EU ETS verification for aviation emissions

Frequently asked questions about EU ETS verification for aviation emissions

When are aviation operators covered by EU ETS?

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).

What is the difference between full scope and limited scope?

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.

Which flights are covered by the limited scope of EU ETS?

- 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

Are there exceptions to EU ETS for aviation?

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.

What are small emitters?

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.

Can alternative fuels reduce emissions within the EU ETS?

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).

How does the EU ETS system for aviation work?

The EU-ETS operates under a cap-and-trade system. This means that a cap is set on the total emissions from the aviation sector.

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

- Starting in 2013, this was reduced to 95% of that baseline level.

Within this cap, airlines receive emission allowances:

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

- 15% of the emission allowances are auctioned through the emissions trading system.

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

More information can be found here: EU ETS Aviation - Phase-out Schedule and Trading Periods

Which airlines and flights are covered by the EU-ETS?

The 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:

- Fewer than 243 flights per period over three consecutive four-month periods, or

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

Exemption for non-commercial airlines:

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

What are simplified procedures for small emitters?

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

They may use simplified monitoring methods, such as:

- The tool for small emitters

- Eurocontrol’s ETS support facility.

This makes it easier to calculate and report emissions.

Which flights are excluded from the EU ETS?

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

- Flights operated by aircraft with a maximum takeoff weight (MTOW) of less than 5,700 kg

- Military flights

- Search and rescue operations

- Firefighting flights

- Humanitarian and medical emergency flights

- Training flights

- Scientific research flights

- Test or certification flights for aircraft or equipment

- Certain flights performed under public service obligations (PSO)

How are CO₂ emissions from airplanes calculated?

CO₂ emissions from 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

Aviation 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 Method A or Method B, depending on whether fuel consumption is measured before or after the flight.

What is a monitoring plan under the EU ETS?

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

This plan includes, among other things,

- Measurement methods for CO₂ emissions.

- Data flows and reporting procedures

- Quality controls

- Risk analysis for data processing.

The monitoring plan must be approved by the competent authority.

Can a monitoring plan be updated?

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

- new activities or fuels are introduced

- the measuring instruments change

- the accuracy of the data can be improved

- recommendations from a verification report are implemented

Changes must always be approved by the competent authority.

What is the EU Registry?

The EU Registry is an online platform operated by the European Commission for managing emission allowances.

Among other things, the system records

- operators’ emission allowances

- Verified annual emissions

- the trading and transfer of emission allowances

- the surrender of emission allowances

Every aviation operator must have a registry account to manage emission allowances.

What happens if an operator is a small emitter?

Operators that fall below the threshold for small issuers may use simplified monitoring and verification.

Many operators of business aircraft and jet aircraft fall into this category.

Normec Verifavia offers a simplified verification procedure for this purpose, which can often be carried out entirely remotely.

What is the geographic scope of the EU ETS?

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

The EEA countries include:

- the 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.

How should emission allowances be surrendered?

Operators must surrender their emission allowances annually through the EU Registry.

Important deadlines:

- March 31: submission of the annual emissions report.

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

Each metric ton of CO₂ emissions corresponds to one emission allowance.