European Union Emissions Trading System (EU ETS)

Find answers to the most commonly asked questions

How does ETS work for aviation?

In 2012, the EU-wide cap on aviation emissions was set at 97% of average annual emissions for the years 2004-2006. In 2013-2023, the cap was lowered to 95%.

The first trading period is the year 2012 and the second is the period 2013-2020 (initially, but now extended to 2023).
85% of the emissions cap is given free to airlines based on reported 2010 payload.

15% of the emissions cap is available through auction, while additional allowances to cover growth must be purchased from other sectors (open trade).

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

Which airlines/flights are concerned?

ETS for aviation covers all aircraft operators, regardless of origin, operating flights to, from and within the EEA.

Commercial operators below the threshold ("De Minimis" rule) are excluded from ETS. This includes commercial operators that have

- Less than 243 flights per three consecutive four-month periods (i.e. less than an average of one return flight to/from the EU per day),

- Or flights with total annual emissions of less than 10,000 tCO2 per year.

Non-commercial operators with total annual emissions of less than 1,000 tCO2 per year ("De Minimis" rule) are excluded from ETS.

Simplified procedures.

Non-commercial and commercial operators emitting less than 25,000 tCO2 (full scope) per year are also considered small emitters and can use simplified monitoring procedures.

Non-commercial operators with less than 243 flights per period for 3 consecutive 4-month periods (full scope) and commercial operators emitting less than 3,000 tCO2 (limited scope) can use simplified monitoring procedures.

Exemptions

Some flights are excluded from the scheme:

- Flights operated by aircraft with a maximum take-off weight (MTOW) of less than 5.7 tons

- Flights carrying non-EU heads of state, sovereigns and ministers

- Military flights

- Search and rescue flights, firefighting flights, humanitarian flights and emergency medical flights

- VFR flights (visual flight rules)

- Circular flights

- Training flights

- Flights conducted solely for the purpose of scientific research

- Flights for the purpose of checking, testing or certifying aircraft or equipment

- Public Service Obligations (PSO routes) within outermost regions or on PSO routes where the capacity offered does not exceed 30,000 seats per year.

Note that:

- Flights to/from and within Norway, Liechtenstein and Iceland are covered.

- Flights from the EEA to Switzerland are provisionally covered.

- Flights from the EEA to the United Kingdom.

- Each operator is assigned to an administering Member State.

How do you comply with ETS?

Operators under the European Union Emissions Trading Scheme (EU ETS) have each been assigned a Competent Authority (CA) to whom they must report. These operators have specific obligations:

- Registry account: Operators must open a registry account for issues related to EU allowances.

- Emissions monitoring and reporting: Operators must monitor and report their annual CO2 emissions. This includes collecting emissions data and preparing an annual emissions report (AER).

- Verification process: Operators must engage with a verifier, an independent party, to confirm the accuracy of their emissions data and AER.

- Reporting deadline: The AER and verifier's opinion must be submitted to the competent authority by March 31 of the year following the monitoring period (N+1).

- Deadline for surrendering allowances: Operators must surrender their allowances by April 30 of the year following the monitoring period (N+1).

How are CO₂ emissions from aircraft calculated?

CO2 emissions from aircraft are an exact multiple of fuel consumption.

To calculate fuel consumption, there are two different approaches for aviation (Method A and Method B).

CO2 emissions are then calculated by multiplying the mass of fuel by the emission factor:

EMISSIONS = fuel consumption (in tons) × emission factor (in kilograms of CO2 per ton of fuel)

Fuel type & emission factor (tCO₂/fuel)

1. Aviation gasoline (AvGas) - 3.10

2. Aviation gasoline (Jet B) - 3.10

3. Jet kerosene (Jet A1 or Jet A) - 3.16

How should spent fuel be evaluated?

Airlines have a choice between two methods of monitoring fuel consumption.

Airlines must track fuel consumption for each flight, including fuel consumed by the APU.

