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Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

Climate action

The monitoring, reporting and verification of greenhouse gas emissions must be robust, transparent, consistent and accurate for the EU Emissions Trading System (EU ETS) to operate effectively. This initiative aims to update the existing monitoring and reporting rules before the beginning of phase 4 of the EU ETS (2021), in order to make them more efficient and actual.

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Public consultation

ID: 12104

Lobbying Activity

42 responses

Consultation response

Transport and Environment (European Federation for Transport and Environment), 23 Jul 2020

Transport & environment wishes to provide feedback to the process “EU emissions trading system – updated rules on monitoring and reporting”. The main concern for Transport & Environment in this regard is the zero emission factor that is provided to the use of biomass, meaning that the real…

Chemical Industry Seeks Carbon Capture Recognition in EU ETS

European Chemical Industry Council, 24 Jul 2020

Cefic requests recognition of carbon capture and use (CCU) as avoided emissions rather than reporting them as emitted. They want biogas rules allowing purchases without grid connection requirements and removal of sustainability criteria from biomass zero-rating. They seek clarification that CO2 transport includes ships and trucks.
Chemical companies would receive emissions credits for captured CO2 in products and expanded flexibility for biomass sourcing.
Environmental integrity weakens if unsustainable biomass receives zero-rating and CCU accounting lacks verification safeguards.

European Steel Association urges recognition of carbon capture technologies

The European Steel Association, 23 Jul 2020

The association requests that carbon capture and usage be incentivized through a consistent accounting framework. They also want emission rules to recognize CO2 transport via ships, trains, and trucks.
These changes would lower compliance costs by allowing industries to avoid surrendering expensive emission allowances.

Fuel industry seeks exemptions for waste biomass in emissions rules

FuelsEurope, 24 Jul 2020

The industry wants biomass waste fuels to have zero emission factors without meeting full sustainability criteria. They also request recognition of ships, trains, and trucks for CO2 transport, not just pipelines.
This would allow continued waste fuel use without proving sustainability credentials for each source.
Environmental groups lose verification that biomass waste fuels meet sustainability standards.

Consultation response

Fern, 13 Jul 2020

The current EU ETS and rules on monitoring and reporting do not take into account emissions from biomass burning (counted as zero). We argue that this is a concern and incoherent with the broader rationale of support to renewable energy under the Guidelines for State aid for environmental…

Consultation response

ENGIE, 16 Jul 2020

Upfront remark: Please refer to our position paper in attachment for more detailed explanations and amendments to the text proposal! ENGIE is a global player with a diversified portfolio of activities including power production from renewables and provision of infrastructure for transport,…

Consultation response

BDEW Bundesverband der Energie- und Wasserwirtschaft e. V., 23 Jul 2020

On 29 May 2020, the European Commission launched a public consultation concerning the draft Commission Implementing Regulation (EU) on the Monitoring and Reporting of Greenhouse Gases pursuant to Directive 2003/87/EC. The regulation provides a set of implementing rules for the fourth trading period…

Consultation response

International Association of Oil Gas Producers Europe, 24 Jul 2020

Please see attached the feedback from the International Association of Oil & Gas Producers.

Consultation response

EUROGAS, 24 Jul 2020

Please find attached the feedback from Eurogas

CEMBUREAU urges broader carbon capture and biomass waste recognition

CEMBUREAU - The European Cement Association, 22 Jul 2020

The group requests exemptions from sustainability criteria for fuels derived from biomass waste. They also want carbon stored through mineralisation to be counted as not emitted.
These changes would significantly reduce the industry's reported carbon emissions and compliance costs.
Environmental advocates lose the ability to verify the sustainable origin of industrial fuels.

Consultation response

Verband der Chemischen Industrie e.V., 24 Jul 2020

VCI-Beitrag zur Stakeholderkonsultation zur Monitoringverordnung: Berücksichtigung von CCU-Produkten in der MonitoringVO: Der jetzige Entwurf der Monitoring-Verordnung sieht Erleichterungen für CCU-Anwendungen ausschließlich für präzipitiertes Calciumcarbonat (siehe Artikel 49) vor. Aus Sicht…

Consultation response

Euroheat and Power, 20 Jul 2020

Euroheat & Power (EHP), representing the District Heating and Cooling sector (DHC) in Europe and beyond, welcomes the draft Commission Implementing Regulation on the monitoring and reporting of greenhouse gas emissions. EHP made comments in the attached document.

