CO2 emissions that do not arise as a direct and immediate result in a process pursuant to Section 2(29)(b) ZuV 2020 are not eligible for allocation as process emissions type b. If no measurement data are available to determine these emissions, conservative estimates should be made in accordance with Section 6(4) ZuV 2020 on the basis of good industrial practice and current scientific and technical information.

The process is explained below using an installation for firing backing bricks as an example.

A possible reference point for determining the incompletely oxidised carbon can be the state of the raw gas, i.e. before it enters the thermal afterburner (TNV) downstream of a kiln. The basis for a conservative estimate of the non-oxidised carbon in the raw gas can be the maximum permissible concentration in the raw gas (organic compounds and carbon monoxide) before the TNV according to the technical data provided by the manufacturer. If these data are not available, literature data that must meet current scientific criteria can be used. For example, Table 3.4 in the 'Bulletin on Best Available Techniques in the Ceramics Industry' (BAT-Bulletin Ceramics 08.2007) ['Merkblatt über die Besten Verfügbaren Techniken in der Keramikindustrie' (BVT-Merkblatt Keramik 08/2007)] contains such data. The prerequisite for this is that the literature data used for the estimation describe the installation sufficiently conservatively, that means the amount of non-oxidised carbon in the installation’s raw gas is not underestimated.

According to the BAT Bulletin for Ceramics, the carbon monoxide concentration and the carbon concentration from volatile organic compounds in the raw gas are 1500mg CO/m³ and 250mg C/m³. For the stoichiometric factor for converting CO to C of 0.4288, a maximum carbon concentration in the raw gas Craw gas can be derived as follows:

Craw gas = (1500 *10-9 * 0.4288 + 250 *10-9) t C/m³ = 893*10-9 t C/m³

The amount of emissions ARcorrection (in t CO2) that cannot be allocated in the allocation element for process emissions type b can be estimated as follows:

ARcorrection = Craw gas * Vraw gas * t-operation * (1 - Cbio process) * 3.664

with

Vraw gas maximum flow rate of raw gas in m³/h according to the technical data specified by the manufacturer or the maximum value from Table 3.5 in the BAT information sheet for ceramics

t-operation number of operating hours of the TNV for the respective year

Cbio process biogenic carbon content of the materials used whose emissions are to be allocated to the allocation element with process emissions.

3.664 stoichiometric factor for converting carbon to carbon dioxide

For ARcorrection the annual activity rate of the process emissions ARtype b eligible for allocation, is calculated from the emissions of the materials used; they are allocated to the allocation element with process emissions (ARtotal), as follows:

ARtype b = ARtotal - ARcorrection

The annual value ARtype b is entered in the field 'Annual value of process emissions' in the FMS.

The estimation procedure must be described in detail in the allocation application (accompanying document, if applicable). The verifier must confirm that the assumptions on which the estimation process is based, in particular the derivation of the raw gas concentration and the above mentioned C-containing materials, describe the actual conditions of the installation in a sufficiently conservative manner.

Due to the decision of the European Commission 2013/448/EU of 05/09/2013, in which the application of the product benchmark for liquid pig iron was determined differently from the original procedure presented in answer 33, the answer is to be regarded as irrelevant.

According to the decision cited, the product benchmark is always applied to the installation in which liquid pig iron is produced in accordance with the definition of product benchmark in Annex I of Decision 2011/278/EU.

Operators and aircraft operators must submit their emissions reports for the previous year to the German Emissions Trading Authority by 31 March each year.

By 31 March, the verifier commissioned by you must have entered or confirmed the volume of the verified CO2, N2O and PFC emissions (VET value), in the Union Registry in CO2 equivalents. The entry can also be made by the operator's authorised representatives, but not its confirmation. However, the entry and the confirmation of the entry must always be made by two different people.

If there were no emissions for the respective greenhouse gas, '0' must always be entered. If the operator or the aircraft operator had no emissions at all, '0' should be entered in all three fields.

By 30 April of each year, operators and aircraft operators must surrender the number of allowances in the Registry corresponding to the emissions caused and verified in the previous calendar year.

The surrender must be initiated by the authorised representative of the respective operator or aircraft operator holding account.

Installation and aircraft operators must submit their emission reports for the previous year to the German Emissions Trading Authority by the 31/03 of each calendar year.

Commissioned verifiers must introduce and approve the amount of verified CO2 , N2O and PFC emissions (VET value) always in CO2 equivalent in the Union Registry by 31/03.

If there have been no emissions for any of the greenhouse gases, always a "0" must be entered. If the installation or aircraft operator had no emissions at all, a "0" must be entered in all three boxes.

