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ReFuelEU Aviation
The ReFuelEU Aviation regulation, part of the Fit for 55 Package, aims to meet the European Climate Law targets and reduce emissions by 55% by 2030. Among legislations focused on helping to cut emissions from transport and mobility, ReFuelEU Aviation aims to set provisions to increase the production and use of sustainable aviation fuels.
The Regulation sets minimum obligations for all fuel suppliers to gradually increase the share of SAFs (sustainable aviation fuels) in the fuel supplied to operators at EU airports, in accordance with a timetable fixed in the Annex I of the proposal (see table). Within this SAF requirement, a sub-obligation is also set for synthetic aviation fuels.
| ReFuelEU Aviation obligations | |
| 2025 | 2% SAF |
| 2030 |
6% SAF 2030-31: 1,2% synthetic fuels (average over the years mentioned) 2032-34: 2% synthetic fuels (average over the years mentioned) |
| 2035 |
20% SAF 5% synthetic fuels |
| 2040 |
34% SAF 10% synthetic fuels |
| 2045 |
42 % SAF 15% synthetic fuels |
| 2050 |
70% SAF 35% synthetic fuels |
Additionally, the regulation also establishes an obligation for aircraft operators to ensure that the yearly quantity of aviation fuel uplifted at a given EU airport is at least 90% of the yearly aviation fuel required, to prevent fuel tankering practices, where aircrafts are refuelled at the origin airport with more fuel than necessary for the flight with the aim to avoid refuelling partially or fully at a destination airport where aviation fuel is more expensive.
In April 2023 the co-legislators came to an agreement and in October 2023 the ReFuelEU Aviation Regulation came into force. It applies since January 2024 (2025 concerning SAFs mandates) and by January 2027 and every 5 years thereafter, the Commission will have to report to the co-legislators on its application and assess the potential need to revise the mandate and the SAFs definition.
What’s in it for hydrogen?
The regulation defines sustainable aviation fuels (SAFs) as aviation fuels that are either:
- synthetic aviation fuels (RFNBOs complying with the lifecycle emissions saving threshold of 70%, thus including green hydrogen);
- aviation biofuels (as defined in the Renewable Energy Directive, excluding those produced from food and feed crops);
- recycled carbon aviation fuels.
However, according to Article 4 which sets the share of SAFs available at Union airports, the mandatory minimum shares of SAFs and of synthetic fuels from Annex I can be reached when using:
- Renewable hydrogen for aviation: hydrogen for direct use in aircraft, that qualifies as RFNBO;
- Low-carbon aviation fuel: synthetic low carbon aviation fuel (aviation fuels from non-biological origin, which energy content is derived from non-fossil-low-carbon hydrogen and meet lifecycle emissions savings threshold of 70%) or low-carbon hydrogen for aviation.
The Regulation introduces certain flexibility mechanisms for fuel suppliers to reach those targets: from 2025 to 2034 (10 years) and for each reporting period (1 year), a fuel supplier may supply the minimum share of SAF as a weighted average over all the aviation fuel it supplied across the Union airports for that reporting period.
Similarly, the European Commission established a SAF monitoring exercise, identifying and assessing the developments on SAF production and supply on the aviation fuel market. Also, a system of tradability of SAFs is developed to enable fuel supply in the EU without it being physically connected to a supply site; as well as incorporating elements from a book-and-claim scheme, enabling aircraft operators and/or fuel suppliers to purchase SAFs through contractual arrangements with aviation fuel suppliers and to claim its use at Union airports. These elements should only be used during the time of the flexibility mechanism period (until 2034).
A clear link with the Alternative Fuel Infrastructure Regulation (AFIR) is also established, whereby airports, fuel suppliers and fuel handlers must cooperate and coordinate with Member States for the preparation of the National Policy Framework for the deployment of alternative fuel infrastructure in airports and to facilitate access of aircraft operators to hydrogen.
The Regulation also ensures the earmarking of revenues from fines for non-compliance with the Regulation to support research and innovation on SAFs, production of SAFs and mechanisms to bridge the cost difference with conventional fuel. Member States will have to report on the use of these revenues by 2026 and every 5 years thereafter.
This mandate for green aviation fuel will enable SAF projects to scale up, providing clearer definitions for investors and suppliers, and establishing a European supply chain for sustainable aviation fuels. With synthetic fuel development projected to exceed 1.8 million tons by 2030, ReFuel EU Aviation will reduce investment risks and boost production goals, making the political context more favourable.
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