Memo10,000 words
Update: 20 March 2025 Guidance in relation to Stage 2 of the free allocation application process now available - UKETS12A FAR. UKETS11 FAR and UKETS13 FAR have been updated. ### Update: 26 November 2025 The main Free Allocation Review response is now available on the [FAR consultation page](https://www.gov.uk/government/consultations/uk-emissions-trading-scheme-free-allocation-review). ### Update: 10 June 2025 The previous version of UK ETS17 stated that the relevant year when allocation would be reduced is 2026 – this was incorrect, and the relevant year is 2027 according to Article 16(5) of the FAR. All installation operators within scope of the UK Emissions Trading Scheme (UK ETS) are required to submit data to their regulator **between 1 April to 30 June 2025**, ahead of the next allocation period. The Baseline Data Collection is an essential part of the free allocation application, and failure to submit this report by the deadline will result in an operator not receiving free allocation at any point in the 2027-2030 period, and in some cases, in 2026. This data collection period is also the application window for hospital or small emitter (HSE) and ultra-small emitter (USE) status. **Applicants for HSE or USE status** must submit all data required to apply to join these lists for the 2026-2030 period **between 1 April to 30 June 2025**. ### Template and guidance The Baseline Data Report (BDR) template is for use by all operators: * to meet their submission requirements * apply to acquire USE/HSE status * and/or to apply to receive FA The following guidance is for operators of installations within the current scope of the UK ETS: * **UKETS12 guidance** explains how operators should report their data using the BDR template during the 1 April to 30 June 2025 collection window * **UKETS12A guidance** explains how operators should report their data using the baseline date reporting template during the 1 April 2026 to 30 June 2026 collection window. There are other supplementary guidance documents for operators explaining the different elements of free allocation applications and calculations: * **UKETS11** explains how the allocation methodology is applied at the installation level, including the impact of the provisions designed to address the exposure to a significant risk of carbon leakage. It describes the different types of sub-installation defined in the methodology and the approach for determining the allocation for each one * **UKETS13** explains the requirements for monitoring and reporting all data required for the free allocation of UK allowances and the Baseline Data Collection * **UKETS14** provides guidance on the verification of data relevant to the free allocation of allowances (baseline data and activity level data) as well as the accreditation of verifiers that conduct verification activities under the UK ETS. * **UKETS15 FAR: Cross-boundary heat flows** explains the allocation of allowances for heat flows across an installation boundary where the heat is defined as measurable heat. The treatment of heat imports and exports to and from UK ETS installations, non-UK ETS installations and district heating networks is described * **UKETS17 FAR: Waste gases and process emissions sub-installations** provides guidance on free allocation to installations engaged in the production and consumption of waste gases and the associated allocation methods, with a focus on process emissions sub-installations * **UKETS18 FAR: Sector specific guidance** provides relevant information for each product referred to by the 52 product benchmarks These guidance documents are subject to review following the outcome of the Free Allocation Review. Existing USEs should consult this guidance: [Register your installation as an ultra-small emitter](https://www.gov.uk/guidance/opt-out-of-the-uk-ets-if-your-installation-is-an-ultra-small-emitter). If an existing USE applies for FA and/or HSE status, you should also refer to the documents here in relation to the BDR. --- UKETS12 FAR – Guidance on completing the 2025 Baseline Data Collection and applying for HSE/USE status March 2025 Note This document is intended to provide guidance for operators of installations. If there is any inconsistency between the guidance and legislation, the legislation prevails. © Crown copyright 2025 This publication is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government- licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gsi.gov.uk. Where we have identified any third-party copyright information you will need to obtain permission from the copyright holders concerned. Any enquiries regarding this publication should be sent to us at: emissions.trading@energysecurity.gov.uk 2 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status Contents Overview of this guidance Important information on submission of data Verification requirements Relevance of sections to each type of operator General guidance on BDR template completion Process of filling in the template A “Installation Data” – General information on this report A.I. Identification of the Installation A.II Information on this baseline data report A.III. List of sub-installations 1. Product benchmark sub-installations 2. Sub-installations with fall-back approaches A.IV List of technical connections D “Emissions” – Attribution of emissions D.I Total direct GHG emissions and energy input from fuels D.I.1 Automatically calculated data at installation level D.I.2 Aggregated reporting at installation level D.I.3 Data for use in Sheets “D_Emission” and “E_EnergyFlows” D.II Attribution of emissions to sub-installations D.II.1 Total emissions at installation level D.II.2 Attribution to sub-installations D.III Cogeneration tool D.III.1 Calculating emissions attributable to heat production (single CHP) D.III.2 Calculating emissions attributable to heat production (two CHPs) D.IV Waste gas tool D.IV.1 Process emissions - waste gases produced outside product BMs 1 D.IV.2 Process emissions - waste gases produced outside product BMs 2 E “Energy Flows” – data on energy input, measurable heat and electricity E.I Energy input from fuels E.I.1 Overview and split into use categories E.II Measurable heat 5 8 11 13 14 17 19 19 23 26 26 27 27 29 29 29 29 30 30 31 31 31 32 33 34 35 37 38 38 38 41 3 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status E.III Waste gas balance E.IV Electricity F “Product BM” – Sub-installation data relating to product benchmarks F.I Historic Activity Levels and disaggregated production details G “Fall-back” – Sub-installation data relating to fall-back sub-installations G.I Historic Activity Levels and disaggregated production details G.I.1 Fall-Back Sub-installation 1, heat benchmark carbon leakage H “Special BM” – Special data for some product benchmarks H.I CWT (Refinery products) H.II Lime H.III Dolime H.IV Steam cracking H.V Aromatics H.VI Hydrogen H.VII Synthesis gas H.VIII Ethylene oxide/glycols H.IX Vinyl chloride monomer (VCM) I Specific – contains new guidance I.i HSE applicants' supporting evidence I.ii Electricity generator supporting evidence B+C "Annual Emissions Data" – alternative option J “Comments” – Comments and further information J.I Documents supporting this report J.II Free space for all kinds of supplemental information K “Summary” – Overview of most important data for FA applications K.I Installation data K.II Baseline period and eligibility K.III Emissions and Energy Flows K.IV Sub-installation data relevant for allocation and benchmark updates K.V Calculation of preliminary annual number of FA 47 48 50 50 62 62 62 70 70 70 72 72 73 74 75 75 76 78 78 80 84 85 85 85 