THG Quote: Who drives e-car, can look forward to a premium

So far, the topic of greenhouse gas reduction quota (THG quota) was relevant for mineral oil companies: these were obliged to reduce their climate-damaging greenhouse gas emissions to avoid penalty. Due to the newly introduced THG quota trade, the application field of the THG quota is expanded, so that e-furniture can now benefit.

The background: incentive system for the mineral oil industry

But from the front: The THG quota was introduced in 2015 to reduce the CO2 emissions of fuels such as diesel and gasoline. The above-mentioned mineral oil companies had to reduce the climate-damaging emissions of their fuels in the manufacture and use of their products to reduce a specified percentage.

For the implementation of the recurred European Renewable Energies Directive 2018/2001 (“Red II”), the national legislature has now launched far-reaching changes – even on the THG quota – to all downstream in the SOG. “Law on the further development of the greenhouse gas reduction ratio”. It is regulated that the THG quota in the transport sector is to be raised from currently 6 percent to 25 percent in 2030 – that is, the undertakings undertakings must gradually reduce their greenhouse gas emissions by 25 percent by 2030.

New advantages for holder and fleet operators

Right here, thanks to the new regulations now comes the topic of electromobility in the game: holder * inside of electric vehicles, private or commercial, saving by switching from the internal combustion engine to the battery operation when driving emissions. These avoided emissions are to be recognized in the context of the THG quota. The basic idea is that the mineral oil companies “buy” the E-Mobilists “buy” their cheap THG ratio to meet their own quota commitment.

In practice, this is implemented as follows: Personal individuals and companies can contact the annual application directly to the relevant Federal Environment Agency or to one of the numerous service providers newly produced in this area, which make a so-called quota bundle.

Who is entitled?

Entitled in this sense are basically all loading point operators according to the relevant § 37a ⁠BimSchG⁠. The amount of the funding payment is not aimed at the amount of electricity removed, but fixed lump sums per vehicle are estimated. In principle, four-wheeled vehicles are entitled to use the packages, which can be led in Germany with a class B driving license, more precisely, the EC vehicle classes M1, N1 and N2. As proof, consequently, the registration certificate Part I of the corresponding pure battery electric vehicle, which must be submitted to the Federal Environment Agency in the immediate application.

Current service models

Various service providers have now discovered services around the THG quota as a business model. Above all, they bundle the odds of many different individuals and / or companies with electric fleet and then enter the obliged corporations with this bundle via appropriate trading platforms. The service providers help to achieve wholesale prices through the summary of many claims. The proceeds – mostly in the amount of several hundred euros – are then passed on to the private individuals / companies, usually with deduction of a certain percentage, which the service provider is retained for its performance.

What should be considered when using the THG quota?

• Plug-in hybrids are not recorded by the quota trade for unavailable charging points. The legislature limits the authorization here only on purely battery electric vehicles.
• For leased vehicles, the person is entitled to participate in the quota trade, which is entered in the vehicle registration as a holder *.
• Company vehicles can also participate in the quota trade. However, this is usually necessary to confirm the company that the registred individual person may act on behalf of the company.
• The premium is awarded by the Federal Environmental Agency for the entire calendar year. For a sub-year sale of the vehicle, this means that for the corresponding calendar year exclusively the person who applied at the beginning of the year (if necessary. About a service provider), benefits. The buyer or. The buyer is the possibility of registering for the THG quota open from the next calendar year.

If the greenhouse gas savings of individual electric vehicles are not asserted by the respective holders on the quota trade, they are sold by the Federal Government. The proceeds then flow into the state budget.

About the authors: Sandra Horn, Lawyer, Knight Gent Collegen Partg MBB, advises focus on national and European emissions trading. In addition, it deals with the topics of hydrogen and e-mobility. Dr. Franziska Lietz, ll.M., Lawyer, Knight Gent Collegen Partg MBB, mainly advises energy-intensive companies on electromobility, hydrogen production and environmental law.

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