Entries but not their approvals can also be made by authorised representatives of the operator account. The entry and the approval of the entry must always be carried out by two different individuals.

By the 30/04, installation and aircraft operators must surrender to the Registry the number of allowances which corresponds to the emissions caused and verified in the previous calendar year.

This surrender must be executed by one of the authorised representatives of the respective operator or aircraft operator holding account.
The Registry verifies whether the surrendered number of allowances corresponds to the verified emissions (VET entry).

If in previous years an installation or aircraft operator submitted more allowances than the verified emissions accounted for, this positive transfer is credited to the surrender obligation of the next year.

Any existing positive or negative amount of the 2013-2020 trading period will be taken over into the new 2021-2030 trading period.

Exhaust gas or waste gas combustion or afterburner facilities are usually waste gas treatment plants. Their purpose is waste gas cleaning and compliance with officially prescribed limit values. As per Section 2(2) of the Greenhouse Gas Emissions Trading Act (TEHG), they are thus an installation or the ancillary equipment of an installation requiring a permit. Emissions from exhaust gas combustion plants fall under the provisions of the TEHG as a part of an installation/ancillary installation if the main facility is an activity within the meaning of Annex 1 TEHG.

Emissions from exhaust gas combustion plants also come under the TEHG if they are a separate part of the installation/ancillary installation requiring a permit and come under Annex 1 TEHG (for example, as a combustion plant with a rated thermal input > 20 MW).

If emissions from an exhaust gas combustion plant come under the TEHG, the CO2 emissions calculation is differentiated by fuel. Separate information on the composition, volume and oxidation factor of the exhaust gas burnt in the installation is required.

Pursuant to Section 23 of the Greenhouse Gas Emissions Trading Act (TEHG) in conjunction with the corresponding announcement in the Federal Gazette (Bundesanzeiger), the German Emissions Trading Authority (DEHSt) has stipulated that the operator of an installation falling within the scope of the TEHG must only use the electronic format templates available on the DEHSt website for the application for the allocation of allowances as per Section 9(2) TEHG and that the form templates completed by the applicant shall be submitted electronically. The electronic form templates and any other requirements to be met by the operator in the electronic application process are explained and made available on this website.

In addition, it is stipulated that communication must also take place electronically in the administrative procedure for the implementation of the TEHG, and that the requirements contained in the above-mentioned notification on the form of encryption must be observed. There are basically no exceptions to this.

The processing of data for accounts is regulated by the Regulation (EU) 2019/1122 in the following manner:

• Operator holding accounts in Art. 14
• Aircraft operator holding accounts in Article 15
• Trading accounts in Article 16
• Verifier accounts in Article 18
• Nomination of authorized representatives in Article 21

Article 18 of Regulation (EU) 389/2013 continues to regulate data processing at the account opening of person holding accounts in the national Kyoto-registry.

You can view this information in the Union Registry as follows: Accounts > Show details > Balance. There is a 3 in the column trading period for the 2012-2020 period, and a 4 for the 2013-2020 period.

Aviation allowances (aEUA, sometimes also referred as EUAA) can be used for emissions since the 4th trading period beginning in 2021 for surrender also by operators of installations in the stationary sector. This also applies to Swiss aviation allowances (CHUA).

Conversely, it is also possible for aircraft operators to use EUAs (and also CHUs of the Swiss system) of the stationary sector for surrender.

No. Individual serial numbers of transactions cannot be selected. The Union Registry displays no serial numbers.

Within a trading period the surplus allowances will be offset against next year's surrendering obligation. From the transition between the 3rd and 4th trading period on, a surplus will not be deleted. Negative and recently also positive values will be carried over to the new trading period.

Accounts contain an alterable list of trusted accounts (TAL). As a standard operator holding accounts and aircraft operator holding accounts (operator accounts) can only perform transactions to trusted accounts. Accounts which are newly added to the TAL only become operational after a delay of four working days at 12:00 noon CET. Additions of accounts always have to be approved by two authorised representatives. Account holders can apply to allow transactions to non-trusted accounts. The account holder can also apply to change the 4-eye principle to the 2-eye principle. For both settings account holders have to apply in the account via the index-tab ‘Trusted Accounts’ in the section ‘Trusted Account List Preferences’.

Transactions to non-trusted accounts can only be proposed for execution with the 4-eye-principle.

Accounts of the same account holder (identical account holder number in the Union Registry) are automatically included on the TAL, as well as the surrender, deletion and return of excess allocation account.

