Ongoing Obligations	View now
Joining the BPF and the membership discount	View now
Maintaining your evidence pack	View now
Target Period Reporting	View now
Audits - What to expect	View now
Helpline and support	View now
Government Consultations	View now
BPF Energy Awards	View now
What to do if you change to a new energy supplier	View now
Wider Policy Landscape	View now

 

Ongoing obligations

Your obligations

• To maintain an evidence pack. Inclusive of the application documents, Underlying Agreement (UnA), yearly eligibility reassessments/Energy reduction survey and evidence of energy reduction measures implemented as a result of the survey or independently implemented, a copy of PP10/11 forms, a copy of data submissions to BPF Energy/Supplier invoices Production records plus any correspondence related to the UnA.
• To notify BPF Energy of any changes that affects the detail of the application and the UnA within 20 working days.  This includes any change to the responsible person.
• Co-operate with any person appointed to undertake an audit of the UnA or CCL relief claims.
• Prompt payment of your BPF Energy Partner Fees and EA Fees.
• Prompt response to requests for data by BPF Energy.
• You are committed to work towards your energy efficiency improvement target and keep a record of your actions

Our obligations

• Ongoing advice on any scheme changes or updates
• To collect and summarise your data and to provide this to EA as per the terms of the Target Periods
• To use your data supplied to advise you of your forecasted position in regards to reaching your targets
• To renegotiate as required the terms of the Climate Change scheme with the Governing bodies
• General helpline support for the duration of the scheme
   

Joining the BPF and the discount on the CCA fees

BPF members receive a large discount of approximately 50% on their CCA administration fees and members of an organisation Affiliated to the BPF receive a 10% discount on their CCA administration fees. 

If you are members of an affiliated organisation you will need to let the CCA team know on [email protected] if you have not already included this information on your BPF Energy Application.

If you would like more information on becoming a member of BPF and receiving the discount please contact Stephen Hunt on +44(0)20 7457 5044 or at [email protected] and he will be able to advise on cost and other benefits of membership.

Maintaining your evidence pack

An Evidence Pack in a vital part of your CCA and a requirement of the scheme. From the point of application and throughout the duration of your involvement in the scheme an evidence pack should be maintained and added to..
As a minimum your evidence pack should include;

• FEF/PP4 Application and all supporting documents including the base year energy invoices and production records.
• Underlying Agreement (UnA)
• Written evidence of error checking procedures
• An annual eligibility assessment of the 70% rule and any additonal 3/7ths of energy associated with the eligible facility
• BPF Data Returns and evidence to support the submission (energy invoices and production records)
• Copy PP10/11 forms that have been submitted to HMRC and your supplier
• Evidence of carbon buy-out payments
• Communication records relating to your CCA
• Detail of any audits and where necessary follow-up actions
• Information on action taken during the Target Period to improve energy efficiency or reduce carbon emissions

Target Period Reporting

Timeframe for Reporting 2025 - 2033 document

At the end of the Target Period, energy consumption and throughput data must be formally reported to the Environment Agency, via BPF Energy. In order to make the reporting of data as easy as possible, BPF Energy has developed an online portal to reduce the administration burden of the scheme. 

The online reporting portal allows a facility to enter energy and throughput data on a monthly basis, to show a current and forecasted position against target for the Target Period. 

The online reporting portal for the CCA may be found here
 
A Target Unit who meets or over achieves against their target will automatically be re-certified for the next certification period. Over achievement is converted into carbon dioxide equivalent (CO2e) which is banked on the register for future use by that target unit, known as CO2e surplus.
 
A Target Unit that doesn't achieve its target, will face a buy-out fee to account for the shortfall between actual and target performance (CO2e tonne). The buy-out fee was set at £12/tonne of CO2e for Target Period 1 and 2, rising to £14/tonne for Target period 3 and 4, and £18/tonne for Target Period 5, payable to a consolidated fund administered by Her Majesty's Treasury (HMT). Target Period 6 has seen an increase in the buy-out cost to £25/tonne. Payment of the fee as specified will allow for the target unit to be re-certified for the next certification period allowing for a continuation in the reduced CCL charge.  
 
