Switzerland
The World’s Carbon Markets: A Case Study Guide to Emissions Trading
Last Updated: May, 2013

Brief History and Key Dates:	  	
  The foundation of Swiss environmental policy was established in 1985 with the Act on the Protection of theEnvironment (PE Act), which was later revised in 1995 and 2003. In 1999, Switzerland adopted the Act on the
Reduction of CO2 Emissions (CO2 Act) as a supplementary environmental policy that centers on carbon dioxide (CO2)
mitigation. The goals and mechanisms outlined in these two Acts were designed to help Switzerland meet its Kyoto
Protocol commitment of 8% greenhouse gas (GHG) reduction relative to 1990 for 2008-2012. The PE Act
enumerates mitigation measures for non-CO2 GHGs from waste disposal (CH4), synthetic gases (HFC, PFC, SF6), and
GHG precursors. The CO2 Act covers 80% of Swiss GHGs (See Figure 1).1 In December 2011, revisions to the CO2 Act
enumerated a CO2 reduction target of 20% below 1990 levels (52.5 MtCO2) by 2020. The country’s 2009 emissions
were about 51.95 MtCO2e. The revised CO2 Act became active on January 1, 2013.2, 3

Figure 1: Components of Swiss Kyoto Target Achievement. Source: FOEN 20094
For 2008-2012, the overarching goal of the 1999 CO2 Act was to reduce CO2 emissions by 10% below 1990 levels.
Specifically, the CO2 Act aimed for a 15% CO2 reduction from heating and industrial process fuels and an 8% CO2
reduction from transport fuels. Instruments outlined in the 1999 CO2 Act included a CO2 levy5 for heating, industrial
process, and transportation fuels, as well as an emissions trading system (ETS) that included Kyoto Protocol
flexibility mechanisms.6 During 2001-2009, about 1,900 companies were covered by the levy and/or ETS outlined in
the 1999 CO2 Act.7 The CO2 levy and the ETS are continuing for 2013-2020, in accordance with the December 2011
CO2 Act revisions.8
The Swiss ETS was introduced on January 1, 2008 as an alternative option for complying with the national CO2 levy
on heating, industrial process, and transport fuels, which also went into effect on that day. For the period 2008-2012,

	
  

	
  

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firms covered by the levy had two choices: (1) pay the CO2 levy, or (2) voluntarily set a verified absolute emissions
target and associated allowance allocation and participate in the Swiss ETS, which exempted them from paying theCO2 levy.9 In essence, the CO2 levy functioned as a hard price ceiling for covered entities, and the option for ETS
participation allowed firms to potentially pay a lower rate for emissions reductions than this ceiling price. For 2008
and 2009 the CO2 levy was CHF $12/tCO2, and this rate increased to CHF $36/tCO2 for 2010-present.10 The ETS(with some mandatory participation) and a CO2 levy has continued after 2012. December 2011 revisions to the SwissETS have increased its similarity to the EU ETS, thereby providing comparable market conditions for Swiss and EU
industries and improving the prospect of linking with the EU ETS.11

