Commission Implementing Regulation (EU) 2018/2066 specifies the requirements for greenhouse gas emissions monitoring and reporting within the EU Emissions Trading System (ETS).1 To comply with the regulation, which is better known as the MRR, companies must provide authorities with a comprehensive set of data on their emissions.
Various laboratory analyses are needed for accurate emissions calculations, especially for large industrial installations and when using mixed fuels that contain both fossil and biobased carbon. Measurlabs offers accredited testing services to determine key calculation parameters, such as the biomass fraction, net calorific value, and carbon content of fuels and emission sources.
Which companies must comply with the MRR?
The MRR applies to companies that perform activities listed in Annex I to the EU ETS Directive on a large enough scale to exceed the applicable production capacity or thermal input threshold. Table 1 contains a list of activities that require stationary installations to be included in EU ETS and subsequently comply with MRR requirements.2 All technical units (boilers, burners, furnaces, etc.) within the installation are added together when determining whether the inclusion threshold is met.
Table 1: Activities included within EU ETS
Activity | Inclusion threshold |
Combustion of fuels, including incineration of municipal waste* | 20 MW (total rated thermal input**) |
Oil refining | 20 MW (total rated thermal input) |
Production or processing of ferrous and non-ferrous metals and secondary aluminum | 20 MW (total rated thermal input of combustion units) |
Iron and steel production | 2,5 tonnes per hour (production capacity) |
Production of cement clinker or lime, calcination of dolomite or magnezite | 50 tonnes per day (production capacity), 500 tonnes per day for cement clinker produced in rotary kilns |
Manufacture of glass, glass fiber, and mineral wool | 20 tonnes per day (melting capacity) |
Ceramic product manufacturing | 75 tonnes per day (production capacity) |
Production of paper and cardboard | 20 tonnes per day (production capacity) |
Production of carbon black | 50 tonnes per day (production capacity) |
Production of bulk organic chemicals | 100 tonnes per day (production capacity) |
Production of hydrogen and synthesis gas | 5 tonnes per day (production capacity) |
Production of pulp, ammonia, soda ash, sodium bicarbonate, and coke. Metal ore roasting, sintering, and pelletization. | Not specified |
Production of nitric, adipic, glyoxal, and glyoxalic acids*** | Not specified |
Production of primary aluminum**** | Not specified |
* Municipal waste incineration plants must monitor and report emissions, but they are not required to participate in emissions trading.
** Total rated thermal input represents the combined calorific value of fuel supplied to all combustion units per unit of time to maintain the process at a specified power level.
*** Nitrous oxide emissions to be monitored in addition to carbon dioxide
**** Perfluorocarbon emissions to be monitored in addition to carbon dioxide
Due to their involvement in the combustion of fuels, practically all large industrial installations must participate in EU ETS, even if the sector is not specifically listed.3 The more specific production capacity thresholds are still relevant, as they take precedence over the thermal input threshold when determining activities to be included in emissions reports.
How are emissions calculated?
Companies that participate in EU ETS must monitor their emissions using one or more methods specified in the MRR:
Calculation using the standard methodology, where carbon dioxide (CO2) emissions are, in the most straightforward cases, calculated by multiplying the net calorific value (NCV) of consumed fuel with its emission factor and oxidation factor.
Mass-balance approach, where all carbon inputs and outputs, including fuel, raw materials, emissions, and carbon bound in the end product, are included in a more complex calculation. This approach should be used when the product itself contains significant amounts of carbon (organic chemicals, carbon black, etc.).4
Direct measurement of CO2 from the flue gas at the exit stream through a continuous emission measurement system (CEMS).5
Some calculation factors required for emissions calculations can be determined using default values, such as those listed in Annex VI to the MRR. Chemical analyses are needed when default values are unavailable or cannot be used because of high data quality requirements.
Determining the extent of MRR testing requirements
The MRR imposes particularly stringent monitoring and reporting requirements for the largest industrial installations, which must typically base emissions calculations on chemical analysis results rather than default values. Installations are classified into the following categories based on their average annual verified emissions from the previous trading period:6
Category A: up to 50,000 tonnes of fossil CO2 emissions
Category B: between 50,000 and 500,000 tonnes of fossil CO2 emissions
Category C: more than 500,000 tonnes of fossil CO2 emissions
Low-emission installations (less than 25,000 tonnes of fossil CO2 emissions per year) are eligible for simplified monitoring and verification requirements. Derogations can also be granted if the operator can demonstrate to the competent authority that meeting a specific monitoring requirement would incur unreasonable costs or be technically unfeasible.7
In addition to the installation category, source stream classification (major, minor, or de minimis) and emission source classification (major or minor) will affect the tier applied to monitoring requirements. Ranging from 1 to 4, with more extensive requirements for higher tiers, the tier will determine whether laboratory testing is needed to obtain certain calculation factors and what degree of measurement uncertainty is acceptable.
Laboratory analyses to meet MRR requirements
When laboratory testing is required to determine emission calculation factors, companies must adhere to the criteria outlined in articles 32 to 35 of the MRR. These include using ISO 17025 accredited laboratories where possible, ensuring sufficiently frequent and representative sampling, and following international or national standard methods, with preference given to European EN standards.8
The following are examples of chemical analyses commonly required to meet MRR requirements:
Biomass fraction of CO2 emissions: As sustainably sourced biomass is zero-rated within EU ETS, the biomass fraction needs to be known to obtain the emission factor of combustion processes where mixed fuels are used.9 The most common approach is using the radiocarbon method to measure biogenic carbon in flue gas collected at the exit stream. Analyses must be performed every 50,000 tonnes of total CO2 emitted, or at least once a month.
Carbon content and net calorific value: These measurements are needed to determine emission factors when the highest tiers are applied to monitoring requirements.
Solid recovered fuel (SRF) analysis: This analysis package can be used to determine the calorific value and CHN(O)S, moisture, ash, and metal content of SRF used as fuel at industrial installations. Emission factor and biodegradability assessments can be included for a more comprehensive set of data.
Measurlabs offers the above and other accredited chemical analyses to support companies with MRR reporting obligations. Contact us using the form below to discuss your testing needs with our experts.
References:
1 Commission Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions (Consolidated version from 01/01/2025)
2 Companies participating in carbon capture and storage, aviation, and maritime transport are also subject to MRR requirements, but these activities are beyond the scope of this article. See Annex I to Directive 2003/87/EC (Consolidated version from 01/03/2024) for a complete list of activities warranting inclusion in EU ETS.
3 The definition of combustion given in Article 3 of the EU ETS Directive is broad, covering “any oxidation of fuels, regardless of the way in which the heat, electrical or mechanical energy produced by this process is used, and any other directly associated activities, including waste gas scrubbing”.
4 More information on mass balance calculations is found on pages 29 to 31 of this Commission Guidance Document on the MRR.
5 Nitrous oxide (N2O) emissions are also measured using CEMS in relevant installations.
6 Classification criteria are outlined in Article 19 of the MRR. Zero-rated carbon is excluded, but carbon for CO2 transport and storage is included when determining the installation category.
7 Article 47 of the MRR specifies the special provisions for low-emission installations, while Article 18 outlines the rules for cost-benefit calculations to determine whether costs are unreasonable.
8 It is, in principle, possible to demonstrate that a laboratory is competent without an ISO 17025 accreditation, but this requires showing that using an accredited laboratory is not technically feasible or involves unreasonable costs.
9 Companies must also show that biomass used in the process meets Directive (EU) 2018/2001 (“RED II Directive“) sustainability criteria, using methods such as supply chain verification.