needed to …
Response attribution not verified
#4 —
Recommendation: We are not convinced that departments are making effective use of the emissions data to drive decision-making. Central government and other public sector bodies need to use emissions data to decide priorities and assess the affordability of plans. While the …
Response attribution not verified
#25 — Implement UK ETS changes to remove conventional aviation fuel from free allocations.
Recommendation: We recommend that the Government implement its proposed changes to the UK ETS so as to remove conventional aviation fuel from free allocations, and that it consult on a methodology to include SAF in the ETS in a way which …
Response attribution not verified
#24 — Free ETS allocations for aviation ending, SAF pricing needs to reflect carbon impact.
Recommendation: We welcome the decision of the UK Government and devolved administrations to end the issuing of free ETS allocations to aviation with effect from the 2026–2030 allocation period. We note that the use of SAF in aviation is currently zero-rated …
Response attribution not verified
#14 — Link and keep aligned the UK and EU Emissions Trading Schemes to prevent trade barriers.
Recommendation: To prevent the UK and EU’s respective Carbon Border Adjustment Mechanism schemes from becoming barriers to trade in electricity and carbon- intensive goods, when doing so maximises export potential and reduces consumer costs, the Government should seek to link, and …
Response attribution not verified
#28 — Undertake detailed review of airport expansion's impact on climate, environment, and biodiversity targets.
Recommendation: The Government must undertake a detailed review on whether significant airport expansion will realistically allow it to deliver on its legally binding climate, environment and biodiversity targets. This should include a detailed examination of the measures that need to be …
Response attribution not verified
#27 — Airport expansion risks climate targets and lacks demonstrated economic benefits outweighing environmental harm.
Recommendation: Whilst it may be possible for the Government to deliver airport expansion alongside its climate and environment targets, we are concerned that the proposed environmental impact from airport expansion will make such targets significantly more difficult to achieve and at …
Response attribution not verified
#26 — Conduct wider review of aviation taxation to ensure 'polluter pays' principle is upheld.
Recommendation: Government should also conduct a wider review of aviation taxation to ensure that the ‘polluter pays’ principle is upheld, and the aviation industry does not receive benefits which are denied to other important industries. The aviation industry will then be …
Response attribution not verified
#23 — Set out detailed analysis on aviation impacts and mitigations if airport expansion proceeds.
Recommendation: If the Government proceeds with airport expansion it should set out to the Committee in its response to this report, in-depth analysis on: • How it will ensure carbon costs will reach the level the Government expected in the Jet …
Response attribution not verified
#21 — Government's Jet Zero Strategy insufficient to deliver Net Zero aviation objectives.
Recommendation: The Government’s Jet Zero Strategy remains reliant on demand management measures that are as yet insufficient to deliver Net Zero objectives, especially if there is an increase in demand. The strategy relies on a far higher cost to industry to …
Response attribution not verified
#4 —
Recommendation: Government does not have a clear way of determining whether its actions to reduce emissions in the UK are transferring emissions to other countries. The net zero target applies to emissions generated within the UK and does not include emissions …
Response attribution not verified
#18 —
Recommendation: We recommend that the Government, at the design stage: a) Include a strategy to engage with the public in the design of the carbon border approach to develop and maintain public support and keep the public informed of the changes …
Response attribution not verified
#16 —
Recommendation: We recommend that the Government: a) clearly define its objectives for any carbon border approach at the outset, and ensure the choice of policy options and design consideration at each stage is led by these objectives. These should encompass the …
Response attribution not verified
#14 —
Recommendation: As the report of the Treasury’s Net Zero Review notes, there can be no one-size-fits- all mechanism to address carbon leakage risks. The UK’s carbon border approach needs to comprise a set of complementary policies, designed to drive industrial decarbonisation …
Response attribution not verified
#11 —
Recommendation: The Government has committed to ensuring businesses do not face any unreasonable barriers to trade; further detail would be welcome on how it plans to work with stakeholders in the EU and UK to achieve this. Given that electricity generators …
Response attribution not verified
#8 —
Recommendation: Our recommendations to Government on the design of the carbon border approach are as follows: a) to ensure, from the outset, that the carbon border approach is designed to adhere to the principles of common but differentiated responsibilities and respective …
Response attribution not verified
#2 —
Recommendation: Multilateral and global approaches to carbon pricing represent the most appropriate way to support global decarbonisation. Since the process to negotiate and agree these is lengthy, they cannot provide the urgent action necessary in the short term. Pursuing a unilateral …
Response attribution not verified
#9 —
Recommendation: The current reporting requirements for central government focus on scope 1 and scope 2 emissions; for example the gas used in boilers and electricity used across the government estate.19 The only scope 3 emissions that are captured by current mandatory …
Response attribution not verified
#6 —
Recommendation: In addition to the BEIS dataset that covers the entire public sector, Defra publishes an annual progress report for the Greening Government Commitments (GGCs). Alongside the government’s other environmental measures, this shows the progress made by central government departments and …