Target Period 6 (1 January - 31 December 2024) -  data submissions for the Plastic sector CCAs must be made via the online reporting portal by 7 March 2025. The Environment Agency's reporting deadline is the 1st May 2025 with buy-out payments due by 1st July 2025.

New to Target Period 6 is a requirement to report action taken during the target period to improve energy efficiency or reduce carbon emissions. The actions are recorded and submitted via an excel file Performance Account Template (PAT). 

Audits - What to expect

The Environment Agency carry out audits to verify the eligibility and performance of the selected facilities. HMRC also conduct separate independent audits to verify the CCL relief claim.

Facilities are selected for audits on a risk based selection (e.g. where the eligible process is complex or the 70% position has changed) and by random selection. The audit itself may be a desk top audit over the telephone or involve a visit to site. In both cases information is usually requested in advance that may be available to you from a well maintained evidence pack. 

A report will follow the audit, with two outcomes. Pass, with no further actions or follow up actions/recommendations required to ensure or reduce further risks of non-compliance.

Where there are recommendations and follow up actions there will be an agreed date for these to be completed. Where no action is taken to follow up within the agreed timeframe, the response may be a penalty or in the worst case, termination from the scheme due to non-compliance.

Helpline and support

Please keep in mind that BPF CCA team are available for any ongoing advice and guidance on your CCA. Please contact us on 020 7457 5026 / 020 7457 5027 or email [email protected]

Government Consultations and updates

BPF/BPF Energy will undertake any renegotiations of the Plastics Sector Climate Change Agreement, actively lobbying the government on behalf of the CCA Partners 

Climate Change Agreements: consultation on a new Six-Year scheme

Consultation response: 16 October 2024

In the Autumn 2023 Budget statement the government announced a new six year Climate Change Agreement scheme (2025-2030) split into three target periods, allowing for a continuation in the reduced CCL charge for eligible participants between 1 July 2027 and 31 March 2033. A consultation on the policy proposals for the new scheme ran between 22 November 2023 and 14 February 2024.

On the 16 October 2024 the Department of Energy Security and Net Zero (DESNZ) published the Government's consultation response to the Climate Change Agreements: Consultation on the New Scheme.  

Some key points from the consultation:

• The start date of the first Target Period of the new scheme will be 1 January 2026, with reduced CCL rates available for participants until March 2033. 
• Target Period 1 will be the 12 months of 2026, Target Period 2 and Target Period 3 will be the 24 months of 2027-2028 and 2029-2030.
• New entrants may apply during May to August 2025 for entry into the new scheme on 1 January 2026, after which new applications will be accepted every year between January and August. 
• The base year will be updated from 2018 to 2022.
• Annual confirmation on the 70:30 eligibility rule for all facilities to ensure compliance with the threshold.
• The use of facility level data to inform Target setting through a Savings Assessment Tool that will help inform Government on the energy saving and decarbonisation potential at facility-level within each sector. 
• A move to facility level data reporting, removing the option for an operator to form a multi-facility bubbled target unit
• Introducing a requirement for annual interim reporting to provide an estimate of the performance outcome at the end of the Target Period, to include energy saving actions implemented during the reporting period. 
• All facilities will report under a Novem type target mechanism with fixed (non-production) and variable (production) energy consumption values.
• Carbon surplus (CO2e) achieved through exceeding the performance Target will be carried forward to the next Target Period to offset any potential underperformance, only within the new scheme and on a facility basis. 

 

CCA Consultation: proposals for a future scheme

Consultation response: November 2023

In December 2021 the Government published an initial consultation setting out key aspects of a potential future scheme and the reforms under consideration, the response to this consultation was may be viewedin the link here

On 15 March 2023 the government announced their intention to extend the CCA scheme for a further two years and to reopen the scheme to new entrant applications between May and September 2023.

