COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the Proposal for a Regulation of the European Parliament and of the Council on ensuring a level playing field for sustainable air transport
Date: 2021-07-14
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: air quality, air transport, aviation fuel, biofuel, greenhouse gas, reduction of gas emissions, renewable energy, sustainable mobility

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 14.7.2021  SWD(2021) 633 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT  Accompanying the Proposal for a Regulation of the European Parliament and of the Council  on ensuring a level playing field for sustainable air transport  {COM(2021) 561 final} - {SEC(2021) 561 final} - {SWD(2021) 634 final}  
 
 
Table of contents 

1. 

INTRODUCTION ................................................................................................................... 3 

1.1.  Political and legal context ............................................................................................. 3 
1.2.  Role of sustainable aviation fuels in the sector’s decarbonisation ................................ 4 
1.3.  Ramp-up trajectories for sustainable aviation fuels (SAF) ........................................... 5 
1.4.  Coherence with the ‘Fit for 55’ initiatives .................................................................... 7 
1.5.  Effects of the COVID-19 pandemic on air transport .................................................... 8 

2. 

PROBLEM DEFINITION ....................................................................................................... 9 

2.1.  What are the problems? ................................................................................................ 9 
2.2.  What are the problem drivers? .................................................................................... 13 
2.3.  How the problem will evolve ...................................................................................... 20 

3.  WHY SHOULD THE EU ACT? ........................................................................................... 22 

3.1.  Legal basis .................................................................................................................. 22 
3.2.  Subsidiarity: Necessity of EU action .......................................................................... 22 
3.3.  Subsidiarity: Added value of EU action ..................................................................... 23 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? .................................................................. 24 

4.1.  General objectives ....................................................................................................... 24 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ....................................................... 26 

5.1.  What is the baseline from which options are assessed? .............................................. 26 
5.2.  Policy measures under consideration and approach taken .......................................... 27 
5.3.  Description of the policy options (PO) ....................................................................... 27 
5.4.  Common elements for all policy options .................................................................... 33 
5.5.  How do policy options differ? .................................................................................... 37 
5.6.  Options discarded at an early stage ............................................................................. 38 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................. 38 

6.1.  Environmental impacts ............................................................................................... 38 
6.2.  Economic impacts ....................................................................................................... 44 
6.3.  Social impacts ............................................................................................................. 54 

7.  HOW DO THE OPTIONS COMPARE? .............................................................................. 54 

7.1.  Effectiveness and efficiency ....................................................................................... 54 
7.2.  Coherence ................................................................................................................... 58 
7.3.  Subsidiarity and proportionality.................................................................................. 61 
7.4.  The impact of the Covid-19 pandemic ........................................................................ 61 

8. 

PREFERRED OPTION ......................................................................................................... 62 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................... 65 

1 

 
 
Term or acronym 

Meaning or definition 

Glossary 

ICAO 

SAF 

RFNBO 

HEFA 

Gas+FT 

ATJ 

TRL 

RED 

RED II 

International Civil Aviation Organisation 

Sustainable Aviation Fuels 

Renewable fuels of non-biological origin, in the meaning of Article 2(63) of 
the Renewable Energy Directive, known as well as “synthetic fuels”  

Hydro-Processed Esters & Fatty Acids, a SAF conversion pathway  

Gasification + Fischer Tropsch, a conversion pathway used to produce SAF  

Alcohol-to-Jet, a pathway to produce SAF 

Technology Readiness Level 

Renewable Energy Directive 

2018 Recast Renewable Energy Directive 

GHG emissions 

Greenhouse gas emissions 

Jet A and Jet A-1 (incl. certified SAF) 

Kerosene fuels types 

HVO 

Mtoe 

ATAG 

Road transport biofuel 

Millions of tonnes of oil equivalent 

Air Transport Action Group 

ASTM International 

American Society for Testing of Materials 

ILUC 

CAPEX 

OPEX 

LCA 

FQD 

EU ETS 

CORSIA 

CAAF/2 

LTAG 

PO 

Non-negligible indirect land use change emissions 

Capital expenditure 

Operating expense 

Life-Cycle Assessment 

Fuel’s Quality Directive 

EU Emission Trading System 

Carbon Offsetting and Reduction Scheme for International Aviation 

Conference on Aviation and Alternative Fuels 

Long-term global aspirational goal for CO2 emissions reductions for 
international aviation 

Policy Option 

WTW Jet Emissions 

Well-to wing emissions  

WTT Emissions 

Well-to-tank (upstream or indirect emissions) 

NvPM 

ECAC 

CO2eq 

UCO 

SCS 

LCA  

Non-volatile particulate matter 

European Civil Aviation Conference 

Equivalent Carbon dioxide, a measure to compare the emissions 

Used Cooking Oil 

Sustainability Certification Scheme 

Life-Cycle Assessment  

 
 
1. 

INTRODUCTION 

1.1. 

Political and legal context 

This  Impact  Assessment  accompanies  a  legislative  proposal  –  hereby  ‘ReFuelEU  Aviation’  –  aimed  at 
maintaining  a  competitive  level  playing  field  in  the  air  transport  market  while  boosting  the  production  and 
uptake  of  sustainable  aviation  fuels.  An  external  support  study1  has  been  carried  out  in  2020  and  will  be 
published alongside this report.  

The EU aviation internal market is essential for the mobility of European citizens and for the European 
economy  as  a  whole.  In  2018,  the  aviation  and  aeronautical  industries  employed  an  estimated  0.4  million 
people  directly  in  the  EU2,  and  contributed  to  the  EU’s  GDP  by  an  estimated  2.1%3  in  2017.  Aviation  is  a 
strong driver for social and regional cohesion that boosts tourism, stimulates business and connects people. In 
20184, over 1.2 billion passengers flew to and from more than 500 airports in Europe. The EU aviation sector 
contributes to European integration and reinforces the EU’s position as a geopolitical leader. 

Air connectivity and the air transport sector as a whole bring significant socio-economic benefits to EU citizens 
and businesses. It is essential to ensure a well-functioning EU aviation market where economic actors can 
operate on a competitive level playing field. Nevertheless, air transport has a significant and growing impact 
on  the  environment,  notably  in  terms  of  greenhouse  gas  emissions  but  also  aircraft  noise  and  local  air 
pollution. In 2018, aviation accounted for 3.6% of the EU’s greenhouse gas emissions (2% at global level) and 
for 13.2% of the emissions from EU transport5. Aviation has been one of the fastest growing sectors in terms of 
CO2 emissions over the past decades6. Looking into the future, EU CO2 emissions from the sector could further 
grow by 17% up to 2030, relative to 20157. This has caused public and political pressure to increase in the 
past years, asking for the sector to intensify its efforts to decarbonise.  

In December 2019, the Commission adopted the European Green Deal Communication8, which emphasised 
the  need  to  accelerate  the  transition  to  a  climate-neutral  economy,  including  through  the  shift  to  sustainable 
mobility. To achieve climate neutrality, a 90% reduction in transport emissions is needed by 2050. All transport 
modes, including aviation, will have to contribute to the reduction.  

In September 2020, the Commission adopted its proposal to cut greenhouse gas emissions by at least 55% 
by 20309 and put Europe on a responsible path to becoming climate neutral by 2050. The Communication on 
the 2030 Climate Target Plan10 clearly mentions: “Both the aviation and maritime sectors will need to scale up 
efforts to improve the efficiency of aircraft, ships and their operations and to increase the use of sustainably 
produced  renewable  and  low-carbon  fuels.  This  will  be  assessed  in  greater  detail  in  the  context  of  the 
ReFuelEU  Aviation  and  FuelEU  Maritime  initiatives  that  aim  to  increase  the  production  and  the  uptake  of 
sustainable alternative fuels for these sectors. The necessary technology development and deployment has to 
happen  already  by  2030  to  prepare  for  much  more  rapid  change  thereafter.”  On  11  December  2020,  the 

1   Ricardo (2021), Study supporting the ReFuelEU Aviation Impact assessment. 
2  
3  
4  
5  
6  

Eurostat (lfsa_egan22d). 
Source: SWD(2017) 207 final. 
Source: Eurostat; Indirect job generated from air transport can be as high as three times the direct ones (European Commission, 2015). 
Source: EEA. 
Total CO2 emissions from flights departing from the EU27 and domestic flights within the territory of a Member State of the EU27 grew 
from around 112 million tonnes (Mt) in 2005 to 120 Mt in 2015, equal to a 7.6% increase. 
The Baseline scenario projections, reflecting the COVID-19 pandemics, are explained in Annex 4. 

7  
8   COM(2019) 640 final. 
9   COM/2020/563 final. 
10   COM/2020/562 final. 

3 

 
 
                                                           
European Council endorsed the binding EU target of a net domestic reduction of at least 55% in greenhouse gas 
emissions by 2030 compared to 199011. 

The  Commission  adopted  in  December 2020 the  Sustainable  and  Smart  Mobility  Strategy12.  This  strategy 
sets the course of action for each mode of transport to decrease its carbon footprint in line with the objective of 
cutting greenhouse gas emissions by at least 55% by 2030 and reaching EU climate neutrality by 2050. It also 
sets a number of milestones for the transport sector, drawing on the common analytical work underpinning the  
2030  Climate  Target  Plan  and  the  Sustainable  and  Smart  Mobility  Strategy,  while  considering  deploying  a 
broad  mix  of  policy  instruments  including  carbon  pricing  and  moderate  increase  in  the  energy  and  transport 
sectoral  regulatory  policy  ambition.  Overall,  the  EU  Emission  Trading  System  (EU  ETS)  and  the  Effort 
Sharing Regulation (ESR) combined, provide the general framework and mechanisms to ensure that emission 
reductions are achieved in line with the 55% increased ambition by 2030 and an EU climate neutral economy 
by  2050.  The  flexibility  of  EU  ETS  ensures  a  central  role  in  delivering  the  required  level  of  ambition.  The 
Commission will propose in 2021, as part of the ‘Fit for 55’ package, a revision of the EU Emissions Trading 
System  Directive  and  of  the  Effort  Sharing  Regulation,  along  an  amendment  to  the  Renewable  Energy 
Directive,  the  revision  of  the  Energy  Taxation  Directive,  the  revision  of  the  Alternative  Fuels  Infrastructure 
Directive, etc. 

Importantly, attainment of the EU’s climate targets is a joint effort between the EU and the Member States. As 
such, the  basic legislative  framework  provide  by  the ETS  and  ESR  needs to  be  supported  by  a  set  of  Union 
level  regulatory  measures  that  complement  action  at  national  level.  These  measures  will  enable  the  various 
sectors of the economy, such as aviation to step up their efforts to decarbonise. The Commission will propose 
two initiatives specifically aimed at accelerating the decarbonisation of aviation and maritime transport  - two 
sectors  which  have  shown  specific  difficulties  to  increase  the  use  renewable  sources  of  energy  and  decrease 
their emissions until now - with the use of sustainable fuels, i.e. ‘ReFuelEU Aviation’ and ‘FuelEU Maritime’.   

The ReFuelEU Aviation is overall welcomed by the air transport and fuels industries, as well as climate non-
governmental organisations, as a key initiative to make aviation more sustainable, while reinforcing the level 
playing  field  in  the  aviation  internal  market  and  the  competitiveness  of  the  sector.  There  is  also  a  strong 
impulse given by a leading group of Member States, for the ReFuelEU Aviation initiative, and more generally 
for a swift delivery of an EU-level regulatory framework for sustainable aviation fuels. During the High Level 
Conference  on  Synthetic  SAF  of  8  February  2021,  the  Ministers  of  Transport  of  eight  EU  Member  States 
(Denmark,  Finland,  France,  Germany,  Luxemburg,  the  Netherlands,  Spain  and  Sweden)  issued  a  joint 
statement to “support the aim of the European Commission to boost the supply and demand for SAF in the EU 
so  as  to  create  favourable  conditions  in  order  to  ramp  up  the  production  and  deployment  of  SAF  (…).  The 
challenge  is  to  make  use  of  the  current  momentum  by  providing  for  a  clear  long-term  perspective  so  as  to 
contribute to a scalable SAF marketplace. A European blending mandate for SAF can achieve this.” 

1.2. 

Role of sustainable aviation fuels in the sector’s decarbonisation 

The  aviation  sector  is  particularly  difficult  to  decarbonise  due  to  its  exclusive  reliance  on  fossil  energy,  the 
limited technological options available for reducing its emissions, and the long lifespan of aircraft. This is why 
the EU has adopted a comprehensive approach to addressing aviation emissions. The decarbonisation of the 
air  transport  sector  will  rely  partly  on  intensifying  the  efforts  and  measures  already  in  place.  These  include 
market-based measures (the EU Emissions Trading Scheme and the Carbon Offsetting and Reduction Scheme 
for  International  Aviation  of  the  International  Civil  Aviation  Organisation  -  ICAO13),  improved  air  traffic 

11   Source: https://www.consilium.europa.eu/media/47296/1011-12-20-euco-conclusions-en.pdf 
12   Source: https://ec.europa.eu/transport/themes/mobilitystrategy_en 
13  

ICAO is the UN specialised agency in the field of air transport; all Member States are ICAO members. 

4 

 
                                                           
management  operations,  and  research  on  more  efficient  aircraft  design  and  technology.  Some  of  the  policy 
instruments  particularly  relevant  for  aviation,  notably  the  EU  Emissions  Trading  System,  the  Renewable 
Energy Directive and the Energy Taxation Directive will be reviewed as part of the forthcoming ‘Fit for 55’ 
package. The coherence of ‘ReFuelEU Aviation’ initiative with those other ‘Fit for 55’ initiatives is discussed 
in section 1.4.  

In  order  to  decrease  significantly  its  emissions,  the  aviation  sector  will  need  to  reduce  its  current  exclusive 
reliance  on  fossil  jet  fuel14  and  accelerate  its  transition  to  innovative  and  sustainable  types  of  fuels  and 
technologies. However, the aviation sector lacks immediate alternatives to liquid fuels for commercial aircraft 
propulsion.  New  zero-emission  aircraft  technologies  such  as  electric-  or  hydrogen-powered  aircraft  are 
promising but not expected to be mature soon enough to play a significant role in commercial aviation in the 
next  decades.  Because  aviation  needs  to  address  its  carbon  footprint  already  by  2030,  the  role  of 
sustainable  aviation  liquid  fuels  will  be  essential.  For  this  reason,  as  part  of  the  comprehensive  approach, 
measures  are  also  needed  to  increase  the  use  of  sustainable  aviation  fuels  (biofuels,  advanced  biofuels  or 
renewable fuels of non-biological origin as defined in the recast Renewable Energy Directive (EU) 2018/2001).  

Figure 2 in section 2.1.3 gives information about the aviation industry’s expectations of the role to be played 
by  SAF  and  other  CO2-reducing  measures  (improvements  in  aircraft  design  and  technology,  more  efficient 
operations and better infrastructure, including ATM, offsetting) in the decarbonisation of the aviation sector by 
2050. Under this scenario focusing on SAF deployment, SAF and offsets would account for 75% of achieved 
emissions savings, improved technology would account for 15% and better operations and infrastructure would 
account for 10%. 

For  the  purpose  of  this  impact  assessment,  the  term  “sustainable  aviation  fuel  (SAF)”  refers  to  the 
following three categories of drop-in15 liquid fuels: Annex IX Part B biofuels16, advanced biofuels (Annex IX 
Part A biofuels) and renewable fuels of non-biological origin (RFNBOs) – mainly synthetic fuels, within the 
meaning of the Renewable Energy Directive (RED II)17, which are certified to be used to power commercial 
aircraft. Section 5.4.1 of this impact assessment brings forward clear policy choices about the precise types of 
SAF that are eligible under the policy options considered. It explains notably why this initiative focuses on the 
three categories of above-mentioned drop-in SAF, and explain why it does not cover hydrogen and electricity 
as primary fuels for aviation. 

1.3. 

Ramp-up trajectories for sustainable aviation fuels (SAF) 

The  common  economic  assessment18,19  underpinning  the  2030  Climate  Target  Plan  and  the  Sustainable  and 
Smart Mobility Strategy, looked at the feasibility of achieving a higher climate target and provided insights into 
the  efforts  that  individual  sectors  would  have  to  contribute.  The  assessment  looked  at  a  range  of  possible 
pathways/scenarios to explore the delivery of the increased ambition of cutting the economy-wide greenhouse 
gas  emissions  by  at  least  55%  by  2030  and  achieving  climate  neutrality  by  2050.  These  pathways/scenarios 
were constructed around a set of indicative policies for all sectors of the economy that either focus on carbon 
pricing or focus on regulatory measures, or combine the two types of instruments. For air transport, the same 
policy instruments including the ‘ReFuelEU Aviation’ initiative were included in all scenario configurations.  

14   More than 99% of jet fuel used in the EU in 2018 was fossil kerosene. Source: Eurostat. 
15   Liquid fuels that can be blended with conventional kerosene and are compatible with aircraft engines that are currently in operation. 
16   Biofuels produced from feedstock listed in Part B of Annex IX of the Renewable Energy Directive. 
17   See  Article  2(33),  Article  2(34)  and  Article  2(36)  of  Directive  (EU)  2018/2001  of  the  European  Parliament  and  of  the  Council  of  11 

December 2018 on the promotion of the use of energy from renewable sources (recast). 

18   Source: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52020SC0176 
19   Source : https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020SC0331 

5 

 
                                                           
The staff working document accompanying the Sustainable and Smart Mobility Strategy describes the ramp-up 
trajectories  for  sustainable  aviation  fuels  in  more  detail20,  drawing  on  the  common  economic  analysis 
underpinning the 2030 Climate Target Plan and the Sustainable and Smart Mobility Strategy. These trajectories 
are  derived  in  a  way  that  enables  kick  starting  the  scale-up  of  sustainable  aviation  fuels  (SAF)  from  2025 
onwards  and  their  large  scale  deployment  by  2050,  while  ensuring  the  consistency  with  the  required  overall 
greenhouse  gas  emissions  reductions  by  2030  and  2050,  preserving  the  competitiveness  of  the  sector, 
promoting innovation, and ensuring feedstock availability for renewable and low carbon fuels in all energy and 
transport  sectors  in  the  transition  towards  a  climate  neutral  economy.  The  pathways/scenarios  delivering  a 
reduction in the EU greenhouse gas emissions by at least 55% by 2030 and climate neutrality by 2050 suggest 
that SAF should represent 4 to 8% of the jet fuel used in 2030, for all flights departing from EU airports, and 63 
to 68% by 2050.  

When  considering  a  pathway/scenario  that  strengthens  and  further  expands  the  carbon  pricing,  be  it  via  EU 
ETS  or  other  carbon  pricing  instruments,  to  the  road  transport  and  buildings  sectors,  combined  with  low 
intensification  of  transport  policies  and  no  intensification  of  energy  efficiency  and  renewables  policies,  the 
analysis  shows that  sustainable aviation  fuels  obligations  should represent  at least  4%  of the jet  fuel  used in 
2030, for all flights departing from EU airports, and 68% by 2050. When considering a pathway/scenario that 
assumes high increase of the ambition of energy efficiency, renewables and transport policies,  while keeping 
the EU ETS scope unchanged, sustainable aviation fuels obligations should represent 8% of the jet fuel used in 
2030 and 63% by 2050. Finally, the pathway/scenario focusing on a combination of carbon pricing and medium 
intensification  of  regulatory  measures  in  all  sectors  of  the  economy  shows  that  sustainable  aviation  fuels 
obligations  should  represent  5%  of  the jet  fuel  used by  2030,  for  all  flights  departing  from  EU  airports, and 
63% by 2050.  

All  the  pathways  described  above  are  consistent  with  the  increased  ambition  of  cutting  the  economy-wide 
greenhouse gas emissions by at least 55% by 2030 and achieving climate neutrality by 2050. They all deliver a 
90% reduction in transport emissions by 2050, in line with the European Green Deal Communication and the 
Sustainable  and  Smart  Mobility  Strategy.  In  addition,  the  impact  assessment  underpinning  the  2030  Climate 
Target Plan21 noted particular benefits in deploying a broad mix of policy instruments, including carbon pricing 
and increased energy and transport sectoral regulatory policy ambition, and clearly suggested that there is no 
single policy instrument being capable of achieving all the objectives considered in the assessment alone. 

An update of the pathway/scenario focusing on a combination of carbon pricing and medium intensification of 
regulatory  measures  in  all  sectors  of  the  economy  for  the  purpose  of  the  ‘Fit  for  55’  package,  while  also 
reflecting the COVID-19 pandemic, the National Energy and Climate Plans and refining the policy design of 
the initiatives, confirms that air transport effectively contributes to the EU climate goals while considering the 
5% share of sustainable aviation fuels obligations in the air transport fuel mix by 2030 and 63% by 2050. 

It is essential to clarify that the fulfilment of the newly adopted EU climate targets is not conditioned on a 
precise SAF ramp-up trajectory. On the other hand, the level of ambition of the SAF ramp up should also 
ensure  an  effective  contribution  to  reducing  emissions  in  the  air  transport. The purpose  of  the  SAF  ramp-up 
trajectory suggested by the common economic assessment underpinning the 2030 Climate Target Plan and the 
Sustainable and Smart Mobility Strategy 2030 Climate Target Plan is to provide an indication, i.e. an order of 
magnitude of the possible contribution of SAF to the decarbonisation of air transport, in line with the EU’s 
climate targets. The cornerstone of the EU’s strategy to reach its climate objectives is the combined action of 
the EU ETS and the Effort Sharing Regulation. These two instruments ensure the overall consistency for the 
necessary reductions of emissions across the EU economy, and act jointly as a safety net for the attainment 

20   Source: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020SC0331 
21   Source: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52020SC0176 

6 

 
                                                           
of the EU’s climate targets. This means that there is some flexibility to decide on the exact level of ambition 
of individual measures (such as ReFuelEU Aviation) for the decarbonisation of the various sectors, such as air 
transport. The corrective mechanisms offered by the EU ETS, Effort Sharing Regulation, Climate Law and the 
Energy & Climate Governance Regulation (and the future evaluation of the current initiative), would allow to 
ensure overall consistency with the level of emission reductions necessary to reach EU climate targets.  

This impact assessment considers the trajectory for sustainable aviation fuels obligation that represent 5% 
of the jet fuel used by 2030 and 63% by 2050 in the scenario focusing on a combination of carbon pricing 
and medium intensification of regulatory measures in all sectors of the economy. The objective of the present 
impact  assessment  is  to  determine  the  design  of  the  policy  option  that  would  best  allow  to  reach  this 
contribution.  Nevertheless,  a  qualitative  assessment  of  the  implications  of  lower/higher  sustainable  aviation 
fuels obligation ramp-up is however provided in section 5.4.3.   

The large-scale shift from fossil energy to sustainable aviation fuels is a significant challenge for the aviation 
sector,  but  also  offers  considerable  economic  opportunities,  as  well  as  potentially  substantial  environmental 
benefits. In particular, it means making European aviation a pioneer in the use of sustainable fuels, and the EU 
a global leader in the production of sustainable aviation fuels. 

1.4. 

