i did start to fill in the papers when our civil aviation authority said we were not concerned since we burn less than 10 000 ton Co2 yearly.
I first thought than we were considered as "small emitters" (who have to fill in the forms as well) but according to our aothority we "have nothing to do to comply with the EU directive"
Maybe having some less than 5.7t aircraft NTOW helps in this case !