Regulatory Burden of the European Emissions Trading System
The European Emissions Trading System (EU ETS-1) plays a crucial role in reducing greenhouse gas emissions in line with the climate objectives of the European Union. It is effective in achieving emission reductions but imposes regulatory burdens on companies. Commissioned by the Dutch Ministry of Climate and Green Growth, Panteia examined the impact this had in 2024 on Dutch maritime shipping companies, aviation companies and companies with stationary installations. We explored the possibilities for reducing the regulatory burden for participants in this system without affecting data integrity, enforceability or the climate effectiveness of the system.
The study was carried out using:
• Desk research into European and Dutch legislation and regulations
• An international comparison with France, Germany, Poland and Spain
• A questionnaire among companies covered by the system, although for aviation targeted interviews and public data were used, as that market is dominated by only a few operators established in the Netherlands
• In-depth interviews with companies, sector associations, Dutch ministries, the Netherlands Emissions Authority and the European Commission
The study found that the Netherlands implements the EU rules as written and that seperate national instruments running alongside the ETS-1 can add costs but are not considered gold plating. The administrative burdens for EU ETS-1 are estimated at approximately €21 million for Dutch companies with stationary installations, €3.5 million for the maritime sector and €1.9 million for aviation. The international comparison shows that the digitalisation of ETS-1 processes in 2024 through the use of portals has significantly reduced the administrative burden and that the information and calculation models provided through these portals help to limit the number of errors. At the same time, some Dutch respondents consider the system complex and the regulatory burden substantial, meaning that further simplification and improvements in implementation would be welcome. The suggestions gathered were assessed per sector, and the report indicates whether their implementation would require adjustments solely at national level or also at EU level.
The results of the study serve as input for policymakers in the run-up to the revision of the EU ETS and the resulting national implementations.
The full report (in Dutch with a summary in English) can be found here.