Transactions to trusted and non-trusted accounts are executed in the following manner:

Transactions to accounts which are not on the trusted account list:

• If they are proposed for execution before 12:00 CET, they will be executed before 12:00 CET on the following business day
• If they are proposed for execution after 12:00 CET, they will be executed before 12:00 CET on the second business day after which the transactions have been arranged
• A transaction can be aborted up until two hours before its execution by a single authorised representative.

Transactions to accounts on the trusted account list:

• They will be executed immediately if they were proposed for execution between 10:00 and 16:00 CET on a business day
• They will be executed the same business day at 10:00 CET if they were proposed for execution before 10:00 CET
• They will be executed the following business at 10:00 CET if they were proposed for execution after 16:00 CET

Please refer to our overview of the transaction rules.

No, borrowing in the sense of using EUAs beyond the limits of trading period, is not allowed.

EUAs and aEUAs are valid from the trading period on in which they were generated.

This is why a deletion and replacement of EUAs and aEUAs is no longer necessary. EUA and aEUA do not lose their validity anymore. However, EUAs and aEUAs issued or auctioned can be used for all years within the same trading period and subsequent trading periods, for instance allowances allocated in 2024 may be used to cover emissions of 2023.

A special case represents the surrender until the 30/04/2021. EUA or aEUA which are allocated in February 2021 cannot be used for the surrender until 30/04/2021, since these allowances are allowances of the 4th trading period but the surrender until 30/04/2021 covers emissions from the 3rd trading period. Therefore, this would represent a case of unallowed borrowing over several trading periods.

Operator holding accounts may perform transactions to accounts not on the trusted account list, given that the account holder applied for the respective setting in the account via the index-tab ‘Trusted Accounts’ in the lower part of the section ‘Trusted Account List Preferences’. Such applications have to signed in a legally valid manner and have to reach us by VPS. For further information please refer to our overview of the transaction rules.

Emission allowances (EUAs) and aviation allowances (aEUAs) can only be held in Union Registry accounts or accounts of linked systems such as the Swiss Emissions Trading Scheme (EU 100 or CH accounts).

EUAs,aEUAs, CHU and CHUA are not transferable to accounts in those national Kyoto Registries whose accounts begin with a Member State’s country identification (e.g. DE 121 accounts), with the exception of Swiss accounts

Swiss allowances (CHU) and Swiss aviation allowances (CHUA) can be held in EU-100 accounts.

CERs and ERUs can be transferred both to accounts in a national Kyoto Registry and to accounts in the EU ETS area of the Union Registry. The latter will only be possible until 30/04/2021.

For transactions of CERs and ERUs to EU-100 accounts they must be approved for an exchange.

From 01/05/2021 CER and ERU can no longer be transferred to EU-100 accounts. Holding CER and ERU on such EU-100 accounts will only be possible until 01/07/2023.

From 01/01/2021 on aEUA and CHUA can also be held by stationary operator holding accounts. However, they cannot be used by operator holding accounts yet for the surrender procedure until 30/04/2021. But, in the following year for the surrender until 30/04/2022 they can be used for surrender also by operator holding accounts.

Transactions from trading, operator and aircraft operator holding accounts to accounts on the trusted account list will be executed immediately if they were proposed for execution between 10:00 and 16:00 CET on a business day. Transactions to accounts which are not on the trusted account list will either be executed the following business day, in case they were proposed for execution before 12:00 CET, or in case they were proposed for execution after 12:00 CET on the second business day following the day of proposal for execution.

For further information please refer to our overview of the transaction rules.

A confirmation of an amended or new mobile number by the German Emissions Trading Authority (DEHSt) at the German Environment Agency is required.

You will be notified to this effect when logging into the Union Registry. Simply click on "Update my number" and confirm the change.

The Union Registry generates an identifier, which you should make a note of for any related questions to DEHSt. DEHSt will process the submitted change requests as quickly as possible.

It is not necessary to submit the change in writing or by VPS. We will inform you of the confirmation of your mobile number.

Please note that, although you can save several mobile numbers at ECAS, you can only log into the Union Registry with the one confirmed mobile number.

The Union Registry only allows confirmation of one mobile number.

Should a confirmed mobile number change, it must be re-confirmed by the DEHSt.

Authorised representatives (AR) can be added via the index-tab ‘Authorised Representatives’ using the button ‘Add AR’.

If an existing representative shall be replaced or removed instead of adding a new representative ‘Replace’ or ‘Remove’ is to be used.

The task needs to be approved by DEHSt.

When a person is to be assigned first time in the Union Registry a URID (union registry identifier) needs to be created by that person first.

The process is explained in depth on the section about accounts.

The completed application including proof of authorisation needs to be sent to the DEHSt using the Virtual Post Office (VPS) service when concerning Operator Holding and Aircraft Operator Holding Accounts. For other account types letter post with the completed application signed authorised personnel may be used instead. You will find an overview of which documentation is required.