Coherence with the ‘Fit for 55’ initiatives 

The ReFuelEU Aviation initiative is coherent with other initiatives of the ‘Fit for 55’ package. Regarding 
the  revision  of  the  Renewable  Energy  Directive  (RED),  its  objectives  converge  with  ReFuelEU  Aviation, 
namely  to  increase  the  share  of  renewable  energy  in  transport.  Coherence  is  ensured  as  the  aviation-specific 
SAF  targets  established  under  ReFuelEU  Aviation  will  contribute  to  reaching  renewable  energy  targets  for 
transport  as  set  out  under RED.  The  coherence  of the  present  initiative  with  RED  will  be  further  ensured  as 
ReFuelEU Aviation will rely on several core pieces of the RED rules, with cross-references in the ReFuelEU 
Aviation  legal  text.  This  will  be  the  case  in  particular  regarding  the  sustainability  framework  of  the  RED  to 
determine the eligibility of SAF, the use of monitoring, reporting and verification systems already established 
under the RED, and caps applying to different types of fuels. However, RED is a cross-sector framework and 
sets targets for overarching sectors, e.g. transport or for the economy as a whole.  It has proven insufficient to 
boost  the  uptake  of  SAF  due  to  the  specificities  of  the  aviation  sector,  including  the  high  fuel  quality 
specifications and the strong EU-wide and global competitive cost pressure. Also, the RED by its design leads 
to a different policy mix from one Member State to another, which is ill suited for the highly integrated and 
competitive EU aviation internal market and its global dimension. While ReFuelEU Aviation is coherent with 
RED  and  contribute  to  the  overarching  objectives  of  RED,  it  will  lay  down  fully  harmonised 
requirements to ensure a level playing field between airlines and the avoidance of competitive disadvantage 
between EU airports. Consequently, also monitoring and enforcement will need to be organised at EU level and 
will  be  carried  out  by  existing  EU  aviation  agencies  such  as  EASA  or  Eurocontrol.  Annex  10  gives  further 
details on the interaction between ReFuelEU Aviation and RED II, and Annex 11 gives further details on the 
reasons why ReFuelEU Aviation objectives cannot effectively be implemented under the RED rules. 

ReFuelEU  Aviation  is  coherent  with  the  revision  of  the  EU  Emissions  Trading  Scheme  (ETS),  which 
applies to aviation since 2012. Their objectives are aligned, namely to reduce CO2 emissions in the aviation 
sector. The EU ETS contains an incentive for SAF usage, i.e. airlines are not required to surrender allowances 
when reporting the use of SAF (this benefit can be claimed only for the amount of ‘net’ SAF used, not for the 
fossil fraction of the jet fuel). As airline increase their use of SAF in the years to come as a consequence of 
ReFuelEU Aviation, this means that the volume of allowances needed by the aviation sector will decrease over 
time.  The  EU  ETS  will  effectively  further encourage airlines to  decarbonise  their  operations,  as  airlines  will 
continue to report the use of fossil jet fuel as fractions of their fuel mix. The effect of the EU ETS is expected to 
be  strengthened  in the  context  of  its  upcoming  revision,  with  a reduction  of the  free  allowances  allocated to 
airlines and the increase of the linear reduction factor. In turn, this is expected to increase the price of carbon 

7 

 
and provide additional incentives for airlines to decarbonise, for example with the use of SAF over and above 
the  mandated  minimum  blend;  and  for  investing  in  fuel  economy  measures,  whether  it  is  new  fuel-efficient 
aircraft  or  operational  measures  such  as  flight  path  efficiency  or  alternative  energy  use  on  the  ground  at 
airports. Therefore, it is clear that the ReFuelEU Aviation initiative and the revision of the EU ETS pursue 
the  same  objectives  and  will  complement  and  reinforce  each  other.  As  SAF  becomes  a  gradually  larger 
share of the aviation fuel mix over time, the air transport sector will decarbonise. In this context, the EU ETS 
will continue to play a major role in further reducing emissions from the sector by also driving improvements in 
energy efficiency. Finally, it is worth noting that coherence will be ensured as ReFuelEU Aviation will rely on 
the  EU  ETS  as  regards  the  monitoring,  reporting  and  verification  of  SAF  use  by  airlines.  Annex  10  gives 
further details on the interaction between ReFuelEU Aviation and EU ETS. 

ReFuelEU Aviation is coherent with the revision of the Energy Taxation Directive (ETD). Their objectives 
are  aligned,  i.e.  providing  the  air  transport  market  with  the  right  (policy  or  fiscal)  incentives  to  accelerate 
decarbonisation with the use of cleaner energy in the sector. Currently, the use of a number of innovative and 
sustainable  energy  products,  such  as  advanced  biofuels  in  transport  are  not  incentivised.  The  revision  of  the 
ETD considers policy options for introducing e.g. a possibility to apply reduced tax rates for SAF. Even though 
the  introduction  of  a  SAF  blending  mandate  may  reduce  the  scope  of  pricing  measures,  considering  that 
aviation  is  also  already  covered  by  carbon  pricing  through  the  EU  ETS,  it  can  be  assumed  that  properly 
differentiated  tax  rates  could  help  to  some  extent  make  SAF  more  economically  interesting  to  airlines 
compared to fossil jet fuel and stimulate greater SAF uptake, i.e. over and above the mandated minimum SAF 
blend  targets.  In  that  sense,  ReFuelEU  Aviation  and  a  revised  ETD  would  work  together  towards  the  same 
objective of encouraging the deployment of SAF.  

ReFuelEU  Aviation  is  coherent  with  the  revision  of  the  Alternative  Fuels  Infrastructure  Directive 
(AFID), but is expected to have limited interaction with AFID. The directive creates a common framework of 
measures for the deployment of alternative  fuels infrastructure in the EU. AFID  places a strong focus on the 
deployment  of  infrastructure  mainly  for  the  road  and  maritime  sectors.  For  aviation,  the  revision  of  the 
Directive explores the need to install electricity supply at airports e.g. for stationary aircraft. As explained in the 
subsequent sections of the present impact assessment, SAF are fully fungible with conventional jet fuel and do 
not require  any  specific refuelling  stations  or  dedicated  infrastructure in addition  to  what  currently  exists  for 
conventional  jet  fuel.  It  is  therefore  not  expected  that  the  revision  of  AFID  would  play  a  role  to  boost  SAF 
deployment in the EU. 

1.5. 

Effects of the COVID-19 pandemic on air transport 

The  COVID-19  pandemic  changed  the  air  transport  landscape.  Since  its  outbreak  in  early  2020,  it  has  been 
having  a  major  impact  on  the  international  and  European  aviation  industry,  as  Member  States  have 
introduced  various  measures  to  contain  the  spread  of  disease,  such  as  suspending  flights  from  other  EU 
Member  States or  third  countries.  According  to  Eurocontrol22,  while  the  number of flights  operating  daily  in 
European  airspace  declined  in  April-May  2020  by  88%  compared  to  the  same  period  in  201923,  the  overall 
number of flights in 2020 could be 55% lower than in 2019, i.e. a drop of 6 million flights.24 Because of the 
pandemic,  the  total  loss  for  the  air  transport  industry  in  2020  could  amount  to  €140  billon.  The  COVID-19 
crisis’  long-term  effects  on  air  transport  activity  are  uncertain  and  depend  on  the  global  evolution  of  the 
pandemic,  the  coordination  of  States  to  address  it,  and  the  ability  of  the  aviation  sector  to  restore  passenger 

22   Source: Eurocontrol – « Current Status Scenario » - 14/09/2020. 
23   Source: https://www.eurocontrol.int/sites/default/files/2020-04/draft-performance-review-report-prr2019.pdf 
24   Eurocontrol Draft Traffic Scenarios for September 2020-February 2021, available at: https://www.eurocontrol.int/publication/eurocontrol-

draft-traffic-scenarios-september-2020-february-2021  

8 

 
                                                           
confidence. Under current trends and policies, air transport activity is projected to go up by close to 45% by 
2030 and close to 90% by 2050 relative to 201525. 

2.  PROBLEM DEFINITION 

2.1.  What are the problems? 

2.1.1.

  General problem 

Air  connectivity  is  an  essential  driver  of  mobility for  EU citizens,  of  development  for  EU regions  and of 
growth for the economy as a whole. High levels of air connectivity within the EU, as well as to and from the 
EU,  are  best  ensured  when  the  EU  air  transport  market  functions  as  a  level  playing  field,  where  all  market 
actors  can  operate  based  on  equal  opportunities.  When  occurring,  market  distortions  risk  putting  aircraft 
operators  or  airports  at  disadvantage  towards  competitors.  In  turn,  this  can  result  in  a  loss  of 
competitiveness of the industry, and a loss of air connectivity for citizens and businesses. 

In  particular,  it  is  essential  to  ensure  a  level  playing  field  across  the  EU  air  transport  market,  when  it 
comes to the use of aviation fuel. Indeed, aviation fuel accounts for a substantial share of aircraft operators’ 
costs, i.e. up to 25% of operational costs. Variations in the price of aviation fuel can have important impacts on 
aircraft  operators’  economic  performance.  Furthermore,  differences  in  the  price  of  aviation  fuel  between 
geographic locations, as is currently the case between EU airports or between EU and non-EU airports, can lead 
aircraft operators to adapt their refuelling strategies for economic reasons. 

GHG emissions from the air transport sector have increased since the early 1990’s at EU and global level 
and are expected to further grow by 2050. The total air passenger traffic in Europe has more than doubled 
since 199026 and has more than tripled at global level over the same period. This important growth has been 
accompanied  by  a  steady  rise  in  EU  GHG  emissions  from  the  sector,  i.e.  an  increase  by  28%  from  2005  to 
201827. In 2018, aviation was accountable for around 3.6% of the EU’s greenhouse gas emissions (2% at global 
level) and for 13.2% of the emissions from EU transport28.  

Aviation  is  under  growing  pressure  to  accelerate  its  decarbonisation  without  hampering  its  highly 
integrated internal market. Over the past decades, fleet replacement by air carriers, investments in research 
and development for cleaner aircraft technologies, more efficient air traffic management systems and market-
based measures have allowed to slow down the increase of GHG emissions of the sector. While industry and 
policy efforts have brought environmental benefits (e.g. -24% fuel burn per flight in 2017 compared to 2005), 
this  has  not  compensated  the  overall  growth  of  the  sector.  As  aviation  emissions  are  projected  to  keep 
increasing in the years to come29, public and political pressure is continuing to build for aviation to accelerate 
its  decarbonisation.  The  decarbonisation  of the  aviation  sector will  come from  a  combination  of carbon 
pricing and regulatory measures acting as a whole to reduce the CO2 emissions of aviation in line with the 
EU’s climate objectives. The common economic analysis underpinning the 2030 Climate Target Plan and the 
Sustainable  and  Smart  Mobility  Strategy  shows  that,  in  the  pathway/scenario  focusing  on  a  combination  of 
carbon pricing and medium intensification of regulatory measures in all sectors of the economy, these measures 
will  contribute  to  this  objective,  reducing  CO2  emissions  from  aviation  by  52%  by  2050  compared  to  2015 
(equivalent  to  14%  reduction  relative  to  1990).  When  also  accounting  for  the  impacts  of  the  COVID-19 
pandemic and the National Energy and Climate Plans, emissions reductions of around 59% are projected in the 

25   The Baseline scenario projections, reflecting the COVID-19 pandemics, are explained in Annex 4. 
26   From 1995 to 2018, air transport activity increased by 140%: https://ec.europa.eu/transport/facts-fundings/statistics/pocketbook-2020_en 
27   EU Transport in figures – Statistical Pocketbook 2020: https://ec.europa.eu/transport/facts-fundings/statistics/pocketbook-2020_en 
28  
29   According to the Baseline scenario, emissions from aviation could increase by 21% from 2015 to 2050. 

Ibid. 

9 

 
                                                           
air  transport  by  2050  relative  to  2015  (equivalent  to  26%  reduction  relative  to  1990).  Those  reductions  are 
consistent with the EU’s long term climate objectives. 

SAF are expected to play an increasing role from 2025 onwards to bring aviation in line with the EU’s 
climate targets. Indeed, SAF would need to account for around 2% in 2025 and 4-8% in 2030, going up to 63-
68% of the total EU jet fuel consumption by 2050. However, in 2020, the production and use of SAF in the EU 
aviation market amounts to less than 0.05% of total jet fuel use. This very low use of SAF in the aviation fuel 
mix can be partly explained by the fact that the EU’s aviation industry is almost exclusively reliant on fossil 
energy that is currently significantly less costly than SAF. EU transport, and in particular air transport has been 
reliant on the use of high-emitting fossil-based fuels, notably imported in the EU from third countries. In 2018, 
EU transport depended on oil products for about 93% of its energy needs. Europe imports around 87% of its 
crude oil and oil products from abroad. This dependency could be reduced by increased SAF supply in the EU. 

The very strong reliance of the aviation sector on oil products can be explained partly30 because of the lack of 
mature  and  price-competitive  alternatives  to  power  commercial  aircraft  in  a  sustainable  way  in  the 
short-  to  medium-term.  Powering  a  commercial  aircraft  requires  fuel  with  high  energy  density.  Currently, 
only liquid jet fuel known as Jet A and Jet A-1 (including certified SAF), are sufficiently energy-dense to meet 
this  requirement.  Other  options  such  as  electricity  and  hydrogen  are  promising  research  options  as 
potential sources of energy to power aircraft in the long-term. Research for technologies such as battery-
powered  aircraft  engines  have  made  substantial  progress  in  the  past  years  and  have  the  potential  to  play  an 
important complementary role in the decarbonisation of aviation in the long-term. Experts recognise that in the 
short- and medium-term, their use will be limited to very short or short-haul flights for aircraft carrying small 
numbers of passengers. Similarly, hydrogen-powered aircraft are expected to play a role in the decarbonisation 
of the aviation sector beyond 2040. However, the emergence in the EU aviation market of a meaningful share 
of  commercial  fleets  powered  by  electric  batteries  or  hydrogen  fuel  cells  is  conditional  on  both  a  shift  of 
aircraft engine technology and the build-up of fuelling infrastructure. Research and innovation costs associated 
with the emergence of such technologies represent important barriers. Given the long research and development 
cycles  in  aviation,  including  lengthy  aircraft  certification  processes,  the  long  lifespan  of  aircraft  and  the 
considerable costs associated with such technological shifts, it is unlikely that hybrid or full electric aircraft or 
hydrogen-powered aircraft will account for a substantial share of the EU airlines’ fleets before 205031.  

SAF are a technologically viable solution to replace conventional fossil jet fuel. As drop-in fuels, they can 
be  blended32  with conventional  kerosene.  SAF can power  existing  aircraft  engines  without any  technological 
changes. Analyses show that there is potential to reach a gradually increasing shares of EU aviation with SAF 
by 2030 and 2050, if additional policies are implemented. This implies to overcome the two major problems 
faced today: production and demand in the current market conditions are very low.  

30   Other  factors  explaining  this strong  reliance include  the  low  prices  relative  to  SAF  and  the  advantageous  fiscal framework  for  fossil  jet 

fuel. 

31   Hydrogen-powered  aviation  A 
https://www.fch.europa.eu/ 

32   A maximum blending ratio of 50% is currently imposed by certification. However, this ratio may be lifted in the coming years to allow for 

fact-based  study  of  hydrogen 

technology,  economics,  and  climate 

impact  by  2050 

- 

flights to operate on 100% of SAF. Demonstration flights have successfully proven that this is possible. 

10 

 
                                                           
Figure 1 - Problem definition. 
The  ReFuelEU  Aviation  initiative  is  under  preparation  at  the  same  time  as  the  FuelEU  Maritime  initiative. 
While the two initiatives are similar in their objective, i.e. increasing the uptake of sustainable fuels in transport 
modes with a prominent global dimension with a view to accelerate their decarbonisation, the problems these 
two sectors face  in this respect are inherently different and require each a tailored approach. The differences 
between  the  two  initiatives  relate  mainly  to  the  legal  and  regulatory  context,  technical  constraints  and 
opportunities (e.g. number and type of fuel alternatives), operating conditions (fuel autonomy, etc.). 

2.1.2.

  Problem 1 – Limited production and supply at reasonable cost 

Europe  is  a  global  leader  in  transport  biofuel  production,  with  a  significant  number  of  commercial  plants  in 
operation.  However,  the  fuel  output  of  EU  bio-refineries  focuses  almost  exclusively  on  road  biofuels. 
Indeed, out of the 17.8 Mtoe of biofuels consumed in the EU in 2018, around 80% was biodiesel and 19% was 
bioethanol for road transport33. While the EU has a potential SAF production capacity estimated at 2.3 million 
tonnes per year34 (corresponding to 4% of the total jet fuel demand in the EU), this production capacity is not 
optimised for aviation fuels, as it is used almost exclusively for the production of bio-based fuel for the road 
transport  sector,  i.e.  biodiesel  and  bioethanol.  There  is  currently  no  plant  in  the  EU  producing  SAF  at 
commercial scale on a regular basis. Out of the approximately 47 Mtoe of jet fuel sold in 2018 in the EU, 
SAF accounts for less than 0.05%, the rest being conventional fossil jet fuel produced from crude oil35.  

The absence of SAF production at commercial scale is one of the reasons36 why SAF production costs, and in 
particular  capital  and  operation  costs,  are  high  in  comparison with  that  of  conventional fossil  jet  fuel. 
Indeed, the SAF production sector does not benefit from the economies of scale that would allow the capital 
and operation cost of production of a batch of SAF to be lower. Depending on the production pathway used, the 
production costs of SAF are generally estimated to be between 1.5 to 6 times higher than for conventional fossil 
jet fuel37. 

90%  of  respondents  to  the  survey38  agreed  or  strongly  agreed  that  low  production  and  supply  of  SAF  at 
reasonable  cost  in  the  EU  is  a  problem.  This  finding  is  in  accordance  with  the  OPC  where  64%  of  the 

33   Source: Biofuels Barometer - A study carried out by EurObserv’ER. – 2020. 
34   This  means  that  the  biofuel  production  infrastructure  currently  installed  in  the  EU  could  produce  up  to  2.3  million  tonnes  of  SAF  on  a 
yearly basis. However, this is currently not the case because this available capacity is used to produce other outputs. Using the 2.3 million 
tonne  capacity  to  produce  SAF  would  mean  reducing  the  output  of  other  types  of  fuel  or  chemicals.  Source:  European  Aviation 
Environmental Report 2019 – EASA, EUROCONTROL, EEA. 

35   Source: Eurostat. 
36   The  main drivers of this problem include high capital and operational costs,  inadequate regulatory and fiscal framework and others (see 

problem drivers 1, 2 and 3). 

37   Study supporting the ReFuelEU Aviation Impact assessment – Ricardo – 2020 – See stakeholders consultation report. 
38  

Ibid. 

11 

 
 
                                                           
stakeholders rated the price of SAF and the excessive production cost of SAF as the top barriers for not using 
SAF. 

This problem directly affects various parties. First, it directly affects air carriers, who do not have access to 
regular supply of SAF. As a result, airlines are not in a position to purchase SAF on a regular basis with a view 
to reducing the GHG impact of their operations. This problem also affects those responsible for the reduction of 
GHG emissions from aviation such as EU Member States, in view of the European Green Deal and compliance 
with the EU’s commitments with respect to the Paris Agreement and other international commitments such as 
CORSIA39.  Ultimately,  this  problem  also  affects  European  citizens,  considering  the  carbon  footprint  of 
individual  flights,  and  subsequently  of  each  air  traveller.  European  citizens  tend  to  become  increasingly 
concerned by the environmental impact of their travel. 

2.1.3.

  Problem 2 – In spite of strong interest for SAF from the aviation sector, demand is low in 

the current market conditions 

The aviation industry is setting ambitious emission reduction targets, which increasingly rely on the use 
of SAF. Already in 2008, the aviation industry decided on an aspirational goal of reducing net emissions from 
aviation  at  global  level  by  50%  by  2050  compared  to  2005  levels40.  In  October  2020,  ATAG  published 
“Waypoint 2050”41, outlining the sector’s vision on concrete pathways towards meeting the 50% objective. All 
scenarios consider that at least 50% of emissions reductions will need to come from SAF. One of the scenarios 
considers that 75% of the emissions reductions achieved will need to come from SAF.  

Figure 2 - Scenario "aggressive deployment of SAF" - Waypoint 2050 report. 

Waypoint 2050 further shows that achieving carbon neutrality in aviation is feasible around 2060. Similarly, 
several  aviation  actors,  including  those  with  differing  business  models  (passenger  airlines,  cargo)  publically 
announced commitments to reduce their carbon footprint with similar levels of ambition, with the use of SAF. 

In spite of the strong and increasing interest of some airlines in sustainable aviation fuels, actual demand is 
very limited in the current market conditions. While generally airlines show increasing interest to use SAF 
in the future, actual projects and partnerships remain an exception. Many airlines groups are still not engaging 
in concrete partnerships or contracts to boost their SAF use in the future, because in the current conditions the 
business case is rarely perceived as economically attractive. This is particularly the case in a market where the 
price gap between conventional fossil jet fuel and SAF is significant  (see problem drivers 2 and 3). As a 

39   Source: https://www.icao.int/environmental-protection/CORSIA/Pages/default.aspx 
40   Source: https://www.atag.org/our-activities/climate-change.html 
41   Source: https://aviationbenefits.org/environmental-efficiency/climate-action/waypoint-2050/ 

12 

 
 
                                                           
result, demand for SAF as an alternative to fossil jet fuel remains very low. In fact, as airlines are sensitive to 
the market price of jet fuel due to the global competition, this can lead to fuel tankering practices, whereby 
airlines choose to uplift more jet fuel than necessary at airports where prices are low. Such practices could lead 
to additional emissions42. Such practices are detrimental to healthy competition on the aviation market as they 
can put some airlines and airports at competitive disadvantage with others. 

66% of respondents to the survey43 strongly agreed or agreed that low demand for SAF in the current market 
conditions is an issue hindering the use of SAF in the EU. The respondents to the OPC agreed as 46% were 
of the view that low demand for SAF is hindering the use of SAF in EU.  

2.2.  What are the problem drivers? 

2.2.1.

  Problem  Driver  1  -  SAF  are  at  very  early  stage  of  commercial  development  and  face 

various constraints (feedstock availability, sustainability, costs, certification) 

A  scale  up  of  SAF  production  requires  at  the  same  time  the  existence  of  certified  production  routes  and the 
availability of sufficient feedstock. As of October 2020, seven SAF production pathways have been certified to 
comply with the technical and safety standards of ASTM International44 (see Annex 14) for use in commercial 
aircraft,  and  several  others  are  in  the  process  of  being  certified.  These  pathways  can  produce  SAF  from 
different  feedstock,  at  different  production  costs,  and  are  currently  at  different  stages  of  commercial 
development.  

Annex IX Part B biofuels45 can play a role to decarbonise aviation, but their potential is limited, due to 
feedstock availability constraints. The most commercially mature pathway in line with the Renewable Energy 
Directive  is  the  HEFA46  pathway  (TRL  9)  that  produces  SAF  from  vegetable  oils  and  waste  lipids  (used 
cooking oil and animal fats). When produced from waste lipids, this pathway is referred as “Part B biofuels” in 
this impact assessment. The vast majority of biofuel production in the EU and globally using Part B feedstock 
are  produced  for  the  road  transport  sector47.  Therefore,  there  is  potentially  a  large  production  capacity  for 
HEFA that is already installed in the EU48. Part B biofuels can achieve emissions savings as high as 85% and 
76% compared to conventional jet fuel when produced respectively from used cooking oil and animal fats49. 
HEFA is also currently the least expensive SAF pathway to produce (see problem driver 2), but the availability 
of feedstock currently included in Annex IX Part B is already a strong limiting factor and will be even more in 
the  future.  Indeed,  they  are  highly  demanded  for  the  production  of  other  transport  biofuels  and  their 
aggregation  (collection  and  supply  chain)  is  not  always  well  organised  at  EU  level.    Besides,  their 
decarbonisation  potential  is  limited  compared to  that  of  advanced biofuels (produced from  Annex  IX  Part  A 

42   A  Eurocontrol  analysis  for  the  European  Civil  Aviation  Conference’s  (ECAC)  airspace  (composed  of  44  countries,  including  the  EU 
Member States) shows that 16.5% of flights are able to perform full tankering and 4.5% partial tankering with negative impacts both on the 
sales  of  European  jet  fuel  producers  and  on  CO2  emissions,  because  of  carrying  more  fuel  than  necessary  which  increases  fuel 
consumption. In addition, interviews with several pilots from airlines, business aviation dispatchers and handling agents, were conducted 
during  this  analysis.  They  reported  that  in  practice  full  tankering  is  performed  on  15%  of  flights,  and  partial  tankering  performed  on  a 
further 15% of flights. 

