The following fuels are included in the new templates: biofuels, RFNBOs (Renewable Fuels of Non-Biological Origin), RCFs (Recycled Carbon Fuels), and SLCFs (Synthetic Low-Carbon Fuels). The emission factor of the alternative fuel fraction may be "zero-rated" if they comply with certain criteria in accordance with the MRR and the Renewable Energy Directive (RED). In addition fuels eligible for ETS Support (FEETS support) can be requested for eligible fuels.
Calculations
Specifically section 8 and 9 of Tab Calculation (7-9) needs to be updated for the monitoring of aviation fuels. For all fuel types, the rules of the MRR(in Articles 53 to 54c) require that the aircraft operator describe procedures for the following:
- Determining fuel usage and compliance with zero-rating criteria.
- Calculating and reporting the amount of neat and blended fuels.
- Reporting CO2 emissions for EU ETS (zero-rating) and CORSIA (using preliminary emissions factor).
- Allocating fuel to individual EU ETS flights or proportionally to departures from the relevant aerodrome.
2024 Reporting Period
The NEa already informed verifiers that you are required to update your monitoring plans to include procedures for alternative and eligible fuels according to the updated MRR, when planning to report them for the 2024 reporting period. Due to the late publication date of the templates, your MP may still be under review during the verification of your 2024 annual emissions report.
Nonetheless, you are required to report in compliance with the new MRR requirements, even if your monitoring plan is still under review, using the following 23/01/2025 - Template No. 5: Annual emissions report of aircraft operators for EU ETS, Swiss ETS, and CORSIA.
Proof of Sustainability – temporary measure
The NEa also informed verifiers that, starting from February 28th, they can request an extract from the Dutch national registry (Register Energie voor Vervoer; REV) for aviation fuel supplied in the Netherlands, for which a PoS has been submitted to the NEa. This is conform the temporary
solution for the parallel claims of renewable energy by aircraft operators and fuel suppliers in the Netherlands.
The NEa also accepts evidence from national registries in other member states, provided the PoS information can be linked to a specific batch of biofuel purchased by the aircraft operator and the PoS is unavailable because it has already been submitted to the competent authority.
Please note: A product transfer document (PTD) alone is not acceptable as evidence. It may only be used as supplementary evidence alongside the extract from a national registry and purchase records.