Summary of Key Policy Features:
CAP/TARGET: As stated above, the CO2 levy and voluntary ETS were designed to help achieve the 1999 CO2 Act’s
goal of reducing CO2 by 10% relative to 1990 levels by 2010. The CO2 Act was implemented as a means ofachieving most of Switzerland’s Kyoto Protocol pledge to reduce total GHG emissions 8% relative to 1990 levels
for 2008-2012.12 For 2013-2020, Switzerland aims to reduce GHG emissions by 20% relative to 1990 by 2020;
this target corresponds to an absolute reduction target of around 10.5 MtCO2e by 2020, down from 1990 emissions of
52.7 MtCO2e. Estimates indicate that the CO2 Act will lead to reductions of 8.5 MtCO2e/year, 0.8 MtCO2e/year ofwhich would come from the ETS and 2 MtCO2e/year of which would come from the CO2 levy. The Federal Council
may increase this 20% reduction target to up to 30%, if an international agreement were to arise.13
Swiss ETS targets are absolute. For 2010, the total cap was 3.42 MtCO2,14 covering approximately 7% of Swiss
emissions.
SCOPE/COVERAGE: The Swiss ETS point of obligation is company-level at the point of combustion, and, for2008-2012, it covered firms that set absolute caps—which were approved by federal authorities—for themselves inorder to receive exemption from the CO2 Act’s carbon levy. As of July 2011, about 950 companies had set caps, andabout 430 of these companies participated directly in the Swiss ETS,15 where the emissions threshold for acompany to qualify as a direct participant was at least 0.25 MtCO2e/year.16 Small-to-medium size entities (SMEs)
were allowed to purchase allowances if they exceeded their cap, but they were not allocated allowances and, thus,
were not considered direct participants.17 See Figure 2.

Figure 2: Breakdown of Swiss ETS Participants. Source: FOEN 201118
For 2008-2012, the Swiss ETS covered heating and process fuels. Sectors with companies covered by the ETS
included ceramics, paper, plastics, aluminum, glass, chemistry, metal-working and engineering, foodstuffs and lime,

	
  

	
  

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foundries, printers, and haymakers. CO2 was the only gas covered by the program.19 The compliance periods
within the Swiss ETS were annual.20
For 2013-2020, the Federal Council will specify economic sectors from which installations that operate with high ormoderate GHG emissions may apply to participate in the ETS. In designating the covered economic sectors, theFederal Council must take into account: (1) the correlation between the CO2 levy burden and the value addition of thespecified economic sector, and (2) the extent to which the CO2 levy adversely affects the specified sector’s economic
competitiveness. In addition, the Federal Council may mandate compulsory ETS participation fromsectors with high GHG emissions per installation. As was the case during 2008-2012, ETS participants are exemptedfrom the CO2 levy for 2013-2020.21
ALLOWANCE DISTRIBUTION: For 2008-2012, allowances were distributed freely to Swiss ETS participants.
Participants received an emissions target for 2010, and this target doubled as the average yearly emissions for eachyear between 2008 and 2012.22 The quantity of allowances that a company received was determined by a “bottomup” approach. Federal authorities verified the company’s potential to reduce CO2 emissions from both a technicaland economic standpoint, based on both projected production and CO2 emissions, and CO2 reduction measuresalready implemented. As mentioned above, small and medium enterprises (SMEs) that volunteered to set anemissions target or follow an emissions reduction plan did not receive free emissions allowances. If, however, theemissions for an SME exceeded the target level, then the company was allowed to purchase allowances in order tofulfill its commitment.23
For 2013-2020, the Federal Council will allocate allowances annually. Allocation will entail both free distribution
and auctions, and the Federal Council will retain an appropriate number of emissions allowances each year in orderto have them available for new ETS participants. According to December 2011 revisions on the CO2 Act, the Federal
Council shall regulate allowance allocation details, and “in doing so shall take account of comparable international
regulations.”24 This language opens the door for Switzerland to structure its allowance distribution similarly to the EUETS.
FLEXIBILITY PROVISIONS: The Swiss ETS allows for companies to submit international offsets in order tomeet up to 8% of their compliance requirements. ERUs, CERs, and RMUs are accepted international offsets within
the Swiss ETS. Temporary certificates from carbon sink projects (RMUs, tCERs, and lCERs), such as afforestation andreforestation, are allowed, but they cannot be banked for use in future commitment periods. The Federal Office for
the Environment (FOEN) may ask companies that use temporary credits to guarantee that additional offsets arepurchased once temporary credits expire. AAUs are permitted from countries that have a similar ETS to
Switzerland.25 See Figure 3.
There are no limits for banking Swiss allowances or international AAUs for use in 2013-2020. The banking limit
through the next commitment period for both CERs and ERUs is 2.5% of banked AAUs. However, companies may
not bank RMUs, tCERs, and lCERs for use in the next commitment period.26 Banking and Borrowing wereallowed within the first commitment period, 2008-2012.27
For 2013-2020, measures carried out abroad may achieve a maximum of 75 per cent of additional reductions in GHG
emissions. Reductions that qualify as “abroad reductions” must have been achieved without support of Switzerland,and, in developing countries, they must contribute to sustainable development while having zero negative social or
ecological impacts.28