86 86 86 86 86 87 4 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status Overview of this guidance What is the purpose of this guidance document? This guidance document is intended for operators of installations within the current scope of the UK Emissions Trading Scheme (UK ETS). The submission window will be open from 1 April until 30 June 2025. The Baseline Data Collection is an essential part of an application for free allocation (FA), and failure to submit a verified baseline data report (BDR) by the deadline will result in the installation not receiving any FA at any point during the second allocation period 2027 – 2030 (and, in certain cases, during the 2026 scheme year1) as set out in the Authority Response to the ‘Moving the Second UK ETS Free Allocation Period’.2 More information is provided in Section 2. This guidance document is not a legislative document, and operators should ensure that they have consulted the legislation listed in Section 1.2 to ensure they are submitting the correct information. In this guidance, we may refer to other guidance documents which have not yet been finalised at the time of publication, and we identify such documents in yellow highlight. Where such guidance documents are referenced, operators should instead refer to their regulator in the first instance. Why is this guidance relevant to my installation? This guidance is important for the following types of operator: • All installation operators, even those who do not want to apply for FA or will not be eligible for FA, in the next allocation period. • All installation operators who would like to apply for FA in the next allocation period who either: o have been issued with a greenhouse gas emissions (GHGE) permit3, o have been issued with a Hospital and Small Emitter (HSE) permit4, or o will hold Ultra Small Emitter (USE) status before or on 30 June 2025. 1 The BDR to be submitted during the April to June 2025 window will be used to determine the following installations entitlement to FA in the 2026 scheme year: (i) an installation was not an FA installation (within the meaning of article 4A of the UK ETS Order) for the 2021-2025 allocation period, (ii) an electricity generator that provides a statement that the condition in Article 2b(2) of the FAR will be met, and (iii) an electricity generator that does not meet the definition of ‘electricity generator’ in Article 2c(3) of the FAR by virtue of Article 2c(4) of the FAR. 2 Please see the Authority Response to ‘Moving the Second UK ETS Free Allocation Period’ here. 3 This includes installations an application for a GHGE permit has been made but not yet determined, as long as the permit is issued before 30 June 2025. 4 This includes installations an application for an HSE permit has been made but not yet determined, as long as the permit is issued before 30 June 2025. 5 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status • Those who wish to apply for HSE status for 2026-2030 under Schedule 7 of the Greenhouse Gas Emissions Trading Scheme Order 2020 (the Order). • Those who wish to apply for USE status for 2026-2030 under Schedule 8 of the Order but are not currently USEs. Existing USEs should consult the separate guidance document. See below for more information on this. • Installations currently on the HSE or USE lists and wishing to be able to apply for FA for the 2026 scheme year and/or the 2027-2030 allocation period. • Operators of installations currently classed as electricity generators, but that meet the criteria laid out in Article 2b of the FAR or their electricity produced falls under Article 2c(4) of the FAR, and wish to apply for FA for 2026 and/or the 2027-2030 allocation period. Note: HSE and USE installation operators who believe they may exceed the USE or HSE emissions thresholds during the period 2026-2030 may wish to apply for FA, as in such circumstances they would be required to rejoin the main UK ETS scheme. USE or HSE installations that join the main scheme during any part of the period 2026-2030 will only be eligible for FA if they submit a full verified BDR in the 2025 submission window. USE and HSE installations should carefully consider the likelihood that they may exceed the relevant thresholds during the 2026-2030 period before submitting a full FA application or whether they may have other reasons to apply to participate in the main UK ETS instead and seek FA. Please note, if a HSE or USE eligible chooses to be a part of the main UK ETS, they cannot acquire HSE or USE status within the 2026-2030 allocation period. All existing USEs should complete the separate USE template to demonstrate verified reportable emissions data and refer to the Ultra Small Emitter application process guidance document. If you are an existing USE applying for FA and/or HSE status, you should also refer to this guidance document and complete the BDR template. (Please see Section 3 for Verification requirements). This document does not apply to UK ETS aviation operators, who are not required to submit data in this period. How is this guidance structured? The main body of this guidance document follows the order of the BDR template and the sections are labelled according to the sheet titles in the template. Not all sections will be relevant to all operators. Please refer to Table 1 (in Section 4 below) to determine which sections are relevant to your installation, with corresponding page links. Where can I refer to the relevant legislation? The following legislation will be referred to throughout this document. Most references to articles within this document refer to the UK ETS Order and to the FAR which are listed first. 6 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status • The Greenhouse Gas Emissions Trading Scheme Order 2020 (the Order) (https://www.legislation.gov.uk/uksi/2020/1265/contents) • The Free Allocation Regulation (FAR) (https://www.legislation.gov.uk/eur/2019/331/contents) as it has effect in domestic law • The Monitoring and Reporting Regulation (MRR 2018) (Commission Implementing Regulation (EU) 2018/2066 of 19 December 2018) on the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the European Parliament and of the Council (disregarding any amendments adopted after 11th November 2020) as given effect for the purpose of the UK ETS by article 24 of the Order and subject to the modifications made by Schedules 4, 7 and 8 to the Order • The Verification Regulation (VR 2018) (Commission Implementing Regulation (EU) 2018/2067 of 19 December 2018) on the verification of data and on the accreditation of verifiers pursuant to Directive 2003/87/EC of the European Parliament and of the Council (disregarding any amendments adopted after 11th November 2020) as given effect for the purpose of the UK ETS by article 25 of the Order and subject to the modifications in Schedules 5 and 8 to the Order The Articles and Schedules in the above legislation that are related to specific types of operator are as follows: • For operators not applying for FA nor HSE/USE status, the requirement to submit data is contained in article 27A of the Order: https://www.legislation.gov.uk/uksi/2020/1265/article/27A • For operators applying for FA, application detail is included in Article 4 of the Free Allocation Regulation: https://www.legislation.gov.uk/eur/2019/331/article/4 • For operators applying to be HSEs in the next period: applicant criteria and application detail, is contained under Schedule 7 to the Order (which also modifies the MMR 2018 for HSE purposes): https://www.legislation.gov.uk/uksi/2020/1265/schedule/7 • For operators applying to be USEs in the next period: applicant criteria and