German Emissions Trading Authority

Aircraft operators

Not only the industrial and energy generating sector, but aviation too are major contributors to global emissions, and their share is on the rise. Aviation has therefore been included in European emissions trading since 2012.

Source: Oleg Ivanov/Fotolia

Aviation in emissions trading

Commercial as well as non-commercial aircraft operators must surrender allowances for each tonne of carbon dioxide (CO2) emitted by their aviation activity. As a general principle, all aircraft operators are included in emissions trading if they carry out flights departing from or arriving at the territory of the European Economic Area (EU Member States, Iceland, Norway and Liechtenstein). From 2010, they have been required to report their emissions to the competent authority (in Germany, to the German Emissions Trading Authority at the German Environment Agency, DEHSt).

For 2012 and 2013-2023, the EU has introduced several exceptions concerning geographic scope, which are explained below.

Stopping the clock 2012

"Stopping the clock" was a temporary concession from the EU to support the ICAO process of negotiating a global market-based measure for regulating international aviation emissions. It allowed aircraft operators to choose to surrender a reduced amount of emissions certificates (i.e., with some exceptions, e.g. Switzerland, only for flights within the EEA) if they relinquished some of the free allocation of emission allowances at the same time.

Amending the Emissions Trading Directive

from 2017

Amendment from 2017

On 06/10/2016, International Civil Aviation Organisation (ICAO) adopted a market-based measure to limit CO2 emissions from international aviation. CORSIA (Carbon Offsetting and Reduction Scheme for International Aviation) provides for the offsetting of carbon emissions by using offsets and emission allowances from emissions trading systems to achieve carbon-neutral growth in international aviation from 2020 onwards. The partly abstract regulations from the A 39-3 resolution are currently being transferred into the documents relevant to the design of CORSIA. Later on, they will also be transferred into national law.

On 29/12/2017, the European Commission published the regulation on the further design of EU ETS in aviation (retroactive to 01/01/2017).

Aircraft operators must now observe the following amendments:

  • The inclusion of international flights (flights to or from airports in countries outside the European Economic Area) and flights to, from certain and within outermost regions of the EU remain suspended until 31/12/2023. As a result, the so-called reduced geographical scope that has applied since 2013 will continue unchanged. However, this is subject to a review of the implementation of the ICAO Global Market-Based Measure (CORSIA) by the European Commission according to Article 28b.
  • Aircraft operators, which emit less than 3,000 tonnes of CO2 per year in relation to the reduced geographical scope, you can now make use of the small emitter regulations. This includes facilities such as the use of the "Small Emitter Tool" or the use of the "Support Facility" of EUROCONTROL. If the emissions report was entirely produced using data from the Support Facility of EUROCONTROL, the verification obligation no longer applies. So far, this has only applied to aircraft operators who have emitted less than 25,000 tonnes of CO2 per year in relation to the original scope.
  • Aircraft operators will receive the same annual free allocation as in 2016 up to 2020. Subject to a review pursuant to the above Article 28b, the linear reduction factor pursuant to Article 9 EU Emissions Trading Directive should be applied -as for stationary installations- from 2021 which is 2.2 percent per year.
  • Non-commercial aircraft operators with annual emissions of less than 1,000 tonnes CO2 are not subject to emissions trading until 2030 (currently 2020).


Amending the Emissions Trading Directive for the reporting years 2013-2016

A new trading period (2013-2020) started on 01/01/2013; in addition, the previously valid Monitoring Guidelines were replaced by the Monitoring Regulation.

At its 38th General Assembly in the autumn of 2013, the International Civil Aviation Organization (ICAO) adopted a resolution to develop by the autumn of 2016 a global market-based climate protection instrument based on which aircraft operators are to reduce their CO2 emissions from 2020. To support this process, the European Union has decided, in addition to "Stopping the Clock", to temporarily adjust the Emissions Trading Directive. The relevant amendment entered into force on 30/04/2014.

The following regulations are of particular importance:

  • Mandatory suspension of the inclusion of international flights in the European Emissions Trading Scheme (EU-ETS)

    • flights to or from airports in countries outside the European Economic Area, with the exception of Croatia and
    • flights to and from certain areas in the outermost regions of the EU
  • adjustment of the allocation amounts from 01/01/2013 to 31/12/2016
  • Exemption for non-commercial aircraft operators with annual emissions of less than 1,000 tonnes of carbon dioxide (CO2), with respect to the original so-called "full scope", from 01/01/2013 to 31/12/2020
  • The verification obligation is waived for the emission reports of operators with less than 25,000 tonnes of annual CO2 emissions, with respect to the original scope, if the emissions report was fully created using data from the Eurocontrol Support Facility.
  • Re-application of the original scope of the Emissions Trading Directive from 01/01/2017 if this is not re-adjusted by the EU due to the introduction of global market-based measures by the ICAO.

Facts and data

Facts and data on aviation in the EU ETS
(1)Absolute figures refer to the original so-called "full scope" of the Emissions Trading Directive
2012 and 2013-2020 reduction targets-3% (2012) and -5% (from 2013) in comparison to 2004-2006 average (baseline), i.e. the cap is 97% or 95%
EU reduction targets in absolute figures (1)Basis line: 221.4 m t CO2
2012 cap: 214.8 m t CO2
2013-2020 cap: 210.4 m t CO2
Participants in emissions trading in aviation (1)Almost 6000 international aircraft operators from more than 150 countries, for 500 of which Germany is responsible
Free allocation (1)

85% of the 2012 certificates
82% of the certificates from 2013

According to a Europe-wide uniform benchmark (calculated by the EU Commission):
2012: 0.6797 emission allowances per 1000 tonne-kilometres
2013-2020: 0.6422 emission allowances per 1000 tonne-kilometres

129 aircraft operators who have applied for allocation in Germany, receive:
42.8 m certificates in 2012
40.5 m certificates from 2013

Reserve3% of the certificates from 2013
Auction percentage15% of the certificates


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