	
  

	
  

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Emission Credit

Assigned Amount
Unit
Removal Unit
Emission Reduction
Unit (converted from
AAU)
Emission Reduction
Unit (converted from
RMU)
Certified Emission
Reduction
Temporary CERLong-term CER
European Union
Allowance

Abbreviation

Kyoto Code

Offsetable
Against Kyoto
Target Limit

Tradable

Bankable

AAU

1

✓/ ✗

CH
✓

EU
✓

Intl
✓

✓

RMU
ERU

2
3

✓
✓

✓
✓

✓
✓

✓
✓

✗
✓

ERU

4

✓

✓

✓

✓

✓

CER

5

✓

✓

✓

✓

✓

tCER
lCER
EUA

6
7
0

✓
✓
✗

✓
✓
✗

✓
✓
✓

✓
✓
✗

✗
✗
✓

Table 1: Emission Credits: Types, Offsettability, and Tradability. Source: FOEN (2007)29
Switzerland and EU have initiated discussions about linkage. According to Aldy and Stavins (2012), this link islikely to become effective in 2014.30 The Swiss are in favor of linking with the EU ETS because a larger market
provides for greater cost-effective reduction potential, liquidity, price stability, and flexibility in achieving targets.
Furthermore, linkage would enable Swiss companies to participate in the same market as EU business partners.31
According to FOEN (2011), “the Swiss Federal Council has also proposed that the Swiss ETS be adapted in the context
of the ongoing complete revision of the CO2 Act with a view to attaining a high level of compatibility with the EU
ETS.”32
MARKET REGULATION AND OVERSIGHT: Swiss ETS credits exist electronically and are listed on the FOENmanaged33 National Emissions Trading Registry, which is an online accounting system that, according to
FOEN (2011), “ensures the issuance, holding, transfer, acquisition, cancellation and surrender of emission credits areaccurately recorded.”34 After the federal government approves a company’s baseline, the agreed-upon quantity ofallowances (the amount of tax-exempt emissions) appears on the Registry under the company’s name. Companies
with emissions that exceed their allowance allocation buy credits on the Registry, and companies that emit below
their caps either bank or sell credits. The annual submission of credits occurs via the Registry and Registry data mustbe published electronically, unless specially protected. The Registry also connects Swiss ETS participants to Kyoto
flexibility mechanisms, and transactions involving these units are subsequently approved by the UN.
For 2008-2012, the penalty for companies that failed to achieve their Swiss ETS targets was retroactive payment of
the carbon levy (plus interest) for each ton of CO2 emitted since the company’s exemption.35 For 20013-2020,
companies that fail to surrender enough emissions allowances and/or emissions reduction certificates must pay the
Confederation CHF $125/tCO2e by the following year.36
COMPLEMENTARY AND SUPPLEMENTARY MEASURES: As noted above, the CO2 Act envisions the Swiss
ETS and the carbon levy as alternative compliance options. This dual-policy approach allows companies to bypass
carbon levy payments if they voluntarily join the Swiss ETS. Beginning in 2013, specified companies face mandatory
ETS participation.37

