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Swiss ETS

Every aircraft operator planning applicable Swiss flights in 2020 must submit an Emissions Monitoring Plan by 30th September 2019 to the FOEN.

Switzerland and the European Union (EU) are seeking to link their respective emissions trading schemes. Once the two emissions trading schemes have been formally linked, aircraft operators are to also be integrated into the Swiss emissions trading scheme.

In 2018, aircraft operators performing domestic Swiss flights and flights from Switzerland to EEA member states were required to submit their tonne-kilometer (tkm) Monitoring Plans and submit tkm Report by the end of March 2019. The reported tkm is going to be used to establish additional free allowances for operators once the linkage between Swiss ETS and EU ETS is completed. An Agreement was signed on 23 November 2017 in Bern. It was approved by the Swiss Parliament on 22 March 2019. It must now be ratified by Switzerland and the EU before it can enter into force on 1st January 2020.

There is now a revised Swiss Ordinance, which entered into force on 1st June 2019. New provisions (Art. 9a and 9b) regulate the submission and evaluation of CO2 emissions monitoring plans for the Swiss ETS. Every aircraft operator planning applicable flights in 2020 must submit an Emissions Monitoring Plan (EMP) by 30th September 2019

Approved EU ETS Monitoring Plans are accepted under certain conditions. Operators who don't have an EU ETS MP are required to use a template provided by the Federal Office for the Environment (FOEN), which is based on the template provided by the EU. 

The entry into force of the Agreement sets 2020 as the first monitoring year for which emissions falling under the Swiss Ordinance must be reported and verified. There is no monitoring obligation for 2019 data, hence there will be no reporting and verification obligation in 2020. In 2021, there will be combined reporting under Swiss ETS and EU ETS, however details of the reporting requirements are not available now.

In principle, all operators of aircraft that fly within Switzerland, or from Switzerland to destinations in the European Economic Area (EEA), are required to submit an EMP to the FOEN for approval. The requirement does not apply to aircraft that fly over Switzerland without landing there.

In the Ordinance, the airport Basel-Mulhouse has a special standing as a French and Swiss airport depending on the ICAO code used. As per this letter to the aircraft operators, the rule has changed. Basel-Mulhouse (both LFSB and LSZM) is now fully under EU ETS (as it always was) and is viewed as a French airport even when using the Swiss ICAO code.

Revised Swiss Ordinance
Information on Aviation Swiss ETS
Linking of Swiss ETS and EU ETS


Collection of TKM data

Please note that if you were subject to EU ETS in 2016 and you have operated any number of flights within Switzerland or between Switzerland and the EEA countries, you are required to submit the TKM report as the de minimis rules do not apply to you.

What is the scope of the Swiss ETS TKM monitoring?

Tonne-kilometre data have to be acquired for the following flights:
a. domestic flights
b. flights from Switzerland to member states of the European Economic Area (EEA)

* Airport Basel-Mulhouse (MLH, BSL, LFSB, LSZM) is considered to be French airport in both EU ETS and Swiss ETS - even when the Swiss ICAO code is used!

Which are the operators that are required to submit verified 2018 Swiss TKM Report?

Commercial operators:
 - performed in each of three successive four month periods at least 243 flights covered by the Ordinance
 - OR if their total annual emissions of CO2 are at least 10,000 tonnes
 - OR if they were subject to the EU ETS in 2016

Non-commercial operators:
 - if their total annual emissions of CO2 from flights covered by the Ordinance are at least 1,000 t
 - OR if they were subject to the EU ETS in 2016

What are the flight exemptions?

The flight exemptions are exactly the same as in EU ETS:
- presidential (monarch) flights
- military, customs and police flights
- search and rescue, firefighting, humanitarian and emergency medical service flights
- circular flights
- training flights
- scientific research
- testing and certification flights
- flights performed by aircraft with MTOM less than 5,700 kg

How to calculate your Tonne-kilometres?

tkm = distance [km] x payload [t]

- distance = GCD + 95 km
- payload = conveyed freight + mail + passengers + baggage

What are the payload details and rules?

The number of passengers corresponds to the number of people on board excluding crew members. The aircraft operators may choose to apply:
     - actual or standard mass for pax and checked baggage as per mass and balance documentation
     - default value 100 kg for each pax and his baggage

The weight of pallets, containers and service weight must be excluded from the payload.

Visit the FOEN website or contact climate@bafu.admin.ch for more information and Monitoring Plan template.