News

Emission Reduction Claims under UK ETS

Home/
- News/
  - Emission Reduction Claims under UK ETS

05 February 2025

Emission Reduction Claims under UK ETS

Introduction

Aircraft operators with UK ETS compliance obligations in a given year who have purchased and used eligible SAF may be able to reduce their reported emissions and the corresponding number of allowances required for surrender. This can be achieved by submitting an Emissions Reduction Claim (ERC) through the Manage Your UK Emissions Trading Scheme Reporting (METS) portal when filling out their Annual Emissions Report. This guidance outlines the requirements laid down by the environment agency to successfully claim the use of eligible SAF.

To successfully make an ERC, the following criteria must be met:

The fuel purchased must be eligible SAF.
The purchase should take place during the scheme year or 3 months prior to the scheme year.
The eligible SAF was delivered to an aerodrome fuelling system or aircraft by 31 March of the following year.
There has been no double-counting of the eligible SAF i.e., it hasn’t been used for other schemes or sold to a third party.
The ERC must be verified by a UK ETS UKAS accredited verifier.

What is an Eligible SAF?

For fuel to become Eligible SAF, it must be derived from biomass and meet the Renewable Transport Fuel Obligation (RTFO) sustainability criteria that are in force at the time of purchase. If a fuel meets the Renewable Energy Directive 2018 (RED II) sustainability rules, it is also regarded as meeting the RTFO standards.

Are there any geographical limits on SAF Acquisitions:

No, the operators can make an Emission Reduction Claim related to eligible SAF purchased and delivered anywhere around the globe.

Does the EMP need to be varied for an ERC?

Before submitting an Emission Reduction Claim (ERC), aircraft operators must update their Emissions Monitoring Plan (EMP) to include details about Sustainable Aviation Fuel (SAF). Additionally, when submitting the updated EMP through the METS platform, the application should include details of the procedures to:

Record the purchase of Eligible SAF.
Record the delivery of Eligible SAF to an aerodrome fuelling system or aircraft.
Demonstrate that the SAF included in the ERC meets the required sustainability criteria for Eligible SAF.
Outline how the operator ensures the fuel is properly accounted for without double claiming.

Are there any limits on the amount of Eligible SAF that can be claimed for a Scheme Year?

Aircraft operators cannot claim more Eligible SAF than the total fuel used for UK ETS aviation activities during the Scheme Year. Under simplified reporting, claims must align with fuel estimates from Eurocontrol Support Facility data, and unused emissions reductions cannot be carried forward to future Scheme Years.

Can aircraft operators use a different method to calculate the amount of eligible SAFs?

Under the UK ETS Order, aircraft operators may use regulator-approved analyses to determine the biomass element of a fuel comprised of fossil fuel and Eligible SAF or to estimate the biomass fraction of the fuel on a mass balance of fossil fuels and biofuels purchased. Authority needs to be contacted for the proposed approach, any required approvals, and potential Emissions Monitoring Plan variations.

Documentary evidence required:

The following documentary evidence is required to demonstrate compliance with the sustainability criteria.

Proof of Sustainability (PoS) or Product Transfer Document (PTD) with a clear reference tying this document to the PoS via an ISCC EU or RSB EU RED batch PoS certificate number. A Proof of Compliance (PoC) can also be considered in the absence of the PoS.
Fuel invoices and supplier reports.
RTFO claim proof (e.g., RTFO Operating System screenshot).
Proof of Mandated SAF meeting sustainability criteria.
Declaration of no double-counting of SAF in other schemes.

For any further questions or assistance required, kindly contact
[email protected].

Key points to remember:

For fuel to be eligible SAF, it must be derived from biomass and meet RTFO or RED II sustainability rules.
SAF purchase must occur within the scheme year or up to 3 months prior, and delivery completed by 31 March of the following year.
ERC must not exceed the total amount of fuel used for UK ETS aviation activities or Eurocontrol estimates.
EMP needs to be updated under the guidance of the Environment Agency to include the procedures related to SAF.
The submission must encompass either a PoS Certificate, or a PTD with reference to the PoS or a PoC, along with SAF invoices, evidence of RTFO compliance, and declarations of no double counting of eligible SAF in other GHG schemes.

Conclusion

The emissions Reduction Claim offers a valuable opportunity for aircraft operators to reduce their aviation emissions and comply with the UK ETS requirements effectively. By adhering to the outlined criteria, including the use of Eligible SAF, ensuring proper documentation, and engaging with accredited verifiers, operators can benefit from significant allowance reductions while maintaining regulatory compliance. The aircraft operator needs to prepare robust procedures, and accurate reporting by avoiding issues such as double-counting or inadequate evidence. Aircraft operators are encouraged to consult and seek clarification from the Environment Agency to ensure successful ERC submissions for the 2024 and 2025 Scheme Years.

View this service

References

How to comply with UK ETS Aviation Activity – a flight regulated under the UK ETS, as defined in Schedule 1 of the UK ETS Order RTFO – Renewable Transport Fuel Obligations Order 2007 RED II – Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of the use of energy from renewable sources