Germany’s National Greenhouse Gas Emissions Inventory Status


In Germany, the German Environment Agency (aka the UBA, Umwelt Bundesamt), founded in 1974, began developing a reporting system in the 1980s. In 1990, the Federal Republic of Germany passed a first cabinet decision on the first national climate target aiming to reduce GHG emissions by at least 25% below the 1987 levels by 2005. In 1990, the UBA announced that German GHG emissions had a base value of 1.250.247 M tons of carbon dioxide-equivalents. That figure and year are still the reference for current GHG emissions reduction targets.

“The first German climate target was to be reached through a series of legislative measures based on a voluntary commitment by the German industry. To this end, the German industrial associations concluded a contract with the economic institute RWI on monitoring greenhouse gases”. Thus, mainly private institutions funded by the industry were initially responsible for keeping records of German GHG emissions. The UBA used that data for its work and estimations, but in 1999, following the agreement of the Kyoto Protocol (signed in 1997) and later also the “Marrakesh Accords” from COP7. In 2000, the Federal Government published the first government-issued greenhouse gas report to the EU as part of ‘EU monitoring of CO2 and other greenhouse gases’. This formed the blueprint of Germany’s first National GHG Emissions Inventory.

From 2005, the Federal Republic of Germany was obliged to make annual submissions of the National GHG Emissions Inventory to the UN Climate Secretariat. Thus, Germany then had to hand over this report to the EU and the UN Climate Secretariat. A full National Inventory Report with a proper description of the method used was first sent to the UNFCCC secretariat in 2003. Nonetheless, it was only in 2007 that a “Climate Protection Statistics Law” was agreed, which is the current legal basis for data collection, evaluation and processing for the GHG inventory in Germany. On a global level, the ‘Good Practice Guidance’ and ‘Guidelines’ are regularly reviewed by the Intergovernmental Panel on Climate Change (IPCC) to ensure the latest science-based contribution on measurement and reporting.

“Since 2007, the National Coordination Agency for Emission Inventories (the ‘Single National Entity’) in the German Environment Agency (UBA Umweltbundesamt) has been responsible for preparing the report in Germany. This coordination agency is supported by other federal institutions, such as the Federal Statistical Office (Destatis) and the Federal Research Institute for Rural Areas, Forestry and Fisheries (the Thünen Institute), which gathers data on GHG emitted by agriculture, land use, land use change and forestry.” The German Environment Agency (UBA) is thus the ‘Technical authority’ for implementing the reporting obligations, whereas the Federal Environment Ministry bears the political responsibility. The following graph shows the entities involved and the flow of information for the annual emissions report:

The German Quality System for Emission Inventories (QSE) was initially designed to serve the purposes of emission reporting under the UN Framework Convention on Climate Change (UNFCCC). It takes account of provisions of the 2006 IPCC (Intergovernmental Panel on Climate Change) Guidelines – General Guidance and Reporting (GGR), of national circumstances in Germany and of the internal structures and procedures of the German Environment Agency (UBA), the reporting institution.

Figure: QSE – Roles, responsibilities and workflow


The German Environment Agency (UBA) currently produces the Annual Inventory of Carbon Emissions, and such inventory focuses on general carbon dioxide (CO2) emissions, including methane (CH4) and nitrous oxide (N2O). It also provides a view on fluorinated greenhouse gases: Hydrofluorocarbons (HFCs), Perfluorocarbons (PFCs) and Sulphur Hexafluoride (SF6). It publishes online not only the annual inventory but also a report on the National inventory of GHG with a retrospective view since 1990, with 30+ years of historical perspective, following the UN Framework Convention on Climate Change and the Kyoto Protocol. The latest available online emission inventory report was issued in March 2023, which includes preliminary data for 2022 and was also submitted to the UNFCC (United Nations Climate Change Secretary) in April’23.

