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State of the aviation ETS

Figures for 2019 show that, unlike other sectors covered by the EU ETS, aviation emissions continued to grow by an estimated 1.5% in 2019. This compares to a fall of 8.9% in the emissions from other sectors covered by the ETS, such as power, coal, steel and cement.

Growth in aviation emissions, while other sectors decline, has been a constant feature of the EU’s climate policy. While the COVID crisis will cause a fall in emissions in 2020, that upward growth in emissions will resume unless governments use this crisis to finally put in place measures to rein in and reverse it.

The figures below reflect emissions from flights within Europe, which is the current scope of the emissions trading system (ETS). A broader scope, for example, covering all flights from Europe, would produce different figures.

NOTE: The figures in this page concern 2019. For more up to date figures, please consult our 2020, 2021 and 2022 analysis.

Overall increase

Aviation emissions grew 1.5% in 2019 on routes covered by the EU ETS – that is, flights within Europe (with the exception of flights to outermost regions). Flights to and from were excluded from the scheme at its outset.

The 1.5% growth contrasts with a 8.9% decline in other sectors, a result of more effective measures applied in those sectors to bring emissions down, such as targets for renewable energy in the electricity sector. Until more effective measures are put in place to rein in aviation emissions growth, that disparity will continue.

That 1.5% growth is, however, the slowest since the scheme was introduced fully in 2013. That could be explained by a number of factors: some fall in demand due to #flygskam, bankruptcies of some airlines, and possibly the rising cost of ETS allowances. While the slower growth in emissions is welcome, ultimately a steep decline in emissions is required to bring the sector in line with the goals of the Paris climate agreement. That will require much more action by regulators.


Ryanair is top 10 emitter

Ryanair retained its position as a top 10 emitter, growing its emissions 5.9% in 2019, and climbing from 9th place to 7th. It added 585,000 tonnes of CO2 emissions to its total, bringing its emissions to 10.5 million tonnes for its flights within Europe. This is the largest absolute growth in emissions of any airline in the ETS. That total growth, however, is the lowest growth in Ryanair emissions for five years, suggesting that the airline’s emissions growth is plateauing. However, while other sectors continue to see their emissions decline, Ryanair will climb this table.


Which airline emissions grew and which declined?

Of the 20 biggest airlines, by EU ETS emissions, 15 saw their emissions grow and five saw their emissions decline, for a total increase of 1.0 Mt. The biggest percentage growth was by at 10.8% growth on 2018 emissions, while the biggest decline was by Norwegian Airlines at 6.4%. The top 20 airlines emissions account for 75% of all aviation emissions in the EU ETS.


Which airlines saw their biggest change in emissions?

The overall growth in aviation emissions of 1.0Mt was among the lowest since the scheme was launched in 2013. For example, the figure for growth in 2018 was 2.8Mt. Slower growth is welcome, but ultimately aviation emissions need to decline steeply if the sector is to be brought in line with the Paris agreement.

How to explain the difference? Several airlines that reported large increases in 2018 had significantly less growth in 2019. In the top 20 airlines, these include: Lufthansa (10% growth in 2018, but only 0.5% growth in 2019); EasyJet (11% growth in 2018, 4.1% in 2019); Wizz Air (11% growth in 2018, 2.5% in 2019), TAP (13% in 2018, 3.4% in 2019) and Iberian (10% growth in 2018, 0.3% growth in 2019). Had these airlines maintained their growth of 2018, an additional 1.25 Mt CO2 emissions would have been emitted, equivalent to two-thirds of the difference between the 2018 and 2019 figures.

Aside from 2014, the top 20 airlines have grown faster than the overall sector, representing a gradual consolidation of the market. In 2014, the top 20 airlines’ share of emissions was 68% and by 2019 this increased to 75%. In 2019, the top 20 airlines increased their emissions by 1.0Mt, while the remaining 443 airlines (considering grouped accounts) that reported emissions saw stable emissions. By way of comparison, in 2018 the airlines outside of the top 20 saw a 1.4 Mt drop in CO2 emissions whereas the top 20 increased CO2 emissions by 4.2Mt.

The nine major airlines that were identified as going bankrupt resulted in a reduction of approximately 0.77Mt CO2 emissions compared to their 2018 emissions. See methodological note for the list of bankrupt airlines and their approximated emissions for 2019.

Aside from the bankruptcies, there were several major airlines collectively recording a 535 kt reduction in CO2 emissions: Norwegian Airlines (179 kt CO2), Blue Air (123 kt CO2), Eurowings (128 kt CO2), and British Airways (105 kt CO2). In 2018, these same airlines reported an increase of 497 kt CO2 (discounting Eurowings acquisition of Air Berlin).

Airlines are top 5 emitters in 14 countries

Reflecting the growth in emissions from this sector, airlines are an increasing presence among top emitters in different member states. In 2018, airlines were top 5 emitters in 13 member states (top 10 in 16 member states). In 2019 airlines were top 5 emitters in 14 member states, with Vueling reaching 5th spot in Spain. The aviation sector, including airports and airlines, is increasingly being recognised as a major emitter in states, after years of its emissions flying under the radar. This has led to increasing calls for these emissions to be included in national climate targets, a move supported by T&E. For more information on the emissions in your country, contact us.

ETS delivering only minimal price impact

ETS allowances in 2019 traded at between prices of €18 and €29 a tonne, but averaged around the mid-20s for most of the year. This resulted in a cost to airlines of around €900 million, a negligible cost given that they benefit from a jet fuel tax exemption estimated at €27 billion a year.

The airline sector also received an estimated 32.3 million tonnes of free allowances in 2019, a subsidy estimated at €810 million. Von der Leyen’s European Green Deal has committed to reducing these free allowances, a move supported by several member states.

However, abolishing free allowances would have only increased the cost of the EU ETS to €1.7 billion in 2019, a small figure in comparison to the €27 billion jet fuel tax exemption. This much greater fossil fuel subsidy must be removed if we are serious about bringing down aviation emissions.

Missing report on non-CO2

When the ETS Directive’s aviation provisions were last amended in 2017, legislators included a requirement that the European Commission produce a report on aviation’s substantial non-CO2 effects by 1 January 2020. That deadline has now passed, with no public report in sight. For years, aviation’s non-CO2 effects have been ignored, despite representing two to four times its CO2 impact. This critical aspect of aviation’s climate problem should be addressed without any further delay and in full transparency.

Aviation vs other sectors in the EU ETS

The 1.5% increase from aviation compares with a 8.9% decrease from all other sectors covered by the ETS (the stationary installations such as coal, steel and concrete plants) indicating that aviation will continue growing its share of overall EU emissions. As shown below, since 2013, aviation emissions have increased 27.6% compared to a 19.7% decrease for other sectors in the ETS. Between 1990 and 2018, total EU aviation emissions grew from 1.5% of EU emissions to 3.6%.

Palm oil diesel factories in Europe

Methodological note

For more information on the data treatment, the grouping of airlines’ ETS accounts and bankruptcies, please see our methodological note. For preliminary data release of 2 April 2021, please see the updated methodology.