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Smoke signals and red herrings: What the UK–EU pact is really about

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By Christopher Caldwell

· 6 min read


When the UK and EU unveiled their most comprehensive post-Brexit agreement to date, it was a significant reset: streamlined trade, joint defence procurement, youth mobility, energy integration, and of particular interest for us climate folks, a landmark carbon market linkage. Yet, predictably, the British political discourse fixated on fish.

Former Prime Minister Boris Johnson, never one to miss a theatrical flourish, proclaimed: “Two-tier Keir is the orange ball-chewing manacled gimp of Brussels. He has sacrificed UK fishing interests, handing over our seas to be plundered again.”

It’s almost a reflex: a complex, forward-looking treaty emerges, one that spans climate, energy, trade, youth mobility, and security, and yet political oxygen is consumed by barnacled over simplified outrage over quota shares and cod. The more transformative aspects, like a potential £9 billion boost to the UK economy by 2040 through energy cooperation and market integration, barely register in the headlines.

This article focuses on the decision to reconnect the UK and EU carbon markets. It may not make front pages, but it could reshape Europe’s energy future.

The post-brexit gap

When the UK left the European Union, it also exited the EU Emissions Trading System, the flagship carbon market that Britain had helped design. In its place, the UK launched its own domestic ETS in 2021. The architecture was familiar, but the separation created new complications. Over time, carbon prices began to diverge. UK allowances traded at a discount, creating cost asymmetries for heavy industry. Cross-border electricity trade, once streamlined under shared rules, became less efficient. And with the EU preparing to apply its new carbon border tax, UK exporters faced the prospect of paying levies just to maintain access to European markets. Businesses operating in both jurisdictions were left juggling two regulatory regimes. What had once been a unified climate market began to fragment, less efficient, more volatile, and increasingly out of step. The new agreement seeks to close that gap, restoring coherence to a system that was always more effective when working as one.

Provisional Agreement: A Road Back to Unity

At the heart of the summit was a common understanding to pursue a formal link between the UK and EU’s emissions trading systems (ETS). The agreement, while still being fleshed out, would allow UK and EU carbon allowances to be recognized across borders, effectively merging the two markets.

Crucially, this linkage promises mutual exemption from the EU’s Carbon Border Adjustment Mechanism (CBAM), avoiding the imposition of climate tariffs on UK exports. That’s significant for industries such as steel, cement, aluminum, and electricity, which are already under pressure to decarbonize while remaining globally competitive.

While there is no definitive timeline, both sides are clear that the political will is present. The UK’s carbon pricing will need to remain at least as ambitious as the EU’s, and the two systems will align dynamically to maintain environmental integrity.

The economics of scale: why linking works

At its core, carbon trading is about creating incentives to reduce emissions where it’s cheapest to do so. A larger, integrated market amplifies this logic. It improves liquidity, reduces volatility, and provides a clearer, more stable price signal.

In practice, this could reduce compliance costs for businesses and unlock billions in savings across sectors through more efficient trading. For the UK, which has struggled with volatility in its smaller, standalone market, linkage offers a path to predictability and investor confidence. For the EU, it’s a chance to consolidate its position as a global leader in carbon pricing.

Critically, stable prices are essential for long-term planning, whether for offshore wind farms, steel plant upgrades, or green hydrogen facilities. A linked ETS would give businesses across the continent the additional certainty they may need to invest, innovate, and accelerate the transition.

Powering the link: the energy sector opportunity

Nowhere is the potential of ETS linkage more tangible than in the power sector. The UK and EU are already physically connected through nearly 10 GW of interconnectors, enabling electricity to flow where it’s most needed. But separate carbon prices have created distortions, complicating cross-border electricity trade and undermining price signals.

The linkage agreement clears a path to harmonize carbon pricing in electricity markets, removing barriers to trade and rewarding the cleanest generators, whether they are wind farms in the North Sea or hydro plants in Norway. Perhaps most critically, it could resolve a looming CBAM headache for electricity exports. Without linkage, even zero-carbon UK electricity could be taxed at the EU border based on average emissions intensity. Linkage removes that risk and restores the full value of British offshore wind and other low-carbon exports to the continent.

For both sides, this means more efficient use of interconnectors, reduced reliance on gas, and faster integration of renewables. It’s a strategic win for energy security and a pragmatic step toward net zero.

Industrial strategy without the penalty

For carbon-intensive industries, the CBAM was fast becoming a thorny issue. Without a linked ETS, UK exports to the EU would face rising carbon tariffs starting in 2026, payments that would go to EU treasuries rather than back into the UK’s decarbonization efforts. The linkage agreement changes that calculus. UK exporters will no longer face CBAM charges on goods shipped to Europe, as long as their emissions are covered by the linked market. This not only levels the playing field but keeps critical funds at home to support industrial transition.

More importantly, it simplifies regulation. Companies will no longer need to double-report emissions or comply with two different monitoring systems. That’s a major relief for businesses operating in both jurisdictions.

Global signal, local stability

Beyond the economics, the linkage carries powerful symbolic weight. In an era of fragmentation and decoupling, it offers a model of cooperative climate policy that prioritizes outcomes over ideology. It also bolsters the credibility of carbon pricing as a tool for international decarbonization showing that alignment, not isolation, is the path to progress.

The linkage could serve as a catalyst for broader climate diplomacy. With the UK and EU aligned, their combined voice will carry more weight in shaping global carbon markets, trade rules, and investment flows. It sets a precedent: adopt robust carbon pricing and enjoy seamless trade with the world’s largest carbon market.

On a personal note, as someone who spent six formative months living in the Netherlands during my studies, I am celebrating the youth mobility scheme. It enriches individuals, strengthens shared understanding, and perhaps most importantly, keeps doors open in a world increasingly marked by walls.

A step in the right direction

The winds over the North Sea don’t respect borders and neither do the challenges of building a net zero economy. Reconnecting the UK and EU carbon markets isn’t some bureaucratic indulgence, it’s a rare outbreak of grown-up politics. It lowers costs, raises ambition, and restores a framework that actually works. It may not make front pages or inspire a Nigel Farage boat stunt, but it will quietly shape the future of our energy system far more than any fish quota ever will. None of this is to dismiss the genuine concerns of UK fishing communities, who deserve fair treatment and clarity. But in a political age fuelled by noise, this is progress, quiet, technical, and desperately needed.

illuminem Voices is a democratic space presenting the thoughts and opinions of leading Sustainability & Energy writers, their opinions do not necessarily represent those of illuminem.

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About the author

Christopher Caldwell is the CEO of United Renewables, where he employs his past experiences as a corporate lawyer, investment banker, and team leader to lead all aspects of the business. Chris holds a degree in business from Trinity College Dublin, an MBA from London Business School, and is currently reading part-time at the Yale Center for Business & the Environment. 

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