43   Study supporting the ReFuelEU Aviation Impact assessment – Ricardo – 2020 – See stakeholders consultation report. 
44   American  Society  for  Testing  of  Materials.  https://www.astm.org/.  To  note  that  the  DefStan  (UK  Defence  Standardization  - 

https://www.gov.uk/guidance/uk-defence-standardization) plays a similar role for the certification of jet fuel, in the UK. 

45   Biofuels produced from feedstock listed in Annex IX part B of the Renewable Energy Directive. 
46   Hydro-Processed Esters & Fatty Acids (see Annex 15). Source: Analysis of current aviation biofuel technical production potential in EU28 

– M. Prussi, A. O’Connell, L. Lonza. 

47   HVO (hydro-treated vegetable oil) is the pathway used to produce biofuel for the road transport sector from the same feedstock as those 

required to produce HEFA jet fuel. 

48   Around 20% of road transport biofuels is produced from Annex  IX Part B feedstock. Increasing the production of aviation biofuel from 

49  

those feedstock would likely result partly in a shift of production from the road sector. 
ICAO document - CORSIA Default Life Cycle Emissions Values For CORSIA Eligible Fuels. Emissions savings are determined relative 
to a baseline for fossil jet fuels of 89gCO2e/MJ. 

13 

 
                                                           
feedstock50) that can be provided from renewable independent feedstock sources. Finally, the contribution of 
Part B biofuels to EU renewable energy transport target is capped under the Renewable Energy Directive.  

Advanced biofuels51 have significant potential but are not yet available at commercial scale.  SAF can be 
produced from feedstock such as lignocellulosic (e.g. agricultural or forestry residues, grass materials), algae, 
bio-waste  feedstock  (biogenic  content  of  municipal  solid  waste)  and  others  (see  Annex  15).  This  type  of 
feedstock  is  potentially  abundant  but  is  also  likely  to  be  subject  to  strong  demand  as  input  for  bioenergy 
processes  in  other  sectors  of  the  economy.  Feedstock  supply  chains,  including  necessary  infrastructure  and 
logistics, also need to be improved by the industry and relevant authorities. Advanced biofuels are recognised 
to be among the most promising resources52 for the production of sustainable transport fuels. They have high 
potential  for  the  decarbonisation  of  aviation  since  they  can  achieve  high  emissions  savings  compared  to 
conventional  jet  fuel  (e.g.  respectively  94%  and  91%  emissions  savings  over  their  lifecycle  when  produced 
from  forestry  residue  and  municipal  solid  bio-waste,  respectively53).  Advanced  biofuels  can  be  produced 
through the approved  and certified  Gasification  +  Fischer Tropsch (Gas+FT) (TRL  6-8)54  and  Alcohol-to-Jet 
(ATJ) (TRL 7-8) pathways. These pathways are generally associated with high production costs (see problem 
driver 2) relative to those of fossil fuels and of HEFA. The production of advanced biofuels is currently only at 
demonstration  phase,  meaning  that  only  a  handful  of  industrial  projects  in  the  EU  are  effectively  able  to 
produce them at this stage. Substantial investments are needed to scale them up to the commercialisation stage.  

RFNBOs55 (i.e. synthetic liquid fuels) have significant potential to decarbonise aviation but face resources 
availability  and  technology  readiness  challenges.  Synthetic  liquid  fuels  (also  called  Power-to-Liquids)  are 
produced through the conversion of renewable electricity (e.g. produced based from wind and solar) into liquid 
hydrocarbons, via the electrolysis of water (TRL 9) to produce green hydrogen followed by a synthesis56 (TRL 
5-6) with CO2 captured directly from air (TRL 6)57, from biogenic origin or from industrial processes. RFNBOs 
have  considerable  potential  for  large-scale  production  and  replacement  of  fossil  jet  fuel.  RFNBOs  can  be 
produced  using  two  different  production routes,  namely  the  Fischer-Tropsch  (FT)  or  the  methanol route (see 
Annex  15).  At  this  stage,  only  the  FT  route  (TRL  9)58  is  approved  and  ASTM-certified  for  blending  with 
conventional kerosene up to 50%. Like the FT route, the methanol pathway relies on process steps already used 
in refineries, but ASTM certification is pending. While RFNBOs offer significant opportunities to decarbonise 
aviation (emissions savings compared to conventional jet fuel can exceed 85%59), their large-scale deployment 
currently face challenges when it comes to the availability of renewable electricity in the EU and CO2 direct air  
capture technology. In addition, in the short-term, RFNBOs are also faced with high production costs compared 
to conventional jet fuel (see problem driver 2).  

Crop  based  biofuels  are  commercially  mature  but  feedstock  availability  is  limited  and  those  biofuels 
raise  important  sustainability  concerns.  Biofuels  produced  from  vegetable  oils  such  as  soybean,  rapeseed, 
palm  oil  or  others  are  a  well-proven  technology  relying  on  the  HEFA  production  route  (TRL  9) and used in 
large amounts in the EU and worldwide notably in the form of hydrogenated vegetable oil for road transport 

50   Advanced biofuels produced from feedstock listed in Annex IX part A of the Renewable Energy Directive. 
51  
52   Narendra Naik Deshavath, Venkata Dasu Veeranki and Vaibhav V. Goud - Sustainable Bioenergy - Chapter 1 - Lignocellulosic feedstocks 

Ibid. 

53  

for the production of bioethanol: availability, structure, and composition – 2019. 
ICAO document - CORSIA Default Life Cycle Emissions Values For CORSIA Eligible Fuels. Emissions savings are determined relative 
to a baseline for fossil jet fuels of 89gCO2e/MJ. 

54   Analysis of current aviation biofuel technical production potential in EU28 – M. Prussi, A. O’Connell, L. Lonza.  
55   According  to  Renewable  Energy  Directive  ‘renewable  liquid  and  gaseous  transport  fuels  of  non-biological  origin’  means  liquid  (or 
gaseous) fuels which are used in the transport sector other than biofuels or biogas, the energy content of which is derived from renewable 
sources other than biomass. For the purpose of aviation, only liquid drop-in synthetic fuels are relevant. 
56   A Reverse-Water-Gas-Shift (RWGS) reaction is required in order to generate Carbon monoxide (CO). 
57   Power-to-Liquids  Potentials  and  Perspectives  for  the  Future  Supply  of  Renewable  Aviation  Fuel  –  German  Environment  Agency  – 

September 2016. 

58   Source: SunFire presentation at VDMA workshop – 22/10/2020. 
59   Clean Skies for Tomorrow: SAF feasibility and sustainability – McKinsey study – September 2020. 

14 

 
                                                           
diesel.  Crop  based  biofuels’  life  cycle  emissions  differs  from  one  type  of  crop  to  another,  but  these  fuels 
generally  deliver  lower  emissions  savings  than  Part  A  and  B  biofuels  or  RFNBOs.  As  crop  based  biofuels 
usually  compete  directly  with  the  food  and  feed  industry  for  the  use  of  farming  land,  sustainable  feedstock 
availability  is  limited,  which  increases  their  life  cycle  emissions.  Finally,  crop  based  biofuels  may  generate 
non-negligible indirect land use change emissions60 (ILUC) as a result of displacing other agricultural crops. 
ILUC  can  reduce  importantly  their  sustainability  potential  or  even  lead  to  an  increase  in  CO2  emissions 
compared to the use of fossil fuel. Under RED II, biofuels produced from high ILUC risk feedstock are capped 
at 2019 level and phased out by 203061. Finally, in the past year, companies producing or using certain types of 
crop-based  biofuels  have  been  subject  to  criticism.  Indeed,  such  biofuels  are  associated  by  the  public  with 
issues such as deforestation and damage to biodiversity, notably in developing countries. Airlines are generally 
discarding the possibility of using crop-based biofuels. 

SAF  technologies  currently  stand  at  different  stages  of  commercial  development  and  face  various 
challenges. Their respective trajectories towards large-scale deployment follow different timelines ranging 
from short- to medium-term. While Part B biofuels could be available in meaningful volumes in the short-term 
(i.e.  before  2025),  it  is  clear  that  their  contribution  will  be  limited  notably  because  of  feedstock  availability 
constraints.  Advanced  biofuels  and  RFNBOs  have  significant  potential  to  increase  the  sustainability  of  the 
aviation sector. However, they currently exist only at demonstration level and still face industrial challenges, 
which means their emergence at commercial scale on the market could be expected towards 2030 if specific 
incentives are in place. Crop-based biofuels are unlikely to play a role in the decarbonisation of aviation.  

There is a broad consensus between fuel producers and airlines that a wide spectrum of production pathways 
and  feedstock  (including  more  innovative,  sustainable  and  cost-effective  pathways)  will  be  necessary  to 
contribute effectively to decarbonising aviation. Several pathways are currently under certification, and more 
should follow in the years to come. However, fuel certification62 is a lengthy and costly process that can be 
a barrier for new small and medium fuel producers. Aviation fuel certification is currently performed by the 
American  Society  for  Testing  and  Materials  (ASTM  –  see  Annex  14).  Given  the  strict  and  technical  safety 
requirements  related  to  the  use  of  fuel  aviation,  SAF  need  to  pass  a  stringent  multi-tier  certification  process 
which spreads over time (3-5 years) and require significant financial investments (between €1 and €5 million). 
The  certification  process  can  prove  highly  resource  consuming  in  particular  for  small  to  medium-size  fuel 
producers aiming to introduce new SAF pathways to the market. Such fuel producers may not always have the 
necessary human and financial resources to dedicate to the process. Significant volumes of fuel are also needed 
for testing purposes, which represent an additional strong constraint.  

55%  of  respondents  to  the  survey63  strongly  agreed  or  agreed  that  the  costs  and  time  needed  for  the  fuel 
certification processes contribute to the limited production and uptake of SAF in the EU.  

2.2.2.

  Problem  Driver  2  -  Scaling  up  SAF  production  means  high-risk  investments  with 

significant uncertainty for producers and investors  

As explained in section 2.1.2, the potential SAF production capacity already installed in the EU amounts to an 
estimated 2.3 million tonnes per year (around 4% of total jet fuel sold at EU airports). However,  EU biofuel 
producers optimise their production setup for other outputs than SAF. The current most important biofuel 
technology  in  terms  of  installed  nominal  production  capacity  in  the  EU  is  the  HEFA/HVO  process.  HEFA 

60   The land use change impact of biofuels consumed in the EU – IIASA, Ecofys, E4Tech – 2015. 
61   Source: https://ec.europa.eu/energy/sites/ener/files/documents/2_en_act_part1_v3.pdf 
62   Fuel certification here refers to the certification of new innovative fuel technologies. It does not refer to the routine certification of jet fuel 

batches for introduction in the fuel system. 

63   Study supporting the ReFuelEU Aviation Impact assessment – Ricardo – 2020 – See stakeholders consultation report. 

15 

 
                                                           
(aviation biofuel) is obtained from HVO (road transport biofuel), thanks to additional process steps64. Biofuel 
production  facilities  operating  with  biomass  feedstock  are  typically  optimized  to  produce  biodiesel  for  road 
transport. When road biofuel is the main desired output, the typical share of SAF could result in the range of 
10-15% of total output. For ATJ and Gas+FT, SAF output can be respectively 25% and 20%65. Maximising the 
SAF output is possible, but tends to reduce the refinery output destined to road transport. The choice of biofuel 
producers  to  favour  road  transport  biofuels  to  the  detriment  of  SAF  is  driven  by  a  higher  return  on 
investment  and  regulatory  obligations.  Indeed,  the  road  transport  biofuel  market  is  well  established  and 
supported by a robust regulatory framework at European and Member States level, which secures a continuous 
demand (see problem driver 3). This is not yet the case for the SAF market, which is in its very infancy and 
where  no  regulatory  obligations  exist  on  SAF  supply  or  demand.  If  HEFA/HVO  plants  would  adjust  their 
production mix to include the SAF production, up to 55% to 60% of the total refinery output could be directed 
to air transport. Similarly, for the other production pathways, maximum yields for SAF could vary from to 32% 
for FT route66, 60% for Gas+FT route67 and 77%68 to 85% for the Alcohol-To-Jet route, while for RFNBOs it 
could be around 60%69. 

While a reasonable share of SAF could come in the short term from the production capacity already installed in 
the EU, this will be far from sufficient for SAF to contribute to the decarbonisation of aviation in line with the 
EU’s climate targets by 2030 and 2050. A major scale-up of the SAF production capacity and a shift towards 
advanced biofuels and RFNBOs is necessary in the years to come. However, building and operating new SAF 
production facilities means high-risk and costly upfront investment expenditures. It is especially the case 
for  SAF  production  routes  that  rely  on  innovative  conversion  technologies  like  advanced  biofuels  and 
RFNBOs. These incur high upfront investment expenditures (CAPEX) as they require e.g. gasification units 
(Gas+FT route), pre-treatment, hydrolysis and fermentation units (ATJ route). Setting up first-of-a-kind SAF 
production  plants  is  costly  and  risky  in  a  context  where  there  is  high  uncertainty  of  policy  framework  and 
demand  from  airlines  (see  problem  driver  3).  Furthermore,  large-scale  investments  in  energy  production 
generally  have  a  long  amortisation  period,  i.e.  around  15  years,  which  adds  to  the  investment  risks  and 
expectations of higher returns for investors, further increasing investment costs.  

The  high  SAF  production  costs  are  also  driven  by  high  operational  expenditure  (OPEX)  for  certain 
production  routes.  For  installations  producing  through  the  HEFA  route,  costs  are  driven  for  80-90%  of  their 
share by the cost of feedstock, as e.g. used cooking oil is expensive. The costs to produce RFNBOs are driven 
by the costs of additional renewable electricity as well as the cost of CO2-capture and purification. A smaller 
part of the costs can be attributed to the synthetic fuel production (FT or methanol route). The costs to produce 
advanced biofuels via Gas+FT and ATJ routes are primarily driven by the upfront investment expenditures for 
conversion  facilities,  but  feedstock  cost  (municipal  solid  waste,  agricultural  residues,  etc.)  is  expected  to 
represent  an  important  driver  in  the  transition  towards  a  climate  neutral  economy  due  to  the  increased 
competition  over  feedstock  with  other  energy  and  transport  sectors.  Finally,  because  advanced  biofuels  or 
RFNBOs  are  novel  or  emerging  fuel  technologies,  the  CAPEX  costs  for  conversion  facilities  are  estimated 
rather than based on existing facility data. This adds a layer of uncertainty and risk. 

85% of respondents to the survey70 strongly agreed or agreed that high upfront capital costs and operational 
costs for novel conversion processes are a challenge for SAF production. Similarly, 74% of the respondents 
to the OPC were of the view that excessive production costs for SAF is one of the most important barriers 

64   These additional process steps include fractionation and isomerization. 
65   Clean Skies for Tomorrow: SAF feasibility and sustainability – McKinsey study – September 2020. 
66   Analysis of current aviation biofuel technical production potential in EU28 – M. Prussi, A. O’Connell, L. Lonza. 
67   Clean Skies for Tomorrow: SAF feasibility and sustainability – McKinsey study – September 2020. 
68  
69  
70   Study supporting the ReFuelEU Aviation Impact assessment – Ricardo – 2020 – See stakeholders consultation report. 

Ibid. 
Ibid. 

16 

 
                                                           
which hinders an extensive use of SAF.  

It  is  difficult  to  put  a  precise  figure  on  SAF  production  costs  because  these  are  partially  based  on  past 
experience,  partially  estimated,  and  expected  to  evolve  over  the  coming  years  and  decades  to  come,  as 
production volumes increase. Economies of scale, ‘learning curve’ and lower renewable electricity prices 
are expected to bring SAF production costs down gradually by 2050. Large scale production volumes lead 
to decreasing CAPEX of novel technology applications. For example, electrolysers (used to produce RFNBOs) 
are  currently  tailor-made  and  the  production  process  is  not  yet  automated.  Yet,  the  technology  is  ready  for 
industrial  scale-up.  Furthermore,  the  efficiency  and  productivity  of  plants  is  expected  to  increase  over  time 
thanks  to  the  learning  curve.  OPEX  are  also  expected  to  evolve  as  the  price  of  resources,  in  particular  the 
levelled cost of renewable electricity at global level could go down by 40% to 70% by 205071. On the other 
hand, the cost of feedstock for advanced biofuels is expected to go up over time in view of the competition 
with other energy and transport sectors. The estimated current production costs of various production routes 
are represented in the Table 1, and compared with the production costs of convention fossil jet fuel. Annex 16 
provides detailed information on the economies of scale, as well as the cost structure of SAF production per 
pathway, and explains the key differences between Part A and Part B biofuel production costs.  

Table 1 - Current SAF price ranges from literature and industry consultation. 

Production route 

Estimated production 
cost72 in 2020 (k€/tonne) 

Fossil jet 
fuel 

HEFA 

Gas+FT 

ATJ 

RFNBOs 

0.6 

0.95-1.14 

1.7-2.5 

1.9-3.9 

1.8-3.5 

2.2.3.

 Problem Driver 3 - There is a SAF market failure that policies have not yet enabled to 
address successfully  

The  important  price  differential  between  SAF  and  conventional  jet  fuel  explains  the  low  demand  for 
SAF. While conventional jet fuel prices vary around 0.5€/litre73, the minimum market price of SAF is estimated 
to be 1.5 to 6 times more expensive, depending on the type of SAF considered. The very low price of fossil jet 
fuel can be explained by several reasons. Indeed, fossil jet fuels are available in significant quantities around 
the world, there are many producers and suppliers in competition with each other at global and regional scale, 
their supply chain infrastructures are well established, demand from the aviation sector has increased steadily 
over the past decades, and they are subject to tax exemptions at various levels. While the important price gap 
between  SAF  and  conventional jet fuel  is  explained  by  higher  SAF  production  costs  and  tax  exemptions  for 
conventional jet fuel (see problem driver  2), it is also to some extent a consequence of the fact that prices in 
aviation (of which jet fuel represent a non-negligible part of airlines’ expenses, i.e. 17% to 25%) do not fully 
internalise the environmental cost of the sector74. 

96% of respondents to the survey75 agreed that high market prices of SAF compared to conventional jet fuel 
represent a challenge for SAF production and uptake. Similarly, 84% of the respondents to the OPC were of 
the view the price of conventional jet fuel as one of the most important barriers preventing uptake of SAF.  

The  existing  fiscal  and  regulatory  framework  contribute  to  maintaining  fossil  jet  fuels’  low  market 
prices.  Indeed,  while  aviation  is  subject  to  several  types  of  taxes  (VAT,  ticket  taxes)76,  jet  fuel  is  generally 

71   Clean Skies for Tomorrow: SAF feasibility and sustainability – McKinsey study – September 2020. 
72   Based on rough estimates sources from Clean Skies for Tomorrow: SAF feasibility and sustainability – McKinsey study – September 2020. 

Values have been converted from USD/tonne to EUR/tonne at an exchange rate of 1USD for 0.85EUR. 

73   Source: ICCT – The cost of supporting alternative jet fuels in the EU – March 2019. 
74   Source: https://op.europa.eu/en/publication-detail/-/publication/0efedf2c-a386-11e9-9d01-01aa75ed71a1.  
75   Study supporting the ReFuelEU Aviation Impact assessment – Ricardo – 2020 – See stakeholders consultation report. 
76   Taxes in the Field of Aviation and their impact – CE Delft – June 2019. 

17 

 
 
                                                           
exempt from excise duty in international aviation. The ICAO Chicago Convention77 requires tax exemption of 
fuel on-board when landing, whereas fuel delivered to aircraft is exempted through most existing air services 
agreements between States78. At EU level, the Energy Taxation Directive79 contains a mandatory tax exemption 
for fuel used in air navigation80, contrary to rail and road transport. It however permits Member States to tax jet 
fuel on domestic flights81 or flights between Member States based on bilateral agreements. Price gaps between 
fossil fuels and biofuels do not exist to the same extent in other transport modes.  

Low prices of fossil jet fuel and strong competition in the aviation market explain the negligible actual 
demand for  SAF.  Airlines  operate  in  an  environment  of  strong  competition,  i.e.  in  the  EU  aviation  internal 
market and on international routes where they also compete with non-EU airlines82. The strong competition in 
the aviation market means that airlines’ net profit margins are overall tight. The price difference between SAF 
and conventional jet fuel means that using SAF would represent additional fuel expenses for airlines, since fuel 
costs account for between 17% and 25% of airlines operating expenses83. In this context of strong competition 
and the current regulatory framework, absorbing the SAF cost premium or passing it on to passengers may not 
be a viable strategy, in particular if competing airlines do not use SAF.  

Practices such as ‘fuel tankering’ occur when aircraft operators, for economic reasons, uplift more aviation fuel 
than necessary at a given airport, with the aim to avoid refuelling partially or fully at a destination airport where 
aviation fuel is more expensive. When performed for economic reasons, i.e. in 90% of cases, fuel tankering 
undermines  fair  competition  in  the  air  transport  market,  as  certain  aircraft  operators  are  able  to  use 
favourable aviation fuel prices at their home base, as a competitive advantage towards other airlines operating 
similar  routes.  This  affects  the  competitiveness  of  some  aircraft  operators  and  can  also  reduce  the 
attractiveness of certain airports. 

84%  of  respondents  to  the  survey84  agreed  that  competitive  air  services  with  low  profit  margins  reduce  the 
willingness of airlines to pay a premium for fuel.  

There is a strong ongoing interdependency between the demand and supply sides of the SAF market, i.e. 
the lingering “chicken-or-egg” issue. The absence of effective demand for SAF is explained by the high SAF 
market prices relative to low fossil jet fuel prices. In turn, this absence of effective demand means that biofuel 
producers on the supply side of the market do not produce SAF. This causes SAF production costs to remain 
high  (absence  of  economies  of  scale  and  learning  curve  –  see  problem  driver  2)  and  SAF  to  remain 
economically not attractive on the market compared to fossil jet fuel. This situation has been ongoing for more 
than a decade, i.e. since the first certification of SAF and the first demonstration flights in the late 2000’s. 

EU  policies  on  renewable  energy  for  transport  have  so  far  proved  insufficient  to  boost  the  production  and 
uptake  of  SAF.  Indeed,  the  regulatory framework of  the  past  decade focused  predominantly  on  driving 
renewable energy to road and rail transport. While this can be justified by the fact that road is by far the 
largest energy consumer of all transport modes (72.2% of the total in 201885), it means that incentives to supply 

77   Source: https://www.icao.int/publications/pages/doc7300.aspx 
78   Nevertheless,  most  EU  comprehensive  aviation  agreements,  as  well  as  many  Member  States’  bilateral  agreements  (as  modified  by  EU 
horizontal  agreements)  signed  with  third  countries  secure  the  right  of  the  Member  States  to  tax  aviation  fuel  for  domestic  or  intra-EU 
flights in line with Council Directive 2003/96/EC. 

