EU ETS - Aviation
Since it was introduced in 2005 CO2 emissions from electricity generation and large industrial plants are limited by the EU Emissions Trading System. In 2012 the EU ETS was also applied to aviation emissions.
Since 2012, aircraft operators operating in the European Economic Area are required to monitor, report and verify their CO2 emissions and to surrender allowances against those emissions.
Several types of flights, such as training and humanitarian flights, are exempt from the EU ETS.
Non-commercial aircraft operators with total annual emissions lower than 1,000 tonnes CO2 per year (based on all their flights departing from or arriving into the European Economic Area/EEA) are exempt until 2030.
Reduced scope of ETS
The scope of the EU ETS is currently limited to flights within the European Economic Area (EEA) until the start of 2027. This was done to support the development of a global market-based measure by the International Civil Aviation Organization (ICAO).
The Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), as the ICAO measure is known, aims to stabilise CO2 emissions at 2020 levels by requiring airlines to buy credits to offset the growth of their emissions after 2020.
By July 2026, the Commission will carry out an assessment of whether more action is required for flights to and from Europe, in line with criteria set out in the ETS Directive for Aviation. Subject to the outcome of this assessment, the Commission will make a legislative proposal that could extend the scope of EU emissions trading to departing flights and exempt incoming flights. Alternatively, the proposal could be to maintain the intra-European scope if CORSIA is strengthened and has a high level of global participation and implementation.
Find out more about these measures on the website of the European Commission.
Which aircraft operators are covered?
The Environmental Protection Agency (EPA) is responsible for administering the EU ETS for aircraft operators assigned to Ireland in accordance with national legislation (SI 471 of 2024) transposing the ETS Directive.
The EU regularly updates the list of aircraft operators assigned to each Member State. The main purpose of this list is to facilitate good administration of the EU ETS by informing aircraft operators about who is regulating whom.
If an aircraft operator does not appear on this list, it does not mean that they are exempt from the EU ETS. Similarly, some aircraft operators appearing on the list may no longer be active or come within the scope (Annex 1) of the ETS Directive. The aircraft operator may be temporarily below one of the thresholds in Annex 1 and is classed as "excluded" for that year.
The EU has published an information note on the legal status of this list of aircraft operators.
Aircraft operators assigned to Ireland and coming into the EU ETS for the first time should contact the EPA by emailing AVETS@epa.ie for instructions on how to proceed.
Monitoring, reporting, and verification (MRV) of non-CO2 effects
The EU Commission is establishing an MRV system for non-CO2 aviation effects to apply from 1st January 2025, estimating per‑flight CO₂‑equivalent emissions using state‑of‑the‑art methodologies based on flight data, aircraft characteristics, and fuel properties, performance information and weather data. By the end of 2027, the Commission will deliver a report on the results and if appropriate, will make a legislative proposal to address non-CO2 effects of aviation. More information can be found on the Commission's webpage.
Resources:
EU Commission webpages on ETS Aviation:
General FAQ on aviation in ETS
FAQ on non-CO2 aviation emissions
Irish EU ETS Regulations for aviation and amendments
List of aircraft operators in the EU ETS and their administering MS
Information note on the legal status of the list of aircraft operators