What are non-CO₂ aviation impacts?
From January 1, 2025, aircraft operators subject to the EU ETS must comply with monitoring, reporting and verification (MRV) of non-CO₂ aviation impacts. These are climate effects and atmospheric changes caused by substances other than carbon dioxide.
Examples of non-CO₂ effects are nitrogen oxides (NOₓ), water vapor, soot particles, sulfur oxides (SOₓ), condensation streaks and induced cirrus clouds. The obligations are set out in the Monitoring and Reporting Regulation (MRR) and the EU ETS Directive.
This means that aircraft operators must not only report CO₂ emissions, but also collect and report data on these additional climate impacts.
Our approach to non-CO₂ MRV and EU ETS compliance
Normec Verifavia supports aircraft operators in meeting the new EU ETS obligations for non-CO₂ aviation impacts. We guide you through the entire verification process: from preparation and monitoring to verification and reporting.
Our approach consists of several steps:
- Pre-engagement and scope determination.
- Preparation and review of the Annual Emissions Monitoring Plan (AEMP)
- Planning and risk analysis
- Verification of emissions and flight data
- Independent technical review
- Verification report and compliance support
This structured approach ensures that your organization complies with regulations and minimizes risks.
Normec Verifavia's expertise in aviation verification
Normec Verifavia has more than 10 years of experience in validation, verification and audits within the aviation sector. Our specialists have extensive knowledge of EU ETS, MRV obligations and aviation emissions.
Why organizations choose Normec Verifavia:
- Extensive experience in aviation verification
- Specialist knowledge of EU ETS and MRV
- Reliable and independent verification
- Compliance and audit support
- International experience within the aviation sector
EU ETS non-CO₂ reporting
Aircraft operators falling under the EU ETS and flying jet aircraft must comply with this new obligation. Operators must choose a geographical scope for reporting years 2025 and 2026:
- Reduced Scope - Flights within EEA countries.
- Full Scope - All flights to and from the EEA.
- In-Between Scope - Reduced scope supplemented by a selection of routes.
Starting in 2027, Full Scope reporting will become mandatory. The scope must be defined in the Annual Emissions Monitoring Plan (AEMP) and must remain the same during the reporting year.
For reporting year 2025, operators must use the Non-CO₂ Aviation Effects Tracking System (NEATS), developed by the European Commission. Operators must additionally choose a calculation method (Method C, Method D or a combination of methods for Small Emitters).
This provides you with the following, among other things:
- Insight into non-CO₂ climate effects of your flights.
- Compliance with EU ETS regulations
- Less risk of fines and penalties
- Reliable monitoring and reporting
- Support with verification and audits
Prepared for future aviation and climate regulations
Regulations surrounding aviation emissions and climate impacts are becoming more and more comprehensive. Non-CO₂ aviation impacts play an increasing role within European climate legislation and reporting requirements.
By meeting monitoring, reporting and verification requirements now, you prepare your organization for future regulations and avoid compliance risks. With Normec Verifavia's support, you work with a reliable partner for verification and compliance within the aviation sector.
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Frequently Asked Questions about non-CO2 aviation effects
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These are climate effects of aviation that are not caused by CO₂, such as nitrogen oxides, water vapor, soot particles, sulfur oxides, condensation streaks and cirrus clouds.
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The obligation applies from January 1, 2025 for aircraft operators covered by the EU ETS.
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NEATS stands for Non-CO₂ Aviation Effects Tracking System and is the European Commission's system to be used for reporting non-CO₂ aviation effects.
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The AEMP is the monitoring plan that defines the geographic scope, calculation method, IT tool and data management procedures, among other things.
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The first report is due by March 31, 2026.
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Method C is mandatory for larger operators. Method D may only be used by Small Emitters below certain thresholds.
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From January 1, 2025, aircraft operators must monitor and report non-CO₂ aviation impacts annually.
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All aircraft operators flying jet engine aircraft and covered by the EU ETS must comply.
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Operators choose between Reduced Scope (flights within EEA countries including territories), Full Scope (all arrivals and departures within the EEA) or In-Between Scope (Reduced Scope supplemented by selected routes).
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Starting in 2027, all operators must report according to Full Scope.
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The European Commission's Non-CO₂ Aviation Effects Tracking System (NEATS) should be used in 2025.
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As of 2026, other tools approved by the European Commission may be used, provided they comply with the Monitoring and Reporting Regulation.
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Method C (For All Operators), Method D (For Small Emitters) Or A Combination Of Methods For Small Emitters.
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The AEMP must include: Aircraft Eligibility, Reporting Scope, Chosen Method, IT Tools, Data Collection And Procedures For Data Gaps.
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No later than March 31 of the year following the reporting year, for example, March 31, 2026 for the 2025 reporting year.
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Primary Data is measured data collected by the aircraft operator itself. Secondary Data is data that can be provided through the NEATS system without operator input.
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Required data can include Flight Information, Flight Path, Aircraft Properties, Fuel Flow, Fuel Properties And Aircraft Performance. Operators may also choose to use Secondary Data and default values in NEATS. Until NEATS is available, operators must monitor flight information and aircraft type on a per-flight basis at a minimum.