79   OJ L 283, 31.10.2003, p. 51-70. 
80   Air navigation other than private pleasure air transport. The objective of introducing such a mandatory exemption was to respect existing 

international obligations, while safeguarding the competitiveness of European industry vis-à-vis third countries.   
81   As of September 2020, the Netherlands is currently the only Member State that levies taxes on fuel for domestic flights. 
82   Non-EU airlines might have access to more advantageous fuel prices at the home hubs, compared to EU airlines. 
83   EUROCONTROL - Aviation Intelligence Unit – Think Paper #1 – June 2019. 
84   Study supporting the ReFuelEU Aviation Impact assessment – Ricardo – 2020 – See stakeholders consultation report. 
85   EC Transport in figures – statistical pocketbook 2020.  

18 

 
 
                                                           
renewable  energy  to  aviation86  were  very  limited.  As  explained  below,  the  Fuels  Quality  Directive  and  the 
Renewable Energy Directive have contributed to the positive effects of reducing the CO2 emissions from road 
transport,  and  of  increasing  the  share  of  biofuels  in  transport  from  3.4%  to  8.3%  between  2007  and  201887. 
However, due to the absence of specific incentives, EU policies on renewable energy in transport have not 
led to a reduction of CO2 emissions in aviation.  

The original 2009 Renewable Energy Directive88 (RED I) set a mandatory target for the transport sector to 
be  supplied  with  10%  of  renewable  energy  including  transport  biofuels  by  2020.  It  contained  no  specific 
target  for  the  air  transport  sector.  The  2018  recast  Renewable  Energy  Directive89  (RED  II)90  revised  the 
mandatory target for transport to 14% by 2030. There is no specific mandatory target for the air transport 
sector,  but  RED  II  allows91  Member  States  to  account  for  biofuels  supplied  to  the  aviation  sectors  towards 
meeting the renewable energy target92. In addition, biofuels directed to the aviation sector can benefit from a 
multiplier of 1.2, meaning that such biofuels can account towards the renewable energy target for 20% more of 
their energy content. A multiplier of 1.2 for aviation represents however a very limited incentive in comparison 
with the multiplier of 4 encouraging the use of renewable electricity in the road and rail sector.  

The  amendment  to  the  Fuels  Quality  Directive93  (FQD)  adopted  in  2009  establishes  that  fuels  used  for  road 
transport  in  the  EU  must  meet  strict  quality  requirements  and  contains  a  mandatory  target  requiring  a 
reduction of 6% of road fuels greenhouse gas intensity by 2020. This was a strong regulatory push to drive 
renewable  energy  towards  the  road  sector,  as  the  target  could  be  met  notably94  with  the  use  of  biofuels  and 
RFNBOs.  Aviation  fuels  were  not  subject  to  a  target  as  they  were  not  covered  by  the  scope  of  FQD. 
Similarly to RED I, the FQD also included the ‘opt-in’ clause since 2019. 

Aviation CO2 emissions have been covered by the EU Emissions Trading System (EU ETS) since 2012. The 
EU  ETS95  includes  incentives  for  airlines  to  use  SAF  by  allowing  them  to  benefit  from  a  “zero  emissions-
rating” if they use SAF96. In practice, this means that airlines are not required to surrender any allowances for 
CO2  emissions  where fossil jet  fuel  is replaced  with  SAF.  This  mechanism  may  provide  a  true  incentive for 
airlines to use SAF if the savings from having to buy fewer allowances, or being able to sell more allowances, 
would match the additional cost of using SAF, compared to the cost of fossil fuels. However, the EU ETS on 
its  own  has  not  been  sufficient  to  boost  SAF  uptake  by  airlines.  Since  2012  the  price  of  CO2  emission 
allowances in the EU ETS has oscillated from around  EUR 4 to over 40 per tonne of CO2. Provided that the 
price  of  SAF  would  be  EUR  1  per  litre,  and  that  the  EU  ETS  would  constitute  the  only  financial  incentive 
towards the use of SAF, the price of CO2 emission allowances should be at least EUR 160 to incentivize the use 
of SAF by airlines97. Hence, only Germany and Sweden reported the use of SAF under the EU ETS in 2016 and 
201798. 

At  global  level,  the  regulatory  framework  relating  to  SAF  consists  mainly  of  the  dedicated  mechanism 
contained  in  the  Carbon  Offsetting  and  Reduction  Scheme  for  International  Aviation99  (CORSIA)  under  the 
International Civil Aviation Organization (ICAO). The scheme, which pilot phase starts in January 2021, aims 

86   Aviation accounted for 12.7% of the transport sector’s energy demand in 2018. Same source as above. 
87   EUROCONTROL - Aviation Intelligence Unit – Think Paper #1 – June 2019. 
88   OJ L 140, 5.6.2009, p. 16-62. 
89   OJ L 328, 21.12.2018, p. 82-209. 
90   While RED II entered into force in 2018, EU Member States have until June 2021 to transpose it into national legislation. 
91   The inclusion of this provision followed the introduction of an opt-in for aviation in Directive (EU) 2015/1513. 
92   This possibility is known as the aviation “opt-in”. 
93   OJ L 140, 5.6.2009, p. 88-113. 
94   Other  types  of  renewable  energy  can  be  used  to  decrease  the  greenhouse  gas  intensity  of  road  fuels,  notably  electricity  and  less  carbon 

intense fossil fuels. 

95   Source: https://ec.europa.eu/clima/policies/transport/aviation_en 
96   This is conditional on their compliance with the sustainability framework of the RED. 
97   Study on biofuel for aviation for the Swedish Government, SOU 2019:11. 
98   Source: https://op.europa.eu/en/publication-detail/-/publication/fc2b7891-704d-11e8-9483-01aa75ed71a1/language-en 
99   Source: https://www.icao.int/environmental-protection/CORSIA/Pages/default.aspx 

19 

 
                                                           
to  cap  CO2  emissions  from  international  air  transport  by  requiring  airlines  to  offset  emissions  beyond  2019 
levels. Instead of purchasing emissions offsets, aeroplane operators can choose to use SAF that comply with a 
dedicated  strict  sustainability  framework.  In  a  similar  way  as  for  the  EU  ETS,  in  the  short-term,  given  the 
current conditions of the carbon market,  it is likely that CORSIA on its own will not provide a sufficient 
economic incentive for airlines to use SAF, as the market price of carbon offsets is expected to be lower than 
the additional market price of SAF. Further work is ongoing at ICAO level to define the possible contribution 
of  SAF  (among  other  types  of  fuels100)  in  international  aviation.  In  2017,  the  Conference  on  Aviation  and 
Alternative Fuels (CAAF/2) adopted recommendations and approved a declaration101, calling for a significant 
proportion of aviation fuels to be substituted with sustainable aviation fuels by 2050. In 2019, the 40th ICAO 
General Assembly adopted a Resolution102 calling on the ICAO Council to explore the feasibility of a long-term 
global  aspirational  goal  for  international  aviation  (LTAG).  SAF  are  identified  as  a  building  block  in  this 
exercise.  The  same  Resolution  calls  for  ICAO  States  to  “consider  the  use  of  incentives  to  encourage  the 
deployment of clean and renewable energies sources for aviation, including SAF”. Policy work at global level 
to  support  SAF  deployment  in  aviation  is  advancing,  but  progress  is  slow.  Discussions  on  lower  carbon 
aviation fuels under CORSIA are diverting the attention from SAF, which effectively can achieve much higher 
emissions savings. 

Finally, the treatment and eligibility of SAF under CORSIA and RED II differs today in several ways, notably 
in  terms  of  sustainability  framework,  accounting  system  and  reporting.  This  adds  a  layer  of  complexity  and 
uncertainty for producers and investors. 

84% of respondents to the survey103 agreed that lack of clear policy signals and limited impact of existing 
legal framework contribute to the challenges for SAF production and uptake. 

2.3.  How the problem will evolve 

SAF  are  expected  to  continue  facing  unequal  commercial  development  and  important  industrial 
challenges (problem driver 1). In the years to come, the potential production capacity for Part B biofuel might 
increase  slightly,  albeit  at  a  very  slow  pace104.  This  is  because  Part  B  biofuels  are  the  most  commercially 
mature and the least costly to produce. However, feedstock availability constraints will continue to be a barrier 
to more significant use of Part B biofuels in aviation.  In addition, they provide the least benefits in terms of 
emissions reductions.  

Regarding  advanced  biofuels  for  air  transport,  only  very  few  demonstration  sites  are  expected  to  scale-up  to 
commercial  production  without further  EU  level  intervention.  RFNBOs  capacity  productions  for  aviation  are 
also  projected  to  make  no  significant  inroads  without  additional  EU  level  intervention.  In  the  absence  of 
regulatory and financial support, this will be insufficient for these technologies to benefit from the necessary 
economies of scale and learning curve that widespread scale-up would deliver. In addition, feedstock prices for 
biofuels are expected to increase over time, due to the competition with other energy and transport sectors in 
the  transition  towards  a  climate  neutral  economy.  The  industrial  challenges  faced  by  advanced  biofuels  and 
RFNBOs  in  air  transport  are  thus  expected  to  remain  in  the  medium-  to  long-term.  While  new  production 
pathways will become certified, these new technologies will have very low market maturity and will need to be 
demonstrated at small scale. Finally, it is possible that the certification process could become lighter for fuel 

100   “Lower carbon aviation fuels” are crude oil based jet fuels that are slightly less greenhouse gas intensive than conventional jet fuel. The 
small emissions savings are achieved by implementing certain practices at extraction sites or oil refineries, such as avoided flaring/venting 
or use of renewable energy in the supply chain. 

101   Source:  “2050  ICAO  Vision  for  Sustainable  Aviation  Fuels”  -  https://www.icao.int/environmental-protection/GFAAF/Pages/ICAO-

Vision.aspx 

102   ICAO Assembly Resolution A40-18. 
103   Study supporting the ReFuelEU Aviation Impact assessment – Ricardo – 2020 – See stakeholders consultation report. 
104   As it can be projected based on the latest projects and partnerships between biofuel producers and airlines. 

20 

 
                                                           
producers in the future, as the ASTM may set up a ‘Fast Track’ certification. This would speed up the process 
to  some  extent,  but  it  is  not  clear  whether  it  would  make  it  less  resource-intensive  in  particular  for  small 
producers. 

Upfront  capital  costs  investment  are  expected  to  remain  high,  as  well  as  the  level  of  risk  for  investors 
(problem driver 2). Investors and biofuel producers are expected to take a low-risk approach when investing 
in  new  production  capacity,  i.e.  by  ensuring  that  the  plants  are  versatile  enough  to  be  optimised  for  other 
outputs than SAF e.g. road biofuel or chemical industry, where demand is expected to remain relatively stable 
in  the  years  to  come.  Concerning  investments  in  plants  to  produce  advanced  biofuels  for  air  transport,  it  is 
likely that the situation will remain unchanged105, meaning that very few demonstration projects will be scaled 
up to commercial size, and levels of investments will continue to be very low. This is even more the  case for 
RFNBOs whereas the capital costs are higher than those for advanced biofuels. As a result, production cost of 
SAF will continue to be substantially higher than that of fossil jet fuel and upfront investments in production 
capacity will continue to represent high risk for investors, in particular early movers. Finally, whether biofuel 
producers  will  durably  optimise  their  installations  to  produce  SAF  on  a  regular  basis  will  depend  on  the 
emergence of a stable, long-term demand on the side of airlines. This is unlikely to happen without further EU 
level intervention, as explained in the following paragraph. 

The existing regulatory framework is not expected to drive biofuels or RFNBOs towards use in aviation 
(problem driver 3). The SAF market prices are expected to remain substantially higher than those of fossil jet 
fuel under current trends and policies, with oil prices projected at 72 €/bbl by 2030 and 106 €/bbl by 2050.106 In 
addition, fossil jet fuels are subject to highly volatile prices, linked to the evolution to the oil prices that react to 
an  array  of  factors  far  beyond  the  dynamics  of  the  aviation  market.  Furthermore,  it  is  not  clear  whether  the 
airlines  will  be  subject  to  less  intense  competition  in  the  future  and  achieve  higher  profits  allowing  them  to 
invest sufficiently in sustainable fuels. The higher SAF market prices relative to that of fossil jet fuel and the 
high level of uncertainty surrounding the two factors mentioned above will continue deterring biofuel producers 
and  investors  from  further  deploying  or  investing  in  SAF.  The  chicken-or-egg  situation  is  thus  likely  to 
continue. This problem is unlikely to be solved if the current regulatory framework is maintained.  Indeed, for 
the EU ETS to make uptake of SAFs economically interesting, a price of CO2 emission allowances of at least 
€160 would be necessary, which is unlikely in the short- or medium-term. Similarly, without further EU level 
intervention, the RED II and the FQD are expected to continue driving the vast majority of transport biofuels 
towards the road sector. The current option given to Member States under the RED II to account for biofuels 
supplied to  the  aviation  sectors  is expected  to  lead  to  different rules  and incentives  introduced  by  individual 
Member States with very few of them taking the advantage of the opt-in. 

Given the elements explained above, problems of (A) low production and (B) low demand are expected to 
remain present in the medium to long term in the absence of further regulatory action. They will continue 
to be strongly driven by problem drivers 1 to 3. The projected baseline uptake of SAF is limited to 0.1 Mtoe in 
2030,  increasing  gradually  to  1.5 Mtoe  in  2050,  which  would account for  0.2%  of total fuel  consumption  in 
aviation by 2030 and 2.9% by 2050. In turn, the persistence of Problems 1 and 2 is expected to aggravate 
the general problem. Air traffic is projected to increase by close to 45% by 2030 and close to 90% by 2050, 
relative to 2015, following the recovery from the COVID-19 pandemic. CO2 emissions would increase by 17% 
by  2030  and  slightly  over  20%  by  2050,  relative  to  2015,  despite  the  significant  improvements  in  energy 
efficiency. Annex 4 provides more explanations on the baseline scenario, reflecting the impacts of the COVID-
19 pandemic. While other sectors of the economy and other transport modes will likely continue reducing their 
carbon footprint, the aviation sector would remain one of the few sectors where emissions keep rising. In this 
context,  the  public  and  political  pressure  on  aviation  would  continue  to  build,  with  important  risk  of 

105   In the current context driven by the COVID-19 crisis, the scarcity of investments could be accentuated. 
106   Please see Annex 4 for more explanations on the baseline scenario.  

21 

 
                                                           
reputational  damage  for  the  sector.  Potentially,  this  could  also  threaten  jobs  in  the  air  transport  industry, 
connectivity, as well as growth of businesses and regions. 

The revision of the Renewable Energy Directive, part of the ‘Fit for 55’ package is expected to help scaling up 
the production of advanced biofuels and RFNBOs. It will however not enable setting specific requirements on 
airlines  and  aviation  fuel  suppliers  in  a  harmonised way  across  the  EU.  This  is  expected  to  lead  to  different 
rules and incentives introduced by individual Member States. It may also lead to uncertainty for the fuel and 
airline industry if Member States obligations support different types of SAF with differing fuels eligibility and 
sustainability  requirements.  As  a  result,  this  would  likely  still  divert  the  advanced  biofuels  and  RFNBOs 
towards the road transport sector instead of air transport. On the other hand, the present initiative can support 
the review of the Renewable Energy Directive by reinforcing the delivery of renewable energy in the transport 
sector, including in the air transport sector. The revision of the Energy Taxation Directive, part of the ‘Fit for 
55’ package, will revisit the tax exemptions for conventional jet fuel. This would however not allow to address 
problem drivers 1 and 2 of the present initiative (SAF face industrial challenges; scale-up of SAF production 
means  high  risk  investments),  because  is  unlikely  to  provide,  on  its  own,  a  sufficient  incentive  for  the  fuel 
industry and airlines to make the necessary investments in SAF production and uptake. Finally, as explained 
above, for the EU ETS to make SAF economically interesting for airlines, a price of CO2 emission allowances 
of at least €160 would be necessary. By comparison, the impact assessment107 accompanying the 2030 Climate 
Target Plan projects carbon prices for the ETS sector in the range of 32 to 65 €/tCO2, to cut the economy-wide 
GHG emissions by at least 55% by 2030. The EU ETS is therefore unlikely, by itself, to drive SAF uptake in 
aviation in the medium-term. 

3.  WHY SHOULD THE EU ACT? 

3.1. 

Legal basis 

The  Treaty  on  the  Functioning  of  the  European  Union  confers  to  the  EU  the  competence  to  lay  down 
appropriate provisions in the air transport sector (Article 100(2)). Transport is a shared competence between the 
European Union and the EU Member States. 

This  initiative  is  fundamentally  about  air  transport,  maintaining  high  levels  of  connectivity,  competition  and 
industry competitiveness level in the aviation internal market while stepping up its sustainability. Sustainability 
is an inherent trait of transport, as safety and security are. The legal text will include detailed aviation-specific 
provisions to cater for the complexities of the sector. 

3.2. 

Subsidiarity: Necessity of EU action 

Air  transport,  climate  and  renewable  energy  are  matters  of  high  EU  relevance.  Aviation  is  a  highly 
integrated market operating in a network dimension across the whole of the EU. The cross-border dimension is 
inherent to air transport, which makes any fragmented regulatory framework a significant hurdle for economic 
operators. The CO2 emissions from aviation are also of transboundary nature and as such cannot be addressed at 
national or local level only. Therefore efforts to reduce CO2 emissions of the air transport sector and to promote 
its use of renewable energy sources should be addressed at EU level. Market players should benefit from clear 
climate and energy rules applying in a harmonised way across the EU.  

An intervention at EU level is necessary, as the scaling up SAFs can contribute to reducing air transport 
emissions  and  is  in  line  with  the  EU’s  climate  objectives.  The  Commission’s  2030  Climate  Target  Plan 
identifies  an  increase  in  the  use  of  SAF  as  one  of  the  important  contributors  to  the  goal  of  reducing  GHG 
emissions by 55% by 2030 and achieving a climate-neutral economy by 2050.  

107   SWD(2020) 176 final. 

22 

 
                                                           
An  EU-level  intervention  is  necessary  to  avoid  a  patchwork  of  national  measures  with  possible 
unintended  effects.  National  initiatives  to  incentivise  the  supply  and  use  of  SAF  in  the  Netherlands  (by  an 
aviation opt-in to the RED II targets) and Nordic States (with the emergence of national blending mandates) are 
expected to have only limited effects on the use of SAF at EU level. Such national initiatives risk creating a 
patchwork of different obligations for the aviation and fuel supply industry. Different levels of obligations per 
Member  State  could  potentially  distort  the  aviation  market  encouraging  adverse  practices  such  as  fuel 
tankering108, whereby airlines would refuel in Member States with less strict obligations in order to save on fuel 
costs.  National  frameworks  could  lead  to  unintended  negative  impacts  by  inducing  inefficiencies  in  air 
navigation (longer flight trajectories, higher volumes of fuel lifted) that could lead to a fragmented regulatory 
framework, inducing higher compliance costs for economic operators.   It may also lead to uncertainty for the 
fuel  and  airline  industry  if  Member  States  obligations  support  different  types  of  SAF  with  differing 
sustainability requirements. Finally, it could lead to higher fuel burn and GHG emissions.  

EU-level  regulatory  action  on  SAF  is  widely  supported  by  consulted  Member  States  and  industry 
stakeholders.  

68% of respondents to the ReFuelEU Aviation open public consultation considered that regulatory action on 
SAF was best suited at EU level. 

Stakeholders consulted109 from across the EU agree that the supply and uptake of SAF will remain relatively 
low  across  the  EU  and  the  price  gap  with  conventional  jet  fuel  will  persist  in  the  absence  of  an  EU-wide 
approach to incentivise the production and use of SAF.  

3.3. 

Subsidiarity: Added value of EU action 

EU-level action is expected to set a clear policy direction for the market players from both the aviation 
and  fuels  industries.  As  explained  in  section  2,  a  part  of  the  problem  is  due  to  the  absence  of  specific 
incentives  to  reduce  aviation  CO2  emissions  in  the  EU  policy  framework.  This  was  confirmed  by  the  desk 
research  and  stakeholders’  consultation110.  One  clear  set  of  EU  rules  on  the  supply  and  uptake  of  SAF  will 
mean that SAF producers and airlines can operate based on equal opportunities across the EU, creating level 
playing field for airlines to compete. It will give clear signals on the need to develop specific types of SAF. A 
single set of rules also means reduced compliance costs for market players. 

EU-level action on SAF would contribute to achieving the desired climate change policy targets. The 2030 
Climate Target Plan establishes that SAF have a major role to play to reduce emissions from aviation by 2030 
and  2050  and  attain  EU  climate  goals.  Therefore,  establishing  EU  rules  on  SAF  production  and  use  allows 
taking  a  “tailored”  approach  towards  meeting  the  targets.  Relying  on  national  measures  only  with  likely 
different targets (if any) would incur the risk that the aggregated level of ambition is not sufficient. The current 
initiative can also support the forthcoming review of the Renewable Energy Directive by reinforcing the share 
of renewable energy in the transport sector. 

EU-level action may have positive effects at international level. As EU intervention would have effects on 
the entire aviation and SAF EU market, it is expected to have higher prominence towards third countries than 
isolated national initiatives. Spill-over effects are also likely to occur more easily, whereby third countries may 
consider adopting similar measures. In turn, this could accelerate the ongoing work at ICAO level on the use of 
SAF. In short, EU action could spur further developments on the production and uptake of SAF outside of the 

108   Fuel tankering is a practice whereby an airline refuels with an excessive amount of jet fuel at a given airport, causing the flight to carry 
more  fuel  than  necessary  and  leading  to  excessing,  avoidable  emissions  from  additional  fuel  burn  due  to  excessive  weight  on  board. 
https://www.eurocontrol.int/publication/fuel-tankering-european-skies-economic-benefits-and-environmental-impact 
109   Study supporting the ReFuelEU Aviation Impact assessment – Ricardo – 2020 – See stakeholders consultation report. 
110   Ibid. 

23 

 
                                                           
EU, which could help create a level playing field at global level, as well as reduce air transport emissions at a 
wider scope. 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1.  General objectives 

The air transport sector needs to maintain a level playing field and accelerate its decarbonisation urgently in the 
years  to  come  in  order  to  be  in  line  with  the  Union’s  climate  targets  for  2030  and  the  Union’s  ambition  to 
become carbon neutral by 2050. As explained in section 1.3, while considering a combination of carbon pricing 
and  medium  intensification  of  regulatory  measures  in  all  sectors  of  the  economy,  the  common  economic 
assessment  underpinning  the  2030  Climate  Target  Plan  and  the  Sustainable  and  Smart  Mobility  Strategy 
identifies the trajectory of SAF ramp up from 2025 to 2050 in order to bring aviation in line with the climate 
ambition of the Union. The general objective of this initiative is to reduce aviation CO2 emissions in line with 
the 2030 and 2050 climate objectives of the EU, by transitioning away from fossil jet fuel and tap into the 
high  decarbonisation  potential  of  sustainable  aviation  fuels  by  establishing  a  competitive  SAF  market, 
while at the same time ensuring a level playing field on the aviation market.   

