Commercial and non-commercial aircraft operators

The EU Aviation ETS draws a distinction between commercial and non-commercial aircraft operators. Operators' emissions and/or number of flights will determine whether they are covered under the EU Aviation ETS.

Commercial aircraft operators

Under the EU ETS, a commercial aircraft operator is defined as an aircraft operator which holds an aircraft operator's certificate (AOC) as described in Section I of Annex 6 of the Chicago Convention. There are two situations in which commercial aircraft operators are exempted from the EU ETS:

  • If they perform fewer than 243 flights per 4-month period for three consecutive 4-month periods; or
  • If their total annual CO2 emissions is less than 10,000 tonnes.

Non-commercial aircraft operators

Non-commercial aircraft operators are those without an AOC. Non-commercial aircraft operators whose total annual CO2 emissions are less than 1,000 tonnes are exempted from the EU ETS.

The full geographical scope of the EU ETS is used to determine whether the threshold is exceeded (this is all flights to and from the 28 EU Member States, Iceland, Liechtenstein and Norway).

Which flights belong to which aircraft operator?

The call sign used by Air Traffic Control (ATC) determines which flights belong to which aircraft operator. The call sign is the ICAO designator listed in box 7 of the flight plan. If this information is not available, the aircraft's registration marking is used. This means that all flights listing your call sign or aircraft registration marking in box 7 of the flight plan are your responsibility, and have to be taken into account to determine whether you are subject to the EU ETS. This also applies in the case of aircraft that have been leased in or leased out, or in the case of code-sharing between various aircraft operators.