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For 2008-2012, a company was covered by the CO2 levy if its emissions exceeded a set percentage of its 1990
emissions from fuel combustion. Beginning January 1 2009, a company that had emitted greater than 90% of its 1990
emissions level in 2007 was covered by the levy. In 2010, a company that emitted greater than 86.5% of its 1990
emissions in 2008, or greater than 85.5% in any subsequent year, was covered by the levy.38 For 2008 and 2009, thelevy was CHF $12/tCO2. The rate was increased to CHF $36/tCO2 in 2010 and will remain in place through 2012.39
There were reduced levy rates for natural gas and biofuels.40 In addition, the CO2 Act earmarked a maximum of up to
CHF $200 million of government revenue from the CO2 levy for the financing of CO2 reduction measures inbuildings.41
The December 2011 revisions to the CO2 Act altered future (2013-2020) aspects of the CO2 levy. The revisions
enumerate how revenues are returned to the population. One-third of revenue from the CO2 levy, but no morethan CHF $300 million/year, may be used to finance measures to reduce CO2 emissions from buildings. In addition, amaximum of CHF $25 million/year of revenues from the CO2 levy may be allocated to the Technology Fund, which
will use this money to guarantee loans to companies that aim to develop and market equipment and processes toreduce GHG emissions, facilitate the use of renewable energies, or encourage the economic use of natural resources.42
The rate of the levy has not change from CHF $36/tCO2e, and the Federal Council is not allowed to raise this levy
above CHF $120/tCO2e. The Federal Council has authority to designate economic sectors subject to the levy, taking
into account: (1) the correlation between the CO2 levy burden and the value added of the economic sector concerned;(2) the extent to which the CO2 levy adversely affects international competitiveness; and (3) the average GHG
emissions agreed on for the years 2008-2012. The noncompliance penalty is CHF $125 for each excess tCO2e that isemitted.43
Apart from the carbon tax and the opt-in ETS compliance option, the CO2 Act of 1999 outlined the following
supplementary measures: (1) a binding target for average CO2 emissions from new cars; (2) the implementation ofemissions reduction measures at home and abroad that allows producers of fossil propellant fuels to fulfill an
obligation to cover a quarter of their emissions; and (3) enhanced climate change adaptation activity.44 The
December 2011 CO2 Act revisions focus on emissions reductions from buildings, passenger cars, and sinks.45
In order to achieve Switzerland’s Kyoto Protocol commitment, the fourth Swiss national communication (2005)
introduced and upheld the development of the following measures:46•••

The January 10 2005 introduction of “climate cent,” a CHF $0.015 tax on transport fuels levied by mineral oil
importers to fund the Climate Cent Foundation. A primary objective of this foundation was to reduce 9 MtCO2
during 2008-2012—one million tons domestically and eight million tons internationally via the purchase of
project-based Kyoto-approved certificates.47
The Swiss Energy program second phase (2006-2010) was officially continued (the first phase was 20002005).
The adoption of action plans for energy efficiency and renewable energy.

The Fifth National Communication proposes the following post-2012 action:48
•

•
•

	
  

Intensified focus on reducing transport emissions: (1) the introduction of CO2 limits from new cars; (2)domestic and international projects to reduce emissions from specific parts of the transport sector; and (3) the
option to introduce a CO2 levy on transport fuels.
Full compensation of emissions from combined cycle power plants.
Further climate change adaptation measures.

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RESULTS: Each year over 2008-2010, ETS emissions were lower than targeted levels (see Table 2). According to
FOEN (2011), “this outperformance demonstrates that the companies take their responsibilities towards the federal
authorities seriously and in some cases have invested early in carbon reduction measures.”49

Emission Target(Allocated emission
allowance)
CO2 Emissions(effective)
Over-performance(surplus emission
allowances)

2008

2009

2010

3.3 MtCO2

3.1 MtCO2

3.42 MtCO2

2.9 MtCO2

2.6 MtCO2

2.85 MtCO2

0.4 MtCO2

0.5 MtCO2

0.57 MtCO2

Table 2: Overview of ETS Performance 2008-2010. Source: Department of the Environment,
Transport, Energy and Communications50

What Distinguishes This Policy?
UNIQUE ASPECTS:
1.

2.
3.

