Following the release of our report Klimagoldesel, Thyssenkrupp has been in contact with Sandbag to explain that their 50% stake in Huttenwerk Krupp Mannessmann (HKM) does not afford them emissions management responsibilities for the Glocke Duisberg installation that we have currently attributed to them.

In light of this information, Sandbag feels it appropriate to revise the methodology used in Klimagoldesel to apply a 51% ownership threshold – reflecting a controlling stake in a subsidiary company – before attributing a company's European Union Allowances to a parent corporation. Our published report had applied a 50% threshold.

Applying this methodology considerably lowers the surplus of European Union Allowances (EUAs) Sandbag attributes to ThyssenKrupp's German installations to 6,009,759 down from the 19,506,005 in the original report. We acknowledge this is a significant change. Sandbag would like to apologize for any reputational damage we may have caused ThyssenKrupp by inadvertently exaggerating the scale of surplus EUAs they have received.

Whilst ThyssenKrupp remain 50% shareholders in HKM, we agree it is fairer to include HKM as a separate company and have amended our database to reflect this. We propose to issue an addendum to the report including a revised league table as soon as possible, in which ThyssenKrupp will move down the list from first place and in which HKM will appear as a separate company.

As a separate note, we have also now reduced the surplus attributed to HKM by 9,809,036 EUAs in light of new information on waste gas transfers they have provided us, and which ThyssenKrupp helped us to identify.

The lack of transparency over the transfer of waste gases and emissions allowances makes a true assessment of the efficacy of the ETS extremely difficult. Sandbag has repeatedly called for this issue to be addressed so that accurate analysis can be undertaken.

We are grateful to ThyssenKrupp for helping us to improve the accuracy of our data. We strongly believe parent company information and waste gas emissions transfers should be included in the publicly available EU ETS database administered by the European Commission.