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National allocation plans

Before the start of the first and second trading periods, Member States had to decide how many allowances to allocate in total and to each EU ETS installation on their territory. This was done through national allocation plans (NAPs).


Commission assessment

The European Commission had to assess NAPs for compliance with criteria laid down in an annex to the Emissions Trading Directive, as well as with EU rules on state aid and competition.

In many cases the Commission required changes to NAPs, in particular reductions in national caps. Once a NAP was approved, neither the cap nor the allocation per installation could be changed.

Phase one NAPs: 2005-2007

Member States had to prepare and publish their phase one NAPs by 31 March 2004 (or by 1 May 2004 in the case of the 10 Member States which joined the European Union in 2004). The Commission published a guidance document to assist them in preparing the NAPs.

All phase one NAPs can be found under the Documentation tab at the top of this page.

The timetable of the Commission’s Decisions on Member States’ phase one NAPs was the following:

  • Austria, Denmark, Germany, Ireland, the Netherlands, Slovenia, Sweden and the UK on 7 July 2004
  • Belgium, Estonia, Finland, France, Latvia, Luxembourg, Portugal and the Slovak Republic on 20 October 2004
  • Cyprus, Hungary, Lithuania, Malta and Spain on 27 December 2004
  • Poland on 8 March 2005
  • the Czech Republic on 12 April 2005
  • Italy on 25 May 2005
  • Greece on 20 June 2005.

Some phase one NAPs were amended prior to the Commission taking its Decision. The Commission also adopted decisions requiring some Member States to change their NAPs. Its most common objections were:

  • Excessive allocation jeopardised the achievement of the Member State’s Kyoto target;
  • The volume of allowances was inconsistent with the assessment of progress towards the Kyoto target, i.e. the allocation exceeded projected emissions;
  • The Member State intended to make ‘ex-post adjustments’ to its NAP, ie it planned to intervene in the market after the allocation was done and redistribute the issued allowances among the participating companies.  

Lessons learned from phase one NAPs

Chief among the lessons learnt from the phase one NAPs was that the process was very time-consuming. The timely notification of NAPs to the Commission and timely final allocation decisions were needed to give companies certainty well before a trading period started.

Another important lesson was that the NAPs were too complex and not sufficiently transparent.

Phase two NAPs: 2008-2012

In its guidance document for phase two NAPs, the Commission therefore emphasised the need to make them simpler and more transparent. To simplify NAPs, the Commission encouraged Member States to review critically the administrative rules created in their first allocation plan. To ensure greater transparency, the Commission drew up a number of standardised tables to summarise key information contained in the NAPs.

Phase two NAPs had to be submitted to the Commission by 30 June 2006. All phase two NAPs can be found under the Documentation tab at the top of this page.

The timetable of the Commission’s Decisions on Member States’ phase two NAPs was the following:

  • Germany, Greece, Ireland, Latvia, Lithuania, Luxembourg, Malta, Slovakia, Sweden and the UK on 29 November 2006, with amendment decisions for Ireland, Latvia, Lithuania, Luxembourg and Sweden adopted on 13 July 2007, amendment decision for Germany on 26 October 2007 and amendment decision for Slovakia on 7 December 2007
  • Belgium and the Netherlands on 16 January 2007
  • Slovenia on 5 February 2007
  • Spain on 26 February 2007
  • Czech Republic and France on 26 March 2007
  • Austria on 2 April 2007
  • Hungary on 16 April 2007
  • Italy on 15 May 2007
  • Finland on 4 June 2007
  • Cyprus on 18 July 2007
  • Denmark on 31 August 2007
  • Portugal on 18 October 2007
  • Romania and Bulgaria on 26 October 2007
  • Poland on 19 April 2010 (this followed rejection of Poland’s proposed NAP on 11 December 2009) 
  • Estonia on 5 December 2011 (this followed rejection of Estonia’s proposed NAP on 11 December 2009 and 29 April 2011).

For  EEA-EFTA States, the Decisions by the EFTA Surveillance Authority were adopted on the following dates:

  • Liechtenstein on 19 December 2007
  • Norway on 27 February 2009
  • (Iceland did not have a NAP as the few installations covered by the EU ETS opted out).