The Fuel Emissions Trading Act (BEHG) currently regulates the national trading of emission allowances for fuels in the transport and heating sectors. Therefore, distributors of fossil fuels such as natural gas, heating oil, diesel, or gasoline must purchase allowances for the CO₂ emissions produced during combustion. The costs for these allowances are passed on to consumers. The aim of the law is to create a financial incentive to reduce fuel consumption. Germany intends to achieve its established climate targets through this measure.
From January 1, 2024, CO₂ emissions from waste incineration will also be subject to emissions trading. Operators of waste treatment plants are obligated to purchase certificates for the CO₂ emissions generated during waste incineration . This obligation also applies to waste oil incineration plants. Taxing waste incineration is intended to create incentives to reduce waste volumes and increase recycling rates.
How does pricing work under the BEHG?
Pricing depends on the waste composition, whereby only the fossil component, not the biogenic component, is subject to emissions trading. As a rule of thumb, the higher the plastic content in the waste mixtures, the higher the resulting CO2 emissions and thus the CO2 levies payable . Standard values for calculating CO2 emissions are listed in Annex 2 of the Emissions Reporting Ordinance (EBeV) 2030. This annex specifies biomass proportions, calorific values, and emission factors for the common waste codes.
The prices per ton of CO2 are set by the German Emissions Trading Act (BEHG) for the first few years. They amount to €35/t CO2 in 2024 and €45/t CO2 in 2025. From 2026 onwards, there is a price corridor between €55 and €65/t CO2 ; thereafter, prices are determined by the market.
What are the consequences of pricing for businesses and private households?
CO2 pricing will lead to a noticeable increase in waste disposal costs. Not only private households will be directly affected. Commercial customers can also expect rising prices, as waste disposal companies will likely pass the CO2 surcharge directly on to waste producers. Based on the standard values from the EBeV 2030 (German Waste Management Ordinance), this results in additional costs of approximately €36 per ton of lightweight packaging, €21 per ton of commercial waste, €14 per ton of residual waste, €19 per ton of bulky waste, and €33 per ton of waste whose waste codes are not explicitly listed in the EBeV for the year 2024 (excluding VAT). This should incentivize many companies to refocus on waste prevention and waste separation.
What obligations do operators of waste incineration plants have under the BEHG (German Emissions Trading Act)?
Plant operators are required to prepare and have approved a detailed monitoring plan for their plant's CO₂ emissions. An emissions report must also be submitted by July 31st of the following year. It is important to note that this reporting obligation applies to all CO₂ emissions , including emissions from biomass for which no certificates need to be purchased. By September 30th of the following year, operators must acquire the corresponding certificates for the reported emissions and submit them via the emissions trading register of the German Emissions Trading Authority (DEHSt).
Do you want to know how your waste disposal affects your carbon footprint? With our climate consulting services , we support you in creating a carbon footprint assessment and developing a reduction plan on your way to a balanced carbon footprint.
Your contact person at Arqum: