Promulgating the list of establishments emitting greenhouse gases subject to greenhouse gas inventory (updated)

Post by: Trương Vân - Post date: Saturday, Aug 24, 2024 | 12:06 - View count: 289

In order to strengthen the implementation of greenhouse gas inventories, reduce greenhouse gas emissions and determine the goal of reducing greenhouse gas emissions of establishments in the period of 2026 – 2030, contributing to the realization of the goal of achieving net zero emissions by 2050, the Ministry of Natural Resources and Environment has submitted to the Government for approval the list of establishments required to carry out greenhouse gas inventories periodically every 1 year from 2022 (stipulated in the Government’s Decree No. 06/2022/ND-CP dated January 07, 2022 regulating greenhouse gas emission mitigation and ozone layer protection). 

On August 13, 2024, Deputy Prime Minister Tran Hong Ha signed Decision No. 13/2024/QD-TTg promulgating the list of fields and establishments emitting greenhouse gases that must carry out greenhouse gas inventories (updated). The number of establishments that must carry out an updated greenhouse gas inventory is 2.166, an increase of 259 establishments compared to the list issued in 2022.

Decision 13/2024/QD-TTg clearly states 6 areas that must carry out greenhouse gas inventory, namely:

(1) Energy: Energy production industry; energy consumption in industry, trade, services and civil use; coal mining; oil and natural gas extraction.

(2) Transportation: Energy consumption in transportation.

(3) Construction: Energy consumption in the construction industry; industrial processes in the production of building materials.

(4) Industrial processes: Chemical production; metallurgy; electronics industry; use of substitutes for ozone-depleting substances; production and use of other industrial products.

(5) Agriculture, forestry and land use: Animal husbandry; forestry and land use change; crop cultivation; energy consumption in agriculture, forestry and fisheries; other sources of emissions in industry.

(6) Waste: Solid waste landfills; solid waste treatment by biological methods; waste incineration and open-pit incineration; wastewater treatment and discharge.

Decision No. 13/2024/QD-TTg takes effect from October 1, 2024. That also means that the Prime Minister’s Decision No. 01/2022/QD-TTg dated January 18/2022 promulgating the list of fields and establishments emitting greenhouse gases that must carry out greenhouse gas inventories expires from October 1, 2024.

Greenhouse gas emitting establishments on the list specified in Decision No. 01/2022/QD-TTg but not on the list specified in this Decision are not obliged to implement and submit the 2025 grassroots greenhouse gas inventory report.

The update of the list of fields and establishments emitting greenhouse gases must take greenhouse gases inventory in order to improve the effectiveness and efficiency of state management of greenhouse gas emission reduction. The number of statistics in 2024 has increased compared to 2022, showing that establishments and businesses that have reached the threshold of having to audit greenhouse gases are always increasing, and the inventory of greenhouse gases is a matter of concern to society. The promulgation and implementation of the Prime Minister’s Decision 13/2024/QD-TTg also contributes to the implementation of the provisions of the Paris Agreement on climate change, aiming to control at least 85% of the main emission sources according to national capacity.

However, there are also some difficulties:

For the transport sector: The list that must carry out a greenhouse gas inventory in Appendix III of Decision 13/2024/QD-TTg which is 75 establishments (the old list according to Decision 01/2022 is 70 establishments). This list is proposed by the Ministry of Transport on the basis of the greenhouse gas inventory reports of the units in Decision No. 01/2022 received by the Ministry of Transport and reports of the attached state management agencies, together with the review, update information on fuel consumption results (according to TOE) for transportation companies. However, up to now, the Ministry of Transport has not issued guiding documents on the Regulation on measurement and reporting on greenhouse gas inventory in the transport sector, so the grounds for accurately determining the greenhouse gas emissions of establishments in this industry are still a question mark.

