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First Swiss ETS Deadline Looming

swiss flag article

Aircraft operators with flights to and from Swiss airports might find themselves confronted with new monitoring and reporting obligations. This is because the Swiss Emissions Trading System (ETS) now also covers CO2 emissions from domestic and international aviation. The first compliance deadline is 30 September 2017. This is the date by which participating aircraft operators must submit a tonne-kilometre monitoring plan to the Swiss Federal Office for the Environment (FOEN).

This article gives you all the information you need to know. It explains what the Swiss ETS is all about and helps you determine whether you have any obligations under this new regulation.


What are the Obligations under the Swiss ETS?

Participating aircraft operators must:

  • submit a tonne-kilometre monitoring plan to the FOEN by 30 September 2017
  • monitor distance and payload information for qualifying flights (see definition below) in 2018 in accordance with the approved monitoring plan and the Swiss Ordinance
  • submit a verified tonne-kilometre report for 2018 to FOEN by 31 March 2019 unless you are below the de minimis threshold


Is the Submission of a Monitoring Plan Mandatory?

Yes. Contrary to the European Union Emissions Trading System (EU ETS), participating aircraft operators are required to submit a tonne-kilometre monitoring plan by 30 September 2017. Failure to do so may lead to a fixed penalty of a maximum of 5,000 Swiss francs (which is 5,200 USD at the current exchange rate).

The tonne-kilometre data collected will serve as a basis for the allocation of free emission allowances. It will also be used to determine the system-wide emissions cap.


Who Must Submit a Tonne-Kilometre Monitoring Plan?

Both Swiss based and foreign aircraft operators must participate in the Swiss ETS unless they are exempt. The following infographic helps you determine whether you are exempt from submitting a tonne-kilometre monitoring plan.



Swiss De Minimis Threshold and Other Exemptions

A commercial operator is below the de minimis threshold if it operates less than 243 qualifying flights in each of the three successive four-month periods or if its total annual emissions of CO2 from all qualifying flights are below 10,000 tonnes.

A private, non-commercial operator is below the de minimis threshold if its total annual emissions of CO2 from all qualifying flights are below 1,000 tonnes.

Same as with EU ETS, the Swiss ETS also exempts flights performed by aircraft with a MTOW of less than 5,700 kg, circular flights or training flights (just to name the most prominent exemptions).


What is the Geographical Scope?

In 2018, you will need to keep track of distance and payload information for qualifying flights. The illustration below tells you which flights fall within the geographical scope of the Swiss ETS. For the purpose of this article, we refer to these flights as qualifying flights.

Geographical scope article v2

* The EEA comprises all 28 EU Member States, as well as Iceland, Liechtenstein and Norway. List of EU Member States: Austria, Belgium, Bulgaria, Cyprus, Croatia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom.


Link with EU ETS

Switzerland and the EU are seeking to link their respective emissions trading systems. Until an agreement is reached and enters into force, the two systems will run in parallel. This means, you will have to deal with two competent authorities – the Swiss FOEN and your current competent authority for EU ETS.


What are the next steps?

The next step is to create a tonne-kilometre monitoring plan using the template provided by FOEN. You must submit the monitoring plan no later than 30 September 2017 by email to In addition, you will also need to send a signed paper copy to:

Federal Office for the Environment FOEN
Climate Division
"Monitoring Plan Aviation Operators"
3003 Bern


More Information

Get in touch if you require more information or if you have any questions regarding the tonne-kilometre monitoring plan. You can reach us by email ( or phone (+34 632 766 521).





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