In this newsletter, the Compensation Office informs you about important decisions, innovations and publications on the subject of offsetting Switzerland's carbon emissions.
Newsletter in italiano
A partire dal numero 16, la newsletter è pubblicata anche in italiano:
Newsletter in English
Starting with issue 19, the newsletter is also published in English:
- 1. New binding template for foreign applications (Mitigation Activity Summary, MAS)
- 2. Special features of attestations from sink projects relevant to meeting the offsetting obligation
- 3. Validity of the apportionment of effect with cantons
- 4. Attestations can only be issued for verified and quantified emission reductions
- 5. Minimum requirements for waste incineration plants can be disregarded in compensation projects
- 6. Charging of expenses for projects and programmes abroad according to the FOEN Fees Ordinance
- 7. Notice must be given of inspections
- 8. Leakage must be monitored for all projects over their entire duration
- 9. The Ordinance on Measuring Instruments for Thermal Energy has been revised
- 10. Consultation on the CO2 Ordinance
1. New binding template for foreign applications (Mitigation Activity Summary, MAS)
For all applications for projects outside Switzerland: the MAS is a supplementary document which has had to be submitted since 01/04/2024 with each Mitigation Activity Description Document (MADD) as an appendix to that electronic document.
The Compensation Office (GS KOP) has decided to introduce this document instead of a mandatory MADD template so that redundancies are prevented because partner states may already require the use of their own MADD template. Nevertheless, this ensures that the key points required by Swiss legislation are addressed.
The document does not contain any new information. For each point in the MAS, there must be a link to the corresponding section in the MADD. The MAS template also contains instructions and explanations, which serve as a checklist for applicants when compiling the MADD. In this way, the MAS ensures that all the required information is included in the MADD.
The MAS is available in English and French:
2. Special features of attestations from sink projects relevant to meeting the offsetting obligation
Reminder: Attestations issued for a sink project can no longer be used to meet the offsetting obligation, if the requirements of the CO2 Ordinance are no longer met. If the sink effect is reversed so that the carbon sink becomes a source of emissions, the attestations concerned will be marked in the register and will no longer be recognised for meeting the offsetting obligation. For example, this could happen in the event of a fire in a managed forest.
This also applies retroactively: if in the past the offsetting obligation has been met using attestations from sink projects, it may subsequently become apparent that these projects were not permanent. In this case the past offsetting obligation must be met all over again, and the attestations issued in the past become retroactively invalid.
3. Validity of the apportionment of effect with cantons
The apportionment of effect remains valid until the project is completed. It remains valid even if the crediting period is reviewed. If the offsetting project undergoes substantial modifications, the apportionment of effect must be updated (Art. 11 of the CO2 Ordinance).
For connection subsidies (measure M-07 of the Buildings Programme), the apportionment of effect agreed with the canton will no longer apply after the re-validation of the crediting period if the standard method in Annex 3a of the CO2 Ordinance is applied.
4. Attestations can only be issued for verified and quantified emission reductions
The values for calculating the emission reductions must be based on the project’s or programme’s measurement data. If this is not possible (e.g. for effect models), conservative values must be taken from comparable projects and a plausibility check ("cross-check") of the data performed (Art. 5 para. 1 let. c No 1 of the CO2 Ordinance).
5. Minimum requirements for waste incineration plants can be disregarded in compensation projects
Article 32 of the Waste Ordinance, in the wording applicable from 1 January 2026, can be disregarded when calculating emission reductions in a compensation project. Article 32 requires that at least 55 per cent of the energy content of municipal waste and waste of similar composition is used outside facilities for the thermal treatment of waste (the use of energy to capture CO2 from the flue gas is regarded as use outside the facilities). Forward Action Requests (FAR) requiring the consideration of this article can be ignored.
6. Charging of expenses for projects and programmes abroad according to the FOEN Fees Ordinance
From 01/01/2025, fees will also be charged in accordance with the FOEN Fees Ordinance (GebV-BAFU; SR 814.014) for services and decisions relating to projects and programmes abroad. The fees are the same for both domestic and foreign projects: MAIN (CHF 700), MADD (CHF 1,400 CHF, or CHF 700 for a revalidation), monitoring report (CHF 1,120) and in particular: CHF 700 per Q&A session after the third session. The number of Q&A sessions is determined based on the question that required most Q&A sessions, and is not based on the number of Excel files submitted. The costs are set out in Annex B to the communication 'Offsetting CO2 emissions: projects and programmes'. This is available here (Annex B is separate from the communication):
7. Notice must be given of inspections
When verifying the first monitoring report or when validating a substantial modification, the validator and/or verifier decides on whether to visit the project. The FOEN has explained the best way to perform an inspection in its communication “Offsetting CO2 Emissions: Validation and Verification". Since 01/11/2023, Article 6 paragraph 5 and Article 9 paragraph 3bis of the CO2 Ordinance stipulate that the validator and/or verifier must give notice of an inspection to the applicant and the FOEN in good time.
8. Leakage must be monitored for all projects over their entire duration
Even if a standard method is used, leakage must be addressed and taken into account pursuant to Article 5 paragraph 1 letter c number 4 of the CO2 Ordinance. If the project situation has changed significantly, leakage must also be addressed as part of the revalidation.
For example, in projects relating to the use of wood as an energy source for heating, a supply of firewood must be ensured for the duration of the project and this use must not lead to leakage outside the project limits. This also applies if the project falls under Annex 3a of the CO2 Ordinance.
9. The Ordinance on Measuring Instruments for Thermal Energy has been revised
The revised Ordinance of the Federal Department of Justice and Police (FDJP) on Measuring Instruments for Thermal Energy (OMITE, SR 941.231) has been in force since 01/01/2024. The fundamental requirements correspond to those of the EU Directive 2014/32/EU (MID). The corresponding provisions are equivalent to those of the MID. The deadlines for recalibration have been extended to eight years for all meters without moving parts and six years for meters with moving parts (Art. 6 OMITE).
10. Consultation on the CO2 Ordinance
The implementing provisions of the CO2 Act for the period after 2024 are under consultation. The consultation runs until 17 October 2024. The consultation template and the accompanying explanatory reports can be consulted here:
Vernehmlassungsunterlagen: Ausführungsbestimmungen zum CO2-Gesetz für die Zeit nach 2024
(in German, French or Italian)
Last modification 28.08.2024
