Who is affected by the exemption?
At EU level, the Emissions Trading Directive (ETD) stipulates that, from 01/01/2026, installations where more than 95 per cent of average total greenhouse gas emissions are attributable to the combustion of sustainable biomass are to be excluded from the EU Emissions Trading Scheme. At national level, this EU requirement has been transposed into national law by Section 26 of the Greenhouse Gas Emissions Trading Act (TEHG). On the basis of the verified emissions reports for existing installations in the EU ETS 1, as well as publicly available information on large biomass installations in Germany, the DEHSt, in some cases in collaboration with the state authorities, has identified those installations that will be subject to an exemption from obligations from 01/01/2026 due to their predominant use of biomass. We have informed the operators of these large biomass installations by letter.
How is the exemption determined?
The DEHSt determines the exemption from obligations for biomass plants in EU ETS 1 by means of a separate exemption notice. Prior to this, the competent state authority must issue an emissions permit for plants that were not previously subject to emissions trading.
Operators’ obligations
The following timetable applies to the submission of the monitoring plan and the emissions data required for the review of the continuation of the exemption:
Prepare and submit a simplified monitoring plan valid from 2026
You should prepare your monitoring plans using an Excel template that we provide. Once you have received our notice of exemption, submit the monitoring plan to us via the VPS or the DEHSt mailbox on the DEHSt platform. We will then review and approve the monitoring plan. You must submit any significant changes to the monitoring plan without delay.
Record and submit emissions data and sustainability information for 2024 to 2028
The Excel template is also used to record emissions data for the years 2024 to 2028.
- For the years 2024 and 2025, you should either import the emissions reports into the Excel template or, for installations that have only been subject to emissions trading since 01/01/2026, record the emissions data based on the best available data.
- For the years 2026 to 2028, enter the emissions data in the Excel template and provide details on the sustainability of the biomass used, based on the approved monitoring plan.
Emissions data for the entire period from 2024 to 2028 must be submitted once by 31/03/2029 via the DEHSt Mailbox on the DEHSt Platform.
Information and further guidance
The information sheet provides an overview of the affected plant groups and the requirements for recording emissions data. It also contains further explanations on how to create and complete the Excel template for the monitoring plan and the emissions data.