application detail is contained under Schedule 8 to the Order (which also refers to the modifications to the MMR 2018 and VR 2018 for USE purposes): https://www.legislation.gov.uk/uksi/2020/1265/schedule/8 • For operators applying to be HSEs and USEs in the next allocation period, Schedule 8A to the Order is also relevant: https://www.legislation.gov.uk/uksi/2020/1265/article/8A. 7 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status Important information on submission of data What are the deadlines for submitting my information? The required information, for which the BDR has been designed to facilitate, must be uploaded to Manage your UK ETS reporting (METS) platform5 by 30th June 2025 for each installation (unless you are an existing USE in which case you submit all of your documents via email to your regulator). What data should I submit? If not applying for FA, nor HSE or USE status, operators must submit the data as required by article 27A of the Order: • Details of the installation, including details of any permit in force • Activity information (that is to say, the information set out in section 1.3 of Annex 4 to the FAR) • Details of eligibility for FA (that is to say, the information set out in section 1.4 of Annex 4 to the FAR) • A statement that the operator is not applying for FA in the 2026-2030 allocation period6 under Article 4 of the FAR. If applying for FA, in accordance with Article 4(2) of the FAR, the operator must provide: • A BDR verified as satisfactory, including the operational data relating to their installation and sub-installations (this can be done using the BDR template provided by the UK ETS Authority) • The monitoring methodology plan detailing how historic data for the baseline period were determined and how data will be determined going forward during the second allocation period (ONLY if this has not already been approved by the regulator). • A verification report, with a positive opinion, proving that data have been verified by a third-party (a template will be made available to verifiers by the UK ETS Authority). If applying to join the HSE list for 2026-20307, in accordance with Schedule 7 to the Order, the operator must provide: 5 https://manage-emissions-reporting.service.gov.uk/ 6 A recent consultation ‘Moving the UK ETS Second Free Allocation Period’ sought views on delaying the start of the next allocation period to 2027. If this proposal is implemented, legislation will be updated accordingly, and operators not applying for FA may need to provide statements that they are not applying for FA in either 2026 or 2027-2030. 7 The Authority Response to the consultation ‘Moving the UK ETS Second Free Allocation Period’, which proposed to delay the start of the next allocation period to 2027, confirms that the next period in which HSE or USE status can be granted will remain as 2026-2030. Please see full response here: https://www.gov.uk/government/consultations/uk-emissions-trading- scheme-free-allocation-review#:~:text=As%20a%20result%20of%20the,allocation%20period%20to%20include%202026 8 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status • Details of the installation, including of any permit in force and evidence that the installation meets Condition A, B or C. The evidence must be verified as satisfactory in accordance with the VR 2018 or, where relevant, set out in an emissions report accompanied by a declaration (referred to in this guidance as a ‘self-declaration’) stating the following: • • • that in preparing the emissions report the operator has complied with the MRR 2018, the operator has complied with the monitoring plan, the emissions report is free from material misstatements. If you are an existing GHGE or HSE permit holder applying for USE status for 2026-2030, the operator, in accordance with Schedule 8 to the Order, must provide: • Details of the installation, including of any permit in force and evidence that (a) a regulated activity began to be carried out at the installation on or before 1st January 20218; and (b) the installation's reportable emissions in each of the 2021, 2022 and 2023 scheme years did not exceed the maximum amount (2,499 tCO2e). As with applications for HSE status, the evidence of reportable emissions must be verified as satisfactory or set out in an emissions report accompanied by a self-declaration. How do I submit my information? A task will appear on your task list within the METS platform. You will also be notified of this task via email. To submit your information, this task on the METS platform needs to be completed. Existing USE applicants will send their USE reports, along with verification reports and the BDR if applicable, to regulators via email which are provided below: For sites in England - the Environment Agency (EA) at etsdatacollection@environment- agency.gov.uk For sites in Scotland - the Scottish Environment Protection Agency (SEPA) at emission.trading@sepa.org.uk. For sites in Wales - Natural Resources Wales (NRW) at GHGHelp@naturalresourceswales.gov.uk. For sites in Northern Ireland - the Northern Ireland Environment Agency (NIEA) at emissions.trading@daera-ni.gov.uk. For offshore facilities - the Offshore Petroleum Regulator for Environment and Decommissioning (OPRED) at OPRED@energysecurity.gov.uk. 8 The UK ETS Authority has recently published the Authority Response to the Consultation on technical and operational amendments including confirmation of our intent to implement legislation to allow operators who began a regulated between 2 January 2021 and 1 January 2024 to become eligible to apply for USE status in the 2026-2030 period. 9 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status Caveat to the BDC and preliminary free allocation values As previously communicated, the UK ETS Authority has announced to operators that the start of the second allocation period will be moved from 2026 to 2027 for FA purposes. This follows recognition of stakeholder views and concerns over the potential misalignment of industrial decarbonisation and carbon leakage policy. This change also enables us to align the implementation of the Free Allocation Review with the introduction of the UK Carbon Border Adjustment Mechanism (CBAM), ensuring a holistic policy approach to carbon leakage, and providing additional time for policy development in what is a complex and challenging area. These are important decisions which will impact the future of business and industry, and we want to get them right. Following this announcement, any changes to FA policy following the Free Allocation Review will take effect from 2027. The Free Allocation Review consultation sought views on some changes to FA rules, such as changes to the carbon leakage list and application of the carbon leakage exposure factor, which, if implemented, could change eligibility for FA. Depending on the outcome of the Free Allocation Review, some installations’ eligibility to FA could change after the baseline data collection exercise has concluded. In addition, the indicative FA values produced by the BDR template may be subject to revision following the publication of any changes to the FA rules resulting from the Free Allocation Review. The Authority response to the consultation to move the start of the second allocation period from 2026 to 2027 has now been published on gov.uk and sets out timings for the second stage of the FA application and more information on any requirements following the baseline data collection exercise. The UK ETS Authority is providing the current guidance now, to ensure that all operators have early notice on requirements for the April-June 2025 baseline data