Response attribution not verified
#5 —
Recommendation: The public sector risks falling behind on the reporting of its emissions but could learn from developing practice in private sector and the devolved administrations. While the UK government has committed to leading by example in efforts to decarbonise, other …
Response attribution not verified
#3 —
Recommendation: Leadership and oversight of emissions measurement and reporting in central government is fragmented and ineffective. At present, there are at least three departments issuing guidance to central government bodies on how to measure and report emissions. However, the guidance is …
Response attribution not verified
#9 —
Recommendation: The maritime sector is global, and the UK cannot regulate it alone. To reach the Government’s net zero target, we welcome the Government’s commitment to live up to its world-leading maritime status and push for the net zero target at …
Response attribution not verified
#24 —
Recommendation: The Government should also set out how free allocation under the UK Emissions Trading Scheme and the forthcoming UK Carbon Border Adjustment Mechanism will interact during the transition, with a commitment to review their combined effectiveness globally once the UK …
Response attribution not verified
#23 —
Recommendation: The carbon budget delivery plan should provide clarity on how key policy mechanisms, including electricity price support, infrastructure delivery, and carbon pricing will operate together during the Seventh Carbon Budget period to support domestic investment and manage carbon leakage. (Recommendation, …
Response attribution not verified
#22 —
Recommendation: The Government should set out clearly how its carbon budget policies will prevent the offshoring of emissions and support domestic decarbonisation, particularly in energy-intensive and trade-exposed sectors. (Recommendation, Paragraph 104)
Response attribution not verified
#19 —
Recommendation: The Seventh Carbon Budget must deliver genuine emissions reductions, not reductions achieved by exporting emissions overseas. Meeting carbon budgets through offshoring would undermine their environmental purpose 61 and the integrity of the UK’s climate framework, and risks weakening public confidence …
Response attribution not verified
#26 —
Recommendation: We ask the Government to provide clarity at the earliest opportunity about the state of play of its engagement, if any, with the EU to agree an interim arrangement for British exports under the EU’s Carbon Border Adjustment Mechanism, while …
Response attribution not verified
#25 —
Recommendation: We support the Government’s intention to act on the commitment made by its predecessor within the Trade and Cooperation Agreement to “seriously consider” linking the UK and EU emissions trading systems. An agreement to that effect would be of benefit …
Response attribution not verified
#24 — UK's reliance on natural gas results in highest energy bill support in Europe
Recommendation: Analysis from the Office for Budget Responsibility concluded that the size of the government’s financial support for energy bills (relative to Gross Domestic Product) was one of the highest in Europe because of the UK’s reliance on natural gas.69 The …
Response attribution not verified
Independent reviews(8)
Helm Energy Review — Rec 6
There should be a border carbon price to address the consequences of the UK adopting a unilateral carbon production target.
Other
Helm Energy Review — Rec 5
The most efficient way to meet the CCA target and the carbon budget is to set a universal carbon price on a common basis across the whole economy, harmonising the multiple carbon taxes and prices currently in place. This price should vary so as to meet the carbon targets. It …
Other
Stern Review — Rec Policy-2
Emissions trading: Expanding and linking the growing number of emissions trading schemes around the world is a powerful way to promote cost-effective reductions in emissions and to bring forward action in developing countries: strong targets in rich countries could drive flows amounting to tens of billions of dollars each year …
Other
Skidmore Review — Rec 125
By 2024, Government should work within the UK ETS Authority to develop a pathway for the UK ETS until 2040. This pathway should: a) Set out a vision on the future design and operation of the ETS b) Set out a timeline for expanding the coverage to the rest of …
Other
Helm Energy Review — Rec 1
The cost of energy is too high, and higher than necessary to meet the Climate Change Act (CCA) target and the carbon budgets. Households and businesses have not fully benefited from the falling costs of gas and coal, the rapidly falling costs of renewables, or from the efficiency gains to …
Other
Skidmore Review — Rec 71
Government should progress its consultation on carbon leakage measures, including a carbon border adjustment mechanism (CBAM) and mandatory product standards by 2023. This will enable Government to implement effective carbon leakage mitigations from 2026.
Other
Stern Review — Rec Ch27-6
The challenge now is to broaden and deepen participation across all the relevant dimensions of action – including co-operation to create carbon prices and markets, to accelerate innovation and deployment of low-carbon technologies, to reverse emissions from land-use change and to help poor countries adapt to the worst impacts of …
Other
Stern Review — Rec Policy-1
Climate change is the greatest market failure the world has ever seen, and it interacts with other market imperfections. Three elements of policy are required for an effective global response. The first is the pricing of carbon, implemented through tax, trading or regulation. The second is policy to support innovation …
Other
LGO / SPSO decisions(18)
23-017-782 — Transport for London
Summary: We will not investigate this complaint about the Authority’s decision that the complainant does not qualify for a payment under the Ultra Low Emission Zone scrappage scheme. This is because there is insufficient evidence of fault by the Authority.
