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Logistics·Oct 20, 2026·5 min read

ETS2 starts in 2027, and the postponement route closed in July

The directive that created ETS2 carried its own escape hatch: a one-year delay to 2028 if energy prices ran hot. The Commission tested that condition on 15 July 2026 and published the answer in one sentence. Here is what is now fixed, and what still is not.

Most writing about ETS2 still hedges the start date, and until this summer that was the careful thing to do. Chapter IVa of Directive 2003/87/EC, which brings fuel for buildings and road transport into emissions trading, was written with its own escape hatch. If energy prices ran hot enough, the whole scheme slipped a year. That condition has now been tested, and the result is a single sentence in the Official Journal.

The escape hatch, and the sentence that closed it

Article 30k is titled, in full, postponement of emissions trading for buildings, road transport and additional sectors until 2028 in the event of exceptionally high energy prices. It set two tests, either of which was enough to trigger the delay: the average TTF gas price over the six months to 30 June 2026 exceeding the average for February and March 2022, or the average Brent price over those same six months running at more than twice the average of the preceding five years.

The Commission had to publish its finding by 15 July 2026, and it did, on that date. The notice runs to one operative line: neither of the two conditions under Article 30k(1) has been met. No delay. Everything in Chapter IVa keeps the dates it was given.

What that fixes, and what it does not

The year is now settled. Article 30d(2) says auctioning starts in 2027, the one route to moving that was Article 30k, and that route is closed. Anyone still describing 2027 as provisional is working from a summary written before the middle of July.

The month is a different matter, and the distinction is worth keeping. The directive says auctioning shall start in 2027 and names no month. Where you see January 2027, that comes from a national implementing body rather than from the directive, and it remains a plan. So the year is firm and the month is not, which is the opposite of how most coverage treats it.

Three dates, and the first one is already behind you

  • 1 January 2025: no regulated entity may carry out the activity in Annex III without a greenhouse gas emissions permit from a competent authority. That deadline passed almost two years ago.
  • 2027: allowances for this chapter are auctioned, separately from the existing ETS, against a Union-wide cap that falls by a linear reduction factor of 5.10 per cent a year.
  • 1 January 2028: Member States must ensure that each regulated entity surrenders allowances by 31 May every year, covering the previous calendar year's emissions.

Read in order, those three show how little slack is left. The permit requirement is historic. The first auction is next year. And the first surrender falls on 31 May 2028, covering emissions in 2027, because Article 30e(2) runs on the preceding calendar year. Had the postponement been triggered, Article 30k(2)(d) would have moved that first surrender to 31 May 2029 for emissions in 2028. It was not triggered, so the earlier pair of dates is the one that applies.

The first two years are governed differently

Two provisions apply only at the start, and both of them soften it. Article 30d(2) opens the auction in 2027 at 130 per cent of that year's volume, with the extra 30 per cent reserved for the surrender obligation rather than added to the cap. And Article 30h releases 50 million allowances from the market stability reserve when the average allowance price over more than three consecutive months exceeds twice the average of the six months before it. For 2027 and 2028 that trigger sits at 1.5 times instead of twice.

A description that mentions only the doubling threshold is describing the regime from 2029 onward. In the first two years the intervention fires sooner.

The obligation sits with the fuel supplier

Chapter IVa regulates the entity that releases fuel for consumption, not the household or the fleet that burns it. Article 30b requires that entity to hold a permit describing the fuels it releases and their end uses, and Article 30a keeps the chapter clear of anything already covered by the existing ETS, so the same tonne is not counted twice. What reaches a customer reaches them through a supplier's tariff, and the directive does not regulate when or how much of it is passed on.

What I am not claiming here

There is no cost per litre, per cubic metre or per kilowatt-hour in this piece, because none exists to quote: no auction has been held and no rule requires a supplier to pass anything through. Nor is any figure per unit you see elsewhere more than an extrapolation. I have not verified penalties or enforcement consequences, and nothing here is legal advice. Nor have I checked twenty-seven national implementations: the dates above are the EU layer, and Member States may also extend the activity to further sectors from 2027 under Article 30j. For a particular company in a particular country, the national implementing act is what decides.

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