Dóra Fazekas Carbon Market Implications for new EU - UniCredit ...

to comply shall have their names published – a provision referred to as “naming and shaming”
in EC Directive 2003/87. This list shall be made available to the public, in an electronic format,
until the obligation to surrender emissions allowances is met.
(2) Should the operator fail to track its GHG emissions and fail to meet its reporting requirements,
or if it operates without possessing a valid emissions permit, the Inspectorate General may levy
a fine up to 500 thousand HUF. (Government Decree no. 272/2004, Section 5, Paragraph 2)
(3) Should the operator fail to meet its reporting requirements or fail to report any changes in its
operation, the Inspectorate General may levy a fine between 10 thousand and 50 thousand
HUF. (Government Decree no. 272/2004, Section 5, Paragraph 3).
(4) Should the operator provide incomplete information or provide information past the relevant
deadlines, the environmental authority may impose a fine between 10 thousand and 50
thousand HUF per day. (Government Decree no. 143/2005, Section 6, Paragraphs 3-4).
(5) Should the operator fail to pay the fees for the management of its holding account (see
Appendix IV) on time, the operator shall be obliged to pay interest for as long as the fee is not
received; the interest shall be two times 1/365 of the prime interest rate, as determined by the
Hungarian National Bank, per day. Once interest on arrears has been paid, no further interest
on arrears can be claimed. (Government Decree no. 143/2005, Section 15/D)
The most substantial financial burden related to the introduction of the scheme was actually the
procurement or installation of certified mechanical devices for measuring emissions. Based on the
discussion above, the introduction of the scheme was not preceded by a preparatory phase of
training or instruction, which would also have posed a significant burden in terms of costs. The
costs of verification were not seen as superfluous expenditures by the companies, since these
assured their compliance and that the data they would be reporting will be correct. Some companies
mentioned the fees of outside consultant experts, but these were not especially significant.
A further cost related to the system, in addition to the administrative expenses mentioned, is the
cost of trading on the exchange. This, too, is relatively low, and is no higher than fees
encountered at exchanges trading other goods. Trading 1 million tonnes, for instance, at Nordpool
carries transaction costs of 0.015 EUR per allowance, for members; if the amount traded is higher
than 2.5 million tonnes, this figure is 0.01 EUR. The fee used on the ECX is 0.002 EUR per
allowance, but this is supplemented by an annual fee of 2,500 EUR.
The expenses listed above all apply to companies covered by the system; but they are not the only
ones who had to face costs related to the scheme: the GOH also had to pay. The first category of
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