Snam advocates for market-based biogas accounting in EU ETS

Snam S.p.A., 24 Jul 2020

Snam proposes adopting a market-based approach using purchase records as the only methodology for biogas. They recommend using guarantees of origin to identify the source of renewable energy. The scope should include decarbonised gases like hydrogen.
This approach enables operators to secure additional revenues through price premiums for cleaner technologies.
Companies using average emission factors may face competitive disadvantages and limited decarbonisation choices.

Consultation response

Green Power Denmark, 24 Jul 2020

Danish Energy welcomes the opportunity to comment on the European Commission’s consultation on the draft Commission Regulation amending and correcting Implementing Regu-lation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the European…

Consultation response

Bellona Europa, 24 Jul 2020

Bellona Europa endorses the improvement of existing Rules on Monitoring, Reporting and Verification of the EU ETS MRV by making them both more efficient and more up to date exercise and strongly believes that correct and transparent accounting, enabled by accurate monitoring and verification of…

Consultation response

Gas Infrastructure Europe, 24 Jul 2020

GIE has 70 members from 26 European countries. They operate the European gas infrastructure (gas storages, LNG terminals and transmission pipelines) and support an EU-wide trustworthy system to document the green value of renewable and low-carbon gases such as Guarantees of Origin (GOs). GIE…

Consultation response

Environmental Defense Fund Europe, 24 Jul 2020

Environmental Defense Fund (EDF) welcomes the opportunity to comment on the EC’s plans to update rules on monitoring and reporting of emissions under the EU ETS for the period 2021-2030. The following comments focus on specific provisions for aviation fuels. The EC’s proposed amendments to Article…

Consultation response

European Network of Transmission System Operators for Gas, 15 Jul 2020

ENTSOG represents gas TSOs and with this response would like to support the Commission in the process of the revision of the Regulation 2018/2066 on the monitoring and reporting of GHG emissions (MRR). We endorse this initiative and suggest that MRR revision should be considered as an opportunity…

Czech Industry Urges Simplified Biogas Reporting in EU ETS

Svaz průmyslu a dopravy ČR, 24 Jul 2020

SP CR requests using existing certificates to prevent double counting of biogas. They propose expanding grid connectivity definitions and removing market value reporting requirements.
The proposal reduces compliance costs and simplifies reporting requirements for industrial biogas users.
EU authorities lose oversight of how state aid affects market values for subsidized biogas.

Consultation response

Zero Emissions Platform, 24 Jul 2020

The Zero Emissions Platform (ZEP) is a European Technology and Innovation Platform (ETIP) under the Commission’s Strategic Energy Technology Plan (SET-Plan), and acts as the EU’s technical adviser on the deployment of Carbon Capture and Storage (CCS), and Carbon Capture and Utilisation (CCU) under…

Consultation response

AGORIA, 23 Jul 2020

Agoria paves the way for all technology-inspired companies in Belgium that increase our quality of life through the development and application of technological innovations. The ETS is the EU’s flagship instrument to combat climate change, establishing a level playing field for decarbonisation for…

Consultation response

Holcim Ltd, 24 Jul 2020

Please find attached LafargeHolcim's perspective and proposals on the revision of the afore-mentioned MRR.

Consultation response

NaTran, 22 Jul 2020

GRTgaz welcomes the opportunity to provide a feedback on the European Commission proposal amending the « implementing Regulation on the Monitoring and Reporting of greenhouse gas emission » (« MRR ») related to the EU Emissions Trading System (« ETS ») following the adoption of Renewable Energy…

Consultation response

IFIEC Europe, 16 Jul 2020

IFIEC EUROPE’s response to EU consultation on Updated rules on Monitoring and Reporting Regulation (2021-30) 10 July 2020 IFIEC Europe welcomes the opportunity provided by the European Commission to give input on the draft updated rules on monitoring and reporting (2021-30) of the EU ETS. The…

Consultation response

CO2 Value Europe AISBL, 23 Jul 2020

CO2 Value Europe represents the CO2 utilisation community in Europe aiming to develop CO2 re-use as a feedstock for a new industrial sector making a significant contribution to Europe’s low-carbon economy. We call for a financial recognition of CO2 emissions that are avoided through putting CO2 to…

Consultation response

European Academies Science Advisory Council, 10 Jul 2020

We wish to comment specifically on the need to reform the ETS related to biomass use, since the current rules fail to reflect the effects of biomass use for energy on the climate. In particular, the effects of switching from fossil fuels to biomass for electricity generation has been widely…

Consultation response

European Lime Association, 23 Jul 2020

Introduction EuLA welcomes the possibility to comment and voice its concerns regarding the opening of a public consultation of the second revision of the Monitoring and Reporting Regulation (MRR) as announced by the European Commission (EC) on 29th May. Lime is a hard to abate sector, mainly due…