Method A includes post-flight APU fuel, while Method B includes pre-flight APU fuel.

One method should be chosen for each aircraft type and applied consistently.

Fuel consumed in flight N: C - F + E (method A) or A + B - D (method B)

Possible sources of fuel uplift and fuel in tanks:

1. Onboard measurement system

2. Fuel supplier

3. Mass & balance

4. Engineering journal

Possible sources for fuel density

1. On-board measurement systems

2. Fuel supplier information.

3. Density-temperature table

4. Standard 0.8 kg/liter

What is the uncertainty assessment?

Uncertainty assessment is an integral part of the monitoring and reporting guidelines.

Airlines are required to monitor tonne-kilometer data and fuel consumption over an annual reporting period with a maximum uncertainty of 2.5% for Tier 2 or 5% for Tier 1 operators.

Airlines must understand and identify the possible causes of monitoring uncertainty.

Airlines should take all necessary measures to avoid missing data by performing appropriate quality control activities.

* Calibration certificates of on-board systems, national legislation, fuel supplier accuracy standards, clauses in customer contracts, routine checks.

What is the verification process?

Operators must have their reported emissions data and annual emissions report (AER) verified by an independent third party called a verifier or verification body.

Verifiers of greenhouse gas emissions under the EU ETS Directive must be accredited under the ISO 17029 standard and be a legal entity accredited by a National Accreditation Body (NAB) under the requirements of the AVR.

Verifiers check the accuracy of emissions data, calculations and AER to ensure compliance with EU ETS regulations. The verifier's opinion statement is submitted to the CA, which improves the transparency and reliability of emissions reporting.
The purpose of verification is to arrive at a verification opinion with reasonable certainty whether:

- The data in the annual emissions or tonne-kilometer reports are fairly presented, i.e. free of material misstatements,

- the procedures in place are consistent with the approved monitoring plans, the MRR and national legislation of the administering Member State.

The verification process consists of a strategic analysis, a risk analysis, a verification plan, process and data verification (on-site if necessary), an internal verification report to be reviewed by a technical reviewer, and a final verification report containing the verification opinion. The entire verification process must follow the verifier's approved procedures.

What is the monitoring plan to be submitted to the competent authority?

What must be included in the monitoring plan?

The monitoring plan should document monitoring procedures for aircraft, flights, CO2 emissions, risk assessment, data flows and control activities.

Must the procedures in the monitoring plan be implemented?

Yes, all procedures described in the monitoring plan must both comply with MRR requirements and be effectively implemented by the operator.

Can the monitoring plan be modified?

Yes, all changes to the monitoring plan must be communicated to and approved by the competent authority (CA).

Are standardized or simplified monitoring plans allowed?

Member States have the authority to allow aircraft operators to use standardized or simplified monitoring plans at their discretion.

In what situations should the monitoring plan be reviewed?

The monitoring plan should be updated when:

1. New emissions arise from new activities or fuels.

2. Data availability changes due to new monitoring instruments.

3. Data from previous methods are inaccurate.

4. Changes improve the accuracy of reported data.

5. The plan does not meet MRR requirements.

6. Suggestions from verification reports are addressed.

Are templates available for creating monitoring plans?

Yes, the European Commission provides templates for monitoring plans.
In addition, some member states may offer customized versions or electronic reporting systems.

Does the updated monitoring plan need to be verified?

No, the updated monitoring plan does NOT need to be verified. It must be submitted to the competent authority for approval. It is better to address questions about this new requirement directly to the competent authority.

How many free emission allowances are allocated to each operator?

As EU ETS is a Cap and Trade scheme, the first allocations were made in 2012. The European Commission has published the benchmark values used to allocate free greenhouse gas emission allowances to more than 900 aircraft operators.

