Skip to content
All posts

PNAQ sites: maintain your quota allowances and benefit from specific CEE thanks to the ISO 50001 approach

Like 1,300 manufacturers in France, your site (known as " ETS ") is subject to the Plan National d'Allocation des Quotas carbone (PNAQ). So you probably know  recent regulatory changes have made it essential to implement a low-carbon roadmap. Have you already taken the plunge? Find out how to maintain your emission allowance allowances. Want to get started? Energy Savings Certificates (CEE) can help. But how do you identify eligible projects? And why is setting up an ISO 50001 program the best way to finance your transition? Follow the guide to find out.

Metallurgical plant

The Carbon Quota Allocation Plan in brief

The Plan National d'Allocation des Quotas (PNAQ) was validated by the European Commission in 2004. It aims to reduce greenhouse gas emissions in the European Union. One of the key components of its operation is the allocation of quotas - an allowance representing the right to emit one tonne of CO2. In France, the NAP concerns some 1,300 industrial sites classified for environmental protection (ICPE). An envelope is allocated by sector, and it's up to the companies in the sectors of activity concerned to respect the pre-established emissions quotas.

Carbon quota reform (EU ETS): taking action to maintain quota allowances

In May 2023, a reform of Directive 2003/87, which forms the legal basis of the European Union Emissions Trading Schemes (EU ETS), changed the face of the carbon market, framing it more strictly.

Maintaining your quota allowances is however possible. If your company is subject to the regulatory energy audit, implementing all the recommendations listed in the action plan resulting from the audit within 3 years according to its wording entitles you to :

  • An allocation of 20% free quotas - subject to implementation of recommendations (Energy Efficiency) with a rate of return on investment of less than 3 years ;
  • Compensation for indirect costs - if your Energy Performance Plan (EPP) contains all the recommendations (Energy Efficiency) of the energy audit, including a rate of return on investment of less than 3 years.

Learn more about the changes brought about by the directive 2003/87.

Investments in the action plan: how to benefit from Specific CEE?

In order to reduce your emissions and not exceed your authorized emission quotas, implementing a decarbonization action plan is essential. The ECE premiums  scheme helps you finance your energy-saving operations.

Conditions for benefiting from CEE

Note that it is mainly the specific CEE that are concerned.  Indeed, standard CEE are not very common for PNAQ sites, as they can only concern uses independent of the consumption of CO2-emitting fuels.

The standard CEE most often implemented at PNAQ sites are Electronic speed variation systems on asynchronous motors (IND-UT-102) and Regulation systems on a refrigeration production unit enabling floating high pressure (IND-UT-116).

The indispensable Energy Management System

Since 2019, specific CEE premiums have been open to sites subject to EU-ETS quotas, on one condition: the classified facility must be covered by an ISO 50001 certified Energy Management System (EMS). ISO 50001 certification is therefore essential to benefit from specific CEE.

An obligation to deliver results

In order for a NAP site to qualify for specific CEE bonuses, a commissioning report is required by funding bodies and conditional on obtaining full funding. For EU-ETS sites, it is mandatory to provide 6 months of data proving the good performance of the installation before submitting an EEC file.

Good to know : For specific CEE, you need to allow 6 months for ADEME to check the file, plus 2 months for processing by the Emmy platform.

Identifying eligible projects

For EU-ETS sites, guidelines specify certain elements for specific operations, such as:

  • Lifespan
  • Reference situation
  • Measurement duration and protocol
  • Energy savings calculation methods

These guidelines cover the following points :

  • Heat recovery system on a cooling production unit (LD2020-001)
  • Fat heat recovery for valorization on a heat network or to a third party (LD2020-002)
  • Heat production by a boiler plant fueled by solid recovered fuels (LD2020-003)
  • Production of heat and electricity consumed on site by a cogeneration plant powered by solid recovered fuels (LD2020-004)

Good to know : Beyond these guidelines, any productive change or need for equipment renewal for modernization may be the subject of a study to assess eligibility for the CEE scheme.

Specific CEE procedure: how to activate the premium

The steps to activate a specific CEE premium are as follows:
  1. Identification of eligible actions, based on technical information provided by the site.
  2. Production of the technical file.
  3. Launch of the CEE approach by signing an agreement. For PNAQ sites, ISO 50001 certification is mandatory to launch the approach.
  4. Commitment of work, justified by a signed estimate or purchase order.
  5. Completion of work, demonstrated by invoice.
  6. Validation of the technical file. For PNAQ sites, this validation involves measuring energy performance over 6 months.
  7. Finalization of the administrative file and signature of a declaration on honor, accompanied by 6 months of data attesting to the achievement of the planned performance.
  8. Filing and validation of the premium.

Learn more about financing your energy efficiency operations.

Steps to obtain a specific CEE bonus

TURPE rebate for sites connected to the RTE network

The TURPE abatement was provided for by the law for energy transition and green growth of August 18, 2015. To benefit from it, you must be ISO 50001 certified and provide an Energy Performance Plan (PPE) to the DREAL.

This PPE is a 5-year action plan, which may be eligible for aid from the DREAL. It is binding : every year, you must provide a progress report, justifying the results achieved, corrective measures or abandoned actions.

They've taken action: Discover the testimonial from Alphaglass concerning the implementation of an ISO 50001 EPP.

Obtaining ISO 50001 certification: an asset for financing your actions

ISO 50001 certification is becoming more and more essential to benefit from investment aid, whether in the form of carbon quota rebates, obtaining specific CEE or TURPE reduction.

Still optional today, it will probably become mandatory by 2026. A good reason to take advantage now of PRO-SMEn 2023-2026, which rewards the implementation of a certified EMS, with the payment of a prime equivalent to 20% of your annual energy expenditure, with a ceiling of 40,000 euros.

Good to know: 90% of beneficiaries received the maximum bonus of 40,000 euros in 2022.

ISO 50 001 certification is a major asset in your low-carbon trajectory. It enables you to realize substantial savings by reducing your energy consumption. What's more, it strengthens your competitiveness by meeting growing sustainability requirements, opening up new business opportunities. Finally, it offers internationally recognized certification, reinforcing your company's credibility in the marketplace and its commitment to sustainable development.

Lemon Energy's expertise at the service of your decarbonization

Of course, the ISO 50001 approach assumes certain prerequisites: producing reliable data and indicators, defining an energy policy, structuring your organization and, above all, committing to monitoring and continuous improvement - guarantees of a documented, virtuous management system. Lemon Energy brings you its expertise in implementing your ISO 50001 approach, in studying and producing specific CEE files, and in drawing up and monitoring your decarbonization action plans. Contact us to discuss your objectives.