Please scroll down to the appropriate account type and select the according document. Here you will find all the necessary information.

There are four different types of authorised representatives for EU-100 accounts

• Initiator: This authorised representative can initiate transactions and processes
• Approver: This authorised representative can approve transactions or processes which already have been initiated
• Initiator/Approver: This authorised representative can both initiate and approve transactions and processes, but not the self-initiated
• Authorised representative with read-only access.

As also accounts which have adopted the 2-eye-principle have certain processes which need approval of two authorised representatives at least two authorised representatives have to be nominated. One needs to pay attention that at least always one authorised representative has the right to initiate processes and second one has the right to approve processes. This why accounts always need to have at least the following combination of roles:

Initiator + Approver

Initiator/Approver + Approver

Initiator + Initiator/Approver

Initiator/Approver + Initiator/Approver

Generally, the initialisation of tasks like for example editing account holder information, entering verified emissions, assigning or removing a verifier, adding, replacing, removing AR or AAR or changing the trusted account list is limited to the roles of Initiators and Initiators/Approvers. Most of these tasks need approval by a second authorised representative with the role of Approver or Initiator/Approver– if the account applies the 4-eye-principle.

Authorised representatives with the role of Initiator or Initiator/Approver can assign Verifier Accounts to Operator Holding and Aircraft Operator Holding Accounts via the index-tab ‘Verifier’

An authorised representative of the verifier account must approve the assignment using the verifier account’s task list.

According to the Registry Regulation (EU) 2019/1122 Article 22 Paragraph 1 account holders have to confirm to DEHSt that the information on their accounts is complete, up-to-date, accurate and true by the end of each year. This ensures that important mailings are received by the authorised representatives and that (Aircraft) Operator Holding Accounts’ surrender transactions can be carried out the following April.

For the confirmation the account information we provide a form in the registry (Section C 'Annual confirmation of the account information') Please refrain from sending informal confirmations.

In order to eliminate your mobile phone as a cause please reboot the phone and try to log in again.

If possible you can also put your SIM card into a different device and try to log in again. Should the issue persist further inquiries need to take place.

Since the Union Registry is being managed by the European Commission and the access authentication is being provided by EU-Login (European Commission Authentication Service) the DEHSt can only forward your requests for further processing.

For a quick handling you can contact the EU-Login Help Desk directly via EC-CENTRAL-HELPDESK@ec.europa.eu

You will find further instructions on the necessary information on the EU-Login website.

To streamline the processing of your issue please fill in this questionnaire beforehand:

1. EU-Login UID (on the EU-Login website -„My EU-Login Account Details“ in the third row)
2. Full Phone number including country code
3. Provider/carrier + the country the user is located in
4. If it was working in Roaming mode or not
5. Has the number been transferred between providers or is it the original provider?
6. The Device Type and Brand + imei (if possible)
7. Complete sequence followed before the issue occurred
8. Has any EU-Login challenge already been working with that number at that provider?
9. The Date of last successful received sms challenge/other sms
10. Are other users with same provider affected?
11. The Date of last modification in EU-Login if any (mobile phone, others...)
12. May the End-User directly be contacted by the Service Desk (EU-Login) or not?

Please note that processing of the issue can only start after reception of the questionnaire.

Subsequently three SMS will be sent. Please provide the content of the messages received and their timestamp to us or the EU-Login help desk in case you chose to contact them directly.

The Markets in Financial Instruments (MiFIR), Regulation (EU) No 600/2014 is the accompanying regulation of the revised Financial Instruments Directive (2014/65/EU). The regulation specifies transparency requirements for trading venues and reporting obligations for participants in emissions trading (market stakeholders and account holders).

In its function as the national market regulation authority and responsible for the implementation of the Directive on Markets in Financial Instruments (MiFID) II/Regulation on Markets in Financial Instruments (MiFIR), the Federal Financial Supervisory Authority (BaFin) provides information on reporting obligations in accordance with the following provisions:

• European Markets in Financial Instruments Regulation (MiFIR)
• Market Abuse Regulation of the European Union (MAR)
• European Market Infrastructure Regulation (EMIR).

The Federal Financial Supervisory Authority (BaFin) is responsible for information on transactions in financial instruments and the duty to report.