collection period. These changes do not impact what information needs to be submitted in the baseline data collection period in 2025. UK Carbon Border Adjustment Mechanism On October 30th 2024, the government issued a response to the consultation on implementing the UK CBAM, confirming that a CBAM is being introduced in 2027, and will apply to all goods in the aluminium, cement, fertiliser, hydrogen, and iron & steel sectors. UK ETS operators within CBAM sectors should apply for free allowances as usual by completing this baseline data collection exercise. The UK ETS Authority published a consultation on how to adjust free allowances in CBAM sectors.9 This opened on 16 December 2024 and all responses should be submitted prior to closing on 10 March 2025 at 11:59pm. 9 https://www.gov.uk/government/consultations/uk-emissions-trading-scheme-free-allocation-review-carbon-leakage 10 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status Verification requirements What are the verification requirements? Operators applying for FA are required to have their BDR verified as satisfactory in accordance with the VR 2018 (see Article 4(2)(a) of the FAR). Operators applying for HSE status under Condition B or C are required to have the evidence of their historic reportable emissions verified as satisfactory in accordance with the VR 2018. Alternatively, the relevant emissions reports must be accompanied by a self-declaration referred to in para 11(2)(b)(ii) of Schedule 7 to the Order (see para 5(6) of Schedule 7 to the Order). The same obligations may apply to operators applying under Condition A (see para 6(3) of Schedule 7 to the Order). Operators applying for USE status are required to have the evidence of their reportable emissions verified as satisfactory in accordance with the VR 2018. Alternatively, the relevant emissions reports must be accompanied by a self-declaration referred to in para 11(2)(b)(ii) of Schedule 7 to the Order (see para 3(7) of Schedule 8 to the Order). Operators providing information under article 27A of the Order, i.e. those not applying for FA nor HSE/USE status, are not required to have their information verified (see article 27A of the Order). It is the operator’s responsibility to ensure that they have complied with the legislation and provided verified data where required. What does this mean for me? Those applying for FA must have their BDR verified irrespective of whether they have previously provided verified data to their regulator which covers the baseline period. If you are an existing HSE applying for either HSE or USE status, you will have been required to provide emissions reports to your regulator in each scheme year you were an HSE. This emissions report would have been verified as satisfactory in accordance with the VR 2018 or would have been accompanied by the self-declaration outlined at para 11(2)(b) of Schedule 7 to the Order. If these reports show that you meet Condition A, B or C for HSE status, or the condition for USE status, then you may decide that they can be your evidence of your reportable emissions and, because they have already been verified or accompanied by the self-declaration, you are not be required to get them re-verified/re-declared. If you are an existing USE applying for either HSE or USE status, it is unlikely that you would have provided your emissions information to your regulator before. As such, you will not have pre-existing evidence of your reportable emissions, which has been verified as satisfactory in accordance with the VR 2018, that you can use as part of your HSE or USE application. Therefore, you will need to provide evidence that you meet Condition A, B or C for HSE status, or the condition for USE status, and the evidence must be verified as satisfactory in accordance with the VR 2018. The USE Data Collection template has been designed for use 11 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status by existing USEs, so that you can include evidence of your reportable emissions and provide this to a verifier for verification. If you are an existing USE, please consult the Ultra-Small Emitter application process guidance. If you are only providing data under article 27A of the Order, you are not required to have this information verified. 12 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status Relevance of sections to each type of operator Which sections of the BDR template are relevant to my installation? Not all sections in this document (and correspondingly, the BDR template) are relevant for all installations. Table 1 indicates which sections of the template are relevant depending on the type of installation or type of application. Installations that are not applying for FA or HSE or USE status, or installations that received a permit before 30 June 2025 but have not operated in the baseline period, need only complete Sections A.I (“Identification of the Installation”), A.II (“Information on this baseline data report”) and, when relevant, A.IV (“List of technical connections”). Applicants applying for USE status or HSE status need only complete Sections A.I (“Identification of the Installation”), A.II (“Information on this baseline data report”), part of D.I.2 (“Emissions”) and, if relevant, the supporting HSE evidence of Section I.I (HSE applicants' supporting evidence). All installations eligible for FA should fill in the template if they wish to apply to receive FA in the 2027-2030 allocation period, and in some cases, in the 2026 scheme year. An overview of the sections to be filled in is given in the table below. Note that the table is indicative only. It is the operator’s responsibility to ensure that they have provided all the information that is required under the legislation. Relevant sections of BDR template and submission requirements Type of UK ETS operator Sections of BDR template Monitoring Methodology Plan Verification report with positive opinion • If applying for FA, yes (see row (5) below) • If not applying for FA, no • If applying for FA – your BDR must be verified • If not applying for FA – does not need to be verified (if applying for USE or HSE status, please see row (2) or row (3)) 1 Electricity generator 2 HSE applicant • Sheet A • Sheet I (I Specific) • D.I.2 (Emissions) • If applying for FA, see row (5) • Sheet A • D.I.2 (Emissions) • Sheet I part 2 (HSE applicants' supporting evidence) • If applying for FA, see row (5) • No, unless they are also applying for FA in which case, yes (see row (5) below) 3 USE applicant: current GHGE or HSE permit holders (existing USEs see USE guidance) • Sheet A • D.I.2 (Emissions) • If applying for FA, see row (5) • No, unless they are also applying for FA in which case, yes (see row 5 below) • If applying for FA – your BDR must be verified • If not applying for FA – your evidence of historic reportable emissions must be verified or accompanied by a self- declaration (this may not be required for Condition A) • If applying for FA – your BDR must be verified • If not applying for FA – your evidence of reportable emissions must be verified or accompanied by a self- declaration 13 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status 4 Operators not applying for FA nor HSE/USE status • Sheet A • No • Does not need to be verified 5 Operators applying for FA • All sheets except B+C (if supplying aggregated data in Sheet D) and Sheet I (if exporting electricity)) • Yes (unless previously approved under Article 8 of the FAR) • Your BDR must be verified Any UK operator that wishes to be eligible to apply for a free allocation of allowances for the 2027-2030 allocation period and, in some cases, to apply for