Strengthening ongoing efforts at EU and global level only will not be sufficient if the aviation sector remains 
entirely dependent on fossil jet fuel. The decarbonisation of aviation can only be achieved if the EU deploys a 
clear  and  comprehensive  aviation  fuels  policy.  In  the  aviation  fuels  landscape,  there  are  very  promising 
alternatives  to  fossil  jet  fuel:  (i)  liquid  sustainable  aviation  fuels  (advanced  biofuels  and  RFNBOs),  (ii) 
hydrogen fuel cells, and (iii) electric batteries. It is clear that the decarbonisation of aviation will come from 
a combination of these alternatives. However, these will become available at different points in time. While 
liquid sustainable aviation fuels should be commercialised as early as 2022, with potential for significant scale-
up as of 2025, electric aircraft and hydrogen-powered aircraft could play a role in commercial aviation in the 
long-term. This requires targeted action on each of these initiatives to ensure that they can be delivered in 
time. ReFuelEU Aviation therefore specifically targets the drop-in liquid sustainable aviation fuels.  

In addition it should be noted that this initiative does not target GHG emissions as a whole but targets CO2 
emissions and some of the non-CO2 emissions from aviation. It should lead to  simultaneous reductions of 
CO2  emissions,  of  non-volatile  particulate  matter  and  sulphur  emissions.  However  due  to  the  remaining 
scientific knowledge gaps on the impact of the non-CO2 emissions from aviation, these will be analysed only 
qualitatively in this report (see section 6.1.4 and Annex 13). 

The initiative will contribute to the achievement of the general objective by pursuing the following two specific 
objectives. 

4.1.1.

  SO1:  To  achieve  large-scale  production  and  supply  of  SAF  in  the  EU  with  high 

decarbonisation potential, at competitive costs 

Specific objective 1 is to achieve the large-scale production in the EU of sustainable aviation fuels  with 
high  decarbonisation  potential,  and  to  ensure  adequate  levels  of  supply  to  the  aviation  sector  at  competitive 
costs. In concrete terms, taking an industrial policy perspective, this means that the aim is to develop the SAF 
production  capacities  on  several  fronts.  First,  the  objective  is  to  support  the  use  of  the  existing  SAF 
production capacity in order to increase significantly the SAF output. As explained under problem 1, there is 
an important SAF production capacity already installed and potentially available in the EU, but it is currently 
not used for SAF production due to the reasons outlined previously (see section 2.2). Second, the objective is to 
boost  the  development  of  new  additional  production  facilities  in  the  EU  for  SAF  with  the  highest 

24 

 
decarbonisation potential, i.e. advanced biofuels for aviation and RFNBOs.111 Third, the objective is to lead 
to  the  emergence  on  the  market  of  new,  sustainable  and  more  cost-effective  SAF  pathways,  taking  a 
technology-neutral  approach.  New  pathways,  using  innovative  technologies  and  sustainable  low-cost 
feedstock can broaden the spectrum of available SAF and unleash the potential for higher emission savings. A 
technology-neutral approach in the regulatory framework can ensure that a wide spectrum of innovative fuels 
technologies  can  reach  the  market,  and  can  contribute  to  the  aviation  fuel  mix  in  the  future.  Fourth,  the 
objective  is  to  reduce  SAF  production  costs  relative  to  the  current  levels.  Due  to  economies  of  scale, 
learning  effects,  and  the  technology  maturity  over  time,  production  sites  will  be  able  to  reduce  their  capital 
costs gradually. This will be counterbalanced to some extent by an increase in the feedstock costs, given the 
competition  over  feedstock  with  other  energy  and  transport  sectors.  This  will  allow  nevertheless  SAF  to  be 
available on the market at lower prices than estimated currently (see Specific Objective II).  

4.1.2.

  SO2:  To  ensure a  level  playing field in the  aviation market and  achieve  a  gradual  and 

continuous uptake of SAF with high decarbonisation potential at competitive prices 

Specific objective 2 is to maintain a level playing field in the aviation market and achieve a gradual and 
continuous  uptake  of  SAF  with  high  decarbonisation  potential  by  the  aviation  sector  at  lower  prices  than 
estimated today and based on the uniform obligations ensuring the integrity of competition within the internal 
market. For this objective to be achieved, it needs policy intervention on several fronts. First, the objective is to 
ensure that airlines have access to SAF at airports. This means that the logistics of the supply network for 
SAF-blended  jet  fuel  must  be  well  organised  and  that  the  necessary  volumes  and  qualities  of  SAF  must  be 
physically distributed at airports, and made accessible to airlines for refuelling on a regular basis. The logistics 
of SAF-blended jet fuel need to be geared to cater for gradual increase of SAF production and supply at airports 
over  time.  Second,  the  objective  is  to  boost  the  uptake  of  the  most  sustainable  types  of  SAF  in  a 
technology-neutral  way.  In  order  to  maximise  the  decarbonisation  potential  of  SAF,  to  accelerate  the 
decarbonisation of aviation and to deliver environmental benefits in line with the EU’s climate targets, it is also 
necessary to ensure that the uptake of the most sustainable SAF increases over time. Third, the objective is that 
airlines can purchase SAF at lower prices than estimated today and based on uniform obligations across the 
Union. This means that the selling price of SAF goes down relative to current price estimates, bridging to some 
extent the gap between conventional jet fuel and SAF prices112. Other initiatives like the forthcoming review of 
the ETS Directive and the Energy Taxation Directive could also play a role in further bridging this gap. Fourth, 
the objective is to ensure a level playing field between airlines to purchase aviation fuel and in particular 
SAF. This means that distortion of competition must be avoided across the internal market, as well as between 
EU and non-EU airlines. In particular, airlines should be able to purchase SAF at competitive prices regardless 
of  the  nature  or  geographical  spread  of  their  operations.  Fifth,  the  objective  is  to  avoid  carbon  leakage 
resulting from  increased fuel tankering. This  means  that this  initiative  should  not lead  to  airlines  carrying 
excessive volumes of fuels or changing their refuelling locations and strategies in order to avoid using SAF and 
incurring higher fuel costs. In this context, it is also necessary that the competition between airlines within the 
internal market is not distorted.   

Due to the “chicken-or-egg” situation on the SAF market, as described in section 2, Specific Objectives 1 and 2 
mutually  support  and  reinforce  each  other.  This  means  that  it  will  be  easier  to  successfully  achieve  Specific 
objective 2 (gradual and continuous uptake of SAF) if Specific objective 1 is successfully achieved (achieve 
large-scale SAF production), and vice versa. 

111   According to the World Economic Forum, developing the advanced biofuels for aviation and Power-to-Liquid technologies would allow 

tapping into abundant resources with high environmental benefits. 

112   Not prejudging other measures which may impact the price of conventional jet fuel itself. 

25 

 
                                                           
5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1.  What is the baseline from which options are assessed? 

The baseline scenario reflects developments under current trends and adopted policies as described in section 
2.3,  without  further  EU  level  intervention.  It  builds  on  the  baseline  scenario  underpinning  the  impact 
assessment  accompanying  the  2030  Climate  Target  Plan  and  the  staff  working  document  accompanying  the 
Sustainable and Smart Mobility Strategy, but it additionally considers the impacts of the COVID-19 pandemic 
and the National Energy and Climate Plans. In this scenario, the total intra and extra-EU air transport activity is 
projected  to  increase  by  close  to  45%  by  2030  and  close  to  90%  by  2050,  relative  to  2015,  following  the 
recovery  from  the  COVID-19  pandemic.  The  pace  of  the  recovery  builds  on  the  GDP  projections  but  also 
considers  some  structural  changes  due  to  limited  shifts  towards  digital  meetings.  The  overall  impact  of  the 
COVID-19 pandemic on the air transport activity is however significant, with lower growth projected relative 
to  pre-COVID  projections  (i.e.  around  11  percentage  points  lower  growth  for  2015-2030  relative  to  the  pre-
COVID projections and 14 percentage points lower growth for 2015-2050). More details are provided in Annex 
4. 

The  energy  demand  in  aviation  is  projected  to  grow  from  around  40  Mtoe  in  2015  to  50  Mtoe  in  2050, 
following the significant decrease estimated for 2020 (to 21 Mtoe) due to the COVID-19 pandemic. Aviation is 
projected  to  remain  almost  entirely  reliant  on  conventional  jet  fuel  by  2050  without  further  EU  level 
intervention, as explained in section 2.1.1. Air transport tank to wing CO2 emissions are projected to increase 
by  17%  by  2030  and  slightly  more  than  20%  by  2050,  relative  to  2015.  This  is  due  to  the  strong  growth  in 
activity,  following  the  recovery  from  the  COVID-19  pandemics  and  despite  the  significant  improvements  in 
energy  efficiency  over  time.  Well-to-wing  emissions  would  follow  a  similar  trend.  The  baseline  scenario 
underlines  an  aggravation  of  the  general  problem  (see  section  2.1.1.).  The  share  in  the  total  transport  CO2 
emissions113  is  projected  to  go  up  from  around  12%  in  2015  to  20%  in  2050.  More  details  on  the  baseline 
scenario  are  available  in  Annex  4,  drawing  on  the  impact  assessment  support  study.  The  very  low  and  slow 
market penetration of SAF by 2030 and 2050 means that problems 1 and 2 (see sections 2.1.2 and 2.1.3) remain 
largely valid, underpinned by the drivers identified in section 2.2. 

The COVID-19 pandemic’s long-term effects on air transport activity are highly uncertain and depend on the 
global evolution of the pandemic, the coordination of States to address it, and the ability of the aviation sector 
to restore passenger confidence. A discussion of the effectiveness of this initiative in relation to the possible 
effects of COVID-19 pandemic is included in section 7. 

The baseline scenario does not include the other ‘Fit for 55’ initiatives. This ensures a consistent approach with 
the impact assessments accompanying the other ‘Fit for 55’ initiatives. However, a qualitative assessment of 
their possible impact on how the problem will evolve is provided in section 2.3, section, 7.2 and Annex 10. 

In addition, as explained in section 1.3, the trajectory of SAF ramp up from 2025 to 2050 in the policy options 
is based on the common economic assessment underpinning the 2030 Climate Target Plan and the Sustainable 
and Smart Mobility Strategy while considering a combination of carbon pricing and medium intensification of 
regulatory  measures  in  all sectors  of  the  economy.  This  ensures  a  consistent  approach  for  delivering  the EU 
climate ambition by 2030 and 2050, while at the same time identifying the impacts of the design of the policy 
option  that  would  best  allow  to  reach  this  contribution.  Nevertheless,  a  qualitative  assessment  of  the 
implications of lower/higher trajectory for the SAF ramp up is provided in section 5.4.3.    

113   Total transport CO2 emissions including international maritime. 

26 

 
                                                           
5.2. 

Policy measures under consideration and approach taken 

Achieving the desired objectives of this initiative requires a holistic approach to the possible levers of action to 
address  the  problems  and  drivers.  A  comprehensive  and  consistent  set  of  actions  is  therefore  necessary, 
which  individually  may  not  be  sufficient  to  achieve  the  desired  objectives,  but  will  need  to  mutually 
complement each other. This is for example the case with the problem of the price differential between SAF 
and conventional jet fuel (see problem driver 3). The measures proposed in this section cannot fully bridge the 
price  gap  on  their  own,  but  can  contribute  to  reducing  it.  A  list  of  policy  measures  (outlined  and  briefly 
described  below)  is  considered  after  extensive  consultations  with  stakeholders,  expert  meetings,  independent 
research and the Commission’s own analysis (see Annex 5).  

The measures included in the scope of the present initiative are structured around  a regulatory requirement 
consisting of a SAF blending obligation. It is important to note that such mandate can be designed in multiple 
ways. Each design has different chances of reaching the objectives depending on their practical applicability, 
political feasibility and expected market and industrial behaviour (e.g. choice to invest in specific SAF types). 
These regulatory measures are complemented by a set of ‘flanking’ measures that support the intervention to 
address  the  problems  and  drivers  identified  along  the  SAF  supply  chain  (also  at  global  level),  and  meet  the 
identified  objectives.  All  flanking  measures  provide  an  enabling  framework  for policy  options  although  they 
are not directly included and assessed in the policy options. They consist of the following: 

Intensifying European efforts at ICAO level to raise ambition on SAF use; 

 
  A strategic alliance on advanced biofuels and electro-fuels; 
  Steering financial support towards SAF development in the EU; 
  Facilitating the certification of new SAF pathways. 

Measures addressed as part of the revision of other pieces of EU regulatory framework, part of the ‘Fit for 
55’  package  and  for  which  dedicated,  in-depth  impact  assessments  have  been  prepared  by  the  Commission 
services, are beyond the scope of this impact assessment. This relates namely to:  

  Revision of the Energy Taxation Directive; 
  Revision of the EU Emissions Trading System; 
  Revision of the Renewable Energy Directive; 
  Revision of the Fuels Quality Directive; 
  Reform of the Single European Sky. 

Annex 10 provides information on each of these measures. These measures may additionally contribute to the 
achievement  of  the  desired  policy  objectives.  Annex  10  provides  a  qualitative  assessment  of  how  these 
measures could contribute and establishes a clear reference to the impact assessments, which provide in-depth 
qualitative and quantitative analysis. This document also assesses the interplay between these measures and the 
preferred policy option of the present initiative, and explains how some of these measures could contribute to 
reaching  the  objectives  of  the  present  initiative.  It  also  explains  how  the  present  initiative  complements  and 
reinforces the objectives of other initiatives part of the ‘Fit for 55’ package.  

5.3. 

Description of the policy options (PO) 

The table below provides an overview of the various policy measures considered under this initiative and the 
way in which they are grouped in policy options (POs) A1, A2, B1, B2, C1 and C2. It is important to note that 
all POs (except PO B2, due to its reduced scope) are designed to achieve the same CO2 savings on a well-to-
wing basis over time.  

27 

 
Table 2 - Description of policy measures. Key: P1 = Problem 1; P2 = Problem 2; D1 = Problem Driver 1; D2 = Problem Driver 2; D3 
= Problem Driver 3; S1 = specific objective 1; S1 = specific objective 2;   = included; 

Policy measure 

SAF obligation 
Fuel  suppliers  are  obliged  to  supply  only  jet  fuel  that  is 
blended with a minimum share of SAF across all EU airports. 

Transition  period:  from  2025  to  2030,  fuel  suppliers  are 
obliged to supply a minimum share of SAF over their total jet 
fuel supply on a yearly basis. All jet fuel supply must contain 
SAF in the range 0% - 50%. 
Transition  period:  from  2030  to  2035,  fuel  suppliers  are 
obliged to supply a minimum share of SAF over their total jet 
fuel supply on a yearly basis. All jet fuel supply must contain 
SAF in the range 2% - 50%. 
Airlines are obliged to use a minimum share of SAF as part 
of  their  total  fuel  consumption  on  intra  and  extra-EU  flights 
on a yearly basis. 
Airlines are obliged to use a minimum share of  SAF as part 
of their total fuel consumption on intra-EU flights on a yearly 
basis. 
Obligation of jet fuel uplift 
Airlines departing from EU airports are required to uplift the 
amount of jet fuel needed for their planned flight. 

Target setting: volumes or CO2 intensity 

The  minimum  target  is  expressed  in  terms  of  SAF  volumes 
blended into jet fuel, expressed as share. 

The  minimum target is expressed in terms of  GHG intensity 
reduction of the jet fuel used. 

Ramp-up of SAF obligation 

The required minimum share of SAF blended in total jet fuel 
supplied increases over time from 2025 to 2050, in line with 
the EU climate objectives. 
The  required  reduction  in  CO2  intensity  of  total  jet  fuel 
supplied  increases  over  time  from  2025  to  2050.  It  is 
designed to achieve the same emissions reductions in the air 
transport sector over time as measure 9.  
Additional incentives for e-fuels 

RFNBOs  are  subject  to  a  sub-mandate  gradually  increasing 
from 2030 to 2050. 

A  multiplier  applies  to  the  accounting  of  RFNBOs  towards 
meeting the SAF obligation. 

Driver 
Problem 
Specific 
Objective 

D1, D2, D3 
P1, P2 
S1, S2 
D1, D2, D3 
P1 
S1 

D1, D2, D3 
P1 
S1 

D3 
P2 
S2 
D3 
P2 
S2 

D3 
P2 
S2 

D3 
P1, P2 
S1, S2 
D3 
P1, P2 
S1, S2 

D1, D2, D3 
P1, P2 
S1, S2 
D1, D2, D3 
P1, P2 
S1, S2 

D1, D2, D3 
P1, P2 
S1, S2 
D1, D2, D3 
P1, P2 
S1, S2 

Penalties for non-compliance114 

Fuel  suppliers  are  subject  to  penalties  applied  at  national 
level  in  case  of  non-compliance  with  the  SAF  supply 
obligation.  

P1 
S1 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

A1 

A2 

B1 

B2 

C1 

C2 

   

   

   

   

   

 

 

 

     

 

 

     

 

 

     

 

 

 

 

   

   

114   Funds collected from non-compliance penalties are injected in an EU fund for the development of SAF, e.g. EU ETS Innovation Fund. 

28 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Policy measure 

14 

15 

16 

17 

18 

19 

20 

Airlines  are  subject  to  penalties  applied  at  national  level  in 
case of non-compliance with the SAF use obligation. 

Airlines  are  subject  to  penalties  applied  at  national  level  in 
case of non-compliance with the jet fuel uplift obligation. 

SAF transaction for accounting purposes  

Fuel  suppliers  may  request  SAF  transactions  between  them 
for  accounting  purposes, 
the  supply 
obligation. 
Airlines  may  request  SAF  transactions  between  them  for 
accounting purposes, to claim the use of SAF. 

to  comply  with 

Monitoring, reporting, verification 

An  existing  EU  agency  (e.g.  EASA)  is  required  to  compile 
the  data  provided  by  fuel  suppliers  and  report  to  the 
Commission.  
An  existing  European  organisation  (e.g.  Eurocontrol)  is 
required to compile the information on SAF use reported by 
airlines, and report it to the Commission. 
An existing EU agency or organisation (e.g. Eurocontrol) is 
required  to  consolidate  the  data  sent  by  airlines  to  comply 
with the jet fuel uplift obligation on a flight basis, and report 
to the Commission cases of fuel tankering. 

Driver 
Problem 
Specific 
Objective 
D3 
P2 
S2 
D3 
P2 
S2 

D3 
P1 
S1 
D3 
P2 
S2 

D3 
P1 
S1 
D3 
P2 
S2 
D3 
P2 
S2 

A1 

A2 

B1 

B2 

C1 

C2 

   

   

   

   

   

   

       

   

5.3.1.

  Policy Option A1: Obligation on the supply side (volume-based approach) 

This policy option consists of imposing an obligation on fuel suppliers to supply physically at least a minimum 
share of SAF (expressed in volume terms) at all EU airports at all times. Certain categories of airports, such as 
remote or insular airports may request to be out of the scope. This means that every litre of jet fuel supplied to 
airports must be blended with a minimum share of SAF from 2025 onwards. Airlines operating on intra-EU and 
extra-EU routes have  no alternative than to use SAF-blended jet fuel when departing from EU airports. This 
minimum share of SAF to be supplied corresponds to the expected trajectory of the SAF market ramp up for 
2025-2050, as explained in section 1.3. A supply sub-obligation applies to RFNBOs as of 2030, meaning that 
every litre of jet fuel must contain a minimum share of RFNBO as of that date (see section 5.4.2). Monitoring, 
reporting and verification115 of the fuel supply obligation is ensured through the dedicated mechanisms under 
RED II, i.e. the Union Database established under RED II Article 28. An existing EU agency (e.g. European 
Aviation  Safety  Agency  EASA),  is  required  to  compile  the  information  provided  on  SAF  supply  under  the 
Union  Database  and  reports  to  the  Commission  on  the  compliance  of  each  fuel  supplier  with  their  supply 
obligation. Penalties imposed on fuel suppliers in case of non-compliance are determined at EU level, reviewed 
yearly if needed, and enforced at national level. Funds collected from penalties are reinjected in an EU fund for 
the development of SAF, e.g. EU ETS Innovation Fund. 

5.3.2.

  Policy Option A2: Obligation on the supply side (CO2 intensity reduction approach) 

This PO is similar to PO A1, with the exception of the target setting. The obligation imposes on fuel suppliers a 
minimum  reduction  of  the  CO2  intensity  (meaning  the  lifecycle  CO2  emissions  per  unit  of  energy)  of  the 

115   Annex IX contains more details on the monitoring, reporting and verification arrangements for each PO. 

29 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
overall  jet  fuel  supplied.  This  PO  aims  to  take  a  technology-neutral  approach  by  using  the  CO2  intensity 
reduction-based  obligation and  therefore it does not set  a specific  sub-mandate on  RFNBOs.  An  incentive  is 
however set in place, i.e. a multiplier116 applying to RFNBOs, to bridge the gap in production costs between 
RFNBOs  and  advanced  biofuels.  The  value  of  this  multiplier  decreases  over  time,  as  the  cost  efficiency  of 
RFNBOs improve. Its value is 1.6 and 1.2 respectively in 2030 and 2040. From 2045, its value is 1. The values 
of the multipliers are tailored to provide a boost to RFNBOs, and correspond to the value necessary to bridge 
the  price difference  between  RFNBOs  and  advanced  biofuels.  As  the  price  difference  evolves over  time,  i.e. 
RFNBOs  prices  go  down,  the  value  of  the  multiplier  also  decreases  over  time  from  1.6  to  1.2.  By  2045,  as 
RFNBO  prices  become  aligned  with  advanced  biofuel  prices,  the  multiplier  value  is  1.  The  reduction  in  the 
CO2 intensity of fuels in Policy Option A2 is designed to achieve the same CO2 emissions reductions in the air 
transport sector over time as in Policy Option A1. Monitoring, reporting and verification of SAF supply is the 
same  as  under  PO  A1,  with  the  exception  that  fuel  suppliers  are  required  to  enter  into  the  Union  Database 
information on the CO2 intensity of the SAF supplied.  

5.3.3.

  Policy Option B1: Obligation on the demand side (intra and extra-EU scope) 

This policy option consists of imposing an obligation on airlines to use a minimum share of SAF (expressed in 
volume  terms)117  as  part  of  their  total  jet  fuel  use  on  intra-EU  flights  and  flights  from  any  EU  airport  to  an 
extra-EU airport. This minimum share of SAF corresponds to the trajectory of the SAF ramp up as explained in 
section 1.3 and it is the same as that of Policy Option A1. An airline is not strictly required to use SAF on each 
flight as long as it can demonstrate that it has used the minimum share of SAF on average over the course of 
each reporting period of one year. As some airlines may not have physical access to SAF at the airports where 
they focus their operations, a transaction system allows them to purchase SAF and claim their use even if they 
do not use it physically, provided that it is used elsewhere in the EU aviation system. Such a system would not 
require any additional IT structure or services (it would work under the EU ETS) and would represent a very 
limited number of transactions by airlines on a yearly basis, hence negligible administrative costs. See section 
5.4.4  for  more  details  on  the  functioning  of  this  system.  A  sub-mandate  applies  to  RFNBOs  as  of  2030, 
meaning  that  airlines  are  required  to  use  a  minimum  share  of  RFNBOs  as  part  of  their  total  jet  fuel 
consumption over the course of a year. Monitoring, reporting and verification of SAF use is ensured through 
the  dedicated  mechanisms  under  the  EU  ETS  Monitoring  and  Reporting  Regulation118,  meaning  that  airlines 
operating intra-EU flights report SAF use within their individual emissions reports Airlines operating extra-EU 
flights  report  their  SAF  use  under  their  emission  reports  as  established  in  CORSIA  rules119.  An  existing 
European organisation (e.g. Eurocontrol) is required to compile the information contained in the EU ETS and 
CORSIA emission reports regarding SAF use, and reports to the Commission on the compliance of individual 
airlines with their SAF use obligation.  Penalties imposed on airlines in case of non-compliance are determined 
at EU level, reviewed on a yearly basis if needed, and enforced at national level. Funds collected from penalties 
are injected in an EU fund for the development of SAF, e.g. EU ETS Innovation Fund. 