As reported by BaFin on 24.02.2017, an active Legal Entity Identifier (LEI) is required in the case of transactions subject to reporting obligation pursuant to Article 26 MiFIR from 03.01.2018 on. According to Article 26 MiFIR, all transactions in financial instruments (including EUA, aEUA, CER and ERU from 2018) must be reported to the BaFin. The prerequisite for this is the unambiguous identification of customers (legal entities or partially legal entities such as OHG, KG or GbR) using uniform identification numbers called LEI codes. This applies both to the purchase and sale of financial instruments. Stakeholders such as securities firms identified by MiFID II and trading venue operators (including operators of multilateral and organised trading systems) are obliged to report. Securities firms and trading venue operators must report transactions made through them or their platforms. This rule also applies if the customers themselves may not be subject to the Regulation.

The extent to which market stakeholders and account holders who are neither securities firms nor trading venues need to have an LEI code depends on where a transaction is made. It is to be assumed that, for example, OTC transactions between account holders are not covered by the MiFIR reporting obligation, unless the account holder himself is classified as a securities firm under Article 4 MiFID II. Transactions (both purchases and sales) performed via securities firms specified by MiFID II and/or trading venues are obliged to be reported.

Securities firms and trading venues are required to report their customers' transactions. In principle, an LEI code is required to identify the customer.

LEIs are issued by Local Operating Units (LOUs). A list of all LOUs and further information can be found below.

The monitoring plan in the FMS must be completed in full and in accordance with the plant set-up.

The relief for low-emission installations shown in the following table can only be claimed if no activities are carried out in the installation for which N2O emissions are subject to monitoring pursuant to Annex 1(2) TEHG (see Article 47(1) MRR). If this is the case, the question: 'Are N2O emissions monitored?' must be answered with 'No' on the 'Cover sheet' form.

'Installation' form

Field	Answer	Additional information
Categorisation of the installation as per the Monitoring & Reporting Regulation	A	… if the installation emits ≤ 50,000 t CO2eq per year.
Is it a low-emission installation?	Yes	… if the installation emits < 25,000 t CO2eq per year. (Note: The field is automatically filled in with 'No' if activities are carried out in the installation for which N2O emissions are subject to monitoring as per Annex 1(2) TEHG).

'Source stream forms'

Quantity consumed	Answer	Additional information
Level according to Monitoring & Reporting Regulation (target level)	Field is automatically filled in	... depending on the 'Categorisation of the installation according to the Monitoring & Reporting Regulation ('Installation' form) and the 'Activity according to Annex IV Monitoring & Reporting Regulation’ (Page 1 of the source stream form).
Envisaged level	Estimated value or entry of the envisaged level	In principle, purchase records can be used and inventory changes can be estimated. If the operator measures the input volume himself and knows the uncertainty of his measurement, the corresponding level must be entered.
Is there a deviation from the level according to the Monitoring & Reporting Regulation?	No	… as allowable relief.
Measuring instrument	No measuring instrument	… if the source amount is determined on the basis of purchase data.
Description of determination method	Determination based on purchase records and estimation of inventory changes	If the operator performs the measurements himself, the determination method must be described.
Note: If the operator measures the substance volumes himself, ‘Measuring instrument’ forms must be created and completed. However, an uncertainty assessment can be dispensed with.
Calculation factors	Answer	Additional information
Level according to Monitoring & Reporting Regulation (target level)	Field is automatically filled in	…depending on the ‘Categorisation of the installation according to the Monitoring & Reporting Regulation‘ (‘Installation‘ form) and the ‘Activity according to Annex IV of Monitoring & Reporting Regulation‘ (Page 1 of the source stream form).
Envisaged level	Level 1/ Level 2a	As it is generally sufficient to comply with Level 1 when determining calculation factors, ‘Level’ can be indicated in the field unless the substance is included in the DEHSt list. The DEHSt list corresponds to Level 2a.
Is there a deviation from the level according to the Monitoring & Reporting Regulation?	No	… as allowable relief.
Determination method	Standard figure	If standard factors are used, ‘Standard figure’ should be entered into the field.
Data source	Field is automatically filled in	The field ‘Name of substance’ is automatically filled in depending on the selection.
Description of data source or determination method	Indication of source for the standard factor	If the entry ‘Other’ appears in the field ‘Data source’, the data source (e.g. bibliography) for the standard factor used must be specified.
Note: The ‘Analysis method’, ‘Frequency of analysis’ and ‘Laboratory’ fields do not have to be filled in if standard factors are used. However, if analyses are carried out, it must be shown that the requirements of Article 32-35 MRR have been complied with. The fields mentioned above and the forms ‘Analysis method’ and ‘Laboratory’ must then be filled in as for all other installations.