FA for the 2026 scheme year, should submit an independently verified BDR that meets the requirements of Article 4 of the FAR to the relevant regulator (EA in England, SEPA in Scotland, NRW in Wales, NIEA in Northern Ireland and OPRED for offshore installations) by 30 June 2025. The BDR template provided by the UK ETS Authority can be used for this purpose. It is the responsibility of the operator to ensure that they have provided all the information required. Any UK operator applying for HSE or USE status must submit the information required under Schedule 7 or Schedule 8 to the Order to their regulator by 30 June 2025. The BDR template can be used for this purpose. It is the responsibility of the operator to ensure that they have provided all the information required. Note that a USE Data Collection template is available for use by existing USEs to demonstrate verified reportable emissions data. If you are an existing USE applying for FA and/or HSE status, you should also complete the BDR template. It is the responsibility of the operator to ensure that they have provided all the information required. UK operators not applying for either FA or status as an HSE or a USE must provide the information required by article 27A of the Order to their regulator by 30 June 2025. The BDR template can be used for this purpose. It is the responsibility of the operator to ensure that they have provided all the information required.General guidance on BDR template completion This is a reminder of the key guidelines listed in Sheet ‘b_Guidelines & conditions’ of the template. It is recommended that you go through the template from start to end as there are formulae in the template that take information from earlier Sheets. To protect formulae against unintended modifications, which usually lead to wrong and misleading results, it is of utmost importance NOT TO USE the CUT & PASTE feature. If you want to move data, first COPY and PASTE the data values only, and thereafter delete the unwanted data in the old (wrong) place. 14 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status There are a few functions which will guide you through the form which depend on previous input, such as cells changing colour if an input is not needed (see colour codes below). Please take note of the following criteria for each installation: • All installations, whether applying to receive FA or not, should fill in the Sheet "A_InstallationData" Sheet. • If applying to receive FA in the second allocation period, you should submit all Sheets (except B+C if inputting aggregated data). • Automatic calculation (to be found in the menu Formula/Calculation options) must be turned on. • It is especially important to fill in Sheet "A_InstallationData", sections A.II.2 (Baseline period chosen) and A.III (definition of sub-installations). Without correct information in these sections, calculation results may be wrong, or data for sub-installations may not be possible to enter correctly. • There are a few functions which will guide you through the form which depend on previous input, such as cells changing colour if an input is not needed (see colour codes below). However, sometimes it is relevant to first continue data input in another Sheet before continuing (e.g. "H_specialBM" needs input before "F_ProductBM" can be finalised in cases where Annex III of the FAR must be applied). • Whenever a value of zero is to be reported, it should be entered rather than keeping the cell empty. If a cell is kept empty, the regulator does not know if the value has not been reported, is irrelevant or unknown. Values needed for calculations should always be entered (especially if zero, because some formulas don't give results when required cells are empty). • In several fields you can choose from predefined inputs. For selecting from such a "drop-down list" either click with the mouse on the small arrow appearing at the right border of the cell, or press "Alt-CursorDown" when you have selected the cell. Some fields allow you to input your own text even if such a drop-down list exists. This is the case when drop-down lists contain empty list entries. • Error messages will occur sometimes when data entries are incomplete. However, the non-appearance of error messages is not a guarantee of correct calculations, as a data completeness test is not always possible. If no result appears in a green field, it can be assumed that some data is still missing. • Special care must be taken regarding consistency of data with the units displayed. • Error messages are often very short due to the limited space available. The most important ones are: 15 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status incomplete! Means that data is not sufficient for calculation (e.g. an emission factor is missing in one year) inconsistent! The units selected are inconsistent, and calculations based upon related inputs will give wrong results. negative! In this calculation no negative values are allowed. A.II.1.a-g! These are references to document sections. This means that data in the referenced sections are missing. Colour codes and fonts: Black bold text: This is text describing the input required. Smaller italic text: This text gives further explanations. Yellow fields indicate mandatory inputs. However, if the topic is not relevant for the installation, no input is required. Light orange fields indicate that an input is optional. Green fields show automatically calculated results. Red text indicates error messages (missing data etc). Shaded fields indicate that an input in another field makes the input here irrelevant. Light grey areas are dedicated for navigation and hyperlinks. • Navigation panels on top of each Sheet provide hyperlinks for quick jumps to individual input sections. The first line ("Table of contents", "Previous Sheet", "next Sheet", "Summary") and the points "Top of Sheet" and "End of Sheet" are the same for all Sheets. Depending on the Sheet, further menu items are added. If the background colour of one of the hyperlink areas turns red, this indicates that data is missing in the related section (not in all Sheets). • This template has been locked against data entry except for yellow fields. However, for transparency reasons, no password has been set. This allows for complete viewing of all formulae. When using this file for data entry, it is recommended to keep the protection in force. The Sheets should only be unprotected for checking the validity of formulae. It is recommended to do this in a separate file. • Data fields have not been optimised for numerical and other formats. However, Sheet protection has been limited to allow you to use your own formats. You may decide about the number of decimal places displayed. The number of places is in principle independent from the precision of calculation. The option "Precision as displayed" of MS Excel should be deactivated if possible. For more details, consult MS Excel's "Help" function on this topic. 