EU-ETS 2 & nEHS Verification

The introduction of EU ETS2 and the continued implementation of the German BEHG are transforming compliance obligations across fuel, energy, transport and heating sectors. Regulated entities operating in these sectors must ensure emissions reporting, robust data management and full regulatory compliance.
Control Union Certifications Germany is officially accredited to verify Emissions Reports under the German National Emission Trading (nEHS) and the European Emission Trading Scheme 2 (EU ETS 2), in accordance with ISO 17029 and ISO 14065.

EU ETS2 and BEHG

The regulations

Germany launched a national emissions trading scheme (nEHS) in 2012 through the implementation of the Fuel Emissions Trading Act (BEHG). In Germany, the BEHG has been complementing the EU ETS 1 since 2024 as it was designed to fill the gap left by the EU ETS1 and to extend carbon pricing to additional sectors of the German economy. It will be integrated into the European Union Emissions Trading Scheme 2 (EU ETS2).

The new ETS 2 system will regulate emissions from fuels used in buildings, road transport and certain industrial sectors, while Germany`s national scheme continues to serve as a key carbon pricing policy during the transition period. The actual compliance phase for the EU ETS 2 will begin on January 1, 2028 after the end of the reporting phase (January 1, 2024- December 31, 2027). Regulated entities under both policies still currently have compliance obligation to fulfill for both systems.

Who we serve

Fuel Suppliers

Energy enterprises

Traders and importers

Transport fuel providers

District heating operators

Oil and gas companies

And more companies…

That are in the business of fuel supply in these sectors.

Our verification services

For accuracy, completeness, and consistency.

Concerning fuel data, emission factor, emissions values.

Based on the findings

Our verification process

We verify emission reports following the ISO 17029 and ISO 14065 guidelines. Our process flow is described as follows;

Pre-Engagement stage

The process begins with your request for verification of annual emission report and activity level report (applicable for EU ETS2 and BEHG). Upon receiving your request, we ask you to complete the application form. The application form must be completed and submitted together with the relevant documents (such as the annual emission report, activity level change report). We will then review your application and examine the documents provided, to determine whether the verification engagement can be undertaken.

The information and documents provided should be sufficiently complete, accurate, consistent and reliable to enable us to determine the feasibility, scope and requirements of the verification engagement for EU-ETS2 and BEHG. Any significant gaps or uncertainties identified during the pre-engagement review may need to be addressed before the engagement can proceed.

Engagement stage

Once the pre-engagement review has been completed and the verification engagement is considered feasible, Control Union Certification Germany (CUCG) prepares a tailored proposal based on the scope, objectives, applicable criteria, complexity and estimated effort of the engagement.

The proposal sets out the scope of services, applicable standards and criteria, planned activities, timelines, responsibilities and fees.

Following acceptance of the proposal and completion of the contractual arrangements, CUCG appoints a competent and impartial assessment team with technical expertise in EU ETS2 or BEHG (as the case may be). The CUCG further develops a verification plan from the information gathered in the pre-engagement stage and additional information obtained and it will be communicated to the contact person of the company prior to the verification exercise. The verification plan defines the scope, objectives, location, criteria, assessment activities, sampling approach, timing, the assessment team and roles of each member of the team. It is proportionate to the risks and complexity of the engagement and provides the basis for conducting the subsequent assessment.

Verification stage

During this stage, the verification audit is conducted in accordance with the agreed scope, applicable criteria and verification plan. The verification audit entails a site visit to the location of the company by the audit team at a mutually agreed date and time. In adherence to the Accreditation and Verification Regulation of the EU ETS (2018/2067) and Section 15 of the BEHG, it is recommended that the site visit should occur at the end of that emission year, whose emission report is being verified or at the earliest time following the completion of the emissions year. There could also be possibility of another site visit or a follow-up via telephone or other appropriate channels. Same location of the company can be visited yearly for the annual verification exercise for both EU ETS2 and BEHG.

Where insufficient evidence, inconsistencies, misstatements, nonconformities or other issues are identified, the verification team communicates these findings to the client and may request additional information, clarification, corrections or corrective actions, as applicable.

Independent review and issuance

Completion of the verification audit, the audit team evaluates the evidence obtained, resolves outstanding findings, and develops the verification conclusions in accordance with the Accreditation and Verification Regulation (both in the EU ETS and BEHG) and the requirements of ISO 14064-3.

Before the verification statement is issued, the verification engagement undergoes an independent review by a competent person who has not participated in the verification exercise. The independent reviewer evaluates the engagement, including the assessment approach, significant findings, supporting evidence and proposed conclusions, to confirm that the verification has been conducted appropriately and that the conclusions are adequately supported. Where issues are identified during the independent review, these are addressed before the engagement is finalized.

Once the assessment and independent review have been satisfactorily completed, the CUCG will issue a verification statement to the client, who will later submit it to the regulator together with the verified annual emission and activity level change reports.

For this reason, CUCG establishes the expected timeline on a case-by-case basis in collaboration with the client. Client cooperation and the timely provision of complete and accurate information are important factors in maintaining the agreed schedule.

Why choose Control Union Certifications Germany?

Accredited verification body

Control Union Certifications Germany is officially accredited to verify Emissions Reports under the German National Emission Trading (nEHS) and the European Emission Trading Scheme 2 (EU ETS 2), in accordance with ISO 17029 and ISO 140655. We provide independent, impartial and professional verification services.
Global reach, local expertise

As part of the global Control Union network, we combine international assurance expertise with local regulatory knowledge. Our experienced verification team delivers an efficient and transparent verification service that helps organizations achieve compliance with confidence.

Are you ready for EU ETS2 and BEHG compliance?

Please contact our verification expert team to discuss your verification and compliance and requirements.

Oyeshola Kofoworola

carbonservices@controlunion.com

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