Further notes:

• Low-emission installations are exempt from submitting a risk assessment (that is evidence that the stipulated control activities adequately address the identified risks of reporting errors and deviations from the monitoring plan) according to Article 47(3) MRR. However, sources and causes (risks) of potential errors and deviations from the monitoring plan must be identified in the ‘Explanation of risks’ field on the ‘Data management’ form, even for low-emission installations (compare Annex I Section 1(1 e) MRR and Article 58(2) MRR).
• An improvement plan based on recommendations of authorised experts is not required. An improvement plan only needs to be submitted if the operator still falls short of the relief allowed by the MRR for low-emission installations (compare Chapter 4.4 in the Guidance Document on the Preparation of Monitoring Plans).

Determination of the substance quantity of natural gas

Individual uncertainty evidence for compliance with the MRR level requirements is not necessary if natural gas is obtained from the general gas supply network and the determination of the substance quantity of natural gas is based on calibrated quantity measuring instruments (flow meter and volume converter). If this is the case, no further documents are required to prove calibration.

Determination of the emission properties of natural gas

In Germany, the parameters of thermal gas billing for the general natural gas supply from the grid are determined according to one of the following three standardised procedures using calibrated measuring instruments. Unlike for other substances, this enables the derivation of the calculation factors required for emission reporting:

A) Analysis by calibrated measuring instruments:

A1) The net calorific value and CO2 emission factor of natural gas delivered to the installation subject to emissions trading are determined from the composition data measured by calibrated process gas chromatographs (full analysis). Sampling and analysis of the gas are carried out in accordance with the standards DIN EN ISO 10715, DIN EN ISO 6976 or DVGW G 488. The C content is calculated stoichiometrically.

A2) Gas property data (calorific value, standard density and CO2 mass fraction) of the gas delivered to the installation subject to emissions trading can be determined by suitable calibrated calorific value, standard density and CO2 measuring instruments (for example correlative calorific value meters, reconstruction systems for gas property data). Sampling and analysis are carried out according to the standards DIN EN ISO 10715 or DIN EN ISO 6976.

B) Calculation using ‘mean value method’:

B3) The calorific value of the gas supplied to a supply network is calculated from the calorific values of the supply at one or more supply points in the network (mean value procedure as per DVGW G 685). This procedure does not include any direct sampling or direct analysis of the gas supplied to the respective installation subject to emissions trading. All three procedures meet the highest MRR level requirements, thus individual verification is unnecessary. The operator of an installation subject to emissions trading determines the procedure used for its installation from the gas supplier or network operator (A1, A2 or B3) and integrates the relevant information in its monitoring plan.

‘Analysis method‘ form

Field	A1	A2	B3
Analysis method	Process gas chromatographs	Suitable calibrated calorific value and CO2 meters	Averaging method as per DVGW G 685
Naming the standards	DIN EN ISO 10715, DIN EN ISO 6976, DVGW G 488	DIN EN ISO 10715, DIN EN ISO 6976	DVGW G 685
Information on procedural instruction	Entering 'N/A' in the fields on procedural instruction	Entering 'N/A' in the fields on procedural instruction	Entering 'N/A' in the fields on procedural instruction

Determination of the calculation factors relevant to emissions trading (net calorific value (NCV) and emission factor (EF))

The calculation factors ‘net calorific value’ and ‘emission factor’ (or C content for use in a mass balance) are required to determine CO2 emissions from natural gas using the calculation method. The gas property parameters such as calorific value, standard density and CO2 mass fraction are often only available for thermal gas billing, which is prepared in Germany according to the standardised procedure in accordance with the DVGW worksheet G 685 (cooperation agreement between the operators of gas supply networks located in Germany – KoV Gas). The emission factor (or C content) and net calorific value of the supplied gas can be determined from these gas property parameters with the help of an algorithm.

This is done using the alternative calculation method described in the G 693 DVGW Worksheet. Operators can carry out this calculation method themselves or have it carried out by a commissioned third party. Some network operators offer this service. The method used to determine the relevant calculation parameters ‘emission factor’ (or C content) and ‘net calorific value’ from the data provided by the gas supplier should be entered in the field ‘Description of data source or determination method’ on the source stream form. If the C content must be indicated, this can be determined from the emission factor, net calorific value and the conversion factor of 3.664 t CO2/t C.

Field	A1	A2	B3
Source stream form
Has sampling been carried out?	Yes	Yes	Yes
Designation of the sampling plan	N/A	N/A	N/A
Information on the procedural instruction	Enter 'N/A' in the fields on the procedural instruction	Enter 'N/A' in the fields on the procedural instruction	Enter 'N/A' in the fields on the procedural instruction
Data on EF and NCV
Determination method	Analysis	Analysis	Analysis
Description of data source or determination method	Calculation of NCV and EF from the composition data of the full analysis *	EF/C content and NCV: determination according to the alternative calculation method described in the G 693 DVGW Worksheet.**	EF/C content and NCV: determination according to the alternative calculation method described in the G 693 DVGW Worksheet.**
Analysis method	Select the analysis method to be used	Select the analysis method to be used	Select the analysis method to be used
Frequency of analysis	Continuous	Continuous	Monthly average
Laboratory	No laboratory	No laboratory	No laboratory

* If, instead of exact composition data, the gas supplier can only provide information on the calorific value, standard density and CO2 content, proceed as for A2 or B3.

