Regulatory note on the impact of the « Dunkirk heat highway »project with regard to the European Union emissions trading system

RÉSUMÉ

This study is a regulatory analysis of the impact of the “Dkarbonation – Dunkirk Heat Highway” project on CO₂ emissions and the free allocation of allowances for installations subject to the European Union Emissions Trading System (EU ETS). It was conducted during the summer of 2025.

The report first clarifies the rules for allocating free allowances, particularly in the case of heat exchanges between installations, whether or not they are covered by the EU ETS. Based on a potential technical configuration (involving the actors concerned, their EU ETS status, and their roles as heat producers or consumers, etc.), the study applies these allocation rules (defined by Regulation (EU) 2019/331 and further specified in accompanying guidance documents) to this configuration. This approach allows the qualitative assessment of the impact of various heat or waste gas exchanges between installations on the free allocation of allowances to EU ETS-covered installations, as well as on the CO₂ emissions of the different installations.

The regulatory analysis shows that valorizing waste heat and waste gases is beneficial in terms of overall free allowance allocations and the reduction of CO₂ emissions reported under the EU ETS, particularly for steam consumers. However, the free allocation of allowances for installations connected to the industrial heat network could be redistributed between heat producers and consumers compared to a configuration without technical connection between installations. This reconfiguration of allocations must be carefully understood and analyzed to grasp the financial and commercial implications for the different stakeholders in the project