For sectors under the Ministry of Construction: According to Appendix IV of Decision 13/2024/QD-TTg, the number of units that must carry out greenhouse gas inventories is 229 establishments, doubling compared to the old list (104 establishments). However, as well as the Ministry of Transport, up to now, the Ministry of Construction has not issued a document guiding the measurement and reporting on the industry’s greenhouse gas inventory (As of June 25, 2024, the Ministry of Construction is drafting a Circular guiding the process of regulating greenhouse gas inventory, measuring, reporting, and even mitigating greenhouse gas emissions in the construction industry). This helps the units under the Ministry’s management to be extremely confused when carrying out greenhouse gas inventories, especially construction material manufacturers subject to CBAM when exporting their products to the European market such as cement, iron and steel-related products because they have to declare greenhouse gas emissions from the fourth quarter in 2023.

For the Agriculture and Rural Development sector: Decision 13/2024/QD-TTg promulgates Appendix I on the list of sectors subject to greenhouse gas inventory, including listing the fields of Agriculture, Forestry and Land Use such as Animal Husbandry, Cultivation, Forestry and land use change, etc Energy consumption in agriculture, forestry and fisheries… however, establishments in this field are not yet named in Decision 13/2024/QD-TTg.

Also in Decision 13/2024/QD-TTg, for the Industry and Trade sectors, Appendix II has 1,805 establishments subject to greenhouse gas inventory, an increase compared to the old List (1,662 establishments), the Environment sector, Appendix V has 57 establishments, down from the old List (76 establishments). Although these 2 sectors have issued guiding documents on measurement and inventory of greenhouse gases (Circular 38/2023/TT-BCT dated 27/12/2023 Technical regulations on measurement, reporting and appraisal of greenhouse gas emission mitigation and greenhouse gas inventory in the industry and trade, Circular 17/2022/TT-BTNMT dated 15/11/2022 Technical regulations on measurement, reporting and appraisal of greenhouse gas emission mitigation and greenhouse gas inventory in the field of waste management). However, these guidelines stipulate that the source of greenhouse gas emissions is: 1. only the direct emission generated from the burning of fossil fuels, mining of minerals on the surface, in the ground or leakage of human storage machinery and equipment (equivalent to group 1 according to the classification of international practices specified in ISO 14064-1:2018 – On greenhouse gas inventory and emission reporting. 2. Indirect sources of emissions caused by the use of forms of energy such as electricity and steam generated from the burning of fossil fuels and other related fuels (equivalent to group 2) without mentioning other sources of greenhouse gas emissions such as other indirect emissions from transportation, using raw materials, using other products and sources… (equivalent to group 3, group 4, group 5, group 6). In fact, greenhouse gas emissions from these sources account for up to 80% of a facility’s total greenhouse gas emissions. This makes the new and old lists miss quite a lot of greenhouse gas emitters of over 3,000 tons of CO2e as prescribed in Clause 1, Article 6, Section 1, Block II of Decree 06/2022/ND-CP.

For some Provincial People’s Committees, there may not be funding available to carry out activities such as: investigations, surveys, and statistics on activities for national and sectoral greenhouse gas inventories; update the list of greenhouse gas emitting establishments that must carry out greenhouse gas inventory; build and operate a system of measurement, reporting and appraisal of greenhouse gas emission mitigation at the provincial level, according to the provisions of Point d, Clause 5, Article 152 of the Government’s Decree No. 08/2022/ND-CP dated January 10, 2022 detailing a number of articles of the Law on Environmental Protection. The fact that many localities and businesses have not carefully prepared resources to develop a greenhouse gas inventory report, even do not know who to ask and where to start and especially what to do after the greenhouse gas inventory is completed, which is also a matter of concern that will continue to be adjusted in future documents.

Some provinces and cities have changed the number of greenhouse gas emitting establishments that must carry out greenhouse gas inventories in 4 sectors:

 Note: The data of establishments according to Decision No. 13/2024/QD-TTg, the +/- part is an increase or decrease compared to Decision 01/2022/QD-TTg. The (-) sign is not statistical.

Trong Hung – QUACERT