** A reference to the G 693 DVGW Worksheet is not sufficient. The operator must always explain his calculation method for the net calorific value and emission factor in the monitoring plan.

Up to the end of 2019 DEHSt granted approval for amendments to a monitoring plan predominantly with effect for the past, even if the operator has already applied the amended monitoring plan at the time of notification or approval.

However, according to the provisions of Articles 15 and 16 of the Monitoring & Reporting Regulation (MRR), the operator should normally receive the approval before its application. In deviation from this rule, Article 16(1)(1) MRR, last half-sentence, only permits a retrospective approval from the date of application in exceptional cases. Accordingly, a retrospective permit may only be granted if monitoring based on the previously approved monitoring plan leads to incomplete emission data.

Based on these MRR requirements, DEHSt will approve significant changes to a monitoring plan that the operator makes in his installation from 01/02/2020 onwards with the following conditions:

1. The operator shall notify DEHSt of significant changes to the monitoring plan in time before they are applied unless there are exceptional reasons. In the event of timely notification, DEHSt shall issue the approval with effect from the date of the announced application.
2. If the amendment to the monitoring plan has been notified prior to its application but has already been applied at the time of approval, DEHSt shall issue the approval retrospectively to the date of application, provided that the approval can be issued without any further substantive objections.
   The retrospective effect of the approval cannot go back further than 1 January of the current monitoring period. The VPS date of receipt of the notification is decisive when determining the current monitoring period. Notifications received by 31 March of a year are still valid for the monitoring period of the previous year.
3. In the case of notifications of significant changes received by DEHSt only after their application, retrospective approval is only possible within the limits of Article 16(1)(1) MRR. This means that an approval will only be granted with effect for the past if monitoring according to the previously approved monitoring plan results in incomplete emission data. Incomplete emission data may result, for example, when a defective measuring instrument must be replaced or a laboratory that has lost the required accreditation must be changed.
   Here, too, the retrospective effect of the approval cannot go back further than 1 January of the current monitoring period.
4. If DEHSt is notified of significant changes to the monitoring plan only after they were applied and monitoring under the previously approved monitoring plan continues to produce complete emission data, DEHSt shall in future only approve these changes with effect for the future. This means that the approved amendment may only be used as a basis in the emissions report from the notification of the approval notice onwards (VPS date of receipt of the approval notice at the operator). Before receiving approval, the released emissions must be reported using the monitoring method approved until then.

1. How often is the fuel stream "waste wood" to be sampled and analysed?

1a) Sampling:

The requirements for sampling frequency are derived from Chapter 7.2.2 and Annexes 1 and 2 of the DEHSt Guidance Document for the creation of Monitoring Plans. If there are legal requirements, for example from the Federal Immission Control Act (BImSchG), or in-house specifications that go beyond the requirements of the Monitoring & Reporting Regulation (MRR), they must also be used for sampling according to MRR. Representative sampling must be ensured. For waste wood as ‘other solid fuel’, an individual determination of the sampling frequency is required depending on fuel heterogeneity. The necessary frequency results from the actual conditions in the installation (for example delivery and storage) and the origin and composition of the waste wood used. If waste wood is delivered from outside, the first approach should be to sample each batch delivered to ensure a representative sample. However, if the fuel arises as waste from the operator's own production, there are no delivery batches. Here, the operator must individually check and determine where and how often to sample.

Waste wood can be very heterogeneous in terms of composition and material properties. Therefore, it is important to provide a sampling procedure that yields representative samples for the respective period and is free from systematic errors. A major potential error is that particularly large pieces (for example railway sleepers) cannot be included in the sampling. The sampling must be designed in such a way that three times the diameter of the largest pieces (largest grains) can still be taken into account. When lumpy waste wood is delivered, sampling should therefore be carried out after shredding if possible. We refer to the publication on sampling of solid secondary fuels linked in Annex 8 of the Guideline and to the Excel work aid for calculating the representativeness of sampling. The individually proposed sampling method and the associated sampling plan must be agreed with DEHSt.

