ESWET Position on the European Consultation on the proposed revision of the Implementing Regulation on the monitoring and reporting of GHG.


The EU’s monitoring and reporting rules (MRR) for CO2 emissions are a crucial tool in the fight against climate change. They promote transparency, accountability, and informed decision-making, eventually helping to reduce GHG emissions from the EU industry and limit the adverse effects of global warming.

Monitoring and reporting of emissions is a cornerstone of the EU Emissions Trading System (ETS), but also of all EU climate-related legislation. As part of the EU’s “Fit for 55” package, the ETS Directive has recently been revised to align with the EU target of 55% net GHG emissions reduction (compared to 1990 levels) by 2030 set in the European Climate Law.

Following that revision, the European Commission (EC) needs to update several regulatory acts for the implementation of the ETS. Among these, it’s the Implementing Regulation (EU) 2018/2066 on the MRR, whose revision process was launched by the EC in the summer of 2023.

Although Waste-to-Energy (WtE) is currently not included in the ETS, and a potential inclusion needs to be evaluated and prescribed by a dedicated impact assessment to be conducted by July 2026, and any inclusion will only follow after 2028, it is imperative that the rules on monitoring and reporting of CO2 reflect properly the particularities of WtE and can be implemented without causing excessive problems to the sector.

ESWET responded to the EC consultation on the proposed revision of the MRR by highlighting that:

  • The revised MRR should recognise the unique feature of the heterogeneous feedstock of WtE plants, which treat mixed waste.
  • Having in mind the mixed waste feedstock of the plants, the MRR require plants to meet very strict uncertainties’ thresholds, for both types of methodologies prescribed. In this case, derogations are a must. ESWET members already supply instruments and solutions for CO2 accounting, but there are still limitations that need to be considered in the new MRR rules.
  • As a way forward, the MRR should allow for flexibility and time for WtE plants to evaluate the situation and should soon be open again for re-assessment to check whether the uncertainties’ levels are fit for the sector.

The full ESWET position paper can be found [here] .

For more information regarding our position on the recent revision of the EU ETS, you can read ESWET’s reaction to the proposed inclusion of Waste-to-Energy in the EU ETS and ESR or ETS: Waste treatments should be in the same basket.