The publication of the benchmark values allows operators to calculate their free allocation of allowances until 2020. Two benchmarks were initially established: one benchmark was calculated for the 2012 trading period and another for the 2013-2020 trading period. In the 4th phase of EUETS from 2021, a linear reduction factor of 2.1% is applied. Free allowances are systematically phased out from 2024 to 2026.

" Go to the EC (European Commission) website.

What is a registry account and how do I open one?

The Union Registry is an online database hosted and operated by the European Commission. It works similarly to an Internet bank account and records allocations of allowances to aircraft operators, annual verified emissions, and the transaction history of allowance transfers and surrenders.

All aircraft operators must open a registry account with the EU registry to comply with the EU ETS, as allowances corresponding to annual emissions must be surrendered through the registry each year by April 30 of the following year.

What is the Union Registry?

The Union Registry is an online database hosted and operated by the European Commission. It works similarly to an Internet bank account and records allocations of allowances for aircraft operators, annual verified emissions and the transaction history of transfers and surrenders of allowances.

" Go to European Commission ETS Registry

What are the consequences if a small emitter is considered?

Operators emitting less than 25,000 tCO2 per year or operating less than 243 flights per period for three consecutive 4-month periods are considered small emitters. Most operators of business aircraft and business flights are small emitters.

Small emitters can use the normal procedure to verify fuel consumption (method A or B) or the simplified procedure (the small emitters tool or Eurocontrol's ETS Support Facility ).

Normec Verifavia has developed a highly simplified verification method for small emitters using the simplified procedure, conducted remotely via e-mail. Normec Verifavia's verification service includes full guidance and compliance support.

At the start of the EUETS, between 2010 and 2013, Normec Verifavia verified about 700 small emitters from 60 countries reporting to 24 different competent authorities in the EU. 65% of these small emitters are flight departments of large U.S. companies.

The latest version of the small emitters tool is used each year to report emissions from flights. The small emitters tool is available free online for small emitters and any operator with missing data.

What is the geographical scope of the EU ETS under stop the clock?

Geographical scope of Annex 1 flights

EU ETS full scope:
All flights to/from EEA Member Countries (including all flights to/from territories of EEA Member Countries and all flights to/from EEA outermost regions).

EEA Member States:

Austria (AT), Belgium (BE), Bulgaria (BG), Croatia (HR), Cyprus (CY), Czechia (CZ), Denmark (DK), Estonia (EE), Finland (FI), France (FR), Germany (DE), Greece (EL), Hungary (HU), Ireland (IE), Italy (IT), Latvia (LV), Lithuania (LT), Luxembourg (LU), Malta (MT), Netherlands (NL), Poland (PL), Portugal (PT), Romania (RO), Slovakia (SK), Slovenia (SI), Spain (ES), Sweden (SE), Norway (NO), Iceland (IS), Liechtenstein (LI).

Territories of EEA Member Countries:

Melilla (ES), Ceuta (ES), Åland Islands (FI), Jan Mayen (NO).

Outermost regions of the EEA Member Countries:

Canary Islands (ES), French Guiana (FR), Guadeloupe (FR), Martinique (FR), Mayotte (FR), Reunion (FR), Saint Martin (FR), Azores (PT), Madeira (PT).

Geographical scope of 'intra-European' Annex 1 flights.

EU ETS reduced scope:

1. all flights between EEA Member Countries (and territories of EEA Member Countries),

2. all flights within the same outermost region,

3. all flights between EEA Member Countries and offshore installations of EEA Member Countries that are outside territorial waters (e.g., oil and gas production or exploration platforms),

4. all flights from EEA Member Countries to Switzerland, and (5) all flights from EEA Member Countries to the United Kingdom.

How to surrender carbon allowances?

Registry - Open & Operate

Aircraft operators must have an account open with the Union Registry in order to be able to comply with the EU ETS.

The Union Registry is an online database hosted and managed by the European Commission. It operates in a similar way to an internet bank account, and records allowance allocations for aircraft operators, annual verified emissions, transaction history of allowance transfers and surrenders of allowances.

