Calling for the European ETS scheme to impose stricter limits on aviation emissions

The European Union are conducting a consultation on the European Emissions Trading System (ETS). This is a mechanism for limiting total emissions by requiring emitters to have “allowances” or permits to emit greenhouse gases. Emitters can acquire allowances by being allocated allowances or purchasing allowances, and the total amount of allowances issued is capped, thereby capping the emissions from the sectors covered by the scheme.

However, there are major flaws which render this scheme currently ineffective at capping emissions from aviation.

We are calling for:

• Meaningful action at EU and international levels to reduce aviation emissions.  The current UN CORSIA scheme is not fit for purpose.  CORSIA allows offsetting of fossil fuel emissions through land use or forestry-based offsetting schemes, which are highly problematic on multiple fronts.  Fossil fuel emissions need to be reduced directly, not “offset” in this way.

• Make the EU Emissions Trading Scheme (ETS) more effective in reducing aviation emissions and emissions generally by ensuring
  • No free permits: airlines should no longer be allocated “free” emission permits or allowances but must pay for all permits/allowances, 
  • Steep reductions in permits: the total quantity of permits/allowances issued should decrease steeply, in line with climate targets,  
  • Include cargo/freight: ETS should be applied to cargo-only flights as well as passenger flights, 
  • Include outside EEA: ETS should apply to flights outside the European Economic Area (EEA) as well as flights inside the EEA.  We note that the consultation states “While in principle the ETS covers emissions from all flights landing in and departing from the European Economic Area (EEA), the EU has temporarily limited the scope to intra-EEA flights. This is to encourage the development of an effective global carbon pricing scheme by the International Civil Aviation Organization (ICAO).” The EU should not wait for international efforts, which are not moving with the needed speed and effectiveness.  Rather the EU must lead by example to avert the climate crisis by putting in place effective measures now, while also encouraging ICAO to also do so.
  • Include all climate-related emissions: ETS should include the substantial non-CO2 climate effects of aviation as well as CO2 emissions.

• Remove jet kerosene tax exemption in the EU: Ensure that jet kerosene tax exemption is abolished EU-wide as in commitments made in 2021 in the Fit For 55 package, and that the abolition of the exemption is not postponed.

• Ban advertising of aviation, advertising of flight-based holiday packages, and advertising of products transported by air freight, throughout the EU. Advertising promotes and normalises patterns of consumption that are destructive to the climate, including frequent flying and air-freight-transported consumer products.

You can also make a submission to this consultation! Please join us by going to the EU ETS consultation page and submitting feedback, before the deadline of 8 July 2025  (midnight Brussels time). Feedback is in the form of a free text box and an optional attachment – you need to create an account on the EU portal if you don’t have one already. Please feel free to use or adapt the points in our submission.

Read our full submission to the ETS consultation here.