16 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status Process of filling in the template The following chapters mirror the structure of the BDR Sheets and include the following: • A “Installation Data” – General information on this report • B+C “Annual Emissions Data” • D “Emissions” – Total emissions & energy input from fuels (installation wide) including the Co-generation and waste gas tools • E “Energy flows” – Data on energy input, including the measurable heat, waste gas and electricity balance • F “Product BM” – Sub-installation data relating to product benchmarks, including attribution of emissions to each product benchmark • G “Fall-back” – Sub-installation data relating to fall-back sub-installations, including attribution of emissions to each fall-back sub-installation • H “Special BM” – Special data for some product benchmarks • I “I specific” – Additional data requirements by the UK ETS Authority for Hospital and Small Emitter applicants and electricity generators • J “Comments” – Comments and further information • K “Summary” – Overview of most important data including the total preliminary FA The table below indicates which Sections of the template cover data relating to specific aspects. Question Relevant section Determination of eligibility of FA Is the installation classified as an “electricity generator”? If yes, does it produce heat eligible for FA? Determination of number of sub-installations Is there a product benchmark sub-installation? Are there fall-back sub-installations (to be specified per type of sub-installation, including CL status)? Determination of relevant technical connections Which technical connections are relevant (name of connecting installation, type of connection, and flow direction)? Determination of direct emissions and energy flows A.II.1(a) and I.III A.II.1(d) and I.III A.III.1 A.III.2 A.IV 17 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status How many direct emissions occur at the installation? D.I or B+C How should direct emissions be attributed to sub- installations? How are emissions split between heat and electricity in the case of a CHP? How are process emissions calculated if waste gases are produced outside product benchmarks? How much energy input from fuels is there at the installation? How are fuels used attributed to sub-installations? What is the heat balance of the installation? What is the waste gas balance of the installation? What is the electricity balance of the installation? Determination of HAL product benchmarks What is HAL of relevant product benchmarks? Determination of HAL fall-back sub-installations HAL heat benchmark sub-installation(s) HAL district heating sub-installation HAL fuel benchmark sub-installation(s) HAL process emissions sub-installation(s) Determination of HSE and Electricity generator supporting evidence HSE applicants’ supporting evidence Electricity generator supporting evidence D.II D.III D.IV E.I.1(a) E.I.1(c) E.II E.III E.IV F and H in case of special product benchmarks G.I.1 and G.I.2 G.I.3 G.I.4 and G.I.5 G.I.6 and G.I.7 I.II.1 – 10 I.III.1 – 12 18 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status A “Installation Data” – General information on this report This section describes the data needed to identify the installation and its most important characteristics for the purpose of determining FA or to join the HSE or USE lists for the 2026- 2030 period. Chapters Identification of the Installation and Information on this baseline report should be filled out by all operators falling within the scope of the UK ETS. Chapter A.II and Chapter IV should be filled out by all operators of installations eligible for FA. Chapter List of technical connections should be filled out by operators of installations eligible for FA and meeting the listed conditions. A.I. Identification of the Installation 1. General information The operator should specify: a) Name of the installation: This is the name generally used on permits and other official documentation and should be consistent with previous communication with the regulator (if applicable). b) Has this installation been included in the UK ETS before? Please select True or False. c) UK ETS Permit number provided by your UK regulator: Please use your current permit number. USEs should use the permit number they had when they left the EU ETS. 19 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status d) UK Registry ID: Please refer to Tab A Row 61 of your Activity Level Report for your Registry ID. This consists of 7 digits starting with 1. E.g. 1000001. HSEs and USEs do not need to provide this. e) Permit information: The operator should fill in the name of the regulator responsible for handling the permit of that installation, the permit ID and the date of issuance when the installation was first included in the UK ETS, as well as the most recent updated permit ID and date of issuance if applicable (i.e. re-issue dates and IDs). f) Date of start of operation of the installation: This input is only relevant if the installation has started operation after 1 January 2019. If this date is left blank, it will be assumed that the date of start of operation was before 1 January 2019. g) This installation is an incumbent: Please select ‘True’ to confirm that the operator is an incumbent. New entrants should not use this template. See “UKETS16 FAR - Guidance on allocation level changes” for details on incumbents, new entrants and closures. See also ‘UKETS11FAR - Determining allocation at the installation level’ on allocation approaches. h) Operator data: Name, address, phone numbers, email and the name of authorised representative. The operator is the person who operates or controls an installation or to whom decisive economic power over the technical functioning of the installation has been delegated. i) Installation address: Address, city and country. 2. Contact persons The operator should specify the contact details of the person(s) responsible for completing or overseeing this report in case clarifications or communication is needed. For example: a) Authorised representative of the operator in charge of the installation; and b) Primary contact person for technical questions. • Also, for both persons the contact details should be reported, such as: name, email and telephone number. 3. Verifier engaged for this baseline data report The operator should specify: a) The name and address of the verifier, for example details of the verification company, in particular: company name, address and country. b) The authorised representative of the verifier: the person who carried out (Ideally it is the lead verifier involved with this report) the verification, in particular: name, e-mail address and telephone number. 20 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status c) Information about the verifier’s accreditation. 4. Further installation data The objective of this section is to understand the activities carried out in the installation and to identify installations that may be eligible for USE or HSE status. Under (a) to (c), the operator should specify: a. The activities carried out at the installation as defined in paragraph 3(1) of Schedule 2 to the UK ETS Order. If activities other than 'combustion of fuels' are carried out, then it is not necessary to indicate activity 'combustion of fuels'. If several activities are applicable, they should be listed starting with the activity causing the highest direct emissions, to the extent feasible. b. Activity code according to the NACE classification10 under which the operator reported value added for structural business statistics. In case of doubt, the operator is requested to contact the regulator. The NACE codes should be entered in the format of 4 digits with no dots or other delimiters in between. c. If applicable, the EPRTR identifier. This information is useful for the regulators for consistency checks and alignment of environmental information sources (i.e. national GHG inventories). Under (d), (e) and (f), the operator should state whether the installation is eligible for exclusion pursuant to Schedule 7 or Schedule 8 to the UK ETS Order. d. According to Schedule 7 to the UK ETS Order, the following types of installations are eligible to apply for HSE status if they meet one of the following conditions: o where