Chemicals and fertilisers · Checklist

CBAM Regulation Regulation (EU) 2023/956 In force Key date:2026-01-01

• Obtain the status of authorised CBAM declarant Registration as an authorised CBAM declarant with the competent authority of a Member State is required before import. Trigger:Importing goods covered by CBAM (steel, aluminium, cement, fertilisers, hydrogen, electricity) · Evidence:Authorised declarant decision, registration details · Timing:Before import
• Submit the annual CBAM declaration Declare the quantity of imported goods, embedded emissions and carbon price paid. Trigger:Each quarter/year in which goods are imported as an authorised declarant · Evidence:CBAM declaration, supplier emissions data, verification documents · Timing:After each quarter; annual declaration by 30 September
• Purchase and surrender CBAM certificates Purchase and surrender CBAM certificates according to embedded emissions; the price is linked to the weekly average EUA price. Trigger:Embedded emissions confirmed in the annual declaration · Evidence:Certificate holding and surrender records, cancellation certificate · Timing:Surrendered after the annual declaration
• Use actual emissions data rather than default values Use of default values is restricted; verified actual emissions data from the production installation must be obtained. Trigger:Importers wishing to reduce certificate costs · Evidence:Verified emissions data provided by the producer, production route description · Timing:From the definitive period starting in 2026

EU ETS Directive Directive 2003/87/EC In force Key date:2003

• Obtain a greenhouse gas emissions permit Before operating an installation covered by the ETS, obtain a GHG emissions permit from the competent authority of the Member State and draw up a monitoring plan. Trigger:Operating an activity listed in Annex I to the ETS Directive (power generation, energy-intensive industry, aviation, etc.) · Evidence:GHG emissions permit, monitoring plan · Timing:Obtained before operation; valid on a continuing basis
• Monitor and report annual emissions Calculate in accordance with the MRR and submit an annual emissions report after verification by an accredited verifier. Trigger:Each operating year in which an emissions permit is held · Evidence:Monitoring methodology document, verified annual emissions report (AVR) · Timing:Submitted by 31 March of the following year
• Surrender a sufficient number of allowances Surrender EUAs equal to annual emissions; in case of a shortfall, a penalty of €100/t applies and the allowances must still be surrendered. Trigger:Annual emissions verified and confirmed · Evidence:Allowance account surrender records, cancellation certificate · Timing:By 30 September of the following year

ETS Transitional Rules for Free Allocation Delegated Reg (EU) 2019/331 (as amended by 2024/873) In force Key date:2019 / 2024

• Submit activity level data and an allocation application Apply for free allocation under the benchmark method and submit a verified baseline-year activity level report (HAR). Trigger:Installations eligible for free allocation · Evidence:Verified activity level report, monitoring methodology documents · Timing:Each year of the allocation period (free allocation until 2030)
• Comply with the monitoring and reporting requirements as amended by 2024/873 The free allocation rules are simplified, but product benchmarks must be monitored under the latest methodology. Trigger:Installations receiving free allocation · Evidence:Updated monitoring methodology documents · Timing:After 2024/873 enters into force

Industrial Emissions Directive IED 2.0 Directive (EU) 2024/1785 In force Key date:2026-07-01 transposition

• Obtain an IED integrated permit and comply with BAT Operate in accordance with best available techniques (BAT/BREF) and apply an environmental management system. Trigger:Industrial activities listed in Annex I to the IED · Evidence:IED permit, BAT compliance assessment, environmental management system · Timing:After transposition of 2024/1785
• Submit a transformation plan The new IED requires high-emission installations to provide a decarbonisation transformation plan. Trigger:Energy-intensive installations subject to the IED · Evidence:Decarbonisation transformation plan · Timing:After transposition of 2024/1785

Renewable Energy Directive RED III Directive (EU) 2023/2413 In force Key date:2023

• Increase the renewable energy share and retain proof of origin Renewable energy targets rise across sectors and must be evidenced by guarantees of origin (GOs). Trigger:Energy producers/consumers · Evidence:GO certificates, renewable share calculation · Timing:2021–2030

