French Hybrid Scheme
On the 26th of April 2022, the French government released a decree (n° 2022-667) related to the greenhouse gas emissions offsetting. This new scheme is a hybrid between EU ETS and CORSIA. The scope criteria are based on the EU ETS scheme while the quota surrender process is based on CORSIA.
Scope of the scheme and timeline
The new scheme applies to French domestic flights only. However, an operator is subject to the French scheme if (1) the operator is subject to the EU ETS scheme and (2) has more than 1 000 tonnes of CO2 on French domestic routes.
Another important element of the scheme’s design is its gradual ramp-up to 100% offsetting. Starting from the 1st of January 2022, operators are required to offset 50% of their emissions, from the 1st of January 2023, operators are required to offset 70% of their emissions, and from the 1st of January 2024, operators are required to offset 100% of their emissions.
The decree outlines the following key dates for compliance:
31.03.2023 – The submission of the verified French Annual Emissions Report to the French Competent Authority (DGAC) on the 31st of March of each year (same as EU ETS). The reporting template will be a light version of the EU ETS Annual Emissions Report with only elements relevant to the French scheme (around 4 tabs long).
30.04.2023 – The cancellation of the carbon credits shall occur by the 30th of April of each year. Emissions Unit criteria are detailed in the next section of this article.
01.06.2023 – Before the 1st of June of each year, the operator shall submit a verified Emissions Unit Cancellation Report to the DGAC. This report shall include the list of projects (and their types, i.e., carbon reduction or carbon sequestration), the location of the project, the activity sector, the quantity of claimed emissions, the methodology used, the year when the project started, information related to financing, and all pertinent elements to assess the eligibility of the projects.
Emissions Unit Criteria
Emissions Units shall be recognized either by the “Bas Carbone” label or by the International Civil Aviation Organization (ICAO) under CORSIA.
Eligible Emissions Units cannot be from projects helping to reduce aircraft emissions. Furthermore, priority is given to sequestration projects located in France or in the European Union Member States.
Finally, Emissions Units cannot be used under more than one scheme simultaneously.
The Verification process and next steps
Operators are required to verify their Emissions Report and their Cancellation Report by an Independent Verifier. Penalty fees may be applicable if an operator does not comply with this scheme.
The DGAC will publish the templates of the Annual Emissions Report and the Cancellation Report along with a guidance document later this year.
More updates on this scheme will be posted by Verifavia as soon as the information is released.
If you have any questions on the scheme itself or wish to know how Verifavia can help you with the verification of the Emissions and Cancellation Report, please contact us.