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UK Carbon Border Adjustment Mechanism: how it will impact key sectors and what we can do to help
21 February 2025

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The transport sector remains the highest emitting sector in the UK and is coming under increasing pressure to transition to decarbonised solutions. Significant progress has been made in recent years, with London now boasting the largest zero-emission bus fleet (ZEB) in western Europe, but the majority of the transport sector’s emissions still come from road vehicles.
ZEB fleets in the UK predominantly consist of battery electric buses which are charged at depots through mains electricity, with a small number of hydrogen fuel cell buses also in operation – as of October this year, London has almost 1,700 ZEBs of which just 20 are powered by hydrogen.
Unlike the zero emission vehicle mandate applying to cars and vans, there is currently no specific regulatory imperative to end the sale of new diesel buses (although this will be a crucial part of the general net zero targets and limits on emissions), leaving the transition to be driven forward by bus operators – many of whom have already set ambitious net zero goals and are actively investing in cleaner technologies.
As well meeting net zero targets, the roll-out of ZEBs can help transport operators to deliver their wider environmental, social and governance (ESG) objectives.
ESG objectives are critical because they demonstrate to investors, customers and the public that a business is operating with regard for the planet and the communities in which they operate. ESG has become increasingly important to UK business, as conscious investors now use ESG to screen potential investments. As a number of UK bus operators rely on private finance (including to fund the roll-out of new ZEB fleets and associated infrastructure upgrades), appealing to investors remains vital to the success of bus operators and the use of buses as a sustainable form of local transport. Our client, and ZEB lessor, Rock Rail was recently ranked number one for ESG performance across all sectors by GRESB – demonstrating the importance of such measures to investors in the sector.
The ESG impacts of ZEBs are wide-ranging, including:
At Burges Salmon, we recognise the impact of ESG on organisations and provide comprehensive advice on all aspects of the ESG agenda, offering both strategic and operational support.
The journey to net zero has already begun, but it is clear that it will not always be an “easy ride”. We work with clients in the bus sector who are looking to find innovative solutions to challenges including the following:
The transition to zero emission buses is not just a technological upgrade but a strategic move towards sustainable and responsible public transport. By continuing to invest in ZEBs and sustainable charging solutions, transport operators can significantly reduce their road-emission related carbon footprints, as well as aligning with broader ESG goals.
At Burges Salmon, we are well equipped to support the shift towards sustainable transport, including the transition to ZEBs, energy supply arrangements and broader ESG considerations. With our market leading and cross sector expertise, as highlighted in this article, we work with our clients to support them in achieving their net zero goals and ESG ambitions.
For further information or advice related to any of the topics discussed, please contact Chris Simms, Chris Lewis, Charlotte Robinson or your usual Burges Salmon contact.
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