Obligations - ETS aviation

Since 1 January 2020, airlines operating flights from Switzerland to Europe have also been subject to the Swiss emissions trading system (CH ETS). These flights count towards the aforementioned threshold values. To make reporting under both systems as easy as possible for the airlines, a so-called ‘one-stop-shop’ has been set up. As a result, airlines only need to report to one competent authority to fulfil their reporting obligation under both systems. Moreover, many of the obligations are regulated in the same manner. There are, however, a few exceptions to this, which are explained below.

Monitoring and improvement reports

Airlines which participate in the EU ETS (see Participants - ETS aviation) must monitor their CO₂ emissions throughout the year. For that purpose, they must prepare a monitoring plan, in which they explain how they will determine the levels of emissions they produce in a manner which is both appropriate and in compliance with the rules. If anything changes or deviates from the monitoring plan, airlines are required to report this to the Dutch Emissions Authority (NEa). There is also an ongoing obligation to check whether any improvements can be made to the monitoring system. In certain cases, airlines must submit an improvement report to the NEa documenting this.

Accounts and emission allowances

Airlines must request an account in the register. This account is used for obligations under both the EU ETS and the CH ETS. The NEa deposits a certain number of free emission allowances for the EU ETS in this account (where applicable). That number is based on historical tonne-kilometre data for the year 2010. In order to qualify for free emission allowances, airlines submitted a verified application to the NEa in 2011. New entrants (airlines which began operations after 2010) and rapidly growing airlines were permitted to submit a verified application to the NEa before 30 June 2015.

Since 2020, free emission allowances for the CH ETS have been deposited in the same account, but by the European Commission. That number is based on historical tonne-kilometre data for the year 2018.

Once it has been calculated how many allowances will be allocated free of charge, that quantity may still be adjusted later if any changes are made to the regulations.

Airlines which have no obligations in respect of the EU ETS in a given year will not receive any emission allowances for that year, either.

Reporting and surrendering emission allowances

Each spring, every airline with obligations reports their emissions from the past year under both the EU ETS and the CH ETS to the NEa in a verified emissions report. They must also surrender enough emission allowances to settle the emissions under both systems. These can either be free emission allowances, or allowances they have purchased on the market or at auctions. The obligation to report and to surrender allowances together constitute the year-end closing obligation.

Supervision and enforcement

The NEa supervises compliance with the obligations by airlines. The NEa can enforce the rules should there be a cause to do so.