In November 2023 the government published their response to the consultation on the extension to the CCA scheme, this included a new Target Period 6 and reduced rates of CCL to 31 March 2027 along with further proposals on a future scheme which was then announced in the Chancellor's Autumn 2023 statement. 

Climate Change Agreements scheme extension and reforms for any future scheme

Consultation response: July 2020

In the spring 2020 budget speech the chancellor announced a two year extension to the CCA scheme and the reopening of the scheme to new entrants. The extension to the CCA;

• reopens the scheme to new entrant applications with a closing date of 30 November 2020
• adds a further Target Period 5 to run from January 2021 - December 2022
• extends Climate Change Levy relief for eligible CCA participants to 31 March 2025
• amends the buy-out and penalty fees that apply to TP5 to £18/tCO2e
• prevents the use of previously gained Carbon surplus to offset under-performance against TP5 targets
• amends the base year to 2018 for TP5

 For the full outcome of the consultation please visit the link here

Reforming the business energy efficiency tax landscape: response to the consultation

Consultation response: March 2016 

This consultation response highlights the requirement for a simplified energy and carbon reporting framework for introduction by April 2019.

In brief the consultation will explore and produce proposals for:

• the integration of the existing compliance and reporting requirements of CCAs, EU Emissions Trading System, and ESOS with any new reporting framework, to further minimise administrative burdens.
• mandatory annual reporting for the organisations within its scope, with board or senior level sign-off and some public disclosure of data.
• applying the new reporting framework to all large UK undertakings who satisfy the qualification criteria for the ESOS scheme (or similar criteria), as well as large public and third sector organisations which meet these criteria.
• protecting the smallest or lowest energy-consuming businesses within the smaller businesses who do not pay CCL remaining fully protected from future CCL increases. CCL paying businesses will have three years to make energy savings before CCL increases will take effect, with RPI increases only from 2016 to 2018

For the full outcome of the consultation please visit the link here 

Energy Awards

BPF Energy, in support of all the energy initiatives undertaken in the Plastics Industry, makes an award each year to acknowledge the energy efficiency improvement within the Plastics Sector Climate Change Agreement - the BPF Energy Award.  This is based on the improvement between the previous two full years and is calculated by taking the incremental energy consumed for the incremental production achieved.

The winner and runner up facilities for this award each year are invited to the British Plastics Federations Annual Dinner in order to be presented with their awards by the BPF President.  They are also able to take advantage of other benefits and are able to use the BPF Energy Award logos.

What to do if you change to a new energy supplier

Please remember that whenever you change to a new energy supplier you need to resubmit a PP10 and a PP11.  The PP10 is to go to HMRC and the PP11 to your new supplier.  Please carefully read the notes on the form and if you have any problems completing these forms please remember the helpline is there for you on 020 7457 5026 / 020 7457 5027  Link to the forms

Wider Policy Landscape The CCA scheme operates within a broader set of exisiting policies which are part of the UK Government's strategy for business energy efficiency and industrial decarbonisation. Other polices in this space include:

CCA Guidance and Operations Manual
For more detailed information on how climate change agreements work and for the Environment Agency's operations manual please follow the link here

Combined Heat and Power Quality Assurance
Certification for good quality CHP and CHPQA financial incentatives, further information can be found in the link here

Energy Intensive Industries (EIIs) - EII exemption (EII) scheme and Network Charging Compensation (NCC) scheme
On 23 February 2023, the government announced the British Industry Supercharger (BIS): a decisive set of measures to make Britain’s strategic Energy Intensive Industries (EIIs) more competitive across Europe and tackle the challenge of indirect carbon leakage and the risk of that the policy costs imposed on EIIs could lead to the displacement of production, and associated emissions.

GOV.UK British Industry Supercharger Network Charging Compensation scheme

The Government will provide eligible Energy Intensive Industries (EIIs) in Great Britain with 60% compensation on their electricity network charging costs from April 2024, this aims to offer comparable support to that offered by certain EU states. Germany, France and Netherlands all offer up to 90% exemptions to EIIs on their network charging costs.

