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Understand and implement the EU Emissions Trading Scheme

23 décembre 2014 - Transports

Sommaire :



12 février 2014 (mis à jour le 3 mai 2016)

Sir, Madam,

Following the ICAO Resolution A38-18, the EU rules on the ETS are being modified.

In this framework, the DGAC issued on December 30, 2013 a statement entitled "Communication as regards EU ETS Aviation – post 2013 OACI Assembly " available on its website at the following link :

This statement has raised a number of questions and requests for clarification. You will find below some answers in the form of frequently asked questions :


Do aircraft operators, as CO2 emitters, have to declare all relevant flights in Annex 1 of Directive 2003/87/EC or only intra-EEE flights ?

The applicable law requires report flights corresponding to a new geographical scope, known as « Intra-EEE » from the Regulation 421/2014 of 16 April 2014.
Below you will find the link to our website with a comprehensive description of the geographical scope « Intra-EEE » :

All aircraft operators have to report and surrender allowances corresponding to their emissions ?

A verified reporting and surrendering corresponding allowances are required only for the aircraft operators emitting more than :

  • 1 000 tonnes CO2 for the non-commercial aircraft operators. In accordance with the Regulation 421/2014, the exemption for the aircraft operators emitting less than 1 000 tonnes CO2 applies from 1 January 2013 to 31 December 2020.
  • 10 000 tonnes CO2 for the commercial aircraft operators

How calculate the threshold of 1 000 tonnes/10 000 tonnes CO2 ? Based on all flights according to Annex 1 or only on intra-EEE flights ?

The threshold of 1 000 tonnes/10 000 tonnes CO2 is based on the full scope (corresponding to Annex 1 of the Directive 2003/87/EC).

Flights to and from Fort-de-France, Pointe à Pitre, Reunion, are taken into account for the calculation of emissions ?

The applicable law for the reporting doesn’t takes into account the flights between the intra-EEE scope and the outermost regions until 31 December 2016.

Nevertheless, the flights between outermost regions must report

To what extend commercial operators are exempted to report their CO2 emissions and surrender the allowances corresponding to their emissions ?

Commercial operators are exempted if they fulfil one of two following conditions :

  • fewer than 243 flights per period for three consecutive four-month periods, or
  • flights with total annual emissions lower than 10 000 tonnes CO2 per year based on the full S (as defined in Annex I to Directive 2003/87/CE).

Will commercial or non-commercial aircraft operators who emit less than 25,000 tonnes CO2 be required to independent verifier to verify his reporting before submission to the competent authority (DGAC) ?

The aircraft operators emitting more than 25 000 tonnes CO2 have to submit a reporting verified by an independent verifier.

The aircraft operators emitting less than 25 000 tonnes of CO2 have two options :

  • Verify their reporting by an independent verifier
  • Or download a simplified reporting by the Support Facility a tool developed by Eurocontrol. In accordance with the Regulation 421/2014 of 16 April 2014 for these aircraft operators, simplified reporting based on estimation considered as verified

Do aircraft operators have to submit a verified report for March 31, N+1 ?

The applicable law requires a verified CO2 emissions report, before the 31st March of the following year.

What about the free allowances for period 2013-2020 ?

The amendment of Directive 2003/87/EC of 13 October 2003 establishing a trading scheme for greenhouse gas (GHG) allowances, introduced a new geographical scope which modified the amount of free allowances allocated to aircraft operators.
You can access to the decree establishing the free allowances via this link below :


Liens utiles

List of the main official documents (Directives, Decisions, list of aircraft operators...) or pages you may find useful :

French legislation (in French) :

Specific to phase II (2012) :

Specific to phase III (2013-2020) :

European legislation :

Specific to phase II (2012) :

Specific to phase III (2013-2020) :

European Commission’s pages :

Eurocontrol :