I've resisted this scheme (dragged kicking & screaming) but did the bare essential to remain in compliance.
We had our plan approved, then they told us we needed to become carbon traders. That was a show-stopper (we're an aviation op, not into trading carbon credits and the dislosure requirements are cumbersome & invasive); despite some resistance and opposition we were able to appoint a proxy to conduct the carbon trading on our behalf.
No credits (we still had our heels dug in), we've adopted the derogation stance (only report inter-European sectors). We got the verification done about a month back and conducted a spot-trade on the purchase of our assessed EUA's (a couple of hundred) due for 2012 recently. So I see us as having done enough to keep these bureaucratic clowns at bay.
We're a Private US-registered global operation that was assigned the UK (we spend quite a bit of time there) for EU-ETS purposes.
I still maintain that it's a giant crock of sh1te however that in itself is not a reason not to be in compliance. My dealings with the ETS folk have clearly shown them to be a crowd of sanctamonious creeps (they send you a bill to cover their operating expenses) - I could imagine nothing worse than to deal with them if they were able to show that you were not in compliance with this ridiculous scheme.
4HP