1b) Analysis:

According to Article 35 MRR, analyses shall be carried out at least at the frequencies specified in Annex VII MRR. For this purpose, composite or aggregate samples may be formed from the individual samples. Annex VII MRR considers the minimum requirement for ‘untreated solid waste’ that every 5,000 tonnes of waste should be analysed and at least four times a year. In most cases, pre-treatment (for example sorting, shredding) of the waste wood takes place; this makes the composition and material properties more homogeneous. Pre-treated waste wood can be classified as ‘pre-treated solid waste’. For this group of substances, every 10,000 tonnes of waste and at least four times a year must be observed as a minimum frequency of analyses.

2. What are the requirements for the analysis method for the ‘Waste wood’ fuel stream?

The method requirements for analysing waste wood are described in Annex 3 of the DEHSt Guideline under ‘Other solid fuels’. DIN EN ISO 21644 can be used for determining the biogenic carbon content in compliance with the stated scopes for the individual methods. According to DIN EN ISO 21644, in addition to the 14C method, the selective solution method can also be used for waste wood. However, outside the concentration range of ten to 90 percent biogenic content, the reliability of the selective solution method decreases (Annex D.2 DIN EN ISO 21644). It was individually assessed for waste wood that the selective solution method can nevertheless be applied since the reliability of the method is good for this material according to Annex D.1. The reliability of the 14C method also decreases with increasing biogenic fractions in the waste wood. Both methods are nevertheless applicable for waste wood.

In principle, continuous emission measurement in waste gas can also be used for installations using waste wood. The biogenic carbon content can be determined according to DIN EN ISO 13833 using the 14C method.

3. Are standard values for the biogenic carbon content available for the ‘Waste wood’ fuel stream?

The derivation of standard values is problematic because of the different compositions and heterogeneous material properties of waste wood.

Operators can make a level independent estimate for Category A1 waste wood as a relief according to Article 38(1) MRR as the waste wood A1 may consist exclusively of biomass. Therefore, a biogenic carbon content of 100 percent can be applied to this amount of waste wood. This does not apply to waste wood quantities that contain other waste wood categories in addition to A1.

In all other cases, the requirements for determining the biogenic carbon content are determined based on the general MRR specifications depending on the category of the installation and the size of the source stream. For many operators who burn waste wood in their installations, the use of a literature value agreed with DEHSt may therefore be permissible under Article 31(1)(c) in conjunction with Section 2.4 of Annex II MRR (Level 1) for waste wood.

A biogenic carbon content of 90 percent can be applied for waste wood as a literature value under certain conditions. The source for this value is the terms of use for the guarantee of origin register and the guarantee of region register (in force since 21/01/2020). A condition for the use of the above-mentioned literature value is that the waste wood fuel stream meets the definition of one of the AVV code numbers AVV 03 01 05, AVV 15 01 03, AVV 17 02 01, AVV 19 12 07. AVV refers to the waste catalogue ordinance.

Furthermore, this value can only be used if the mass-related proportion of wood-plastic composites in the source stream is negligible. The new wood composites Wood Polymer Compounds (WPC), for example, would be unsuitable due to the high proportion of plastics.

4. The other method for estimating the biogenic carbon content

The estimation of the biogenic carbon content via the recipe of the produced wood-based materials basically corresponds to an estimation according to MRR, which is approvable for de minimis source streams without further evidence, for other source streams only if can be proved that the case is unreasonable.

For operators who burn residues from their own production (for example chipboard), a calculation of the biogenic share from the recipe of higher level products can provide an estimate. The prerequisite for this is that the fossil carbon contents of the products’ composition are known and the internal production waste can unambiguously be assigned to the respective products. The determination via the recipe must be described to DEHSt in a traceable way.

Note on sustainability requirements for waste wood:

According to MRR and the Emissions Trading Ordinance (EHV) the definitions for “biomass” and “biomass fuels” from the Renewable Energy Directive (RED II) apply to European emissions trading. The term biomass in the MRR therefore differs from the term biomass in the meaning of the Biomass Regulation and the Biomass Electricity- Sustainability Ordinance. Hence, in European emissions trading the biogenic components in waste wood have to be considered as biomass.

The following applies to reporting from the 2023 reporting year onwards:

If biomass is used for combustion, the resulting biogenic emissions are only deductible if the biomass complies with the sustainability criteria and greenhouse gas reduction in accordance with Article 29 paragraphs 2 to 7 and 10 RED II as well as the mass balancing requirements in accordance with Article 30 RED II. According to section 3 paragraph 1 EHV the evidence that the above-mentioned requirements are fulfilled, has to be provided by a proof of sustainability from the Nabisy database of the Federal Office for Agriculture and Food (BLE). Details on the requirements can be found in our guideline for the preparation of monitoring plans and emissions reports for stationary installations, Chapter 8.