Consultation response

Global CCS Institute Ltd, 24 Jul 2020

The Global Carbon Capture and Storage Institute (the Institute) is an international think tank whose mission is to accelerate the deployment of carbon capture and storage (CCS), a vital technology to tackle climate change and deliver climate neutrality. The Institute welcomes the opportunity to…

Consultation response

Fédération belge des industries chimiques et des sciences de la vie, 24 Jul 2020

The MRR offers an framework to allow consistent accounting in ETS. Essenscia welcomes improvements on the MRR provided they are based on following main principles: - Every emitted CO2 is accounted for and only once; IPCC guidelines are respected - Accounting rules in ETS and non-ETS accounting are…

Consultation response

Syndicat des énergies renouvelables, 24 Jul 2020

SER’s response to the public consultation on MRR revision Biogas is a carbon-neutral renewable energy which has a key role to play in the energetic transition, in full complementarity with renewable electricity. As such, it is important to promote sustainable biogas consumption for industrialists…

Consultation response

Ervia Limited, 23 Jul 2020

Introduction Ervia and Gas Networks Ireland support and welcome the European Commission’s revision of the Implementation Regulation (EU) 2018/2066 on the monitoring and reporting (MRR) of greenhouse gas emissions. We suggest that the revision of MRR should be considered as an opportunity to…

Consultation response

Fachverband der Stein- und keramischen Industrie, 16 Jul 2020

We propose to add the following wording to transpose Article 29 (1) RED II concerning an exemption for waste and residues from applying the sustainability criteria (RED II article 29 2-7) into the MRR: „Article 38 Biomass source streams […] 2. The emission factor of biomass shall be zero, provided…

Consultation response

Fundacja Instytut Spraw Obywatelskich, 24 Jul 2020

Opinia Instytutu Spraw Obywatelskich w konsultacjach dokumentu Ares(2020)2800422 „Unijny system handlu uprawnieniami do emisji – zaktualizowane przepisy dotyczące monitorowania i sprawozdawczości (2021–2030)” W opinii Instytutu szczególnej uwagi wymaga kwestia poprawnego – to jest realnego,…

Consultation response

EURAMET e.V., 24 Jul 2020

The European Association of National Metrology Institutes, (EURAMET) supports the proposed updates to the monitoring and reporting rules. We agree strongly with the summary that “for it to be effective, greenhouse gas emissions must be monitored, reported and verified in a transparent, consistent…

Consultation response

European Renewable Gas Registry, 24 Jul 2020

ERGaR fully welcomes the initiative of the European Commission to revise the Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions (hereafter MRR). It is an opportunity to introduce additional tools to incentivise and accelerate decarbonisation of the…

Consultation response

Chemical Industries Association, 24 Jul 2020

Biomass In the EU Emissions Trading System (ETS), biomass has hitherto been zero-rated for greenhouse gas emissions according to the UNFCCC IPCC guidelines for national greenhouse gas inventories, which guarantees consistency in international reporting. Under the IPCC guidelines, emissions…

Consultation response

Fédération des services énergie environnement, 24 Jul 2020

A. Presentation : FEDENE, Federation of Energy and Environment Services, brings together, through seven specialized professional trade unions, 500 service companies focused on energy efficiency, building performance, district heating & cooling, renewable heat & cold production, waste heat & cold…

Consultation response

Association for District Heating of the Czech Republic, 24 Jul 2020

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on “Draft Implementing Regulation amending and correcting Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the…

Consultation response

, 23 Jul 2020

De herziening van de verordening over de monitoring en de rapportering van de broeikasgasemissies (EU) 2018/2066 biedt volgens het Verbond van Belgische Ondernemingen (VBO FEB) de mogelijkheid om: - in de verordening ook rekening te houden met nieuwe technologieën zoals CCU en CCS die een bijdrage…

Consultation response

Kenneth Richter Consultancy, 23 Jul 2020

NRDC submission to the consultation “EU emissions trading system – updated rules on monitoring and reporting (2021-30)” The Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas (GHG) emissions pursuant to Directive 2003/87/EC of the European Parliament and of…

Consultation response

Český plynárenský svaz, 23 Jul 2020

The Czech Gas Association (CGOA) welcomes the opportunity to comment on “Draft Implementing Regulation amending and correcting Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the European Parliament and of the…

Consultation response

Swedish Gas Association / Energigas Sverige, 25 Jun 2020

Swedish Gas Association (Energigas Sverige) is the member association for the energy gases industry in Sweden, appreciate the opportunity to express our position on the abovementioned consultation. Our members cover technology providers, producers, suppliers, distributors, gas grid operators, gas…