The non-CO2 MRV system is designed to cover the full geographical scope of the European Emissions Trading System 1 (EU ETS 1). However, to facilitate implementation, aircraft operators are permitted to apply the non-CO2 MRV to flights within the reduced geographical scope under EU ETS 1 for 2025 and 2026. Alternatively, operators may choose a geographical scope that covers at least the reduced geographical scope, including other additional flights of their own choice.
It is important to note that the non-CO2 MRV only includes flights performed with jet engine aeroplanes and therefore the data below do not need to be recorded for flights performed with other aircraft.
The monitoring of the required data under the EU ETS 1 is generally performed based on an approved monitoring plan. Since the application in the Form Management System (FMS) intended for this purpose will not yet be available for the period starting January 1, 2025, the monitoring must temporarily be performed in accordance with regulations established by the EU Monitoring Regulation (MRR). You will be notified straight away, once the FMS application is operational.
In the case of the non-CO2 MRV, the MRR mandates the use of an IT instrument that is either provided or approved by the European Commission (COM). For the 2025 reporting year, the only instrument to be used for this purpose will be the COM’s NEATS instrument which is provided free of charge. However, NEATS will not be available by January 1, 2025 either. Pursuant to Article 56b(6) MRR, in such case aircraft operators are required to independently monitor the flight information and the aircraft properties per flight, which they will then transfer to NEATS at a later time.
The flight information shall include the call sign as provided in Article 51 MRR, the day and time of departure and arrival of the flight and the ICAO or IATA codes for origin and destination airports allowing for unique identification of the given flight.
The aircraft properties consist of three different categories of information: the aircraft type used (ICAO code), the engine identifier (engine UID) as well as the aircraft mass along the flight trajectory.
In addition to own data, the conservative default engine identifiers listed in Annex IIIb MRR may be used for the engine identifier.
The aircraft mass along the flight trajectory may be determined in different ways, either using
- the actual mass, which is calculated by subtracting from the take-off mass the fuel burn during flight or
- based on an estimate using a model. This estimate may be calculated in NEATS at a later time.
The actual mass is established by quantifying the fuel burned at time intervals not exceeding 60 seconds. Please contact us if you wish to make use of this option, so that a MRR-compliant procedure can be coordinated, even without the preliminary approval of a monitoring plan.
The estimate using a model follows a gradual approach. For maximum accuracy, the take-off mass must be provided. If the take-off mass is not available, the actual load factor may be used and if this is not available, a load factor of 1 shall be used. The load factor in accordance with Annex IIIa, Section 1, point 32 MRR means the weight of passengers, cargo and baggage, including mail and hand luggage, expressed as fraction of the maximum payload mass. The load factor is used in conjunction with a default value for the maximum mass of the aircraft type used to determine a proximity value for the take-off mass if the latter is not available.