For 2008-2012, the ETS worked as a voluntary opt-in program that provided an alternative way tocomply with a carbon levy. This is not how the vast majority of emissions trading systems have been
designed. For 2013-2020, the Swiss ETS will move from a customized system to a standardized (EUstyle) system, as Switzerland continues linkage negotiations with the EU.
Entities face absolute caps, but the system as a whole does not stipulate an absolute cap. This is a byproduct of
the “bottom-up” allowance allocation methodology.
The Swiss ETS is relatively small in size—3.42 MtCO2 in 2010. By contrast, the Tokyo ETS covers
approximately 13 MtCO2e annually,51 and the EU ETS (Phase II) covers approximately 2,083 MtCO2e/year; so,the Swiss ETS’s emissions coverage is 26.3% that of the Tokyo ETS and approximately 0.16% that of the EU ETS.

CHALLENGES:
1.
2.

	
  

Modifying certain program characteristics in order to link with the EU ETS.
The small size of this market results in less cost-effective reduction potential, liquidity, price stability, andflexibility in achieving targets.

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Author Acknowledgements:
If you have any comments or suggestions for this case study, please do not hesitate to contact lead authors:
EDF co-author: Peter Sopher
EDF contact: Daniel Francis (dfrancis@edf.org)
Environmental Defense Fund (EDF)
1875 Connecticut Ave NW Ste. 600
Washington, DC

IETA co-author: Anthony Mansell
IETA contact: Anthony Mansell (Mansell@ieta.org)
International Emissions Trading Association (IETA)
20 F St NW Suite 700
Washington, DC

EDF and IETA would like to thank Ruben Lubowski, Pedro Piris-Cabezas, Jos Cozijnsen, Jennifer Andreassen, Joe
Billick, Clayton Munnings, and Juerg Fuessler (INFRAS) for their contribution to Development of Emissions Trading
Around the World.
Disclaimer: The authors encourage readers to please contact them with any corrections, additions, revisions, or any
other comments, including any relevant citations. This will be invaluable in strengthening and updating the casestudies and ensuring they are as correct and informative as possible.