an installation started to carry out a regulated activity on or before 1st January 2021, they have reportable emissions of less than 25,000 tonnes of CO2 equivalent and, where they carry out combustion activities, have a rated thermal input below 35MW in each of the 2021, 2022 and 2023 scheme years. o where an installation started to carry out a regulated activity after 1st January 2021 or will commence before 1st November 2025, that their reportable emissions are below 25,000 tonnes of CO2 equivalent and, where they carry out combustion activities, have a rated thermal input below 35MW in each of the scheme years they have been operating and that their reportable emissions and rated thermal input are not likely to exceed these thresholds in each of the 2026- 2030 scheme years. o installations which primarily provide services to hospitals or intend to do so before 1st November 2025. e. According to Schedule 8 to the Order, the following types of installations are eligible to apply for USE status: 10 Please see (EC) No 1893/2006 for rev. 2 NACE codes in place 26/07/2019: https://www.legislation.gov.uk/eur/2006/1893/pdfs/eur_20061893_2019-07-26_en.pdf 21 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status a. installations which have reported to the regulator reportable emissions of less than 2,500 tonnes of CO2 equivalent, excluding emissions from biomass, in each of the 2021, 2022 and 2023 scheme years.11 f. The annual emissions from the three previous years are automatically taken from Sheet D of the tool for plausibility checks on the previous question. Nothing needs to be entered manually here, but the information should be entered onto Sheet D. If applying to be an HSE for the next allocation period, you should go to Sheet I to complete your application. 11 The UK ETS Authority has recently published the Authority Response to the Consultation on technical and operational amendments including confirmation of our intent to implement legislation to allow operators who began a regulated between 2 January 2021 and 1 January 2024 to become eligible to apply for USE status in the 2026-2030 period. The data they are required to submit as part of their application will relate to the date when their regulated activity commenced. Please see full response here: https://www.gov.uk/government/publications/technical-and-operational-amendments-to-the-uk-emissions-trading- scheme-uk-ets-authority-consultation-response 22 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status A.II Information on this baseline data report 1. Eligibility for free allocation under current legislation The purpose of this section is to determine whether the installation is eligible for FA. For more information on the eligibility criteria please refer to the installations chapter of ‘UKETS10 FAR - General guidance on the allocation methodology’. If applying for FA, you should complete this section. The operator should specify: a) Will the installation be considered an electricity generator pursuant to Article 2c of the FAR in the second allocation period? Please answer this question carefully and consult the legislation. This is an installation in which both the following apply: o That in the baseline period produced electricity for sale for consumption outside the installation. N.B This does not include relevant CHP electricity or if the electricity sold for consumption outside the installation represents no more than 5% of the total electricity (not including relevant CHP electricity) produced at the installation in the baseline period – see Article 2c(4) of the FAR. o At which the regulated activity (combustion of fuels) and no other regulated activity is carried out (apart from the following: the capture of greenhouse gases from a regulated activity for the purpose of transport and geological storage in a storage site; the transport of greenhouse gases by pipelines for geological storage in a storage site; the geological storage of greenhouse gases in a storage site). If you are unsure whether you meet the conditions set out in Article 2c(4) of the FAR to be eligible to receive free allocation, without the restriction in Art 2a(1)(b) of the FAR, please contact your regulator. 23 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status b) Is the installation for the capture of greenhouse gases for the purpose of transport and geographical storage in a storage site, for transport of greenhouse gases by pipelines for geographical storage in a storage site or the geological storage of greenhouse gases in a storage site? c) If the answer to (a) is yes, will the installation stop producing any electricity (other than relevant CHP electricity) for sale for consumption outside the installation in the period beginning with the date of the application for FA and ending with 31 December 2030 (see Article 2b of the FAR)? d) If the answer to (a) is yes, does the installation produce heat not used for electricity production as covered by Article 2a(1)(b)(i) and (ii)? Please use the below descriptors to help understand whether your answers in section (1) signal that you are able to apply for free allocation or not. • • • • If the answer to (a) is positive and the answer to both (c) and (d) is negative, then the installation may not be eligible for FA. If the answer to both (a) and (c) is positive, then the installation may satisfy the condition under Article 2b(2) of the FAR and therefore may be eligible for FA without the restriction in Article 2a(1)(b) of the FAR. You will need to provide data in Sheet I (I.II) to complete your application ‘Electricity generator supporting evidence’. If the answer to (a) is positive and the answer to (d) is positive as well, the installation may be eligible for FA for measurable heat under Article 2a(1)(b). You will need to complete Sheet I to determine whether, as an electricity generator, you are eligible for free allocation for heat (i.e. if you produce measurable heat by means of high-efficiency cogeneration or if you export measurable heat for the purpose of district heating). If the answer to (a) is negative, the installation may be deemed not to be an electricity generator under Article 2c(4) of the FAR and therefore may be eligible for FA without the restriction in Article 2a(1)(b) of the FAR. Please provide data in Sheet I (I.II) ‘Electricity generator supporting evidence’ to complete your application. It is essential that you provide all of the information required by Article 4 of the FAR and submit this alongside a verification report and a validated MMP (unless it has already been approved by your regulator) to apply to receive any FA in the 2027-2030 allocation period. If you are newly eligible for FA for 2026, information submitted will be used to determine your eligibility and calculate your FA for the 2026 scheme year. 24 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status The operator should further answer either (e) or (f), which will also lead to answer (g). Confirmation of non-eligibility for free allocation: e) Confirm the non-eligibility of the installation for FA, in cases where the answer to (a) is positive and the answer to both question (c) and (d) is negative. Application for free allocation: f) Confirm the eligibility of the installation for FA in cases where the answer to (a) is negative, or if the answer to (a) is positive and to (c) and/or (d) is positive. Important note: Electricity generators must check in Sheet I whether they are entitled to FA depending on whether the heat they produce meets the relevant criteria (set out in Article 2a(1)(b)(i) and (ii) of the FAR). g) Confirmation of intent to make an