One of the most significant differences between the national emissions trading system (nEHS) and the European emissions trading system (EU-ETS) is that in the nEHS, it is not those companies that cause the fuel emissions that participate in fuel emissions trading (so-called downstream emissions trading), but rather the companies that bring the heating and fuels into circulation at the upstream trading level, where the energy tax arises (so-called upstream emissions trading).

Thus, the more than 4,000 participants in the nEHS are companies from both the first and last trading levels. These primarily include:

• Petroleum dealers
• Liquid gas traders
• Natural gas and heat suppliers
• Coal suppliers and coal users
• Importers
• Refineries

Despite the actual separation of the two systems, plant operators who are already subject to emissions trading under the EU ETS will be affected by the ETS. In cases where an installation subject to the TEHG procures fuels subject to the nEHS, fuel emissions will be subject to both the BEHG and the TEHG.