These are the investments in new docks, deeper channels and larger cranes, and not the elusion of the European system of exchange of emission quotas (EU ETS), to explain the growth of the container ports of the United Kingdom. It is the thesis of the new report of the British Ports Association (BPA), entitled "Drivers of UK container growth", which contests the reading according to which the European price of carbon would be hijacking traffic from continental ports to British ones. A reading that was proposed in July by the Spanish Observatorio ETS, which attributes the increase of the container traffic on the inter-ceanic routes in the ports of the United Kingdom mainly to a reorganization of the marine services that favors the British ports of continental Europe, with a decisive role, according to the hypothesis formulated by the authors, of the costs linked to the EU ETS system(of 31 July 2026).

The Spanish relationship excludes that the phenomenon is explained simply by an increase of the British demand or by a greater economic efficiency of the ports of the United Kingdom, but admits an effect deriving from the investments in the British harbour infrastructures, mainly with interventions of dredging and modernization of the cranes to Felixstowe, London Gateway and Southampton, aimed at improving the ability to accommodate the portacontainer of greater size, even if it considers them a structural factor that facilitates the strengthening of the British ports intercontinental only as direct ports of the

The British Ports Association considers that the analysis of the Spanish Observatory, according to which the increase of the British quota in the container activities of Northern Europe would be index of "carbon leakage", has influenced the policies of the European Union. Or, at least, so it is deducted from the communiqué with which the British harbour association has introduced its own study, in which it is affirmed that "at the beginning of this year the EU has proposed measures against the container ports of the United Kingdom, starting from the idea that the ETS is moving containerized marine traffic from the continent to Britain. This - says the BPA - rests on the reports of the Observatory on the EU ETS of the Spanish government".

It is difficult to say why the BPA considers that the EU intends to "punish" the British ports, since if the ports of the United Kingdom have certainly been brought into play in the course of comparisons between the politicians of the Union regarding the impact of the ETS on the marine transport, until now the European Union has not officially predicted provisions on the carbon leakage involving the British ports. Perhaps the reference of the British Ports Association is to the revision of the EU ETS system proposed last July by the European Commission that tightens the anti-elusion rules for the ports of transhipment not EU, in order to prevent the operators to reduce the exposure to the ETS with a stop in a near port extra-EU(of 17 July 2026).

Referring to the analysis of the Observatorio ETS, the study of the BPA recalls that the Spanish observatory is an initiative of Puertos del Estado, the national state agency of the ports, born in June 2025 to analyze and preview possible losses of traffic of the Spanish ports tied to the marine ETS and to support the government of Madrid in front of the European Commission. "The Observatory - it is observed in the British study - must therefore be understood as a policy-oriented monitoring initiative, born in response to an already existing concern regarding the competitiveness of European ports, and in particular of Spanish ports. This does not invalidate the data produced by it; means, however, that the changes observed and the explanations subsequently provided on such changes must be considered separately.'

The study of the BPA, therefore, argues that the reading of the data collected by the Spanish Observatory is not granted and the explanations that it provides on the changes of the routes of the ships found. According to the British study, the first critical point concerns the metric, as the "market rate" of the Spanish Observatory is measured in teu-mill, that is the nominal capacity of the ships multiplied by the distance traveled. It does not indicate the container enlivened from a port, the goods imported or exported, or the filling rate of the ships. The study notes that the value is very sensitive to the order of the steps. If a ship Asia-North Europe touches both Rotterdam and Felixstowe, the long intercontinental section is attributed to the first touched port. Inverting the two steps, the "transport work" attributed to the United Kingdom can climb a lot even if the ship makes the same ports and loads change little. The study highlights that the deviations of the routes around the Cape of Good Hope, traveled to avoid transit in the Red Sea where the ships are subject to attacks, amplify the effect, because they stretch the journey.