application for FA in the 2027-2030 allocation period (subject to legislative change) and, in some cases, in the 2026 scheme year. Please confirm which statement describes your situation regarding whether or not you are making an application to receive FA. Please consider that: • any applications for FA are being made under current legislation, and eligibility to FA is subject to change after the Free Allocation Review has concluded. • You will not be able to receive FA at any time in the 2027-2030 allocation period and, if relevant, in the 2026 scheme year if you have not submitted a BDR alongside a verification report and an MMP (if not previously approved under Article 8 of the FAR). Please select from the following options: • • • • I am eligible, under current legislation, to receive FA, and would like to make an application to receive FA under Article 4 of the FAR for 2027-2030. I am eligible, under current legislation, to receive FA, and would like to make an application to receive FA under Article 4 of the FAR for 2026. I am eligible, under current legislation, to receive FA, and would like to make an application to receive FA under Article 4 of the FAR for the 2026 scheme year and 2027-2030. I am eligible, under current legislation, to receive FA, but would not like to make an application to receive FA under Article 4 of the FAR. 25 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status • I am not eligible under current legislation to receive FA and therefore I do not want to make an application to receive FA under Article 4 of the FAR For installations that are not eligible to receive FA, the other Sheets in this BDR template are in principle not relevant. It is however recommended that you provide the data requested in section E ‘Data on energy input, measurable heat and electricity’ to ascertain that the status of the “electricity producer” is appropriately defined. h) Confirm that the data contained in the BDR may be used by the regulator to determine FA. The consent is necessary to make the submission of data complete. If the operator confirms point (e) or (f), it is automatically assumed that they consent to the regulator using data contained in this file and therefore answer to (h) is automatic. 2. Baseline period chosen • The operator should not change the baseline period for this report. All should remain 2019-2023. • Years in which the installation was operating. Please select ‘Yes’ for all years in which the installation has been operating. A.III. List of sub-installations 1. Product benchmark sub-installations The operator should specify all product benchmark sub-installations covered by the installation’s MMP. For each type of product, only one sub-installation may be chosen, and each sub-installation name may occur only once. Products that are covered by the same product definition in the FAR are aggregated in the same sub- installation and have the same product benchmark. In the BDR template, the operator can select the benchmark products in the drop-down menu. For an overview of product benchmarks and associated product definitions and system boundaries see Annex I of the FAR and for more guidance on the appropriate product definition see ‘UKETS18 FAR - Sector specific guidance’.12 The operator should also determine for each sub-installation whether it is deemed to be exposed to a significant risk of carbon leakage. In the BDR, the carbon leakage exposure status will be determined automatically. For an overview of carbon leakage exposure statuses, see Annex I of the FAR or ‘UKETS18 FAR - Sector specific guidance’. In addition, in the second yellow column, the operator should provide the date of the start of normal operation13 of each sub-installation, in line with Article 2(12) of the FAR. This will help identify which years are used to determine the historical activity level, in line with Article 15(7) in Sheets F and G. It will help identify whether a sub-installation has operated less than two 12 Note that in some cases separate sub-installations can cover the same physical units, for example two benchmarked products can be manufactured from the same production line. This is not an issue as long as the activity levels for each product are well defined. For a practical example please see ‘UKETS11 FAR - Determining allocation at the installation level’. 13 For guidance on the definition of start of normal operation, see ‘UKETS11 FAR - Determining allocation at the installation level’. 26 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status calendar years during the baseline period, in which case specific provisions will apply for the calculation of its historical activity levels. For more information on sub-installations that haven’t been operating during the full baseline period, see section 6.2 of ‘UKETS11 FAR - Determining allocation at the installation level’. 2. Sub-installations with fall-back approaches The operator should specify which fall-back sub-installations are relevant for the installation, and which are not (no yellow fields should remain empty). Each installation can have a maximum of seven sub-installations covered by fall-back approaches: for each type of fall-back approach (heat benchmark, fuel benchmark and process emissions), a maximum of two sub- installations may exist, one deemed to be exposed to a significant risk of carbon leakage, and the other non-exposed. An exception to this rule is the possible presence of a third sub- installation for measurable heat, corresponding to the delivery of heat for the purpose of district heating. See ‘UKETS11 FAR - Determining allocation at the installation level’ for further input on sub-installations covered by fall-back approaches. See also ‘UKETS13 FAR - Monitoring and reporting in relation to the free allocation rules’ for more information on the data required to justify using a district heating sub-installation. In addition, in the second yellow column, the operator should provide the date of the start of normal operation14 of each sub-installation, in line with Article 2(12) of the FAR. This will help identify which years are used to determine the historical activity level, in line with Article 15(7) in Sheets F and G. It will help identify whether a sub-installation has operated less than two calendar years during the baseline period, in which case specific provisions will apply for the calculation of its historical activity levels. For more information on sub-installations that haven’t been operating during the full baseline period, see section 6.2 of ‘UKETS11 FAR - Determining allocation at the installation level’. In line with Article 10(3) of the FAR, an exemption from distinguishing between “Carbon Leakage” and “non-Carbon Leakage” is possible for reporting purposes, if at least 95% of inputs, outputs and emissions belong to one of the statuses. For more information on this “de minimis rule”, see ‘UKETS11 FAR - Determining allocation at the installation level’ and ‘UKETS13 FAR - Monitoring and reporting in relation to the free allocation rules’. A.IV List of technical connections This section is only relevant in the following cases: • installations where measurable heat, waste gases, intermediate products covered by product benchmarks or “transferred CO2”, as defined by the MRR 2018 are transferred to or from another UK ETS installation or non-UK ETS entity. 14 For guidance on the definition of start of normal operation, see ‘UKETS11 FAR - Determining allocation at the installation level’. 27 UKETS12 FAR – Completing the 2025 Baseline Data Collection and applying for HSE/USE status • installations in which heat produced by a nitric acid producing