Methane Regulation Regulation (EU) 2024/1787 In force Key date:2024

• Methane MRV and leak detection and repair in the energy sector Measure, report and reduce methane emissions from oil and gas and coal mines (LDAR). Trigger:EU energy operators and importers · Evidence:MRV reports, LDAR records · Timing:Phased from 2025
• Importers report methane emissions in supplier countries Imports of fossil energy must report upstream methane data and mitigation measures. Trigger:Importing oil, natural gas and coal · Evidence:Supplier country MRV data, evidence of equivalent measures · Timing:From 2027

Fluorinated Gases Regulation Regulation (EU) 2024/573 In force Key date:2024

• Comply with F-gas quotas and leak checks Production, import and use are subject to quotas, with leak checks and reporting. Trigger:Production/import of fluorinated greenhouse gases or operation of equipment containing them · Evidence:Quota records, leak check reports, operator certification · Timing:Phased after 2024/573 enters into force

Innovation Fund ETS Directive, Article 10a(8) In force Key date:continuous

• Apply for Innovation Fund support Funding is provided for breakthrough low-carbon technologies through calls for proposals. Trigger:Companies with emission reduction technology projects · Evidence:Project application, emission reduction and financing plan · Timing:According to call cycles

Landfill Directive Directive 1999/31/EC In force Key date:1999 (as amended by 2018/850)

• Only treated waste may be landfilled Except for inert waste that cannot technically be treated, waste must be treated before landfilling. Trigger:Operating a landfill · Evidence:Pre-treatment records, acceptance inspections and ledger · Timing:Ongoing
• Reduce landfilling of biodegradable municipal waste Reduce in stages to 75%, 50% and 35% against the 1995 baseline. Trigger:Landfilling biodegradable municipal waste · Evidence:Landfill volume statistics, compliance evidence · Timing:Phased (1995 baseline)
• Obtain a landfill permit and control leachate and landfill gas Meet technical operating requirements for siting, lining, leachate and landfill gas collection. Trigger:Constructing or operating a landfill · Evidence:Operating permit, leachate and landfill gas management records · Timing:Before operation and on a continuing basis

Waste Framework Directive Directive 2008/98/EC In force Key date:2008 (as amended by 2018/851)

• Apply the waste hierarchy, prioritising prevention, reuse and recycling Waste prevention and management legislation must follow the priority order of prevention, preparing for reuse, recycling, other recovery and disposal. Trigger:Generating or managing waste · Evidence:Waste management plans, disposal and recovery records · Timing:Ongoing
• Meet reuse and recycling targets Household waste and construction and demolition waste must meet the prescribed reuse and recycling rates. Trigger:Management of household waste and construction and demolition waste · Evidence:Recycling rate statistics and reports · Timing:Phased from 2020
• Meet producer responsibility (EPR) Within the scope of extended producer responsibility, organisational and cost obligations for take-back and disposal apply. Trigger:Product falls within the scope of extended producer responsibility · Evidence:EPR registration, records of fulfilment of take-back obligations · Timing:According to Member State transposition rules

Packaging and Packaging Waste Directive Directive 94/62/EC In force Key date:1994

• Packaging must meet essential requirements and join a recovery system Packaging placed on the market must meet the essential requirements on prevention, reuse and recovery and participate in recovery organised by Member States. Trigger:Placing packaging or packaged products on the EU market · Evidence:Compliance technical documentation; Member State producer responsibility registration and fee payment evidence · Timing:Continuing application; PPWR 2025/40 replaces it in stages
• Meet Member State recovery targets The Directive sets minimum recovery rates; specific fees, marking and deposit rules are set by Member States and may be stricter. Trigger:Parties responsible for producer responsibility for packaging waste · Evidence:Declared quantities, recovery evidence and registration with the Member State competent authority · Timing:According to Member State statutory deadlines

Single-Use Plastics Directive Directive (EU) 2019/904 In force Key date:2019

• Restrict certain single-use plastic products The Directive bans certain single-use plastic products from the market and requires reduction, marking or producer responsibility for others. Trigger:Producing or importing single-use plastic products covered by the Annex to the Directive · Evidence:Whether the product falls within the Annex; marking and producer responsibility registration · Timing:Phased from 2019
• Member States may levy separate single-use plastic charges The Directive only requires Member States to take measures and does not set a uniform tax. The German single-use plastic fund, the Spanish plastic packaging tax and the Portuguese plastic bag contribution are national measures on top of it. Trigger:Selling single-use plastic or lightweight plastic bags in the relevant Member State · Evidence:Member State registration, declaration and payment · Timing:According to the Member State entry-into-force date

