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BEHG trading with CO₂ certificates

Approximately 4,000 distributors of fossil fuels must submit emissions reports annually and surrender certificates to the DEHSt to avoid fines of up to €500,000. Early decarbonization and strategic certificate procurement are essential, as the scarcity of the „cap“ will massively drive up prices starting in 2028.

The Fuel Emissions Trading Act (BEHG) is part of the national emissions trading system (nEHS) in Germany, which has been in force since January 2021. The BEHG trading regulates the CO₂ pricing from fossil fuels such as natural gas, LPG, heating oil, diesel, or gasoline. The BEHG covers additional non-ETS sectors, such as transport, building heating, and small plants, which until now not subject to the EU ETS I fallen. The BEHG trading will be integrated into EU ETS II in 2028, thus becoming part of the European CO2 certificate trading. This means that the fixed certificate prices and established price corridors of German CO2 certificates will be discontinued and will also be freely traded from 2028 onwards.

Which companies are affected by SESTA trading?

The following are affected by SESTA trading "Distributor of fuels", which do not participate in the EU ETS I and are not exempt from CO₂ compensation. These include, for example, mineral oil producers, natural gas suppliers, and importers of fossil fuels. The trade in fossil fuels, energy and industrial plants, and heating generators in the building sector are also affected. Indirectly, since 2023 also real estate landlords The landlords have to bear a share of the CO₂ costs arising from fuel emissions trading. This is done in accordance with the CO₂ Cost Sharing Act, which regulates the allocation of additional costs between tenants and landlords. Overall, participation in the BEHG is responsible for around 4,000 German companies along the fossil fuel value chain obligatory.

Functioning of SESTA trading

German BEHG trading is part of EU emissions trading, trades in national emission allowances (nEZ) and is based on the principle of "Cap and Trade. A politically determined upper limit ("cap") defines the maximum amount of CO₂ emissions that may be produced through the consumption of fossil fuels. As in the EU ETS, this cap is gradually reduced. Affected companies are obliged to reduce their CO₂ emissions to calculatefor every tonne of CO₂ emitted, a corresponding Acquire a certificate and then submit them to the German Emissions Trading Authority (DEHSt) in due time. to be submitted for cancellation.

The certificates are tradable, which means that a Market price based on supply and demand. As soon as certificates become scarce, their price rises, which creates an additional incentive for companies to reduce their emissions. At the same time, companies can use surplus Sell certificates or, if necessary, additional repurchase. This creates an economic incentive to use fossil fuels efficiently and to switch to lower-emission alternatives.

Acquisition of certificates and options in SESTA trading

Companies can purchase BEHG certificates (national emission allowances, nEZ) up to and including 2025 at a fixed price of EUR 55 in Germany directly on the European Energy Exchange (EEX) in Leipzig, provided they have submitted an application for admission. Alternatively, they have the option of obtaining certificates via approved Intermediary or Intermediaries to acquire. These service providers offer a range of services, from pure trade execution to consulting and validation of emission reductions. Companies have the flexibility to choose the appropriate service providers based on their specific needs to effectively manage their CO₂ certificates and meet their obligations under emissions trading. This is particularly sensible when trading will be organized through auctions on the [Exchange/Platform Name] starting in 2028.

Conditions and deadlines in SESTA trading

Companies must submit their certificates annually by September 30 to the German Emissions Trading Authority (DEHSt) in accordance with the amount of CO₂ emissions they caused in the previous year. To do this, they should ensure that their Issue reports are correct and complete and that Emissions trading register account is maintained without errors. At the same time, the necessary certificates must be acquired and submitted first. The certificate auction phase will start in 2026 with a Price cap up to a maximum of 65 euros, before free market pricing is enabled starting in 2028. Experts then expect certificate prices between 200 to 350 Euro within the framework of the EU ETS II. Companies should plan their purchases in a timely manner and keep an eye on fluctuating prices. External service providers or consultants with experience in emissions trading can be helpful in this regard.

Consequences of violations of the BEHG

Once a company fails to correctly document its CO₂ emissions or fails to cover them with certificates in accordance with the BEHG, customs will make an estimate. Uncovered CO₂ emissions or missing certificates must be retroactively paid for from 2027 at least 100 Euro acquired and offset. This sum is regularly adjusted in line with the European Consumer Price Index, meaning that the financial burden will increase over time. In the event of negligent or even deliberate breaches of the BEHG obligations, there is a risk of Fines of up to 500,000 euros. Companies that repeatedly violate the requirements risk losing their access to the national emissions trading register.

Conclusion

Emissions trading under the German Greenhouse Gas Emissions Trading Act (BEHG) represents a mandatory yet strategically exploitable measure for companies in CO₂ pricing. With the gradual transition from national emissions trading to the European EU ETS II from 2028 onwards, the market for CO₂ certificates is set to become increasingly dynamic. Therefore, companies should take early action to optimize their emissions costs – whether through strategic procurement of certificates, investments in low-emission technologies, or the use of external consulting services. Adhering to deadlines and ensuring correct documentation are essential to avoid significant penalties and regulatory consequences. In the long term, the rising price of CO₂ certificates will compel companies to align their business models more sustainably and further reduce their use of fossil fuels.

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