National Emissions Trading
Experience report
The Fuel Emissions Trading Act (Section 23 BEHG) legally states that an evaluation of the BEHG must be carried out by the Federal Government at regular intervals. To this end, the Federal Government presented the initial experience report to the Bundestag in 2022. Further reports will follow in 2024 and then every four years.
The Federal Ministry for Economic Affairs and Climate Action (BMWK) – supported by us, the German Emissions Trading Authority at the German Environment Agency – is in charge of preparing experience reports and further developing national emissions trading (nEHS).
The experience report for 2022 was officially released on 08/12/2022. The report is based on a research project for which we commissioned the services of the Ecological-Social Market Economy Forum, Prognos and the German Institute for Economic Research to conduct an in-depth expert analysis on the impact of the nEHS. The study examined the effect of the nEHS on the trend in fuel prices for consumers, the nEHS’s effect on CO2 emissions in the relevant sectors and its distributional influence on CO2 prices within private households.
Experience report (available in German only)
Erfahrungsbericht der Bundesregierung gemäß § 23 BEHG
Situation of emissions
Evaluation report on the emissions situation in 2021 and 2022
The first nEHS evaluation report for the years 2021 and 2022 was published on 26/03/2024. The report contains detailed information on the emissions situation in the nEHS, broken down by obligated parties as per BEHG, fuels and deductible emissions, among other things.
Full nEHS evaluation report
nEHS: Emission Situation 2021 and 2022 (06/08/2024, PDF, 1MB, File meets accessibility standards)
Reporting of reported data on the emissions and surrender situation
5.7 million tonnes of CO2 (2.0 percent) less than in the previous year - this is the reduction in emissions reported by the German Emissions Trading Authority (DEHSt) at the German Environment Agency (UBA) in the third year of the national emissions trading system (nEHS). The figures are preliminary. Around 282.8 million nEHS certificates (nEZ) were surrendered for the 2023 reporting year - each nEZ corresponds to one tonne of CO2. With regard to the reported decline, it should be noted that additional fuels such as coal have been regulated in the nEHS for the first time since 2023. If these fuels are excluded, the adjusted reduction compared to 2022 is as much as 9.2 million tonnes of CO2 (3.2 percent).
For 2023, companies that are obligated to participate in the nEHS had to surrender nEZ in the amount of their reported emissions by 30/09/2024. The surrender was made in the nEHS registry at the DEHSt. Since 04/11/2024, the data has been publicly accessible via the nEHS registry (in accordance with the requirements of Section 33 of the Fuel Emissions Trading Ordinance - BEHV).
A more detailed summary of the surrender situation in 2023 in the nEHS and access to the public area of the nEHS registry can be found via the links below.
To the reports (available in German only)
Public area of the nEHS registry (available in German only)
nEHS-Register: Compliance-Informationen
Cap increment amount and additional demand
Publication of an Additional Demand Pursuant to Section 36 BEHV
In the national emissions trading scheme (nEHS), there is a legally specified volume target for greenhouse gas emissions that serves as a maximum allowable limit for all participants. Since the sale of allowances during the introductory phase (up to and including 2026) will follow the actual demand from nEHS participants, there is the possibility that the specified volume target may be exceeded during this period.
We, the German Emissions Trading Authority (DEHSt) at the German Environment Agency, calculate the ‘additional demand’ that arises if the nEHS volume targets are exceeded in accordance with the provisions of Section 36(1) and (2) of the Fuel Emissions Trading Ordinance (BEHV).
In cases where there is a positive additional demand and the annual volumes specified by the EU Climate Protection Regulation are not met simultaneously, the excess demand for emission allowances is covered by utilising flexibilisation options according to the EU Climate Protection Regulation. This may include the purchase of a corresponding amount of emission allocations from other Member States.
The additional demand in a calendar year is calculated according to Section 36 BEHV from the amount of national emission allowances (nEZ) surrendered in the nEHS Registry minus the fuel emissions of the ETS offsetting and the specified emission volume (Section 34(2) BEHV) in the same year.
For 2021, according to DEHSt calculations, there is an additional demand in the nEHS of 4,623,836 nEZ.
There is no additional demand for 2022, as the calculation in accordance with Section 36(1) and (2) BEHV shows a negative value of -3,962,525 nEZ.