Urban Wastewater Treatment Directive Directive (EU) 2024/3019 In force Key date:2024 (applies from 2027-01-01)

• Ensure urban wastewater collection and secondary treatment Build and operate collection and treatment facilities according to population equivalent size and the timetable. Trigger:Generating urban wastewater · Evidence:Collection and treatment permit, effluent monitoring reports · Timing:Phased according to the timetable
• Apply quaternary treatment at treatment plants of ≥ 150 000 p.e. Treatment plants with a load of 150 000 population equivalent or more must remove micropollutants. Trigger:Treatment load ≥ 150 000 p.e. · Evidence:Quaternary treatment operation and monitoring data · Timing:2033 / 2039 / 2045
• Advance energy neutrality and GHG emission reductions Improve the energy balance of collection and treatment activities and progressively reduce GHG emissions to sustainable levels. Trigger:Urban wastewater collection and treatment activities · Evidence:Energy consumption and energy balance reports · Timing:By 2045

Nitrates Directive Directive 91/676/EEC In force Key date:1991

• Implement action programmes in vulnerable zones Draw up and implement mandatory action programmes for designated nitrate vulnerable zones. Trigger:Located in a nitrate vulnerable zone · Evidence:Action programme, fertilisation and livestock housing records · Timing:Within 2 years of designation
• Comply with fertiliser application limits and closed periods Limit organic and chemical nitrogen fertiliser application and observe prohibited application periods. Trigger:Agricultural fertilisation activities · Evidence:Fertilisation records, livestock housing capacity evidence · Timing:Ongoing

Product Environmental Footprint (PEF) Method Recommendation Commission Recommendation (EU) 2021/2279 In force Key date:2021

• Use PEF / OEF methods to measure and communicate environmental performance When voluntarily measuring or communicating life-cycle environmental performance, environmental footprint methods should be used. Trigger:Voluntary measurement or communication of life-cycle environmental performance · Evidence:PEF / OEF study report · Timing:Ongoing
• Use category rules where a PEFCR exists Where a PEFCR exists for a product category, the environmental footprint must be calculated according to the category rules. Trigger:A PEFCR exists for the product category · Evidence:PEFCR applicability statement and calculation documents · Timing:Ongoing
• Complete verification before disclosure to third parties PEF / OEF studies disclosed to third parties must be verified in accordance with the methodological requirements. Trigger:Disclosing a PEF / OEF study to third parties · Evidence:Verification report · Timing:Before disclosure

Greenhouse Gas Protocol: Corporate Standard (revised edition) GHG Protocol Corporate Standard In force Key date:2004 (revised edition)

• Determine organisational boundaries and choose a consolidation approach Define the operational scope covered by the inventory using the equity share or control approach. Trigger:Preparing a corporate GHG inventory · Evidence:Boundary document, consolidation approach description · Timing:In the first year and on boundary changes
• Define and account for Scope 1 / 2 / 3 emissions Distinguish direct emissions, indirect emissions from purchased electricity and other value chain indirect emissions. Trigger:Establishing and maintaining a GHG inventory · Evidence:Emissions source inventory, scope classification and emission factors · Timing:Ongoing
• Follow the transparency principle and retain an audit trail Record processes, assumptions and limitations so that a third party can reproduce the results from the same source data. Trigger:Reporting GHG data · Evidence:Assumptions and limitations statement, audit trail documentation · Timing:Ongoing

TfS/Cefic Chemical Industry Product Carbon Footprint Guideline (2024) TfS PCF Guideline v3 (2024) In force Key date:2024

• Calculate product carbon footprint on a cradle-to-gate basis Covers resource extraction to the reporting company's gate (including transport), excluding use and end-of-life stages. Trigger:Communicating PCF for chemical products externally · Evidence:PCF report, system boundary and inventory description · Timing:Ongoing
• Aggregate PCF of purchased goods and pass it downstream Aggregate the PCF of purchased goods into Scope 3.1 and pass the results downstream in the supply chain. Trigger:Annual corporate reporting and supply chain data exchange · Evidence:Supplier PCF data, summary tables · Timing:Annually
• Partial PCFs must not be used for comparative claims A cradle-to-gate PCF covers only one impact category and cannot be used for product comparisons. Trigger:Making comparative claims about products · Evidence:Full LCA study · Timing:At the time of comparison