REA Consultation response to UK Emissions Trading Scheme Scope Expansion: Waste

Following member feedback, the REA has responded to the UK Emissions Trading Scheme Scope Expansion: Waste consultation. Thank you to all those who contributed via our online member session and independently.

Click here to read the REA’s response to this consultation.

The consultation sets out proposals for incorporating incineration and combustion of waste and other energy recovery from waste including waste-to-fuel and other advanced waste treatment activities. The full consultation is available here.

 

Within our response, the REA:

  • Supports the inclusion of waste to energy into the UK ETS acknowledging the need for protections for more nascent technologies.
  • Calls for greater clarity regarding treatment of assets using biowaste as a feedstock under the ETS, including waste wood and anaerobic digestion plants.
  • Supports the removal of the 20MW exclusion threshold in favour of an emissions output approach.
  • Advocates for the exclusion of hazardous waste from the scheme.
  • Supports a mandatory MRV-only period for the sector between 2026-2028, suggesting lighter touch penalties during this time.
  • Calls for an upward adjustment of the cap to better reflect EfW activities to be  captured in the expansion.
  • Opposes the potential incorporation of landfill into the UK ETS, with landfill tax to remain the primary lever for avoiding diversion back down the waste hierarchy.
  • Advocates for a variable tax on RDF export reflecting carbon price differentials.
  • Supports the use of a subtraction of ETS allowances to incentivise heat offtake for heat networks.

You can read our response here.