Click here for more information about the Union registry

Registry - Propose

If you report to Austria, Croatia, Denmark, Finland, Germany, Hungary, Iceland, Ireland, Italy, Lithuania, Luxembourg, Malta, Netherlands, Norway, Portugal, Romania, and Sweden, it is your responsibility to enter (to 'propose') your emissions in the Union Registry. In order to do so, you need to appoint Verifavia as your verifier. As soon as you have proposed your emissions, please send me an email so that I can validate your entry through the Union Registry account of Normec Verifavia.

Click here to go to the Registry website

Click here to access the user guide

If you report to any other Member State, it is either you or the national registry administrator who enters your emissions. Verifavia is not involved in this process. Please contact your Competent Authority if you have any doubts about what you have to do.

Registry - Surrender carbon allowances

By 30 April, you must log on to your account and surrender the number of allowances that correspond to your verified and validated annual emissions figure. 1 tonne of CO2 emissions corresponds to 1 allowance.

You must do this through your Union Registry account before 30 April N+1. Please note that this deadline is a 'hard' deadline, meaning that access to the Union Registry is expected to be blocked starting from 1 May.

What is the exact geographical scope of the latest EU ETS regulation?

The new EU ETS regulation restricts EU ETS to intra-European flights for the period 2013-2030 and exempts small emitters below 1,000 tCO2 for the period 2013-2030.

This means that only flights operated between airports located in the European Economic Area (EEA) must be reported. Extra-European flights (flights between the EEA and third countries, and vice-versa) do not have to be reported.

List of EEA Member States

Austria (AT), Belgium (BE), Bulgaria (BG), Croatia (HR), Cyprus (CY), Czechia (CZ), Denmark (DK), Estonia (EE), Finland (FI), France (FR), Germany (DE), Greece (EL), Hungary (HU), Ireland (IE), Italy (IT), Latvia (LV), Lithuania (LT), Luxembourg (LU), Malta (MT), Netherlands (NL), Poland (PL), Portugal (PT), Romania (RO), Slovakia (SK), Slovenia (SI), Spain (ES), Sweden (SE), Norway (NO), Iceland (IS), Liechtenstein (LI).

List of European territories also included in the EEA: Melilla (ES), Ceuta (ES), Åland Islands (FI), Jan Mayen (NO).

Flights between any aerodromes located in the EEA and offshore installations located outside territorial waters, such as oil and gas production or exploration platforms, also remain fully covered under the EU ETS.

Note that Basle-Mulhouse (LFSB) is considered to be in France.

EEA outermost regions

Although they are part of the EEA, flights between the EEA outermost regions and any other EEA area or third countries are fully excluded from the scheme.

The EEA outermost regions are Canary Islands (ES), French Guiana (FR), Guadeloupe (FR), Martinique (FR), Mayotte (FR), Reunion (FR), Saint Martin (FR), Azores (PT), Madeira (PT).

Important note: Flights operated within the same EEA outermost region must still be reported.

Indicative list of airports in the EEA outermost regions:

- Azores: LPAZ, LPCR, LPFL, LPGR, LPHR, LPPD, LPPI, LPPO, LPSC, LPSJ

- Canary Islands: GCCC, GCFV, GCGC, GCGM, GCHI, GCLA, GCLB, GCLP, GCMP, GCRR, GCTS, GCXO

- French Guiana: SOCA, SOGS, SOOO

- Guadeloupe: TFFR

- Madeira: LPMA, LPPS

- Martinique: TFFF

- Reunion: FMEE, FMEP

- Saint Martin: TFFG

European territories not included in the scope

The following European territories are not considered to be part of the EEA: Greenland, Faroe Islands, Svalbard, Guernsey, Jersey, Isle of Man, Akrotiri and Dhekelia.

Consequently, flights between the EEA and these territories must not be reported.