The following is a commentary by Philippos Ioulianou, Managing Director of EmissionLink, on the looming expansion of the UK Emissions Trading Scheme (UK ETS) against the backdrop of the Strait of Hormuz crisis:

The events unfolding in and around the Strait of Hormuz are understandably commanding the industry’s attention. Whilst management attention is focused on one of the world’s most strategically important trading corridors, another major challenge is rapidly approaching.

The UK Emissions Trading Scheme will extend to maritime on 1 July, adding to an already intense regulatory burden for owners, operators and chartering teams. With many companies still managing FuelEU administration, reporting deadlines, verifier submissions and wider decarbonisation compliance requirements, maritime emissions compliance provider, EmissionLink, says there is a real risk that UK ETS preparations could slip down the priority list.

Philippos Ioulianou, Managing Director of EmissionLink, said: “Shipping is dealing with serious and immediate pressures, and it is entirely understandable that attention is being drawn towards developments in the Strait of Hormuz. But regulatory timelines do not pause because the market is facing operational or geopolitical disruption. That is where the risk lies. It is not a lack of awareness, but the possibility that understandable focus on immediate events leaves too little time to prepare for what comes next.”

EmissionLink cautions against treating UK ETS as simply a smaller or more localised version of EU ETS. While there are clear similarities, UK ETS is a separate regime with its own timeline, administration and commercial implications.

“Carbon pricing is no longer new to shipping,” Mr Ioulianou added. “The market has already been adapting to EU ETS, FuelEU, verifier processes, pooling arrangements and a steadily increasing compliance burden. But UK ETS is distinct, and with implementation beginning in July, preparation needs to be happening now.”

According to EmissionLink, one of the biggest areas of exposure for owners may not be emissions reporting itself, but contractual readiness.

Under EU ETS, the industry has learned that carbon cost allocation must be explicitly addressed in charterparties and related agreements. Assumptions do not recover costs; contractual wording does. EmissionLink says the same principle will apply to UK ETS, and owners who fail to update contracts accordingly may find themselves retaining liabilities they expected to pass on.

For example, charterparty clauses that address EU allowances but make no provision for UK ETS could leave owners commercially exposed. Assuming reimbursement mechanisms will automatically carry across could prove to be a costly error.

EmissionLink also stresses that UK ETS should not be seen solely as a sustainability or compliance issue. Its impact will extend across chartering, legal, operations and commercial decision-making, particularly where voyage economics and liability allocation are concerned.

“The danger now is delay,” says Mr Ioulianou. “Companies may assume that existing systems, assumptions and contractual protections will be enough. In many cases, they may not be. The smarter course is to act now: understand the exposure, review the contracts, and make sure the right systems and advice are in place before the deadline arrives.”

As the deadline draws closer, EmissionLink is encouraging shipping stakeholders to take practical steps now to avoid unnecessary financial and contractual risk later.

Photo credit: EmissionLink
Published: 16 February, 2026