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Germany’s Emissions Cap Program Now Accepts Carbon-14 Biogenic Content Testing

The Brennstoffemissionshandelsgesetz (BEHG) is Germany’s national emissions cap program. In 2023, the Federal Office of Justice (Bundesamt für Justiz) published an ordinance on emissions testing under the BEHG for 2023 to 2030. One result of this ordinance is that the program has started to recognize the biogenic portion of emissions from waste incineration, such as from coal facilities using co-firing and waste-to-energy (WtE) plants. As a result, operators of these plants reporting their emissions for 2023 will be able to use carbon-14 (C-14) testing results to quantify the biogenic portion of their emissions. The BEHG will run until the European Union Greenhouse Gas Emissions Trading Scheme – EU ETS 2 is published and confirmed to be running well, most likely after December 31, 2026.

BEHG Background

The BEHG was passed in December 2019 and came into effect starting in 2021. The program’s initial scope covered emissions from the heating and transportation sectors, with a goal of addressing all fuel emissions not regulated by the EU ETS. The program’s legislation set fixed prices through 2027, at which point the program will either transition to an auction based pricing system or adopt an expanded ETS that covers these sectors, which is already being negotiated in the European Parliament.

From 2021 onward, C-14 testing was one of the methods recommended to determine the biogenic content of some gaseous fuels, liquid fuels, and solid fuels. 

Ordinance on Emissions Reporting 2023-2030

The addition of testing requirements for waste incineration facilities such as co-firing and waste-to-energy plants as part of the program for the next reporting period means C-14 testing will be an accepted method for these facilities to demonstrate biogenic content. Under the new ordinance, waste incineration plants can test emissions either by continuous emissions monitoring (KEMS) or calculation factors (Berechnungsfaktoren).

For facilities testing using KEMS, a representative sample of flue gas should be tested for biogenic content, with C-14 testing following a standard such as ISO 13833. For facilities using calculation factors to estimate biogenic content, C-14 testing of representative waste samples is an acceptable method for demonstrating the accuracy of the calculations.

The German Emissions Trading Authority (DEHSt) guidelines require analysis to be conducted by laboratories accredited by DIN EN ISO/IEC 17025.


2023. “Creation Guide of Surveillance Plans and Emission Reports for Stationary Systems.” Deutsche Emissionshandelsstelle (DEHSt) 

2023. “Ordinance on emissions reporting under the Fuel Emissions Trading Act for the years 2023 to 2030.” Bundesministerium der Justiz

Beta Analytic is not affiliated with the Brennstoffemissionshandelsgesetz (BEHG), the German Emissions Trading Authority or the European Union Greenhouse Gas Emissions Trading Scheme.

Miami-based Beta Analytic is an ISO 17025-accredited laboratory committed to provide rapid, high-quality, and reliable biogenic carbon content testing using analytical standards ISO 13833 and ASTM D6866.

For inquiries on testing fees and turnaround time, please contact the lab using this form or call (+1) 305-662-7760.


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This entry was posted on Friday, August 18th, 2023 and is filed under Biogenic Carbon Testing of Biofuels, Renewable Carbon .