116   The  multiplier  applies  to  the  formula  calculating  the  CO2  intensity  reduction,  and  does  not  apply  to  the  actual  emissions  savings.  This 

avoids the flaws of a system where a multiplier would lower the amount of emissions savings achieved. 

117   Both POs B1 and B2 are designed with a volume-based approach because airlines, to the difference of fuel suppliers, have less control over 
the CO2 intensity of the fuel produced and introduced in the system. Imposing an obligation on airlines to meet a CO2 intensity reduction 
over their total jet fuel use would reduce the chances of successfully meeting the obligation, since airlines traditionally purchase, monitor 
and record fuel use in volume terms. While CORSIA uses a GHG approach to determine the benefits to be granted from the use of SAF, 
the CORSIA system for SAF does not consist of an obligation, but rather an incentive. It is worth recalling that all POs (except PO B2 for 
reasons  related  to  its  scope)  are  designed  with  the  same  climate  ambition.  The  choice  of  the  volume  or  GHG  based  approach  does  not 
determine the climate ambition of the PO. 

118   C/2018/8588, amended by C/2020/8769 with specific provisions applying to biofuels (article 54). 
119   ICAO SARPs – Annex 16 Volume IV – Chapter 2. Monitoring, reporting and verification of aeroplane operator annual CO2 emissions. 

30 

 
                                                           
5.3.4.

  Policy Option B2: Obligation on the demand side (intra-EU scope) 

Same as PO B1, with the exception that the scope is reduced to cover only intra-EU flights. This means that an 
obligation is  imposed  on  airlines  to  use  a  minimum  share  of  SAF  (expressed  in  volume  terms)120,  as  part  of 
their  total  jet  fuel  consumption  on  intra-EU  flights  only.  Airlines  operating  such  flights  are  not  expected  to 
compensate for the reduced scope, meaning that they are required to use the same minimum share of SAF as in 
PO  B1  but  only  applied  to  the  total  jet  fuel  used  on  intra-EU  flights.  As  a  result,  PO  B2  achieves  lower 
emissions  reductions  from  intra-  and  extra-EU  air  transport  than  all  other  POs121.  Monitoring,  reporting  and 
verification of SAF use by airlines is ensured through the dedicated mechanisms under the EU ETS Monitoring 
and  Reporting  Regulation,  meaning  that  airlines  operating  intra-EU  flights  report  SAF  use  within  their 
individual emissions reports. An existing European organisation (e.g. Eurocontrol) is required to compile the 
information contained in the EU ETS emission reports regarding SAF use, and reports to the Commission on 
the compliance of individual airlines with their SAF use obligation.  

5.3.5.

  Policy Option C1: Obligation on supply and uplift (volume-based approach) 

Fuel suppliers are obliged to supply physically a minimum share of SAF (expressed in volume terms) at all EU 
airports  at  all  times,  post-2035  (following  a  transition  period).  Certain  categories  of  airports,  such  as  small 
airports  could  be  exempted.  This  should  be  done  by  setting  a  threshold  e.g.  on  the  volume  of  traffic  per 
airport122. This means that every litre of jet fuel supplied to airports must be blended with at least a minimum 
share of SAF. Airlines (EU and non-EU) operating on intra-EU and extra-EU routes taking off from airports 
located on EU territory have no alternative than to use SAF-blended jet fuel. This minimum share of SAF to be 
supplied corresponds to the trajectory of the SAF market ramp up as explained in section 1.3 and is the same as 
in PO A1 and PO B1. A specific supply sub-mandate applies to RFNBOs as of 2030; its level is the same as in 
PO A1 and PO B1. A system of SAF transactions for accounting purposes is established to allow fuel suppliers 
to meet their obligation in a more cost-effective way. This system is only in place during the transition period, 
i.e. between 2025 and 2035 since beyond 2035 all fuel suppliers are required to distribute only SAF-blended jet 
fuel at all airports. Hence, during this period there is no possibility for suppliers to supply fossil jet fuel. Such a 
system could be set out under the present initiative. Section 5.4.4 contains detailed information on the nature 
and functioning of this system. 

Monitoring,  reporting  and  verification  of  the  fuel  supply  obligation  is  ensured  through  the  dedicated 
mechanisms under RED II, i.e. the Union Database already established under RED II Article 28. An existing 
EU agency (e.g. European Aviation Safety Agency), is required to compile the information provided on SAF 
supply under the Union Database and reports to the Commission on the compliance of each fuel supplier with 
their supply obligation.  

Monitoring,  reporting  and  verification  of  SAF  use  by  airlines  is  ensured  through  the  dedicated  mechanisms 
under  the  EU  ETS  Monitoring  and  Reporting  Regulation,  meaning  that  airlines  operating  intra-EU  flights 
report SAF use within their individual emissions reports. An existing European organisation (e.g. Eurocontrol) 
is already required today to compile the information contained in the EU ETS emission reports regarding SAF 
use, and reports to the Commission on the compliance of individual airlines with their SAF use obligation. The 
jet fuel uplift obligation applicable to all airlines departing from EU airports will be monitored through a direct 
reporting by all airlines to an existing European organisation or EU agency (e.g. Eurocontrol). The information 
on jet fuel uplift at flight level per airline will be processed by this agency or organisation to identify cases of 
fuel tankering and reported to the Commission. 

120   Same explanation as for PO B1. 
121   At  EU  level,  considering  that  energy  use  for  intra-EU  flights  represent  only  about  one  third  of  the  total  aviation  fuel  use,  post-2030  it 
would not be possible to achieve the same level of emissions savings as in PO B1 even if considering 100% SAF in the intra-EU fuel mix. 
122   For instance, setting the threshold at 0.5 million passengers per year means that around 98% of passenger traffic would be captured in the 

scope. An analogous threshold could be set to cover airports where the vast majority of air cargo traffic takes place. 

31 

 
                                                           
Penalties imposed on fuel suppliers in case of non-compliance are determined at EU level, reviewed yearly if 
needed,  and  applied  at  national  level.  Funds  collected  from  penalties  are  reinjected  in  an  EU  fund  for  the 
development of SAF, e.g. EU ETS Innovation Fund. 

In order to allow for a more cost-effective SAF supply in the first years of the supply obligation, a two-stage 
transition period applies from 2025 to 2035.  

  From  2025  to  2030,  fuel  suppliers  are  required  to  meet  the  ramp  up  target  and  can  supply  EU 
airports with jet fuel containing SAF in the range 0% - 50% (which corresponds to the maximum 
limit for certified SAF blends). This means that fuel suppliers are not required to distribute SAF at 
all airports. Nevertheless, they are individually required to meet the overall ramp up target over the 
course of a one year reporting period. 

  From 2030 to 2035, fuel suppliers are required to meet the ramp up target overall (i.e. 5% in 2030 
and 20% in 2035) but must all supply EU airports with jet fuel containing SAF in the range 2% - 
50%123. This means that every litre of jet fuel supplied to all airports must be blended with at least 
2% of SAF. Fuel suppliers are required to supply overall 0.7% of RFNBOs from 2030, and every 
litre of jet fuel supplied at airports must contain RFNBOs in the range 0.3%124 - 50%. 

Level  playing  field  (anti-tankering)  safeguard:  All  airlines  (EU  and  non-EU)  departing  from  EU  airports  are 
obliged to uplift jet fuel prior to departure. The amount of jet fuel uplifted must correspond to the volume of jet 
fuel necessary to operate the planned flight (including the fuel safety margins), regardless of the destination. All 
airlines  are  required  to  report  their  jet  fuel  uptake  to  a  European  organisation  which  will  be  in  charge  of 
detecting and reporting cases of obvious fuel tankering on a yearly basis to the Commission (e.g. Eurocontrol). 
It is not strictly necessary to request reporting on a per-flight basis. Indeed, this measure can be just as efficient 
if the fuel uplift is monitored over the course of a year for all flights departing from a given EU airport. This 
means that an airline would be required to ensure that its total jet fuel uplift at a given EU airport corresponds 
to the cumulative amount of fuel necessary to operate all of its flights departing from that airport. A degree of 
flexibility  could  be  relevant  to  cater  for  airlines’  operational  constraints.  For  instance,  the  measure  would 
achieve  its  objective  if  airlines  were  to  demonstrate  that  they  uplifted  at  least  90%  of  the  fuel  required  to 
operate  all  of  their  flights  departing  from  a  given  airport.  Penalties  imposed  on  airlines  in  case  of  non-
compliance would be determined at EU level, reviewed on a yearly basis if needed, and enforced at national 
level.  Funds  collected  from  penalties  are  injected  in  an  EU  fund  for  the  development  of  SAF,  e.g.  EU  ETS 
Innovation Fund.  

This  measure  has  a  double  purpose.  First,  it  allows  to  preserve  a  level  playing  field  for  all  flights  departing 
from EU airports, including extra-EU flights. Indeed, as all airlines (regardless of whether they are established 
in the EU or not) will be required to uplift the jet fuel available at EU airports, higher jet fuel costs will apply to 
all. This reduces the possibility of competitive disadvantage for EU airlines and for EU hub airports.  Section 
6.2.8  provides  details  on  the  level  playing  field  (anti-tankering)  safeguard.  Secondly,  this  measure  aims  to 
prevent the risk of increased fuel tankering as a result of higher fuel costs for airlines at EU airports over time. 
While the risks of additional tankering is expected to be low in the early stages of the obligation (see section 
6.2.8), this measure should be implemented already from 2025 as it cannot be excluded that market prices for 
jet fuel  and  SAF  fluctuate  to  a  point  that  could  make  fuel  tankering  economically  interesting.  Moreover,  the 
prevention of tankering brings immediate benefits by removing avoidable emissions caused by the additional 
fuel carried, regardless of the reasons airlines may have for tankering. A study125 conducted by the International 

123   The choice of 2% as a minimum of SAF to be supplied at all airports was retained as it is a reasonable, attainable target by 2030. It allows 
all suppliers to smoothly transition to a system where all airports must be supplied with SAF-blended jet fuel, and gradually develop their 
supply chain for this purpose.  

124   The choice of 0.3% for RFNBOs follows the same logic. The ratio is the same between 0.3% and 0.7%, as it is between 2% and 5%. 
125   https://theicct.org/publications/tankering-eu-SAF-mandate-apr2021 

32 

 
                                                           
Council on Clean Transportation in 2021 concluded that additional tankering stemming from the SAF blending 
mandate  could  result  in  a  22%  lower  SAF  uptake  by  airlines  by  2035.  In  turn,  this  could  reduce  the  CO2 
benefits of the initiative by a quarter by 2035. Mitigation measures identified in the study include defining and 
prohibiting fuel tankering on flights departing from EU airports. 

5.3.6.

  Policy Option C2: Obligation on supply and uplift (CO2 intensity reduction approach) 

Same as PO C1, with the exception of the target setting. The obligation imposes on fuel suppliers a minimum 
reduction  of  the  CO2  intensity  of  the  overall  jet  fuel  supplied.  This  PO  aims  to  take  a  technology-neutral 
approach  by  using  the  CO2  intensity  reduction-based  obligation.  For  consistency  with  the  technology-neutral 
approach,  this  PO  does  not  set  a  specific  sub-mandate  on  RFNBOs.  An  incentive  is  however  chosen,  i.e.  a 
multiplier  applying  to  RFNBOs,  designed  in  a  way  to  bridge  the  production  costs  between  RFNBOs  and 
advanced biofuels. The value of this multiplier decreases over time, as the cost efficiency of RFNBOs improve. 
Its value is 1.6 and 1.2 respectively in 2030 and 2040. From 2045, its value is 1. The values of the multipliers 
are tailored to provide a boost to RFNBOs, and correspond to the value necessary to bridge the price difference 
between  RFNBOs  and  advanced  biofuels.  As  the  price  difference  evolves  over  time,  i.e.  RFNBOs  prices  go 
down, the value of the multiplier also decreases over time from 1.6 to 1.2. By 2045, as RFNBO prices become 
aligned with advanced biofuel prices, the multiplier value is 1.  

The monitoring, reporting and verification of SAF supply and use are the same as in PO C1, with the exception 
that fuel suppliers and airlines are required to report information on the CO2 intensity of the SAF supplied/used, 
respectively into the Union Database established under RED II and EU ETS emissions reports. The reporting, 
monitoring and verification of the jet fuel uplift is identical to that of PO C1. 

5.4. 

Common elements for all policy options 

5.4.1.

  Types of SAF supported and sustainability requirements 

Under all policy options described in section 5.3, eligible SAF is restricted to the following types of  ASTM-
certified  drop-in  fuels,  where  compliance  with  the  RED  II  sustainability  framework126  can  be 
demonstrated: 

 

 

 

“Biofuels” produced from feedstock listed in Part B of Annex IX, in the meaning of Article 2(33) of 
the Renewable Energy Directive. 
 “Advanced biofuels” in the meaning of Article 2(34) of the Renewable Energy Directive (Annex IX 
Part A). 
 “Renewable fuels of non-biological origin” (RFNBOs), in the meaning of Article 2(36) of the recast 
Renewable Energy Directive. For this initiative, the synthetic liquid fuels are relevant127.  

The  selection  of  the  above  three  SAF  categories  to  be  supported  under  the present  initiative  is  a  clear 
policy  choice  based  on  the  following  five  criteria:  sustainability,  market  readiness,  expected  feedstock 
availability, production costs and regulatory fitness. From this analysis, it derives that Part B biofuels, advanced 
biofuels and RFNBOs present overall the highest potential to reduce aviation emissions, for their ability to be 
gradually deployed in aviation already in the short- and medium-term, at reasonable costs and with sufficient 
feedstock  availability.  Crop  based  biofuels  are  capped  under  RED  II  and  present  limited  decarbonisation 
potential  when  considering  their  indirect  land  use  effects;  they  are  thus  not  considered  in  this  impact 
assessment.  Hydrogen  and  electricity  have  the  potential  to  bring  important  climate  benefits,  but  significant 

126   Sustainability  and  greenhouse  gas  saving  criteria  set  out  in  Article  29  of  recast  Renewable  Energy  Directive  as  well  as  GHG  emission 
savings requirements for RFNBOs. Biofuels and advanced biofuels produced in new installations are required to achieve 65% savings and 
RFNBOS are required to achieve at least 70% savings. Actual emission savings are typically higher. 

127   As per Article 2(36) of the Renewable Energy Directive, RFNBOs can also be gaseous fuels. 

33 

 
                                                           
additional research and development must continue in the coming decades and major technological changes are 
needed  for  aircraft  engines  and  fuelling  infrastructure.  Therefore  at  this  stage,  it  is  too  early  to  consider 
regulatory action on fuel technologies such as hydrogen or electricity as primary fuels for aircraft. Indeed, 
these  are  expected to reach  the  market in the  coming  decades  and  play  a role at  market scale in  commercial 
aviation in the long-term. 

5.4.2.

  SAF blending mandate 

All  POs  consider  different  designs  to  establish  a  SAF  blending  mandate.  It  should  be  noted  that  a  blending 
mandate  sets  an  obligation  for  economic  operators  (fuel  suppliers  or  airlines)  to  integrate  SAF  in  their  fuel 
supply  or  use.  The  SAF  obligation  alters  the  jet  fuel  mix,  which  de  facto  becomes  SAF-blended  jet  fuel.  In 
particular in POs where all EU airports are supplied with only SAF-blended jet fuel (i.e. POs A1, A2, and C1, 
C2 beyond the transition phase), the consideration of a price gap between SAF and fossil jet fuel is no longer 
relevant, as fossil jet fuel is no longer available. The price of jet fuel becomes the price of SAF-blended jet fuel, 
and  reflects  the  weighted  participation  of  different  types  of  fuel  (SAF,  fossil)  in  the  blend.  The  price  gap 
between  SAF  and  fossil  jet  fuel  is  no  longer  a  factor  determining  the  economic  choices  of  airlines  when 
purchasing jet fuel. It should be noted that it is still desirable for SAF prices to decrease over time. Indeed, this 
limits the costs of the jet fuel mix to be borne by airlines. However, the elimination of the price gap is no longer 
a sine qua non condition for SAF uptake.  

5.4.3.

  SAF ramp-up trajectory 

For POs A1, B1, B2 and C1, the mandatory shares of SAF to be supplied (A1 and C1) or used (B1 and B2) 
with respect to total jet fuel supply/use respectively in a given reporting period is shown in the following table. 
For  policy  option  B2,  where  the  obligation  applies  only  for  intra-EU  flights,  the  figures  in  the  table  below 
apply, meaning that airlines are obliged to use the below SAF shares as part of their total jet fuel consumption 
on intra-EU flights. 

As  explained  in  section  1.3,  the  ‘central’  SAF  ramp-up  trajectory  has  been  based  on  the  common  economic 
assessment underpinning the 2030 Climate Target Plan and the Sustainable and Smart Mobility Strategy while 
considering a combination of carbon pricing and medium intensification of regulatory measures in all sectors of 
the economy. It has been derived in a way that enables kick starting the scale-up of sustainable aviation fuels 
from 2025 onwards and their large scale deployment by 2050, while ensuring the consistency with the required 
overall greenhouse gas emissions reductions by 2030 and 2050, preserving the competitiveness of the sector, 
promoting innovation, and ensuring feedstock availability for renewable and low carbon fuels in all energy and 
transport sectors in the transition towards a climate neutral economy. An update of the pathway/scenario for the 
purpose of the ‘Fit for 55’ package focusing on a combination of carbon pricing and medium intensification of 
regulatory measures in all sectors of the economy, while also reflecting the COVID-19 pandemic, the National 
Energy and Climate Plans and refining the policy design of the initiatives, confirms that air transport effectively 
contributes to the EU climate goals while considering the SAF ramp-up trajectory in the table below. 

The impact of considering different SAF ramp-up scenarios would be as follows. 

A  lower  SAF  ramp-up  by  2030  require  airlines  to  surrender  more  emission  allowances  as  aviation  CO2 
emissions are covered by the EU Emissions Trading System (EU ETS). However, considering the limited share 
of aviation CO2 emissions in the total stock, the effect on the price of ETS allowances is expected to be low by 
2030. This would not allow intensifying the efforts of the aviation sector to reduce its emissions by 2030.  At 
the same time, with a lower ramp-up by 2030, the build-up of SAF capacities could be delayed, due to path 
dependency effects, diverting advanced biofuels and RFNBOs towards the road transport sector, where more 
promising options (like for example large scale electrification) are available. Post-2030, a steeper trajectory for 
the reduction in the air transport emissions would be needed to contribute towards EU climate neutral economy 
by 2050. This would require a steep build-up of SAF production capacities, starting from a low base and under 

34 

 
a  limited  time  horizon,  which  may  not  be  feasible.  It  may  also  require  substantially  higher  effort  when 
approaching  2050.  The  latter  could  result  in  steep  reductions  in  air  transport  activity,  with  negative 
consequences  on  the  jobs  in  the  air  transport  industry,  connectivity,  as  well  as  growth  of  businesses  and 
regions. 

A higher SAF ramp-up by 2030 would push to some extent the price of the EU ETS allowances downwards 
and would require less emissions reduction efforts in other sectors. Yet, a higher SAF ramp-up by 2030 would 
lead  to  higher  jet  fuel  costs  for  airlines,  increase  in  the  ticket  prices  for  the  consumers  than  in  the  central 
trajectory, with further reduction of air transport activity and possible associated effects on air connectivity. On 
the other hand, more options for emissions reduction would be available in other sectors at lower costs. At the 
same time, some advanced biofuels would still be required in the road transport sector by 2030 considering that 
the electrification of the sector takes time due to the gradual replacement of the vehicle fleet. The higher SAF 
ramp-up  would  intensify  the  competition  for  biomass  feedstock  with  other  transport  and  energy  sectors, 
pushing the feedstock prices further up. A faster ramp-up could also mean that fuel suppliers have to resort to 
more imports of feedstock from third countries. It would also mean higher needs in renewable electricity for the 
production of RFNBOs, which would increase the competition with other sectors for access to such electricity 
(see section 6.1.2). A higher ramp up would mean a need to for increased production capacity compared to the 
central scenario, and thus an increase in investment needs (see section 6.2.5).  

Overall, as explained in section 1.3, a range of 4 to 8% for the share of SAF in the jet fuel mix is feasible by 
2030, while keeping in mind the considerations above. The possibilities of lower or higher SAF ramp-up post-
2030  are  more  limited  while  ensuring  the  consistency  with  the  required  overall  greenhouse  gas  emissions 
reductions by 2050, preserving the competitiveness of the sector, promoting innovation, and ensuring feedstock 
availability for renewable and low carbon fuels in all energy and transport sectors in the transition towards a 
climate  neutral  economy.  This  assessment  takes  into  account  the  current  knowledge  related  to  the  possible 
evolution  of  technology  costs  and  feedstock  costs.  If  higher  decrease  in  these  costs  would  materialise  in  the 
future,  higher  SAF  ramp-up  could  be  possible  post-2030.  On  the  other  hand,  lower  ramp-up  post-2030  may 
require substantially higher effort when approaching 2050, with the associated risks explained above.   

Table 3 – Central SAF ramp-up trajectory128 (volume based approach). 

Total shares in the fuel mix (in %)  

2025 

2030 

2035 

2040 

2045 

2050 

SAF ramp up out of which: 

Biofuels (including Part A and Part B biofuels) 

Specific sub-mandate on RFNBOs129 

2 

2 

- 

5 

4.3 

0.7 

20 

15 

5 

32 

24 

8 

38 

27 

11 

63 

35 

28 

For POs A2 and C2 with a CO2 intensity reduction-based obligation, fuel suppliers are required to supply jet 
fuel  that  achieves  a  minimum  CO2  intensity  reduction  compared  to  the  baseline  for  fossil  fuel130  over  the 
course of a reporting period131. All CO2 intensity reductions achieved with the use of SAF that are compliant 

128   Where SAF shares in the jet fuel mix indicate values superior to 50%, this implies that airlines would be required to uplift jet fuel blended 
at a higher ratio than the currently certified maximum blending ratio of 50%. As such values are reached beyond 2040, the assumption is 
made that the maximum blending ratio imposed by current certification will be lifted by then. 

129   The choice of 2030 as starting date of the sub-mandate for RFNBOs is justified by the fact that in the baseline scenario, this technology 
only appears in 2050. The sub-mandate allows to bring this technology to the market 20 years earlier than under the baseline scenario.  

130   The baseline for fossil fuel is 94gCO2e/MJ, as defined in RED II. 
131   No policy option includes an obligation on airlines expressed in terms of jet fuel CO2 emissions reduction because airlines have limited 
control  on  the  CO2  intensity  of  the  SAF  that  is  placed  on  the  market,  as  this  depends  on  the  fuel  suppliers.  Hence,  whereas  the  CO2 
intensity reduction approach can influence the economic behaviour of fuel suppliers when applied on the supply side, the same approach 
would have limited effects on the demand side. 

