Procurement teams negotiating long term residual waste contracts have had a known date to work around. Expansion of the UK Emissions Trading Scheme to cover energy from waste and incineration was expected in 2028, and change in law provisions in disposal contracts commonly point at a scheme of that kind.
That date has gone. Updated government material states that the expansion will not take place in 2028, and that a new timeline will be set in due course.
Source: GOV.UK, UK Emissions Trading Scheme scope expansion: waste (updated 26 August 2026)
What is actually in place
A voluntary monitoring, reporting and verification (MRV) period began on 1 January 2026. Participating operators can use it to understand emissions and prepare; it does not itself impose a carbon charge on waste producers.
Separately, energy from waste in Northern Ireland is treated under distinct arrangements connected to the EU scheme through the Windsor Framework, so a single UK-wide description of the position would be wrong.
Source: GOV.UK, UK Emissions Trading Scheme scope expansion: waste (updated 26 August 2026)
Why the questions do not go away
A postponement is not a cancellation, and the reasoning that produced the policy has not changed. Residual waste sent to energy recovery carries fossil derived carbon, largely from plastics, and the direction of travel across comparable regimes is towards pricing it.
If you are signing a five or seven year disposal contract, the relevant question is not when the scheme starts. It is what happens to your price, and who bears the increase, if it starts at any point during the term.
Contract questions worth asking now
- Does the change in law clause reference a specific scheme or date that has now moved, and does it still function if the timetable changes again?
- If a carbon cost is introduced, how is it passed through, on what evidence, and is there any cap or sharing mechanism?
- Is any pass through calculated on your actual tonnage and composition, or on a facility average applied to everyone?
- What visibility do you get of the underlying emissions data supporting a charge?
- Does the contract allow you to divert material away from energy recovery without penalty if you improve segregation during the term?
A hypothetical, clearly labelled
The following is an illustration only, using invented figures to show how a sensitivity test is structured. It is not a forecast and no rate has been set.
Suppose a site sends 500 tonnes of residual waste to energy recovery each year. If a hypothetical charge of £20 for each tonne of waste were ever passed through, the annual effect would be £10,000. At a hypothetical £40 it would be £20,000. Remove 100 tonnes into segregated streams and the same hypothetical charges would apply to 400 tonnes instead, giving £8,000 and £16,000.
Read the limitation as carefully as the arithmetic. A real emissions trading scheme prices fossil carbon dioxide per tonne, not waste per tonne. Whether any of that reaches you, and in what form, depends on your contract terms, the composition of your waste, its fossil carbon content and the facility's own monitoring data. The illustration above assumes a flat surcharge on every tonne of waste, which is a simplification and not how such a scheme would work.
That simplification matters for a second reason. Because the charge would follow fossil carbon rather than mass, removing card or other largely biogenic material would not necessarily reduce a carbon related cost in proportion to the tonnage removed, while removing fossil derived plastics could have a different effect again. Any real estimate needs composition data, not a tonnage figure.
The practical position
Do not build a business case on a carbon charge that has no date and no rate. Do make sure your contracts are written so that a future mechanism does not simply arrive as an uncapped pass through, and do understand what is actually in your residual waste. Composition and contract terms are the two things that would determine your exposure, and both are worth knowing regardless of what any scheme eventually does.