ETSdesk contribution on European Carbon Capture and Utilisation (CCU) Delegated Regulation

ETSdesk is one of the most knowledgeable ETS service providers in Europe and other regions. Our vision is to help companies meet their EU and other ETS obligations while enhancing operational efficiency.

To serve our vision, we review Emissions Trading Systems following a holistic approach. It is not only about EUAs, MRV, trading, or decarbonization. It is about all aspects connected to its complex framework.

As an example, following this holistic approach, we have thoroughly investigated the consequences of Carbon Capture and Utilisation (CCU) legislation, which we believe will be one of the key points in the effort to limit EU ETS financial losses for shipowners and charterers.

We have actively interacted with the European Commission secretariat on the formulation of a Delegated Regulation related to CCU. The process from a GHG emission at the emitter's installation until this quantity is finally utilized under CCU has many stages.

As it is not apparent in any CCS-related regulations which framework governs the transitional phases from emission to utilization, ETSdesk proposed the inclusion of the following additional articles:

[x.]. In case a formal agreement between an Emitter and an accepted as per this Regulation, CCU installation has been established, then the quantity of GHG emitted by the Emitter, included in this agreement, may be waived from the EU ETS obligations for surrendering of Allowances and relevant entry may be included in the MRV template for this Emitter.

[xi]. For the transportation sector and particularly for Maritime in which the vessels' routing is generally decided with short notice, the delivery of any GHG captured onboard and included in the formal agreement as per Article [x], may be done at any temporary storage installation and/or at any port either in European or other Continents.

[xii] Verification for the quantities intended to be delivered from the Emitter for CCU to the CCU installation, under a formal agreement, may be done exceptionally by confirmation from an emitting installation's Responsible Person (i.e. Executive Management or Board of Directors representative or Master of a vessel) and relevant entry may be included in the MRV template for this Emitter.

We at ETSdesk believe that this type of formal initiative will assist the maritime sector in coping with ETS in the most efficient and permanent way. Maritime stakeholders are kindly requested to contribute.