Who has to determine the biogenic share?
Swedish waste-to-energy plants have been in the EU Emissions Trading System since 2013, under the Swedish Ordinance on Certain Greenhouse Gas Emissions (SFS 2020:1180). Biogenic carbon dioxide has an emission factor of zero, so the biogenic share must be determined and reported every year. The same applies to plants with mixed fuels, for example recovered wood, solid recovered fuel, tyres and plastics in CHP plants, cement kilns and lime kilns, where the fuel composition is hard to establish from fuel samples. If the share is not determined at all, all the carbon counts as fossil.
What the regulation requires
The requirement is in the EU Monitoring and Reporting Regulation (MRR), (EU) 2018/2066, which applies directly in Sweden. The Swedish Environmental Protection Agency (Naturvårdsverket) is the permit authority, and the method goes into the plant's monitoring plan.
- Biomass has an emission factor of zero. Where the sustainability criteria of the Renewable Energy Directive apply, they must be met, otherwise the carbon counts as fossil (Article 38).
- The share is determined by carbon-14 in the flue gas to EN ISO 13833, by the balance method of ISO 18466 or by an estimation method from the Commission (Article 43(4)).
- Flue gas samples are analysed for every 50,000 tonnes of carbon dioxide, but at least once a month, and the sampling plan must be representative of the whole reporting year (Article 43(4) and Annex VII).
- Without a determination the biogenic share is set to zero (Article 39).
- The annual emissions report is due by 31 March of the following year (Article 68).
How the result goes into the report
The biogenic share for each sampling period is multiplied by the period's total carbon dioxide emissions, which the plant measures in the stack from the carbon dioxide concentration and the flue gas flow, or calculates. The sum over the year gives the tonnes of biogenic and fossil carbon dioxide, and the biomass emissions are deducted from the total. Every percentage point of biogenic share is therefore carbon dioxide the plant needs no allowances for: at 200,000 tonnes a year and €80 per allowance, about €160,000 a year. Work it out for your plant.
The timeline in the EU
- Sweden: waste-to-energy plants in the EU Emissions Trading System since 2013.
- The rest of the EU: emissions from municipal waste incineration have been monitored and reported since 1 January 2024.
- Proposal, July 2026: on 17 July 2026 the Commission proposed bringing waste incineration plants above 3 tonnes per hour fully into the trading system. The proposal has not been adopted.
- Proposal, 2031–2034: allowances would be surrendered step by step from 2031 and in full from 2034, if the proposal is adopted.
The method, the requirements of the standard and the choice between carbon-14 and the balance method are on the biogenic CO2 service page. The sampler, the field data and what one percentage point is worth are on the biogenic CO2 overview.