“Greenhouse gas emissions in Germany have fallen since 1990: from 1,251 million tons of CO2 equivalents in 1990 to 746 million tons in 2022 – a significant decrease following the emissions of 2020 and 2021, which were characterised by extraordinary factors. Overall, this corresponds to a reduction of over 40 %. Excluding the low values in certain years with special circumstances, the indicator follows a long-term downward trend. After stagnation, emissions have fallen significantly from 2017 to 2022, mainly due to increased emissions trading certificate prices and the expansion of renewable energies.” Source.

However, the Russian war over Ukraine and the consequent bans on Russian gas -from which Germany was largely dependent- and the return to relative normality after COVID restrictions took a toll on the emissions reduction trend. In 2022, Germany’s greenhouse gas emissions (GHG) fell slightly by 1.9%. While Germany is generally on track to meet the Federal Climate Change Act targets, emissions in the energy sector -the largest emitter- increased significantly to 10.7 million tons higher than in 2021 (around 256 million tons CO₂ equivalents). This is because, despite savings in natural gas -induced by importantly higher prices and scarcity due to the Russian war, the increased use of hard coal and lignite for electricity generation caused emissions to rise. Nonetheless, there was a positive consequent trend: electricity production using renewables could curb emissions, up by 9% over 2021. Therefore, The energy sector can just about meet its annual emissions target in 2022 of 257 million tons.

On the other hand, the transport and buildings sectors once again exceed the annual emission budgets stipulated in the Federal Climate Change Act[1].  The transport sector even shows a year-on-year increase in emissions simultaneously. Despite exceptionally high fuel prices in 2022 and the temporary rollout of the “9-euro ticket”[2], public transport emissions from road transport rose again. After COVID-19 restrictions were widely lifted, passenger car traffic increased slightly. High fuel prices were alleviated by the “fuel price rebate”[3]. “Although 2022 was a record year for the number of new registrations of electric cars, the increase is insufficient to balance out the spike in emissions.”

The industry -the second largest emitter in industrial country Germany- kept the approximate share on overall emissions (only down 2% against the previous year, but up 1% against average since 1990) but was able also to reduce them “significantly by 19 million tons of CO₂ equivalents (10.4%) to 164 million tons of CO₂ equivalents in 2022. This is due to the sharp drop in energy consumption triggered by the war in Ukraine, especially in the metal processing and chemical industries. The main reason for the lower energy use and thus lower emissions in the industry are energy costs, which have risen sharply compared to the previous year due to inflation and the crisis.” Except for hard coal – consumption remains almost the same level as in 2021 – the use of other fossil fuels has fallen. As a result, production figures have also declined in some areas, especially in energy-intensive industries.


The calculation method is described in the latest inventory report (Submission under the United Nations Framework Convention on Climate Change and the Kyoto Protocol 2023

National Inventory Report for the German Greenhouse Gas Inventory 1990 – 2021 UBA 2023)

Clear action needs to be taken by the German government to keep and increase the downward trend on emissions, especially for the largest emitters: Energy Industry, Industry, Transport and Buildings. The current government coalition of the Green Party, the socialist party (SPD) and the Liberals (FDP) may be well positioned to push the required energy transition if unity is achieved. Several discussions over measures such as the following need clear resolution:

  • The German Energy Law, including the Building Energy Act, a reform to reduce building emissions, is central to achieving Berlin’s climate goals. A controversial law championed by the government would ban almost all new oil and gas heating systems starting next year. Homes and businesses must purchase appliances that meet strict environmental standards, such as heat pumps. The Building Energy Act, known colloquially as the “heating law,” has opened yet another rift in the tenuous three-party governing coalition led by German Chancellor Olaf Scholz. While Scholz has thrown his support behind the measure, some key governing partners stonewalled its initial passage.

“The law aims to phase out oil and gas heating systems in buildings throughout Germany. It is the brainchild of Vice Chancellor Robert Habeck, a member of the environmentalist Greens who also serves as minister for economics and climate action. If Habeck’s legislation is passed, new heating systems in the country would be required to rely on at least 65% green energy sources starting Jan. 1, 2024, and municipalities would have to devise environmentally friendly heating master plans by 2028 at the latest. The law is modelled on existing common policies in many Scandinavian countries.”

