New EU Law on Non-CO₂ Emissions Reporting Sparks Airline Industry Concerns

This month, a new EU regulation requiring airlines to monitor and report non-CO₂ emissions took effect. However, airline industry groups have voiced concerns about their ability to comply, citing the absence of a functioning system to administer the requirements.

The regulation, known as the Non-CO₂ Monitoring, Reporting, and Verification (MRV) system, mandates airlines to track pollutants per flight, including soot, nitrogen oxides, and water vapor. These emissions contribute significantly to global warming, with some studies suggesting their impact rivals that of CO₂ emissions. Airlines have until March 2026 to submit data collected from 2025.

The EU plans to centralise the data using the Non-CO₂ Aviation Effects Tracking System (NEATS), which has not yet been launched. Industry groups, including Airlines for Europe (A4E), the German Aviation Association (BDL), and the European Cargo Alliance, have urged the European Commission to delay the implementation timeline. In a December letter, these groups highlighted the challenge airlines face in collecting data without clear guidance or access to NEATS.

Concerns Over Implementation
The letter, dated December 24, 2024, noted that airlines are in a difficult position as they cannot determine whether to rely on NEATS, develop proprietary tools, or use third-party solutions. A4E Policy Director Monika Rybakowska warned that airlines may need to collect thousands of data points per flight without clarity on submission methods.

IATA Director General Willie Walsh previously raised concerns over the scientific complexities of measuring non-CO₂ emissions, such as nitrous oxide, water vapor, and soot, suggesting a lack of consensus on methodology. Industry leaders fear the MRV system could lead to stricter emissions caps or financial penalties if compliance deadlines are missed.

A European Commission spokesperson acknowledged the delay, stating that NEATS would be launched in 2025. The Commission plans to consult with the industry on data models in the coming months. “Airlines will in any case need to monitor some data to be fed to the tool. This data is already available to airlines either because they already monitor it or because it is available in existing databases,” the spokesperson added.

Environmental Advocacy Perspective
Environmental campaign group Transport & Environment (T&E) expressed concern about NEATS’ delay but opposed postponing the rules. Carlos López de la Osa, aviation technical manager for T&E, stated, “Unfortunately, this is the only piece of meaningful non-CO₂ aviation emissions legislation in the world.” He emphasized that some sectors of the aviation industry have resisted climate policies, further underlining the importance of implementing MRV.

What’s Next?
As the aviation industry grapples with the operational and logistical challenges of the new law, the European Commission is under pressure to roll out NEATS promptly. The outcome of this initiative could set a precedent for global non-CO₂ aviation emissions legislation, making it a critical step in the EU’s broader climate strategy.

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