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EU ETS verification for aviation emissions

• Comply with EU ETS obligations for aviation through independent verification of emissions reports
• Ensure reliable emissions data and avoid compliance risks within European emissions trading

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Emissions trading within the European aviation sector

The European Union Emissions Trading System (EU ETS) is an emissions trading system introduced in 2005 through Directive 2003/87/EC to reduce greenhouse gas emissions. Since 2012, the aviation sector has also been covered by this system, based on Directive 2008/101/EC. 

Within EU ETS, airlines must monitor, report and annually surrender emission allowances corresponding to their emissions. These obligations are supervised by national Competent Authorities. 

Initially, EU ETS applied to flights to and from the European Economic Area (EEA). Due to the introduction of CORSIA, the international system for emissions reduction in aviation, the scope has been adjusted to a “reduced scope”. 

The latest official templates, along with guidance documents, are available through the European Commission’s EU ETS website. 

Our approach

Normec Verifavia supports airlines in meeting EU ETS obligations through independent verification of emissions reports. 

Our approach includes, among other things:

  1. 1.

    Verification of Annual Emissions Reports

  2. 2.

    Assessment of monitoring methodologies

  3. 3.

    Review of fuel consumption and flight data

  4. 4.

    Verification of alternative fuels and emissions reductions

Our verification processes follow international standards such as:

  1. 1.

    ISO 17029:2019

  2. 2.

    ISO 14065:2020

This ensures transparent and reliable verification of emissions data. 

The benefits of EU ETS verification for aviation operators

Correct verification of emissions data helps airlines comply with regulations and report transparently. 

  • You avoid fines and compliance risks through timely and correct verification  
  • You comply with EU ETS reporting obligations for aviation emissions  
  • You increase transparency towards regulators and stakeholders  
  • You strengthen the reliability of emissions data within your organization  
  • You build trust with regulators, partners and investors  

Normec Verifavia's expertise in aviation verification

Normec Verifavia has more than 10 years of experience in validation, verification and auditing within the aviation sector. 

Our aviation experts have extensive knowledge of: 

  • EU ETS regulations for aviation  
  • Emissions calculations and fuel monitoring  
  • International climate regulations such as CORSIA  
  • Monitoring and reporting requirements for operators  

Thanks to this expertise, we can support aviation organizations with reliable and efficient emissions reportig . 

Future emissions regulations in aviation

The aviation sector plays an important role in global climate goals. EU ETS is an essential instrument to reduce emissions and increase transparency. 

Aviation operators must, among other things: 

  • Submit their Annual Emissions Report to the competent authority before 31 March  
  • Surrender sufficient emission allowances before 30 September  
  • Submit an Improvement Report before 30 June when verification findings require this  

By investing in reliable monitoring and verification in time, you ensure that your organization is prepared for future climate and aviation regulations.

Would you like to know more about EU ETS?

Frequently asked questions

Aviation operators are covered by EU ETS when they operate more than 243 flights per period for three consecutive four-month periods, or when their annual emissions exceed 10,000 tCO₂ (for commercial operators).

Full scope includes flights to and from EEA countries. The current limited scope limits reporting to specific flights within and around the EEA, in part due to the introduction of CORSIA.

- The limited scope includes

- Flights within the EEA.

- Flights between EEA countries and Switzerland or the UK

- Flights between outermost regions (OMRs)

- Flights between an OMR and another EEA state

Yes. Among others, military flights, search and rescue operations, emergency medical flights, training flights and flights with aircraft of less than 5,700 kg maximum take-off mass can be exempted.

Operators with fewer than 243 flights per period for three consecutive four-month periods or fewer than 25,000 tCO₂ per year may be considered small emitters and may use simplified reporting methods.

Yes. Aviation operators can claim emission reductions if they use sustainable alternative fuels, provided they meet the sustainability criteria of Directive 2008/101/EC and are supported by proof of sustainability (PoS).

EU ETS works according to a cap-and-trade system. This means that a ceiling ("cap") is set on total emissions from the aviation sector.

- In 2012, the emissions cap was set at 97% of average emissions between 2004 and 2006.

- From 2013, this was lowered to 95% of that reference level.

Within this cap, airlines receive emission allowances:

- 85% of allowances were originally allocated for free based on historical load data (2010).

- 15% of allowances are auctioned through emissions trading.

If an operator emits more than its allocated allowances, it must buy additional allowances on the market.

More information can be found here: EU ETS Aviation - Exit situation and trading periods

EU ETS applies to all airlines operating flights to, from or within the European Economic Area (EEA).

However, some operators fall under the "de minimis" rule and are therefore exempt.

Exemption for commercial operators:

- Less than 243 flights per period for three consecutive four-month periods, or

- Less than 10,000 tons of CO₂ per year.

Exemption for non-commercial operators:

- Less than 1,000 tons of CO₂ per year.

Operators emitting less than 25,000 tons of CO₂ per year (full scope) are considered small emitters.

They can use simplified monitoring methods, such as:

- The small emitters tool

- Eurocontrol's ETS support facility.

This allows for easier calculation and reporting of emissions.

A number of flight categories are excluded from the EU ETS, including:

- Flights with aircraft of less than 5,700 kg maximum take-off weight (MTOW)

- Military flights

- Search and rescue operations

- Firefighting flights

- Humanitarian and emergency medical flights

- Training flights

- Scientific research flights

- Test or certification flights for aircraft or equipment

- Certain public service obligation (PSO) flights

CO₂ emissions in aviation are calculated based on fuel consumption.

The basic formula is

Emissions = fuel consumption × emission factor.

Examples of emission factors:

Fuel Emission Factor

Aviation gasoline (AvGas) 3.10 tCO₂/t fuel

Jet gasoline (Jet B) 3.10 tCO₂/t fuel

Jet kerosene (Jet A / 3.16 tCO₂/t fuel

Jet A1)

Fuel consumption can be calculated using either Method A or Method B, depending on how fuel consumption is measured before or after the flight.

A monitoring plan describes how an aircraft operator monitors and reports its emissions.

This plan includes, among other things

- Monitoring methodologies for CO₂ emissions.

- Data flows and reporting procedures

- Quality checks

- Risk analysis for data processing.

The monitoring plan must be approved by the competent authority.

Yes. A monitoring plan should be updated when, for example

- New activities or fuels are introduced

- Measuring instruments change

- Data accuracy can be improved

- Recommendations from a verification report are acted upon

Changes must always be approved by the competent authority.

The Union Registry is an online platform of the European Commission where emission allowances are managed.

Among other things, the system records

- Operators' allowances

- Verified annual emissions

- Trading and transfer of allowances

- The surrender of allowances

Each aviation operator must have a registry account to manage allowances.

Operators who fall below the small issuer threshold can use simplified monitoring and verification.

Many business jet and jet aircraft operators fall within this category.

Normec Verifavia offers a simplified verification procedure for this purpose that can often be done completely remotely.

EU ETS for aviation covers flights within the European Economic Area (EEA).

EEA countries include.

- Netherlands

- Germany

- France

- Spain

- Italy

- Sweden

- Norway

- Iceland

- Liechtenstein

In addition, flights to Switzerland and the United Kingdom may also be subject to reporting requirements.

Operators must surrender their allowances annually through the EU registry.

Important deadlines:

- March 31: submission of the annual emissions report.

- April 30: surrender of allowances corresponding to verified emissions.

Each 1 ton of CO₂ emissions corresponds to one allowance.