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The CH ETS is a cap-and-trade system administered by the Swiss Federal Office for the Environment (FOEN). Linked with the EU ETS since 2020, it follows a one-stop shop principle, where aircraft operators with obligations under both systems are administered by one state (an EEA State or Switzerland). The system is mandated by the Federal Act on the Reduction of CO₂ Emissions (CO₂ Act) and regulated through the CO₂ Ordinance.
The linking of the Swiss and European Union ETS facilitates reporting and mutual allowances recognition. A one-stop-shop approach streamlines compliance, where aircraft operators who have obligations under both the CH ETS and EU ETS are administered by one State, to which they will submit Annual Emission Reports and Monitoring Plans; use one registry for allowances transactions and surrender allowances for both systems through the same process.
If an aircraft operator is covered by the EU ETS, it is automatically covered by the CH ETS and has obligations if it performs the following flights (CH ETS scope):
If the aircraft operator is not covered by the EU ETS, then these thresholds apply, considering the CH ETS scope:
Small emitters, as defined under the EU ETS, can estimate emissions with the Small Emitters Tool.
Aircraft operators must submit a verified Annual Emissions Report to their Competent Authority by March 31st and surrender allowances by September 30th. Additional obligations include submitting an Improvement Report by June 30th if there were verification findings.
The table below summarises the distinction of coverage of flights under each of the systems.
| EU ETS & CH ETS Linking: Reporting scopes | |
|---|---|
| Flights covered by EU ETS | Flights covered by Swiss ETS |
| Intra-EEA flights | Swiss domestic flights |
| Flights from the EEA to Switzerland |
Flights from Switzerland to the EEA (including OMRs) |
| Flights from the EEA to the UK |
Flights from Switzerland to the UK |
| OMRs flights: between OMRs of different States & between an OMR and another State. |
– |
In line with the EU ETS, exemptions for special flights apply, the following flight
The latest official templates, along with regulatory documents, are available through the Federal Office for the Environment (FOEN)’s website.
Our commercial team engages with the client. Thereafter, a pre-contract is elaborated and sent to the client.
During the engagement stage, clear objectives are set with the client, which involves the comprehensive definition of the operational scope, ensuring that all relevant parties have a clear and shared understanding of the verification boundaries. The engagement is formalized through a contract, setting the stage for a structured and transparent verification process.
The verification activities are determined and planned based on the claims. An Audit Preparation Letter (APL) is sent to request all the required data and documents to begin the verification process. A strategic and risk analysis is performed to assess the risks and prepare a verification plan.
A thorough analysis of emissions data and supporting documents to verify accuracy, completeness, and consistency. The process ensures compliance with relevant regulations. It includes cross-checking flight and fuel data, reviewing monitoring methodologies, and validating control systems to confirm the integrity of the reported information.
An independent technical review is conducted in accordance with ISO 17029:2019 and ISO 14065:2020 standards. After achieving reasonable assurance, a verification report is issued, ensuring that the client’s report is free from any material misstatements.
If there is any significant information that comes to light after the verification opinion has been issued and if such information could impact the verification results, it may necessitate a reassessment or correction in the report.
With the goal of minimizing administrative burden for aircraft operators and noting the linking of the Swiss ETS and the EU ETS, compliance with Swiss ETS will be reached together with compliance for EU ETS, through a “one-stop-shop” approach. All compliance processes and procedures will be handled via a single Competent authority (CA).
Operators based in Switzerland have had their Competent Authority (CA) change to the Federal Office of Civil Aviation (FOCA). Competent Authorities remain unchanged for other operators.
Since Swiss ETS will be administered through the “one-stop-shop,” the deadline will be the same as for the EU ETS (typically March 31).
Swiss domestic flights and flights from Switzerland to the EEA (including outermost regions and overseas territories) will be accounted for in the Swiss ETS.
Note: Due to the linking of the Swiss ETS and the EU ETS, the scope of EU ETS was expanded to include flights from EEA to Switzerland, so the EU ETS will now cover intra-EEA flights and EEA-Switzerland flights.
Aircraft operators will have only one aircraft operator holding account in relation to their obligations under the EU as well as and the Swiss ETS. For an aircraft operator administered by an EEA member state, such an account will be in the Union Registry. For an aircraft operator administered by Switzerland, such an account will be in the Swiss registry.
Yes, both EU ETS and Swiss ETS aviation allowances can be used for meeting surrendering obligations of both programs through the “one-stop-shop.” This includes free allowances issued by either of the programs.
Due to the linking, all flights between the EEA and Switzerland (both directions) subject to reporting and surrendering must be entered exclusively in the form “Carbon dioxide emissions in EU-ETS by aerodrome pair” from the reporting year 2020 onwards. Flights between Switzerland and non-EEA countries can still be reported voluntarily in the form “Carbon dioxide emissions under article 2 del. Regulation (EU 2019/1603) by aerodrome pair”.
No, as of January 1, 2020, the Swiss ETS is linked to the EU ETS.
Swiss authorities allocate free allowances based on 2018 TKM data. The allocation is now complete, and FOEN has informed all eligible operators of their Swiss free allowances.
From 2024, flights from Switzerland to EU outermost regions will no longer be exempt from the Swiss ETS. Aircraft operators can apply for free emission allowances by providing verified tonne-kilometre data from 2018 to the FOEN.
The European Commission issues an updated version of the EU ETS Annual Emissions Report (AER) template, which facilitates Swiss ETS reporting alongside EU ETS reporting. The new template is essentially the old one, expanded to include Swiss ETS sections. For further information about the reporting and to access the new template click here.