Guidance

Guidance for General Export Facility exporters

Published 25 March 2022

1. UKEF’s Fossil Fuel Policy

The UK Government has a policy (“HMG Policy”) on aligning UK international support for the clean energy transition, whereby in most cases it will no longer provide support for the fossil fuel energy sector outside the UK.

In line with HMG Policy, UKEF’s Fossil Fuel Policy sees the eligibility of applicants for UKEF’s GEF product (“GEF Exporters”) assessed by reference to the percentage of their total revenue they derive from export sales to the fossil fuel energy sector - the Revenue Threshold Test. As used in this document, “Policy” refers to UKEF’s Fossil Fuel Policy.

1.1 Definition of ‘in scope’ activities of this Policy

For the purpose of this Policy, ‘in scope’ activities and ‘fossil fuel activities’ are defined as: the extraction, production, transportation, refining and marketing of crude oil, natural gas or thermal coal, as well as any fossil-fuel fired power plants except those specifically covered by an exemption listed in the HMG Policy.

Exemptions are grouped into the following categories:

1. Technical assistance and capital support
2. The decommissioning of existing fossil fuel energy assets
3. Gas fired power generation and directly related infrastructure in limited circumstances
4. Stand-alone generators and Liquid Petroleum Gas for cooking and heating in limited circumstances
5. Carbon Capture and Storage (CCS) or Carbon Capture Usage and Storage (CCUS) projects in the gas power sector.

Additional information relevant to each category is provided in Part A of the published HMG Policy.

For clarity, a list of activities which are not deemed to be ‘in scope’ of this Policy is included in Part C of the HMG Policy.

2. The Revenue Threshold Test

All GEF exporters are required to provide UKEF with a figure for the % of their total revenue (if any) which is derived from export sales to customers engaged in activities ‘in scope’ of this Policy. A worked example of this being applied is included in the Annex.

This calculation should be based on the GEF exporter’s most recent set of statutory and/or audited accounts. To do this, they should follow the following steps:

Step A - Determine total revenue from export sales in the most recent set of statutory and/or audited accounts

This calculation may also be used when making the relevant declaration in Paragraph 4 (‘Exporter Eligibility’) of the Exporter Declaration.

Step B - Of the revenue determined in Step A, identify which export sales were to customers engaged in ‘In scope’ activities

‘In scope’ activities are defined above as the extraction, production, transportation, refining and marketing of crude oil, natural gas or thermal coal, as well as any fossil-fuel fired power plants, except those specifically covered by an exemption listed in Part A of the HMG Policy.

Examples of out of scope activities are in Part C of the HMG Policy.

Step C - Determine total revenue

Use the same set of statutory and/or audited accounts used for Steps A and B.

Step D - Take the figure from Step B and divide by the figure from Step C.

This calculation will provide you with the percentage of revenue from export sales to customers engaged in ‘in scope’ activities as calculated pursuant to the Policy (your “Revenue Threshold Test Percentage”).

In the relevant section of the Exporter Declaration, you will be asked to declare whether your Revenue Threshold Test Percentage is 5% or below.

1. If it is below 5% no further information is required.
2. If it is 5% or above, you will be asked to make several additional declarations relating to your business strategy around ‘in scope’ activities and provide UKEF with supporting information relating to your climate change commitments (if available).

3. Annex

Worked example of the Revenue Threshold Test:

Business activity and location of customer	Customer 1 Offshore oil extraction (North Sea, UK)	Customer 2 Offshore oil extraction (overseas, decommissioning)	Customer 3 Offshore oil extraction (overseas, drilling)	Customer 4 Offshore wind installation (overseas)
Is the customer engaged in the fossil fuel energy sector?	Yes	Yes	Yes	No - out of scope of the Policy
Are the goods supplied an export?	No, activity is in UK - out of scope of the Policy	Yes	Yes	Yes
Activities of customer supported by export	Ongoing asset management	Decommissioning	Drilling	Turbine installation
Does the activity fit under an exemption (Part A of the HMG Policy)?	N/A (already deemed out of scope)	Yes – out of scope of the Policy	No	N/A (already deemed out of scope)
Is the revenue from the customer ‘in scope’?	No - customer’s activity is in UK and therefore is not an export sale	No - decommissioning is an exempt activity	Yes	No - customer is not in fossil fuel energy sector
Revenue from these activities	25%	10%	15%	50%

The assessed company’s revenue threshold test figure is 15%. This is because only Customer 3’s activities (overseas offshore oil extraction and drilling) are in scope of the Policy.