LGO (Local Government & …
Transport And Highways
Apr 2024
23-010-620 — Transport for London
Summary: We will not investigate this complaint about ULEZ penalty charges. We cannot consider matters that were for the adjudicator to decide on appeal. There was no fault in Transport for London (TfL) increasing the charges. It would be disproportionate to investigate now TfL’s decision-making about how Mr X should …
LGO (Local Government & …
Transport And Highways
Apr 2024
24-004-540 — Transport for London
Summary: We will not investigate this complaint about Penalty Charge Notices and a vehicle’s compliance with emissions standards, as we could not achieve a worthwhile outcome. There is insufficient evidence of fault in the Authority issuing the Penalty Charge Notices.
LGO (Local Government & …
Transport And Highways
Jul 2024
25-001-118 — Transport for London
Summary: We will not investigate this complaint about Transport for London’s issue and pursuit of payment for penalty charge notices issued for contraventions of its ‘low emission zone’ scheme. This is because Mr X had a right of appeal against any penalty charge notices which it would have been reasonable …
LGO (Local Government & …
Transport And Highways
Jun 2025
25-014-263 — Transport for London
Summary: We will not investigate this complaint about low emission zone penalty charge notices as they have been cancelled and there is insufficient remaining injustice caused to the complainant to warrant our further involvement.
LGO (Local Government & …
Transport And Highways
Oct 2025
21-018-148 — Transport for London
Summary: We will not investigate this complaint about Transport for London’s issuing a penalty charge notice for entering an ultra-low emission zone without paying the charge. This is because Transport for London has now agreed to waive the charge and it is unlikely an investigation would achieve anything more.
LGO (Local Government & …
Transport And Highways
Upheld
Mar 2022
22-004-045 — Transport for London
Summary: We will not investigate this complaint about the level of a low emission zone fine as Transport for London is going to consider Mr X’s case.
LGO (Local Government & …
Transport And Highways
Jul 2022
23-015-905 — Transport for London
Summary: We will not investigate Mr X’s complaint that Transport for London failed to pay him the correct amount under the Ultra-Low Emission Zone van scrappage scheme. This is because there is not enough evidence of fault to warrant an investigation.
LGO (Local Government & …
Transport And Highways
Apr 2024
24-004-267 — Transport for London
Summary: We will not investigate this complaint about a refusal to refund charges for using the Ultra Low Emission Zone. There is not enough evidence of fault to justify investigating.
LGO (Local Government & …
Transport And Highways
Jul 2024
23-014-476 — Brighton & Hove City Council
Summary: Mr X complained about a resident’s parking scheme which the Council sets charges for based on vehicle emissions. The Council is not at fault. It administers the scheme in line with a 2018 traffic regulation order and the fees are agreed and approved each year by the relevant Council …
LGO (Local Government & …
Transport And Highways
Not Upheld
Jul 2024
23-015-506 — Transport for London
Summary: Mr B says Transport for London misled him about whether his car was compliant with the ultra low emission zone and failed to address the points he raised about the costs he incurred when responding to his complaint. Transport for London provided Mr B with an incorrect outcome for …
LGO (Local Government & …
Transport And Highways
Upheld
Sep 2024
24-008-644 — Transport for London
Summary: We will not investigate Ms X’s complaint about Transport for London’s refusal to pay her the £2,000 scrappage allowance for scrapping her car. This is because there is not enough evidence of fault to warrant investigation.
LGO (Local Government & …
Transport And Highways
Oct 2024
24-009-107 — City of Bradford Metropolitan District Council
Summary: We will not investigate this complaint about the Council’s decision not to issue a Clean Air Zone exemption for the complainant’s private hire taxi. This is because there is insufficient evidence of fault by the Council.
LGO (Local Government & …
Transport And Highways
Oct 2024
24-009-879 — City of Bradford Metropolitan District Council
Summary: We will not investigate this complaint about the Council’s decision not to award a grant to upgrade a non-compliant vehicle in relation to the Clean Air Zone. This is because there is insufficient evidence of fault by the Council.
LGO (Local Government & …
Transport And Highways
Oct 2024
24-015-337 — Bristol City Council
Summary: We will not investigate this complaint about a Penalty Charge Notice in relation to the Clean Air Zone. This is because the complainant could have appealed to the tribunal.
LGO (Local Government & …
Transport And Highways
Dec 2024
25-006-861 — Transport for London
Summary: We will not investigate this complaint about Transport for London’s refusal to refund Mr X’s payments for driving in the ultra-low emission zone since 2022. This is because there is not enough evidence of fault by Transport for London in making the charges. The Authority accepts it wrongly awarded …
LGO (Local Government & …
Transport And Highways
Dec 2025
25-021-042 — Transport for London
Summary: We will not investigate Mr B’s complaint that the extended Ultra Low Emission Zone is unfair to motorists like him. This is because an investigation would not achieve the outcome Mr B seeks.
LGO (Local Government & …
Transport And Highways
Dec 2025
25-010-695 — Transport for London
Summary: We will not investigate Mr X’s complaint about emission zone charges. There is insufficient remaining injustice to warrant investigation.
LGO (Local Government & …
Transport And Highways
Jan 2026