The calculations were based on the allowance volumes surrendered from the nEHS Registry as of 11/03/2024 and data from the offset applications from EU ETS 1 installations as of 18/03/2024.
The deadline by which the adjusted additional demand for nEZ for the 2021 – 2026 calendar years must be published is specified in Section 36(3) BEHV. These deadlines are shown in the following table:
| Calendar year | Publication deadline (Section 36(3) BEHV) |
|---|---|
| 2023 | 31/03/2025 |
| 2024 | 31/03/2026 |
| 2025 | 31/03/2027 |
| 2026 | 31/03/2028 |
Publication of the cap increment amount in the Federal Gazette
The cap increment corresponds to the fuel emissions for which a contribution was made in both the EU ETS 1 and the nEHS. These double-balanced emissions are allocated to the EU ETS 1 and not to the nEHS, which is why the nEHS cap is increased by this amount. We will determine the increased quantity and publish it in the Federal Gazette.
Annual increment amount for the years 2021 to 2024 in the Federal Gazette (available in German only)
Veröffentlichung der jährlichen Erhöhungsmengen für die Jahre 2021 bis 2024
Sales reports
The Federal Republic of Germany has offered emission allowances (‘nEHS allowances’) for sale under the national emissions trading scheme (nEHS) since October 2021. The sales are conducted twice a week on the European Energy Exchange (EEX) in Leipzig. We regularly keep the public and market participants informed about the results of the sales through evaluation reports.
Our regular sales reports contain a detailed evaluation of the German sales results as well as comprehensive information on the sales process.
Carbon leakage
Reports on the BECV consultation procedure
Since 2022, we have been evaluating the impact of the BECV by conducting an annual consultation (Section 26(2) BECV).
The objective of this is to determine the impact of CO2 pricing within the framework of the national fuel emissions trading system and compensation mechanism for carbon leakage on the competitive situation of companies based in Germany. The consultation is directed at interest groups working for affected sectors and sub-sectors, social partners and other carbon leakage experts.
The consultation process from 2024 involved two main components: firstly an online survey and secondly, a discussion of the results at an expert forum. The final report summarises the results of both sub-processes. It is part of the annual report on BECV, which the Federal Government is mandated to submit to the Bundestag each year by September 30th. It was initially included in this context when the report was first published.
Central topics
- Effect of the CO2 price and carbon leakage offsetting
- Concrete design of the State aid, the environmental service in return and the relief for companies with a low total energy consumption of fossil fuels
- Experiences with the procedure for applying for carbon leakage compensation for the accounting year 2022
As in the previous year, the Ecological-Social Market Economy Forum (Forum Ökologisch-Soziale Marktwirtschaft - FÖS) supported us in the 2024 consultation process following a public call for tenders and the awarding of the project.
The BECV consultation procedure 2025 will again include an online survey and an expert forum. The publication of the final report is planned for autumn 2025. For this, we will again launch a public call for tenders.
Reports (available in German only)
Evaluation reports on offsetting carbon leakage
In accordance with the BEHG Carbon Leakage Ordinance (Section 26(1) BECV), we, the German Emissions Trading Authority at the German Environment Agency, publish the results of the application procedure in the year following the submission of applications. A detailed evaluation of the results for 2021 (CLK Report 2021) was published on 27/03/2024. A similar publication for the 2022 application year (CLK Report 2022) is planned for mid-2024.
To the report (available in German only)
Transparency reports on carbon leakage compensation
The European Commission's authorisation text stipulates that the Federal Republic of Germany is obliged to publish some data on companies receiving State aid in excess of 100,000 euros. DEHSt complied with this obligation by publishing the 2021 Transparency Report on Carbon Leakage Compensation on 27/03/2024.
Transparency report (available in German only)
EU ETS 1 Offsetting
Evaluation report on offsetting by EU ETS 1 installations in the nEHS 2021 and 2022
The first evaluation report on offsetting by EU ETS 1 installations in the nEHS for the years 2021 and 2022 was published on 29/05/2024. The main results of the offsetting process are analysed in accordance with Section 11 of the BEHG Double-Balancing Ordinance (BEDV). The offsetting data for the EU ETS 1 is analysed and the enforcement perspective is presented.