The commencement of the Network Charging Compensation (NCC) scheme from 1 April 2024 aligns with the uplift in the EII Exemption Scheme (an exemption from the indirect costs of funding the costs of renewables e.g. CfD, RO, FiT) from 85% to 100%. Any energy intensive installation eligible for 100% exemption from the costs of renewables from 1 April 2024 is also eligible to apply for the 60% network charging cost compensation on 100% of the electricity passing through the relevant meter. 

To apply for an exemption/compensation the business must manufacture in the UK within an eligible sector defined by NACE code (this includes 20.16 Plastics in primary forms, 22.17 Synthetic rubber in primary forms, 22.19 Rubber products, 22.21 Plastic plates, sheets, tubes and profiles, 22.22 Plastic packing goods, 22.29 Other plastic products) and pass a 20% electricity intensity test. Energy Intensive Industries (EIIs): Guidance for applicants seeking a certificate for an exemption

Eligible companies should make a claim for the network charges incurred during April to June 2024 between 12 July and 30 August 2024. The compensation payments for eligible companies will begin in May 2025. The Government will require EIIs to submit 3 months of network charging data 4 times a year once the scheme is operational. 

The Network Charging Compensation (NCC) portal will be operational from 12 July 2024 - NCC scheme portal

Energy Savings Opportunity Scheme (ESOS)
ESOS is a mandatory energy assessment scheme for large UK undertakings and their corporate groups. Organisations that qualify must carry out ESOS assessments every 4 years, this is an audit of the energy used by their buildings, industrial processes and transport to identify cost-effective energy saving measures. Further information on the qualification criteria and ESOS compliance may be found in the link here 

Energy Technology List (ETL)
The ETL scheme helps UK businesses and the public sector to make greener energy choices. It's free to use and backed by the Government's Department for Energy Security and Net Zero. As one of the world's largest databases of energy-saving technology, it provides easy access to around 8,000 tested and stringently assessed energy efficient products. Further information including the verified technology list can be found in the link here

Industrial Energy Transformation Fund (IEFT)
The IEFT is designed to help businesses with high energy use, such as energy intensive industries, to cut their energy bills and carbon emissions through investing in energy efficiency and low carbon technologies. The UK government announced £315m of funding in the 2018 budget, available up until 2024 this will be managed over 2 phases: phase 1 was open to applications from 20 July to 28 October 2020, phase 2 will launch in 2021. Further information on the scheme eligiblity and funding may be found in the link here

Streamlined Energy and Carbon Reporting (SECR)
SECR regulations require large businesses to annually report on their energy and carbon emissions and report on any efficiency measures they are taking to show continual annual improvements. All quoted companies in the UK need to comply if they meet any two of the determining factors that qualify them as large, more than 250 employees, an annual turnover of more than £36m or an annual balance sheet of over £18m. Further information and guidance on SECR including greenhouse gas (GHG) reporting may be found in the link here  

UK Emissions Trading Scheme
The UK ETS applies to energy intensive industries, the power generation sector and aviation. Further details on who it applies to and how it works can be found in the link here 

Carbon Price Support
If you own electricity generating stations or you're an operator of combined heat and power stations (CHP), you pay Carbon Price Support Rates. Further details on this may be found in the link here

 

The British Plastics Federation has launched a Carbon Footprint Tool which follows GHG protocol guidance using the three scopes necessary to help you measure and report the total greenhouse gas emissions caused by your organisation. 

Participants of the Plastic sector Climate Change Agreement schemes are provided with access to the tool FREE of charge. To get started please register your organisation via the CCA Reporting Website, this is to allow for the transfer of the energy data already submitted as part of your Climate Change Agreement.

Once you access the CCA reporting website there will be a new Carbon Footprint tab that will take you through the registration process. To register your interest or for further infromation please contact [email protected]

A link to the Carbon Footprint Tool may be found here