The BPA study points out that physical data does not show an equal transfer. According to the statistics of the British Department of Transport - remembers the study - in 2025 the British container traffic has grown of +10% in tons (6,2 million more) and of +11% in units (about 0.6 million). But the ports of Rotterdam, Antwerp-Bruges, Hamburg and Haropa/Le Havre have enlivened all more container than in 2024. British growth is also concentrated: 5,4 million tons on the 6,2 totals, and about 0.5 million units on 0,6, are attributable to London, where the Department connects the increase to the new capacity of the port terminal London Gateway. This - note the study of BPA - is not the trend that would be expected more naturally from an advantage deriving from valid regulations for the entire UK. The vast majority of growth at national level - it is observed - it is concentrated in the port area of London, where a new, substantial capacity for the container had just become available. The document recalls that the construction of the fourth dock of the London Gateway terminal was started in October 2022 and the work became operational in November 2024, increasing the capacity of the London port of more than a third. Moreover, in October 2023 the port of Felixstowe has completed the deepening of the channel of access (from -14,5 to -16 meters) and the docks 8 and 9 (from -16 to -18 meters) to accommodate the largest portacontainer ships. The study then emphasizes that the field of marine transport has entered the ETS on January 1, 2024 and evidences that the British are long-term harbour investments, conceived before this European norm.

The study also examines the reorganization of the network of routes of the line companies, remembering that in 2025 the Gemini Cooperation cooperation between the companies Maersk and Hapag-Lloyd, the autonomous network of MSC and the Premier Alliance. Gemini chose London Gateway as a British port for Asia-Europe services, defined by Maersk as the most "optimal" to reduce the complexity of the network and improve reliability, coverage and speed. The British study specifies that even congestion and difficult operating conditions in continental European ports have had an impact: in May 2025 Maersk has removed the port of Rotterdam from the TA5 transatlantic service for operating constraints in the terminals, maintaining Felixstowe, Hamburg and Antwerp. In the same month he moved the British port of call from London Gateway to Felixstowe for the London operating situation: an example - BPA observes - how smooth the choices of carriers and how the picture is not a simple United Kingdom-EU contrast.

The British study then notes that the connectivity of the EU ports has not collapsed and precise that if the British Oceanic ports have increased, however the same analysis of the Spanish Observatory does not detect a significant decline of the touched in the EU ports of Northern Europe. Rotterdam registered 46 ocean ports per week in 2023, 45 in 2024 and 47 in 2025; the number of its first European ports was 30, 29 and 30 respectively, while the last steps were 9 to 11. The number of ports of call has descended from 8.811 to 8.530, but the average size of the ports of call has climbed from 4.145 to 4.675 teu and the total traffic has grown.

The study of the BPA also refers to the first report of the European Commission on the monitoring of the effects of the marine ETF, relative to the first three quarters of 2024, which was published last year(of 19 March 2025), observing that it has not detected any significant increase of the ports of call in the British before or after those EU and no general evidence of changes of the order of the ports of call to circumvent the ETS. The Commission - the study - it has found an increase on the U.S.-EU routes with intermediate port in the United Kingdom (from 30% of 2023 to 34% of 2024), but without identifying a systematic scheme, and has attributed the main changes of course especially to the crisis of the Red Sea.

The report therefore notes that the same consultation carried out by the UK ETS Authority recognizes a possible marginal effect, with some additional British ports designed to reduce exposure to the EU ETS, but indicates limited evidence of route changes to evade coverage. The study also adds that the effects of the carbon price difference on maritime routes are transient, as emissions of national maritime transport entered the UK ETS in July 2026 and the authority proposed to include 50% of international travel emissions from 2028, in line with the EU approach.

Commenting on the results of the study, the director for BPA's policies and external affairs, Mark Simmonds, recalled that "the British ports have invested hundreds of millions of pounds to attract more ships and move more goods", and emphasized that "the investments are giving fruits and make the United Kingdom more competitive. It would be extraordinary - he said - if the EU responded to this success by introducing measures to penalize the British ports. From all available evidence, including the evaluations and data of the same EU, it emerges that the increase in volumes in the ports of the United Kingdom coincides with the entry into service of new capacity". Specifying that the BPA supports the efforts to reduce the emissions of the marine transport, Simmonds has concluded that "the climate policy must be based on solid evidence, not on hypotheses that could damage competition and investments".

The British Ports Association, highlighting that there is the risk of exchange of normal competition between ports for normative elusion, has therefore invited both the British government and the European Commission to review the tests before adopting measures that could damage the competitiveness of the ports on both sides of the Channel.