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Polowiec & Partners

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Consulting areas

EU ETS (including ETS 2)

Legal insight. Industrial understanding.

We support entities covered by the EU ETS in areas where the allowance system directly translates into costs, operational risks and investment decisions

We organize the annual compliance process and prepare the organization for verification and inspections – from the monitoring plan, through reporting, to the cancellation of allowances.
Learn about the scope of support
Rules of cooperation

EU ETS (including ETS2)

We act as legal advisors

NWe do not act as a verifier, but we support clients in preparing documentation, communicating with the verifier and minimizing risks non-compliance and financial consequences. We implement the solution as part of the team.

MRV as a process

Roles, data flow, evidence, corrections and accountability procedures.

Ready for verification

Document order, evidence trail, support in responses and explanations (without performing verification).

Compliance Calendar

Planning activities and deadlines to avoid costs and risks.

Value and cost

We look at the ETS through the prism of production costs, competitiveness and risk mitigation options (allocation, benchmarks, compensation).

Proceedings and disputes

Representation, corrective and preventive actions.

EU ETS (including ETS2)

Scope of support and Products

MRV and Annual Compliance (advice, not verification)

  • Support in preparing/updating the monitoring plan and managing changes (technology, fuels, organization)
  • Organizing the flow of data and evidence (procedures, responsibilities, corrections, archiving)
  • Preparation for verification: completing documents, consistency of methods, answers to the verifier's questions, identification of risk areas (without acting as a verifier)
  • Support in communicating with authorities regarding MRV and settlement matters

Emissions settlement and surrender of allowances (EUA)

  • Advice on settlement obligations (report, verification, write-off)
  • Non-compliance risk analysis (penalties, administrative consequences, business impact)
  • Support in updating internal processes to ensure repeatable settlement.

Benchmarks, free allocation and compliance optimization (including carbon leakage / CBAM)

  • Analysis of the impact of product/heat/fuel benchmarks on the level of free allocation and identification of risk drivers (production changes, installation changes, boundaries, process definitions)
  • Support in the correct assignment of streams, products and activities for benchmarking purposes (consistency with the monitoring plan and MRV documentation)
  • Review of documentation and processes to identify verification process risks and administrative risks (audit trail, evidence, change control)
  • Organizational optimization recommendations: roles, correction procedures, archiving, and compliance calendar - lower maintenance costs, greater predictability
  • Consequences of CBAM/phase-out and carbon leakage for plant strategy and value chain contracts

ETS2 – cost and implementation impact

  • SENT
  • ADR (road)
  • RID (railway)

Compensation for indirect costs of the EU ETS

  • Seveso regulations - ZZR and ZDR
  • Particularly dangerous work
  • Operational work on power equipment (SEP)
  • UDT, TDT, CE markings

Regulatory implementations

  • Analysis of the impact of changes in ETS/ETS2/implementing acts on costs and obligations
  • Updated MRV procedures, documentation, and governance
  • Implementation training and consistency testing (documents–data–practice)

Administrative proceedings and litigation

  • Representation in proceedings concerning ECJ obligations (MRV, settlement, decisions of authorities, penalties/consequences)
  • Pre-litigation activities and representation in administrative court proceedings
  • Analysis of the consequences of the decisions on the further operation of the installation and a plan for corrective and preventive actions

Training and workshops

We build the competencies of teams

Implementation training

Operational training

Strategic workshops

Polowiec & Partners

Clear rules of Cooperation

Common priorities

We set tasks together with the client's business and operational teams, focusing on issues that require a quick response and are important for business continuity.

Direct communication channels

We tailor our collaboration to the client's preferences and needs. We are available both remotely and on-site – during meetings, workshops, and on-site visits. We prioritize direct contact, efficient communication, and the absence of unnecessary barriers.