Aviation EU-ETS Update: Clarification on the EC “Stopping the Clock” Memo for Operators

Aviation EU-ETS Update: Clarification on the EC Stopping the Clock Memo for Operators

Aviation EU-ETS Update: Clarification on the EC Stopping the Clock Memo for Operators

The Nov 12th memo on “Stopping the clock of ETS and aviation emissions” issued by the European Commission (EC) and subsequent new material include a lot of information and statements regarding aviation EU-ETS that should be reviewed carefully.

1. Initial information regarding the changes

The EU Commissioner for Climate Action, Connie Hedegaard, has shown through her statement a willingness by the EC to compromise with respect to EU-ETS requirements for aviation activities that occurred during the 2012 monitoring year. The proposal that Commissioner Hedegaard has recommended via conference call would remove the requirement for operators to monitor, report, and verify CO2 emissions and surrender carbon allowances for international flights to or from the EU (i.e. KTEB-EGGW), but maintains that all current obligations for any operations within the EU (i.e. EGGW-LFPB) remain intact.

2. There are three important items to note regarding this “Stop the Clock” proposal

  1. This proposal has to be ratified by all 27 EU Member States to become effective.
  2. All operators are still responsible for monitoring, reporting, and verifying CO2 emissions for intra-EU activity, and surrendering the appropriate amount of carbon allowances by current posted deadlines.
  3. It is only a temporary measure to “create a positive atmosphere” around the negotiations with ICAO, to create a global greenhouse gas reduction scheme and not a permanent change to the EC Directive.


In summary, the international aviation community must continue to prepare for compliance with EU-ETS as presently constituted until an official resolution is reached regarding this proposal or any other proposal of its nature.

If this proposed measure were to be implemented, operators would still be responsible for all phases of EU-ETS for intra-EU activity. To comply with these regulations, operators need to have systems and procedures in place to monitor, report, and verify CO2 emissions, and surrender carbon allowances. Establishing a Carbon Registry/Aircraft Operator Holding Account to bank and surrender allowances should still be the top priority for operators captured by the scheme.

For more information on EU-ETS and business aviation, visit www.eu-ets.aero.


If you have any questions about this article, contact me at adamhartley@univ-wea.com.