	
  FOEN (2009). “Switzerland’s Fifth National Communication under the UNFCCC.” Available at http://unfccc.int/resource/docs/natc/che_nc5.pdf
FOEN (March 2011). “First formal round of negotiations held with EU for linking of emissions trading systems.” Available at
http://www.bafu.admin.ch/dokumentation/medieninformation/00962/index.html?lang=en&msg-id=38021
3 FOEN (December 2011). “Federal Act on the Reduction of CO2 Emissions (CO2 Act).” The Federal Assembly of the Swiss Confederation. Available at
4Supra, Note 1.
5 According to FOEN, “the term ‘levy’ has been used in order to distinguish the CO2 levy from a conventional tax, since the revenue from the levy is not channeledinto the national budget, but is returned in its entirety to the population (via reduction of health insurance premiums), to businesses that pay it (in the form of a cut
in old-age pension contribution), and to the buildings program.” Source: Supra, Note 3.
6 Supra, Note 1.
7 Government of Switzerland (May 2011). “Swiss Climate Policy – an overview.” Federal Department of the Environment, Transport, Energy, and Communications(DETEC) and Federal Office of the Environment (FOEN). Available at http://www.up.ethz.ch/education/carbon_mitigation/cmitigation_ch_climatepolicy_fs11.pdf
8 Supra, Note 3.
9 Supra, Note 1.
10 Meyer, Rolf (July 2009). “Emissions Trading in Switzerland.” Bern Mobil. Available at
http://www.uitp.org/advocacy/climate_change_docs/CO2_emission_trading_CH.pdf
11 Supra, Note 3.
12 Supra, Note 2.
13 Supra, Note 3.
14 Government of Switzerland (July 2011). “Exempt companies involved in emissions trading.” Available at
http://www.news.admin.ch/NSBSubscriber/message/attachments/23689.pdf
15 FOEN (July 2011). “CO2-tax exempt companies exceed CO2-targets also in 2010.” Available at
http://www.bafu.admin.ch/dokumentation/medieninformation/00962/index.html?lang=en&msg-id=40237
16 Reinaud, Julia and Cedric Philibert (December 2007). “Emissions Trading: Trends and Prospects.” OECD and IEA. Available at
http://www.oecd.org/dataoecd/60/38/39725657.pdf
17 FOEN (January 2010). “Emissions trading for companies.” Available at http://www.bafu.admin.ch/emissionshandel/05545/index.html?lang=en
18 Supra, Note 7.
19 Supra, Note 16.
20 Supra, Note 15.
21 Supra, Note 3.
22 Mace, M.J., Ilona Millar, Christoph Schwarte, Jason Anderson, Derik Broekhoff, Robert Bradley, Catherine Bowyer, and Robert Heilmayr (May 2008). “Analysisof the legal and organizational issues arising in linking the EU Emissions Trading Scheme to other existing and emerging emissions trading schemes.” FIELD.
IEEP. WRI. Available at http://www.field.org.uk/files/Linking%20emission%20trading%20schemes_0.pdf
23 Parliament of Australia (November 2010). “Swiss emissions trading scheme.” Available at
http://www.aph.gov.au/About_Parliament/Parliamentary_Departments/Parliamentary_Library/Browse_by_Topic/ClimateChange/responses/economic/emissi
ons/international/swiss
24 Supra, Note 3.
25 FOEN (November 2007). “Emission Credits, Offsetting and Trading.” Available at
http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&ved=0CB4QFjAA&url=http%3A%2F%2Fwww.bafu.admin.ch%2Femissionshandel%2F05564%2F05565%2Findex.html%3Flang%3Den%26download%3DNHzLpZeg7t%2Clnp6I0NTU042l2Z6ln1ad1IZn4Z2qZpnO2Yuq2Z6gpJCFdX54fGym162epYbg2c_JjKbNoKSn6A--&ei=QnaJUMrZNof40gH80ICABQ&usg=AFQjCNGaMYfuU8M0xEl98Q5wuJjICru_qQ&sig2=0YprQbaL5owwKj0MVaFqJw
26 Supra, Note 25.
27 Supra, Note 22.
28 Supra, Note 3.
29 Supra, Note 25.
30 Aldy, Joseph and Robert Stavins (May 2012). “Post-Durban Climate Policy Architecture Based on Linkage of Cap-and-Trade Systems.” The Chicago Journal ofInternational Law.
31 FOEN (November 2010). “Linking the Emissions Trading System Swiss-EU.” Available at
http://www.bafu.admin.ch/emissionshandel/10923/index.html?lang=en
32 Supra, Note 2.
33 FOEN (December 2010). “The National Emissions Trading Registry.” Available at http://www.bafu.admin.ch/emissionshandel/05564/index.html?lang=en
12Page 7 of 8	  Supra, Note 33.
Hood, Christina (November 2010). “Reviewing Existing and Proposed Emissions Trading Systems.” OECD/IEA. Available at
http://www.iea.org/papers/2010/ets_paper2010.pdf
36 Supra, Note 3.
37 Supra, Note 3.
38 Supra, Note 17.
39 Supra, Note 14.
40 Supra, Note 1.
41 Supra, Note 2.
42 Supra, Note 3.
43 Supra, Note 3.
44 Supra, Note 2.
45 Supra, Note 3.
46 Supra, Note 1.
47 Supra, Note 10.
48 Supra, Note 1.
49 Supra, Note 15.
50 Supra, Note 14.
51 Bureau of the Environment, Tokyo Metropolitan Government (March 2010). “Tokyo Cap-and-Trade Program: Japan’s first mandatory emissions trading
scheme.” Available at http://www.kankyo.metro.tokyo.jp/en/attachement/Tokyo-cap_and_trade_program-march_2010_TMG.pdf
34
35

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