Emissions trading

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Outline

This subtopic includes the following overarching Practice Notes:

  1. •

    Emissions trading outline—sets out an outline of emissions trading regulation, including the Kyoto Protocol, the Paris Agreement and carbon markets, the EU Emissions Trading System (EU ETS) and the UK Emissions Trading Scheme (UK ETS). It covers requirements for greenhouse gas (GHG) permits under the EU ETS and UK ETS and emissions trading and aviation

  2. •

    Emissions controls and carbon pricing in respect of carbon emissions from UK fossil fuel powered electricity generation—provides a consolidated summary of the key emissions controls that apply to fossil fuel powered electricity generation in the UK. It includes coverage of the Emissions Performance Standard, the closure of existing unabated coal generation, environmental permitting requirements under the Industrial Emissions Directive 2010/75/EU and Environmental Permitting (England and Wales) Regulations 2016, and carbon pricing by virtue of the application of the EU ETS, the UK ETS, the Climate Change Levy’s carbon price support (CPS) mechanism (sometimes referred to as the carbon price floor (CPF)) and the European Commission’s carbon border adjustment mechanism (EU CBAM)

  3. •

    Emissions trading considerations in aviation finance transactions—explains the legislative

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Latest Environment News

Welsh Government consults on Deposit Return Scheme implementation

The Welsh Government has launched a consultation on the implementation of a Deposit Return Scheme (DRS) for drinks containers. The scheme would apply to containers between 150 ml and 3 litres made from PET plastic, glass, aluminium and steel, covering both single-use and reusable containers. The consultation seeks feedback on proposals including reuse targets for 2031–40, minimum standards requiring containers to be used at least eight times, and transitional arrangements, such as zero deposits for single-use glass containers. The implementation timeline has been accelerated to align with the introduction of DRS across the rest of the UK. A Deposit Management Organisation will also be appointed to oversee the scheme's operations. The consultation closes on 10 November 2025.

DfT publishes response to RTFO statutory review consultation

The Department for Transport (DfT) has published the response to its November 2024 consultation on the statutory review of the Renewable Transport Fuel Obligation (RTFO). The review confirms that the RTFO continues to meet its objectives of delivering greenhouse gas savings across surface transport. The DfT also plans to launch another consultation on: (1) proposals for the future target trajectory, including options for increased targets; (2) support for development fuels; (3) broadening the RTFO to cover fuels produced from nuclear energy; and (4) expanding the list of eligible non-road transport to include hydrogen fuel cell mobile generators. Additionally, the DfT commits to a separate call for evidence on the eligibility of crops under the Sustainable Aviation Fuel (SAF) Mandate and to establishing an expert working group to consider whether ethanol blending in petrol can be increased beyond E10 (10%) in the UK. Subject to the outcome of the planned consultation and parliamentary time, the DfT intends to introduce any necessary legislation in 2026 and implement changes to the RTFO in time for the start of the 2027 reporting year.

ESMA and EEA sign MoU to enhance sustainable finance cooperation

The European Securities and Markets Authority (ESMA) and the European Environment Agency (EEA) have signed a Memorandum of Understanding (MoU) to formalise and strengthen cooperation on sustainable finance. The MoU sets out terms for collaboration on integrating environmental factors into the EU sustainable finance framework and its supervision.

ECHA publishes updated version of EU PFAS restriction proposal

The European Chemicals Agency (ECHA) has published an updated proposal to restrict per- and polyfluoroalkyl substances (PFAS) under REACH regulation. The revision follows evaluation of over 5,600 scientific and technical comments and includes assessments for eight additional sectors not previously covered. The proposal introduces alternative restriction options that allow controlled manufacturing and use, rather than imposing a full ban. ECHA’s Risk Assessment and Socio-Economic Analysis committees are currently reviewing the proposal, with the final decision to be made by the European Commission in consultation with EU Member States.

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