  • Imposing a speed limit on German highways: While more than 96% of German roads are subject to a permanent speed limit, just 30% of the 13,000km network of motorways – or autobahn – has permanent or temporary speed limits, according to the German Association of the Automotive Industry (VDA).  Germany is one of the only major countries in the world not to have a nationwide speed limit. This topic has garnered increasing attention as the country struggles to meet its transport decarbonisation targets. But, according to a new paper published in the Ecological Economics journal, Bringing in a speed limit of 130kph (80mph) across all of Germany’s motorways could result in nearly €1bn in welfare savings, a new study says, with “avoided warming” leading the benefits. (In January this year, a studyfrom the UBA showed that bringing in a speed limit of 120km/h (75mph) on motorways across Germany would cut emissions from passenger cars and light commercial vehicles by 6.7MtCO2e a year.  Calls for the introduction of an autobahn speed limit based on environmental benefits have been growing since the introduction of the country’s first national climate law in 2019.

While there is growing evidence pointing to the implementation of a speed limit helping to tackle emissions, it is far from certain that Germany will implement the policy.

“Given that a significant majority of Germans are in favour of a speed limit, including the policies, we, unfortunately, have a situation where the decision is blocked by a small party [the FDP] for reasons of personal interests or pressure from lobby organizations. There is no rational argument against a speed limit” said Professor Stefan Gössling at the School of Business and Economics (Linnaeus University) cited by Carbon brief.

“Polls have shown for a while that a majority of Germans supports a motorway speed limit although a relatively large and loud minority opposes them.” Dr. Giulio Mattioli (Technical University Dortmund) cited also by Carbon brief. “Like Gössling, he points the finger at the FDP, but also the opposition CDU, for blocking the implementation of an autobahn speed limit”. He concludes “Two right-of-center parties (CDU and FDP) oppose it and have become even more opposed over time, going as far as to include a rejection of motorway speed limits in their 2021 electoral manifestos. Given the nature of coalition politics in Germany, every government coalition will include at least one of these two parties for the foreseeable future, and they will be able to continue vetoing the measure. So I don’t see that happening anytime soon.”

Several other issues can be mentioned, such as the practical course of the energy transition in Germany; which is something the current government was not only willing but had forcibly to speed up -due to the Russia’s war on Ukraine and the subsequent energy crisis-.

In any case, unity is proving in the actual coalition quite difficult. For instance, in the case of “the heating law”, the Greens lined up enthusiastically behind Habeck. “The SPD was split, with Scholz (German chancellor) endorsing the proposal while others in his party questioned its potential impact on consumers. And the FDP loudly dissented, calling the proposal too costly and preferring to let the market dictate technological innovation. The Greens and the FDP are fundamentally divided on the state’s role in confronting almost every major issue Germany faces today, and their constant bickering has stymied many of the coalition’s attempts to legislate. Nowhere is this more evident—and existential—than in climate policy.”

“If we really want to tackle climate change, the state has to interfere more in what had been private issues because we have to change our behavior,” said Andrea Römmele, the dean of executive education at the Hertie School of Governance in Berlin, as cited by “Foreign Policy”.

This Brief was submitted by Climate Scorecard Germany Country Manager Katherine Cote.

[1] The Federal Climate Change Act intends to ensure that national and European targets are met and support Germany’s commitment at the UN climate summit in New York in September 2019 to pursue greenhouse gas neutrality as a long-term goal by 2050.  It establishes annual budgets and an emissions reduction path with clear emissions reduction goals for 2030. On June 24th, 2021, the Bundestag passed an amendment to set the carbon neutrality goal to 2045 instead of 2050.

[2] Scheme through which passengers could travel for that price a month on local and regional transport in all Germany over the 3 summer months of 2022; aimed at reducing energy amid the global energy crisis and ease cost of living. A similar scheme has been applied since May’23 at a 49€ adjusted price

[3] As part of a government package aimed at cushioning the financial impact of the Ukraine war on citizen by providing a temporary 0.175€/liter reduction of excise duty on diesel and petrol from 16 March to 30 September 2022, which was set to not apply as soon as the price at the pump drops to and/or below EUR 1.70/liter


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