35 

 
 
                                                           
with the sustainability requirements (see section 5.4.1) count towards the obligation. This approach is currently 
used under CORSIA and the FQD. 
The  target  setting  and  the  approach  chosen  (volumes  or  CO2  intensity  reduction)  can  influence  the  way  the 
market will react to the obligation, in terms of resulting fuel mix and costs.  
The following table shows the mandatory reduction in the well-to-wing jet fuel CO2 intensity that fuel suppliers 
are required to comply with under options A2 and C2132. 

Table 4 - SAF ramp-up trajectory (CO2 intensity reduction approach). 

WTW jet fuel CO2 intensity reduction (in %)  

Resulting from the use of SAF 

2030 

- 5% 

2040 

- 29% 

2050 

-59% 

5.4.4.

  SAF transactions for accounting purposes 

In the early years of the SAF obligation, it is expected that fuel suppliers may not all be in the same position to 
meet  the  obligation.  While  some  may  be  able  to  supply  more  than  required  SAF-blended  fuel  -  due  to  e.g. 
scaled-up  production  capacity,  well  established  commercial  partnerships  and  fit  for  purpose  logistics,  others 
may fall short of meeting the obligation. This could be the case if e.g. meeting the last 10% of the SAF supply 
target would mean significant additional costs for e.g. expanding production capacity. In such cases, a system 
of SAF transactions for accounting purposes could be useful (but not indispensable) to allow fuel suppliers to 
meet  their  targets  in  a  more  cost-effective  way.  Over  achievers  (suppliers  with  an  excess  of  SAF  supplied) 
could  allow  under-achievers  to  account  for  part  of  their  over-supply  so  as  to  allow  them  to  meet  their 
obligation.  Legal  provisions  establishing  such  a  system  could  be  set  up  under  the  present  initiative.  The 
functioning  of  this  system  would  be  the  following.  By  the  end  of  each  reporting  year,  fuel  suppliers  (over-
achiever)  would  be  able  to  inform  the  existing  EU  agency  (e.g.  EASA)  in  charge  of  SAF  monitoring  at  EU 
level and request transactions of SAF volumes to another supplier (under-achiever). Such transactions would be 
documented  and  reflected  in  the  SAF  monitoring  process  of  the  EU  agency.  The  monitoring  process  should 
ensure  that  transactions  between  suppliers  are  traceable  and  verifiable.  The  EU  agency  in  charge  of  the 
monitoring  at  EU  level  would  only  deal  with  reflecting  the  transaction  for  SAF  volumes/CO2  intensity 
accounting  purposes,  verifying  it  and  recording  it.  The  financial  transactions  between  fuel  suppliers  for  the 
amount  of  SAF  transacted  is  out  of  the  scope  of  this  work.  This  system  represents  flexibility  for  the  fuel 
industry to meet supply targets. It is only relevant for policy designs where suppliers have flexibility to supply 
SAF where it is the most cost effective to do so, i.e. in POs C1 and C2 during the transition phase (2025-2035). 
Indeed, in the case of POs A1 and A2 and in the case of POs C1 and C2 beyond 2035, suppliers are required to 
supply only SAF-blended jet fuel at all airports. In this case, it is not desirable to allow SAF transactions, since 
this  would  jeopardise  the  physical  supply  of  minimum  shares  of  SAF  to  all  EU  airports.  Indeed,  one  could 
imagine  that  a  given  fuel  supplier  would  continue  supplying  fossil  jet  fuel  at  certain  airports,  and  fulfil  its 
obligation by ‘acquiring’ SAF (for accounting purposes) from other over-achieving suppliers. This would not 
be  compliant  with  the  requirement  that  SAF  suppliers  shall  supply  all  airports  with  a  minimum  SAF  share. 
Therefore such a system is compatible only with POs C1 and C2 for the first and second transition periods. 

A system of SAF transactions could also be relevant, in particular for POs B1 and B2 where airlines have to 
meet their SAF use obligation. This needs to come with the appropriate safeguards to avoid double counting. 
Such transactions for airlines could be set up under the auspices of the EU ETS and would work in the same 
way as the trading of allowances. Such a transaction system between airlines would only be relevant for POs 
B1 and B2, and is not relevant for POs A1, A2, C1 and C2, as airlines are not subject to SAF obligations. 

132   The well-to-wing jet fuel CO2 intensity reduction reported here does not include the multiplier,  to show the actual reduction in the CO2 

intensity of fuels.  

36 

 
                                                           
As shown in Table 2, section 5.3, there is no policy option where the transaction system applies at the same 
time to airlines and fuel suppliers. It applies only to airlines in POs B1 and B2, and only to suppliers in POs C1 
and C2. It should be noted that such a system does not require additional new IT support or structure, as it relies 
on existing schemes, i.e. the EU ETS (POs B1 and B2) or the monitoring process of the EU agency (POs C1 
and  C2),  for  which  administrative  costs  are  already  accounted  (see  sections  6.2.9  and  Annex  3).  It  can  be 
operationalised through the legal text of the current initiative or in the case of POs B1 and B2 under the ETS. It 
does not strictly need to be operational as from entry into force of the present initiative, but only by 2025, when 
the SAF obligation begins.  

5.5.  How do policy options differ? 

5.5.1.

  Technology-neutrality, volume-based and CO2 intensity reduction-based approaches 

This initiative aims to operate a gradual transition in the fuel mix of aviation. Concretely, this means replacing 
a fuel technology (conventional fossil kerosene) that leads to high emissions, with fuel technologies (SAF) that 
achieve much lower emissions on a lifecycle basis. Therefore, a choice is made between different technologies, 
based on their ability to deliver the expected climate benefits in a cost-effective way. Not all fuel technologies 
can be treated in the exact same way simply because certain technologies (advanced biofuels, Part B biofuels, 
RFNBOs – synthetic fuels) have much higher potential to attain the objectives in the short term, as the situation 
requires.  Some  (crop-based  biofuels)  have  too  limited  decarbonisation  potential  and  others  (hydrogen  and 
electricity)  have  potential  only  in  the  longer-term  and  still  require  significant  research  and  development. 
Furthermore,  the  RED  II  framework  promotes  certain  promising  technologies  (advanced  biofuels)  to  count 
more towards meeting the target via multipliers133, or incentivises them with specific sub-mandates134.  

Because of the facts explained above, it is difficult to design perfectly technology-neutral policy options. The 
proposed policy options in section 5.3 take the following approaches for the SAF target setting: 

  Volume-based approach. Policy options A1, B1, B2, C1 contain a volume-based obligation and a sub-
mandate  on  RFNBOs.  The  volume-based  approach  is  moderately  technology-neutral  and  it  is 
generally associated with technology choices. It proves efficient to support the scale up of SAF. Indeed, 
it  de-risks  investments  by  providing  certainty  about  the  mandated  amounts.  It  is  also  easier  to 
implement as supplied amounts can be measured and thus easily verified. On the contrary, emissions 
savings can only be estimated based on a complex life cycle assessment usually conducted by the fuel 
producer.  The  sub-mandate  on  RFNBOs  is  justified  by  the  high  potential  of  this  fuel  technology  to 
deliver important climate benefits, the high price difference in comparison to conventional jet fuels and 
other SAF options, and the need for a swift scale up of production capacity that facilitates the reduction 
of technology costs.  

  CO2  intensity  reduction-based  approach.  Policy  options  A2  and  C2  contain  a  CO2  intensity 
reduction-based obligation and a multiplier on RFNBOs. The CO2 intensity reduction-based target is 
generally  recognised  as  technology-neutral  because  it  does  not  impose  the  scaling  up  of  certain 
technologies  to  determined  levels,  but  lets  the  market  react  based  on  the  CO2  performance  of  each 
technology. SAF can count towards meeting the target to the extent of the CO2 intensity reduction they 
achieve. To respect the technology-neutrality dimension of this approach, it was preferred to opt for a 
multiplier on RFNBOs, to help reduce the gap of cost-effectiveness between RFNBOs and advanced 
biofuels. A multiplier is a lighter form of support, compared to a sub-mandate. It provides less certainty 

133   Pursuant  to  the  recast  Renewable  Energy  Directive  -  Article  27(2a),  the  share  of  biofuels  and  biogas  for  transport  produced  from  the 

feedstock listed in Annex IX may be considered to be twice its energy content 

134   Pursuant to  the  recast  Renewable Energy  Directive  -  Article  25(1),  the  contribution  of  advanced  biofuels and  biogas produced  from  the 
feedstock listed in Part A of Annex IX as a share of final consumption of energy in the transport sector shall be at least 0.2 % in 2022, at 
least 1 % in 2025 and at least 3.5 % in 2030. 

37 

 
                                                           
that innovative types of fuel are developed at commercial scale. Claims about achieved CO2 emission 
reduction may also be more difficult to verify. The value of this multiplier decreases over time, as the 
cost  efficiency  of  RFNBOs  improve.  The  values  of the  multipliers  are  tailored to  provide  a  boost  to 
RFNBOs, and correspond to the value necessary to bridge the price difference between RFNBOs and 
advanced biofuels. As the price difference evolves over time, i.e. RFNBOs prices go down, hence the 
value of the multiplier also decreases over time from 1.6 to 1.2. By 2045, as RFNBO prices become 
aligned with advanced biofuel prices, the multiplier value is 1. 

It is essential to highlight that under the present initiative, all policy options (except PO B2)135 achieve the same 
reduction of CO2 emissions overall. Therefore, the choice of approach (volume or CO2 intensity) will not 
determine the level of climate ambition of this initiative. Rather, it will determine how the market will make 
choices and orient SAF production towards scaling up the different SAF technologies. 

5.6.  Options discarded at an early stage 

5.6.1.

  Obligation on airlines, reduced scope, higher SAF blend ratios 

This  option  consists  of  the  same  as  PO  B2,  with  the  exception  that  the  SAF  blend  ratios  are  increased  to 
compensate for the reduction of scope (only intra-EEA) and achieve the same climate ambition as PO B1. This 
means that airlines operating intra-EEA traffic are required to uptake around 3 times as much SAF as under PO 
B2. This is explained because jet fuel used for intra-EEA traffic amounts to around one third of the total jet fuel 
used for intra and extra-EU flights departing from EU airports. The remaining two-thirds are used for extra-EU 
flights  departing  from  EU  airports. This  means  that  airlines  would  be  required to  use  already  100%  SAF  by 
2040. Post-2040, even with 100% SAF they will not be able to deliver on the same climate ambition as PO B1. 
For this reason, this option has not been retained. 

5.6.2.

  Voluntary agreements 

This option consists of relying on the evolution of the market, with the expectation that airlines and the fuel 
industry will increasingly engage in offtake agreements. This option was initially suggested by certain market 
actors.  However,  it  appears  from  the  research  conducted  in  the  context  of  this  impact  assessment  and  other 
stakeholders’ views that the efficiency of this option would be limited, as there are no reasonable grounds to 
believe that market forces alone would achieve the desired level of SAF production and uptake by 2050, and 
therefore, contribute effectively towards meeting the EU climate objectives. 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

6.1. 

Environmental impacts 

6.1.1.

Impacts on the aviation fuel mix 

All  POs  lead  to  a  significant  increase  of  the  share  of  SAF  in  the  aviation  fuel  mix  driven  by  the  fuel 
obligations, gradually starting from 2025. By 2030, under all POs except for PO B2, SAF accounts for 5% 
(i.e.  2.3Mtoe  of  SAF)  of  total  jet  fuel  consumption  at  EU  airports  (i.e.  an  increase  of  4.8  percentage  points 
compared to the baseline). In PO B2 SAF accounts for only 1.6% (i.e. 0.7Mtoe of SAF) of total jet fuel demand 
(i.e. an increase of 1.4 percentage points compared to the baseline). This is explained by the fact that the SAF 
obligation  under  PO  B2  applies  to  intra-EU  traffic  only136.  In  the  early  years  of  the  SAF  obligation, 
advanced biofuels (ATJ route) and Part B biofuels (HEFA route) are the main types of SAF fulfilling the 

135   PO B2 achieves lower emissions reductions because the scope is limited to intra-EU. 
136   This difference in scope between PO B2 and the other options is an important driver of the differences in impacts. The energy use in intra-
EU air transport represents only around one third of the total air transport energy demand.  For the sake of readability, the  text does not 
repeat this. 

38 

 
 
                                                           
obligation  under  all  POs  (except  for  PO  B2),  with  respectively  1.8-1.9%  and  1.6-1.7%  and  of jet  fuel  used. 
Imported biofuels account for a more limited share, projected at 0.9% of all jet fuel use. Under PO B2, only 
Part  B  biofuels  and  imported  biofuels  are  used  to  meet  the  obligation.  The  predominant  use  of  advanced 
biofuels  (ATJ  route)  and  Part  B  biofuels  by  2030  is  explained  by  the  fact  that  advanced  biofuels  (Gas+FT 
route) emerge in 2035, 10 years later than the ATJ route137. RFNBOs would represent about 0.2 to 0.7% of the 
fuel mix in 2030 (0.2% in PO B2, 0.5% in PO A2, 0.6% in POs C2 and 0.7% in POs A1, B1 and C1). This 
highlights that POs following a volume-based approach and a sub-mandate on RFNBOs (POs A1, B1 and 
C1)  achieve  higher  RFNBOs  supply/uptake  (except  PO  B2,  for  scope  reasons).  POs  following  a  CO2 
intensity  reduction approach,  including  a  multiplier on  RFNBOs  (POs  A2  and C2),  achieve  somewhat  lower 
RFNBOs  uptake.  This  trend  is  confirmed  over  time.  The  multiplier  provides  an  incentive  for  the  uptake  of 
RFNBOs under the CO2 intensity reduction approach; in its absence the uptake of RFNBOs would be lower. 

Table 5 - Aviation fuel mix by production pathway in the policy options in 2030 and 2050. 
PO B2 
Aviation fuel mix (in 
%) 

PO A1 

PO B1 

PO A2 

PO C1 

PO C2 

Biokerosene 

HEFA route 

Gas+FT route 

ATJ route 

Imports 

RFNBOs 

Electricity 

Kerosene 

2030 

2050 

2030 

2050 

2030 

2050 

2030 

2050 

2030 

2050 

2030 

2050 

4.3% 

1.6% 
0.0% 

1.8% 

0.9% 

0.7% 

0.0% 

34.8% 

4.0% 
12.9% 

12.9% 

5.0% 

27.9% 

0.5% 

4.5% 

1.7% 
0.0% 

1.9% 

0.9% 

0.5% 

0.0% 

38.7% 

4.5% 
14.4% 

14.3% 

5.6% 

23.9% 

0.5% 

4.3% 

1.6% 
0.0% 

1.8% 

0.9% 

0.7% 

0.0% 

34.8% 

4.0% 
12.9% 

12.9% 

5.0% 

27.9% 

0.5% 

1.4% 

1.1% 
0.0% 

0.0% 

0.3% 

0.2% 

0.0% 

10.9% 

2.5% 
0.3% 

4.8% 

3.3% 

8.7% 

0.5% 

4.3% 

1.6% 
0.0% 

1.8% 

0.9% 

0.7% 

0.0% 

34.8% 

4.0% 
12.9% 

12.9% 

5.0% 

27.9% 

0.5% 

4.5% 

1.7% 
0.0% 

1.9% 

0.9% 

0.6% 

0.0% 

38.7% 

4.5% 
14.4% 

14.3% 

5.6% 

23.9% 

0.5% 

95.0% 

36.8% 

95.0% 

36.8% 

95.0% 

36.8% 

98.4% 

79.9% 

95.0% 

36.8% 

95.0% 

36.8% 

Source: Ricardo at al. Impact assessment support study; PRIMES-TREMOVE, E3Modelling 

Towards 2040 and 2050, as SAF take over a large part of the aviation fuel mix, the SAF mix becomes 
more diversified under all POs. By 2050, under all POs, SAF accounts for around 63% (i.e. 28-29Mtoe) of 
total jet fuel use (i.e. an increase of around 60 percentage points compared to the baseline), except for PO B2 
where SAF accounts for only 20% of total jet fuel use at EU airports. RFNBOs and advanced biofuels are the 
largest  contributor  to  the  aviation  fuel  mix  under  all  POs  (except  for  POB2)  by  2050.  For  POs  with  a 
volume based target including a sub-mandate on RFNBOs (A1, B1, and C1), RFNBOs account for 28% of the 
total jet fuel mix, i.e. 13Mtoe (except for PO B2 where a share of 9% is projected, explained by the intra-EU 
scope). Where SAF obligations are expressed in terms of CO2 intensity reduction (POs A2 and C2), RFNBOs 
account for  24% (i.e.  11Mtoe)  of  the total jet  fuel  mix. Thanks to technology  development  supported  by  the 
increase  of  the  SAF  ramp-up,  advanced  biofuels  (Gas+FT  route)  reach  commercial  scale  around  2035.  The 
share of Gas+FT route and ATJ route is projected to be relatively similar by 2050, providing together 26-29% 
of the aviation fuel mix under all POs (except B2). As Gas+FT route biofuels, ATJ route biofuels and RFNBOs 
are  deployed  on  large  scale  by  2050  and  significantly  contribute  towards  the  fuels  obligations,  the  share  of 
HEFA route biofuels and imported biofuels would be limited, representing 2-5% and 3-6% of the aviation 
fuel mix respectively. By 2050, electricity use is projected to represent around 0.5% of the aviation fuel mix in 
all POs. 
The  aviation  fuel  mix  differs  across  Member  States  depending  on  the  flexibility  allowed  in  the  SAF 
supply.  Under POs  A1,  A2  and  B1,  the  fuel  mix is estimated  to  be  the  same  in  each  Member  State. This  is 
explained  because  fuel  suppliers  (in  POs  A1  and  A2)  are  required  to  respectively  supply  and  use  the  same 
minimum share of SAF at all EU airports, and because under POs B1 and B2, all airlines are required to use the 
same minimum share of SAF. For PO B2 the shares are the same for all Member States when considering the 

137   While  the  production  costs  of  these  two  routes  become  rather  similar,  the  earlier  deployment  of  the  ATJ  route  is  due  to  its  technology 
maturity and availability that is enabled earlier in time by developments in ethanol production from lignocellulosic feedstocks, as opposed 
to biomass gasification and conversion of syngas to fuels. 

39 

 
                                                           
intra-EU scope138.  On the other hand, differences in the aviation fuel mix can be observed between EU airports 
and Member States under POs C1 and C2. This comes as a result of the transition period allowing for flexibility 
in the supply from 2025 to 2035. Section 6.2.2 explains the benefits of this flexibility in terms of logistics costs. 
Until the end of the transition period, the shares of SAF can be lower in some  Member States that have low 
passenger  traffic  and  low  feedstock  availability  (e.g.  CY,  MT).  It  can  be  higher  for  Member  States  with  the 
busiest airports and highest feedstock availability (e.g. FR, DE, IT). It is worth noting that even with flexibility 
in the SAF supply by 2035, SAF is used in all Member States by 2025. The details at Member State level are 
provided in Annex 4.  

All  POs  result  in  a  reduction  of  the  fossil  fuels  use  relative  to  the  baseline.  By  2030  the  reduction  is 
estimated  at  3%  relative  to  the  baseline  in  PO  B2  (i.e.  1.6Mtoe)  and  at  around  7%  in  all  other  POs  (i.e. 
3.2Mtoe). By 2050 PO B2 would reduce the fossil fuels used in aviation by about 22% relative to the baseline 
(i.e. 11 Mtoe) and all other POs by around 65% (i.e. 31-32 Mtoe).  

6.1.2.

Impact on feedstock and renewable electricity needs 

From 2025 to 2050, there is sufficient used cooking oil in the EU to ensure Part B biofuels production for 
aviation and other transport modes in all POs. The needs for used cooking oil to produce Part B biofuels for 
aviation increases steadily over time. By 2030, under POs A1, A2, B1, C1 and C2, the production of Part B 
biofuels for aviation requires 28% of the total available used cooking oil (UCO) in the  EU139. The remaining 
72%  of  EU’s  stocks  of  used  cooking  oil  are  consumed  in  other  transport  sectors  such  as  road  transport  and 
maritime. Towards 2040 and 2050, aviation would need more used cooking oil, while other sectors such as 
road transport would need it less due to the high potential for the electrification in the sector140. By 2040 
and  2050,  Part  B  biofuels  for  aviation  would  consume  respectively  up  to  43%  and  53%  of  the  EU’s  total 
available used cooking oil, meaning that by 2040 and 2050, respectively 57% and 47% of the EU’s UCO stocks 
will  be  available  for  biofuel  production  in  other  transport  modes.  This  coincides  with  the  large  scale 
electrification of the road transport vehicle fleet, and the resulting decrease in demand for biofuels that will take 
place in the sector. Under PO B2, Part B biofuels would require around 19% and 33% of the available used 
cooking oil in the EU, respectively in 2030 and 2050.  

This analysis considers that other types of Part B feedstock would remain entirely dedicated to biofuel 
production  for  other  transport  modes.  It  should  be  noted  that  animal  fats  are  another  important  source  of 
feedstock  for  Part  B  biofuels  production,  representing  25%  of  total  Part  B  feedstock  use  for  EU  biofuel 
production  in  2019141.  For  simplicity,  this  section  considers  that  all  animal  fats  will  be  used  for  biofuel 
production in other transport modes. Finally, the revision of RED II may lead to the enlargement of Annex IX 
Part B to other types of waste lipids, thereby allowing for even greater feedstock availability in the EU.  The 
potential  displacement  of  biofuels  from  road  to  aviation  is  expected  to  be  low.  With  Part  B  feedstock 
contributing  by  15%  to  EU27’s  road  biofuel  production142,  used cooking  representing  around  75%  of  Part B 
feedstock  used  for  this  production143,  and  an  anticipated  28%  and  53%  use  of  used  cooking  oil  for  SAF 
production  respectively  by  2030  and  2050,  all  POs  of  the  present  initiative  would  result  in  a  potential 
displacement of biofuels from road to aviation of 3.2% and 5.9% by 2030 and 2050. This would be even lower 
under PO B2, i.e. 2.1% and 3.7%. 

138   When reporting the share of SAF in total aviation fuel mix at Member State level, the shares of intra- and extra-EU aviation also play a role 

thus leading to different shares by Member State. 

139   The policy context of POs is established within the Climate Target Plan ambition, which means that significant quantities of bioenergy are 
demanded also by other transport modes (including international maritime) and energy sectors. The high demand context refers to POs A1, 
A2, B1, C1 and C2 while low demand context refers to PO B2.  

140   This  conclusion  is  supported  by  the  analysis  underpinning  the  impact  assessment  accompanying  the  2030  Climate  Target  Plan  and  the 

Sustainable and Smart Mobility Strategy.  
141   Source: Biofuels Annual – USDA 2020.  
142   Biofuels Barometer - A study carried out by EurObserv’ER. – 2020. 
143   Source: Biofuels Annual – USDA 2020. 

40 

 
 
                                                           
Table 6- Share of the available feedstock in the EU used for SAF production. Blue: all POs except PO B2. Red: PO B2. 

Source: Ricardo at al. Impact assessment support study; PRIMES-TREMOVE, E3Modelling 
Note: UCO stands for used cooking oil. Solid biomass refers to feedstock included in Annex IX Part A. 

The  substantial  production  of  advanced  biofuels  for  aviation  would  rely  on  a  diversity  of  feedstock 
sourced in  the  EU,  and  available  stocks  should  be  sufficient. The  needs  for  solid  biomass  feedstock144  to 
produce advanced biofuels for aviation increase steadily over time. By 2030, under POs A1, A2, B1, C1 and 
C2,  the  production  of  advanced  biofuels  for  aviation  requires  2.7%  of  the  EU’s  total  available  potential  of 
agricultural and wood waste. By 2040 and 2050, as advanced biofuels reach significant shares of the fuel mix, 
the demand for solid biomass increases. The supply of advanced feedstock diversifies over time with the use of 
forestry  residues  and  energy  crops,  which  limits  the  strain  on  specific  supply  chains.  By  2050,  advanced 
biofuels (ATJ and Gas+FT routes) require about 11% of the EU’s available potential of agricultural residues 
and wood waste, 3.0% of the available potential of forestry products and residues, and 9.4% of the available 
potential  of  energy  crops.  Under  PO  B2,  demand  for  solid  biomass  reaches  2.0%  of  the  EU’s total  potential 
available agricultural and wood waste in 2040 and 2.7% in 2050. Forestry residues and energy crops also play a 
minor role between 2040 and 2050.  

Table 7 - Feedstock consumption for biofuel production in 2030 and 2050. 

Mtonnes 

Baseline 

Policy Option A1 

Policy Option A2 

Policy Option B1 

Policy Option B2 

Policy Option C1 

Policy Option C2 

UCO 

0.05 

1.10 

1.14 

1.10 

0.59 

1.10 

1.14 

2030 

Solid biomass 

0.02 

5.52 

5.72 

5.52 

0.00 

5.53 

5.72 

UCO 

0.69 

2.8 

3.1 

2.8 

1.4 

2.8 

3.1 

2050 

Solid biomass 

0.43 

62.5 

69.8 

62.4 

7.6 

62.5 

69.8 

Source: Ricardo at al. Impact assessment support study; PRIMES-TREMOVE, E3Modelling. 
Note: UCO stands for used cooking oil. Solid biomass refers to feedstock included in Annex IX Part A 

While Part B feedstock will play a non-negligible role to bring (affordable) SAF to aviation in the first 
years,  overall  the  largest  share  of  SAF  will  be  produced  from  Part  A  feedstock.  Looking  at  the  total 
feedstock volumes needs in the table above, under all POs, Part B feedstock such as used cooking oil represent 
around 17% of total SAF feedstock by 2030. PO B2 would fully rely on used cooking oil by 2030 but the level 
of feedstock used would be lower than in all other POs. The share of used cooking oil in the biomass feedstock 
consumption decreases significantly over time. By 2050 it would only represent about 4% of the total feedstock 

144   Solid biomass means feedstock included in Annex IX Part A and includes feedstock such as agricultural and forestry residues, wood waste, 

forestry products (e.g. round wood), annual and perennial energy crops. 

41 

0.6%1.0%2.7%33%9.4%3.0%11%53%0%20%40%60%80%Energy cropsForestryAgri residuesand wood wasteUCO2050Series1Series20%0.3%0%19%0%0%2.7%28%0%20%40%60%80%Energy cropsForestryAgri residuesand wood wasteUCO2030Series1Series20%0.1%2%38%4.5%2.5%12%43%0%20%40%60%80%2040Low demandHigh demand 
 
 
                                                           
consumed in aviation in POs A1,  A2, B1, C1 and C2 and 16% in B2. By then, Part A feedstock account for 
around 84-96% of total feedstock needs under all POs.  

Competition  with  other  energy  and  transport  sectors  for  access  to  feedstock  will  increase,  but  SAF 
production will require a limited share of feedstock with regards to total feedstock availability. The POs 
are  fully  consistent  with  the  policy  context  where  the  EU  must  reach  its  climate  targets  of  55%  emission 
reductions by 2030 and climate neutrality by 2050. This results in a  significant increase of the demand for 
bioenergy from other energy and transport sectors, by around 82% between 2015 and 2050 (from about 140 
Mtoe to 255 Mtoe). This means higher competition between sectors of the economy for access to feedstock. On 
the supply side, the results show that there is abundance of EU-sourced available biomass to meet the demand 
increase. SAF production in the EU is expected to require less than 10% of all biomass feedstock used to 
meet bioenergy demand in a climate neutral context by 2050. 

Energy needs for the production of Part B and advanced biofuels are relatively low. Bioenergy production 
requires  energy  inputs  in  several  steps  in  the  production  process,  from  biomass  collection,  to  transport,  and 
conversion  of  biomass  to  bioenergy.  The  present  analysis  (using  the  PRIMES  Biomass  model)  takes  into 
account  the  energy  requirements  across  the  production  chain.  Accordingly,  the  production  of  all  bioenergy 
commodities projected in the context of EU climate neutrality, requires around 36 Mtoe of electricity, liquid 
fuels and gas in 2050. This corresponds to less than 3% of the overall energy supply (of electricity, liquid fuel 
and gas) for the same year. The share of energy inputs needed to produce Part B and advanced biofuels for 
aviation is less than 0.2% of the total energy supply in 2050.The production of RFNBOs is highly energy-
intensive  and  drives  an  increase  in  the  demand  for  renewable  electricity  in  the  EU.  RFNBOs  require 
electricity  that  is  100% renewable  to  produce  hydrogen  as  an  intermediate  product,  before  the  production  of 
synthetic  kerosene.  By  2030,  the  electricity  demand  for  RFNBOs  production  represents  between  0.04%  to 
0.13%  of the  EU’s  gross  electricity  generation  or  between  0.1%  and  0.4%  of the  EU’s  renewable  electricity 
generation. By 2050, the shares increase to 0.7-2.2% of the EU’s gross electricity generation, or 1.8% to 5.5% 
of  the  EU’s  renewable  electricity  generation145.  POs  expressed  with  a  volume-based  target  (A1,  B1,  C1)  are 
slightly  more  demanding  in  terms  of  renewable  electricity  requirements  than  those  expressed  with  a  CO2-
intensity reduction based target (POs A2 and C2). This is due to the lower supply of RFNBOs resulting from 
the CO2-intensity reduction based approach, even when accounting for the multiplier. Finally, electricity needs 
are the lowest in PO B2 which, by design, only applies the SAF obligation to intra-EU flights.  

Table 8 - Share of renewable electricity generation used for the production of RFNBOs. 

Policy Option A1 
Policy Option A2 
Policy Option B1 
Policy Option B2 
Policy Option C1 
Policy Option C2 

2030 
0.4% 
0.3% 
0.4% 
0.1% 
0.4% 
0.3% 

2050 
5.5% 
4.7% 
5.5% 
1.8% 
5.5% 
4.7% 

Source: Ricardo at al. Impact assessment support study; PRIMES-TREMOVE, E3Modelling. 

6.1.3.

Impacts on CO2 emissions 

All POs lead to significant reductions146 in EU27 CO2 emissions147 in the aviation sector on the well-to-
wing basis, compared to the baseline. The levels of reduction are similar between all POs by 2030 and 2050 by 
design, except PO B2 where the scope of the obligation covers only intra-EU flights. By 2030, CO2 emissions 

145   The  relative  shares  are  based  on  the  MIX  scenario  of  the  impact  assessment  accompanying  the  2030  Climate  Target  Plan  which  was 

quantified with the PRIMES energy systems model. 

146   Emissions savings achieved by specific SAF technologies are expressed relative to the RED II baseline for fossil fuel, i.e. 94gCO2e/MJ. 
147   Well-to-wing emissions: this take into account emissions over the entire life cycle of the jet fuel, from production to combustion. 

42 

 
 
 
 
                                                           
are lower by up to 6.6% in all POs compared to the Baseline, except B2 where the reduction is limited to 3.3%. 
The impact of POs becomes even more evident in the years leading to 2050. By 2050, CO2 emissions in the 
aviation  sector  are  lower  by  around  60-61%  in  all  POs  compared  to  the  Baseline,  except  for  B2  where  the 
reduction is limited to around 17%. The fact that all POs except B2 achieve very similar high levels of CO2 
reductions by  2030  and  2050,  by  the design  of the POs,  shows that similar  level  of  climate ambition  can  be 
achieved regardless of the choice of the obligated party (fuel suppliers as in PO A1 or airlines as in PO B1). 
This  also  holds  true  for  the  choice  of  the  target  setting  (volume-based  target  as  in  A1  or  CO2  intensity 
reduction target as in A2). On the other hand, the level of climate ambition strongly differs depending on the 
scope chosen for the obligation (jet fuel used on all intra and extra-EU flights as in B1 or only intra-EU as in 
B2). At EU level, considering that energy use for intra-EU flights represent only about one third  of the total 
aviation  fuel  use,  post-2030  it  would  not  be  possible  to  achieve  the  same  level  of  emissions  savings  even  if 
considering 100% SAF in the intra-EU fuel mix.  

Table 9 - Changes in the tank to wing and well to wing CO2 emissions in POs relative to the baseline. 
Air transport CO2 emissions (% change 
to Baseline) 

Baseline (Mt CO2) 

PO A1 

2030 

2040 

2050 

2030 

2040 

2050 

PO A2 

2030 

2040 

2050 

Tank to wing emissions 

Well to wing emissions 

Air transport CO2 emissions (% change 
to Baseline) 

Tank to wing emissions 

Well to wing emissions 

Air transport CO2 emissions (% change 
to Baseline) 

Tank to wing emissions 

Well to wing emissions 

140 

183 

143 

187 

144 

189 

-6.8% 

-6.5% 

Baseline (Mt CO2) 

-34.1% 

-31.4% 
PO B1 

-65.3% 

-60.8% 

-6.8% 

-6.5% 

-33.9% 

-31.0% 
PO B2 

-65.2% 

-60.2% 

2030 

2040 

2050 

2030 

2040 

2050 

2030 

2040 

2050 

140 

183 

143 

187 

144 

189 

-6.9% 

-6.6% 

Baseline (Mt CO2) 

-34.1% 

-31.4% 
PO C1 

-65.3% 

-60.9% 

-3.4% 

-3.3% 

-11.7% 

-10.1% 
PO C2 

-21.8% 

-17.4% 

2030 

2040 

2050 

2030 

2040 

2050 

2030 

2040 

2050 

140 

183 

143 

187 

144 

189 

-6.8% 

-6.5% 

-34.1% 

-31.4% 

-65.3% 

-60.8% 

-6.8% 

-6.5% 

-33.9% 

-31.0% 

-65.2% 

-60.2% 

Source: Ricardo at al. Impact assessment support study; PRIMES-TREMOVE, E3Modelling. 

On the tank to wing basis, the emissions reductions are projected to be slightly higher in the POs relative to the 
baseline, as shown in the table above, because by assumption biofuels are assigned a zero emission factor148. 
The 65% tank-to-wing CO2 emissions reductions relative to the baseline in 2050, projected to be achieved in all 
POs except for PO B2, translate in reductions of 58% in CO2 emissions by 2050 compared to 2015 and 24% 
emissions  reductions  relative  to  1990.  As  explained  in  section  2.1.1,  this  is  fully  consistent  with  the  climate 
neutrality objective for 2050. 

All POs achieve emissions reductions for the transport sector by 2030 and 2050. Total transport emissions 
(including international shipping) would reduce by 0.6% in 2030 relative to the baseline in PO B2 and by 1.1-
1.2% in all other POs. This is mainly driven by the SAF uptake in the aviation sector but also by the limited 
reduction in the transport activity relative to the baseline, driven by the higher air ticket prices. By 2050 PO B2 
would  result  in  around  4%  reduction  in  transport  emissions  relative  to  the  baseline  and  all  the  other  POs  in 
about 13-14% reduction. In relative terms the reduction is relatively similar when considering the tank to wheel 
and the well to wheel emissions.   

6.1.4.

Impacts on air pollutant emissions and non-CO2 emissions 

The introduction of increasing shares of SAF in the aviation fuel mix leads to somewhat higher ticket prices 
and a subsequent reduction of air transport activity compared to the baseline (see section 6.2). As a result, some 
reductions in air pollutant emissions (CO, NOx and PM)149 would take place in the aviation sector for all 
POs by 2030 and 2050. By 2030, air pollutant emissions would be 3.3 to 3.5% lower compared to the baseline 

148   Commission Regulation (EU) No 601/2012. 
149   The air pollutants considered include: CO (carbon monoxide), NOx (nitrogen oxide) and PM2.5 (particulate matter emissions). 

43 

 
 
                                                           
in  all  POs.  For  2050,  PO  B2  would  result  in  about  7%  reduction  in  air  pollutant  emissions  relative  to  the 
baseline  and  all  other  POs  in  about  9-10%  reduction.  In  addition  to  the  air  pollutant  emissions  reductions 
resulting from lower air transport activity, the substitution of fossil jet fuel with SAF may also deliver non-CO2 
benefits  under  all  POs.  Indeed,  it  is  considered  that  the  introduction  of  increasing  shares  of  SAF  in  aviation 
could lead to reductions of other non-CO2 emissions such as non-volatile particulate matter (nvPM) or sulphate 
(SO4)150. See Annex X for more information on non-CO2 benefits from SAF use.  

6.1.5.

  Environmental costs of aviation 

The environmental costs of aviation are reduced significantly under all POs relative to the baseline. In the 
Baseline scenario, the present value of external costs due to CO2 emissions is estimated at EUR 330 billion for 
the  period  2021-2050  (i.e.  CO2  emissions  from  air  transport  multiplied  by  the  price  of  CO2151).  The 
introduction of the SAF mandates leads to a reduction in the order of EUR 86-87 billion in all POs relative to 
the baseline, with the exception of PO B2, in which external costs are lower by around EUR 30 billion.  

6.2. 

Economic impacts 

6.2.1.

Impacts on SAF prices and the cost of jet fuel blend 

SAF prices are derived drawing on relatively conservative assumptions, considering the uncertainty associated 
to their future developments. The cost structure is such that variable non-energy costs152 of biofuels production 
are maintained within a range of 35% to 47% of total production costs (depending on the year and production 
pathway), which constitutes the second largest cost component for advanced biofuels and Part B biofuels, and 
the largest cost component in the case of Gas+FT route.  

SAF prices projections are fully embedded in the 2030 Climate Target Plan policy context, where the EU 
economy  is  moving  towards  carbon  neutrality  by  2050.  This  leads  to  strong  competition  for  biomass 
feedstock  with  other  energy  and  transport  sectors.  Feedstock  and  renewable  electricity  are  considered  to  be 
sourced  predominantly  in  the  EU,  in  order  to  support  the  reduction  in  energy  dependence.  This  further 
contributes to driving feedstock prices upwards.  

Prices for Part B biofuels (HEFA route) remain relatively stable over time and become lower than the 
projected conventional jet fuel prices by 2030 under all POs. They remain close to the current estimates (i.e. 
around EUR 1050 per tonne) under all POs (see Figure 3). They have limited scope for price reductions due to 
economies of scale153, since the technology is mature and their capital costs are already low (i.e. around 4% of 
the production costs). Feedstock costs are projected to slightly increase over time, due to the competition with 
other sectors. As fossil jet fuel prices are projected to increase over time, linked to the projected evolution of 
the oil prices, Part B biofuels prices reach the break-even point and become more economically attractive by 
2030. They are projected to be around 2% lower by 2030 (close to EUR 1005 per tonne) and 16% lower by 
2050 (around EUR 1048 per tonne) relative to fossil jet fuels under all POs.  

Prices for advanced biofuels (ATJ route) decrease significantly by 2035 relative to the current estimates 
under all POs. Post-2035 their prices follow an increasing trend, driven by the feedstock costs. The early 
emergence on the market of advanced biofuels (ATJ route) is a consequence of the mandatory SAF targets for 
2030, for which Part B biofuels are no longer sufficient. Advanced biofuels (ATJ route) are therefore the next 
least expensive SAF type (EUR 2086 per tonne in 2030) that the supply industry turns to in all POs (except PO 

150   Updated analysis of the non-CO2 climate impacts of aviation and potential policy measures pursuant to the EU Emissions Trading System 

Directive Article 30(4). 
https://ec.europa.eu/clima/news/updated-analysis-non-co2-effects-aviation_en 

151   CE Delft et al. (2019), Handbook on the external costs of transport.  
152   Costs such as those of catalysts, enzymes, other utilities used in the conversion processes, as well as waste management. 
153   Annex 16 provides details on how economies of scale are achieved for SAF technologies. 

44 

 
 
                                                           
B2), since RFNBOs are still more expensive by that time (estimate at around EUR 2968 per tonne in 2030). 
While economies of scale allow to decrease capital costs and operational costs over time under all POs, this is 
outweighed by the increase of feedstock prices post-2035. By 2030, advanced biofuels (ATJ route) are still 2 
times more expensive than fossil jet fuels. However, the price gap ratio decreases slowly over time. By 2040 
and 2050, these fuels are respectively 1.9 and 1.7 times more expensive than fossil jet fuels. 

Prices  for  advanced  biofuels  (Gas+FT  route)  are  projected  to  decrease  compared  to  the  current 
estimates.  Their  level  would  however  remain  relatively  stable  during  2035-2050  due  to  increasing 
feedstock costs over time. These fuels are projected to emerge in the market in large volumes between  2035 
and 2040 in all POs (except PO B2) at a price of around EUR 2039 per tonne. Capital costs would decrease by 
around  23%  between  2035  and  2040  due  to  economies  of  scale  and  learning  effects  and  stabilise  thereafter. 
During 2040-2050 these reductions are however outweighed by the rise in feedstock costs in all POs (except 
PO B2154). All POs nevertheless contribute to reducing the Gas+FT biofuels prices compared to the currently 
estimated levels. The advanced biofuels (Gas+FT route) prices are projected to be 1.9 times higher than those 
of  fossil  jet  fuels  in  2035,  going  down  to  1.8  in  2040  and  1.7  times  by  2050.  The  projected  prices  for  the 
Gas+FT  route  draw  on relatively  conservative  assumptions for  variable non-energy  costs,  which  decrease by 
4%  during  2035-2050  and  constitute  the  largest  cost  component  (45%  of  total  production  costs  by  2050155), 
ahead of feedstock costs (33% of total production costs by 2050). If variable non-energy costs are assumed to 
decrease at faster pace the impact on reducing the Gas+FT biofuels prices relative to the currently estimated 
levels would be higher.  

RFNBOs  reach  the  market  much  earlier  than  under  the  baseline  and  prices  decrease  significantly  by 
2050 under all POs. Whereas in the baseline scenario, RFNBOs do not make inroads in the fuel mix, all POs 
allow to introduce them on the market as early as 2030. RFNBOs prices decrease by 22% from 2030 to 2040 
and  by  an  additional  17%  from  2040  to  2050  and  follow  very  similar  trends  over  time  across  all  POs.  The 
decrease in prices is explained by a reduction in the costs of electrolysers needed for the production. Whereas 
by 2030, RFNBOs are projected to be 2.9 times more expensive than fossil jet fuel, this gap ratio reduces over 
time and becomes 2 and 1.5 respectively by 2040 and 2050 under all POs. 

It should be noted that current estimates for the SAF prices, drawing on literature review (see  Figure 3) and 
discussed above in relation to the evolution of the SAF prices, do not consider a profit margin on production 
costs,  while  the  model  projections  consider  a  profit  margin  of  10%.  This  means  that  the  SAF  prices  are 
projected to decrease even more over time relatively to the current estimates.      

Figure 3: SAF prices – current estimates and projections in the policy options (except PO B2). 

154   In PO B2 no significant decreases in the capital costs take place during 2035-2040 as the Gas+FT biofuels are not deployed at scale.  
155   Such  contribution  levels  to  the  total  production  costs  are  in  line  with  the  literature  (Baker  et  al.,  2017;  de  Jong  2015,  IRENA  2016, 

WEF2020). 

45 

 
                                                           
Source: Ricardo at al. Impact assessment support study; PRIMES Biomass and PRIMES-TREMOVE models, E3Modelling. 
Note: Current cost range is based on literature review and do not include a profit margin. The projected SAF prices for 2030-2050 also 
include a profit margin of 10% on top of production costs. 
Overall,  SAF  prices  become  more  competitive  with  fossil  jet  fuel  over  time  in  all  POs,  although  the 
average jet fuel blend remains more costly than conventional jet fuel. This is the result of a combination of 
factors.  First,  under  all  POs,  the  current  costs  of  SAF  decrease  over  the  next  decade  compared  to  current 
estimates, due to the introduction of the blending mandate. This provide strong and long-term market certainty 
for fuel producers and investors. Second, in the baseline scenario and all POs, fossil jet fuel prices are expected 
to  rise  gradually  over  time  (+21% between  2030 and  2050)  in  line  with  the  development  of international  oil 
prices.  This  contributes  to  bridging  the  price  differential  and  making  SAF  gradually  more  economically 
attractive compared to conventional jet fuel over time.  

Economies of scale and learning effects allow SAF production costs to decrease over time. The analysis 
assumes that advanced biofuel producers implement measures with a view to improve their production process, 
which  results  in  the  scale-up  of  production  at  lower  cost.  This  is  particularly  relevant  for  advanced  biofuel 
production routes (ATJ and Gas+FT routes) and RFNBOs that are not yet deployed at commercial scale. The 
scale-up  of  SAF  production  contributes  to  the  reduction  of  scalable  cost  components  such  as  capital  and 
variable costs. This is the case because SAF production costs evolve from the current state of the market where 
SAF  production  is  in  its  infancy  and  SAF  production  capacity  is  extremely  limited.  Similarly  to  advanced 
biofuel routes, the demand for RFNBOs drives an increase in hydrogen demand and eventually leads to large-
scale  deployment  of  hydrogen  generation  technologies.  The  modelling  considers  learning-by-doing  effects, 
reducing  the  costs  of  electrolysers  over  time,  which  is  a  critical  cost  component.  At  the  moment,  SAF 
production consists essentially of demonstration projects where SAF outputs are negligible, hence production 
costs and resulting prices are high. In the presence of a blending mandate, cost reductions are expected to take 
place in particular in the short to medium term, i.e. 2025-2030. In addition, a regulatory intervention such as a 
SAF  blending  mandate,  obliging  one  side  of  the  market  to  supply  SAF  provides  the  necessary  long-term 
certainty  for  investments  to  take  place  to  develop  new  or  expand  existing  SAF  production  capacity, 
leading  to  economies  of  scale.  This  translates  into  the  conversion  of  demonstration  plants  into  full-size 
commercial plants as well as in the construction of new SAF production plants, and thereby helps achieving 
economies of scale, bringing SAF prices down. More information on the role of economies of scale is available 
in Annex 16. 

Under all POs, while the SAF blending mandate allows to bring SAF costs down compared to current 
estimates,  it  results  in  an  increase  in  the  average  price  of  the  blended  jet  fuel  over  time.  Indeed,  the 

46 

 
 
average jet fuel blend price increases as a result of the participation of more expensive fuels in the mix. Policy 
options A1, A2, B1, C1 and C2 which foresee a similar and significant participation of SAF in the average fuel 
mix, result in small differences mainly caused by the different composition of the fuel mix resulting from the 
use  of  volume-based  and  CO2  intensity  reduction-based  targets.  On  the  contrary,  Policy  option  B2  which 
foresees lower SAF participation results in a lower overall price increase. 

When looking at competition for feedstock by various sectors of the economy, and the relative impacts on the 
price of SAF, it is also important to consider possible price rigidities on the supply or the demand sides of the 
market.  

Table 100 - Average jet fuel blend prices in the baseline and policy options in EU27. 

2030 (€/toe) 

Increase on 
baseline 

2040 (€/toe) 

Increase on 
baseline 

2050 (€/toe) 

Increase on 
baseline 

Baseline 
PO A1 
PO A2 
PO B1 
PO B2 
PO C1 
PO C2 

1028.4 
1062.5 
1060.2 
1062.5 
1033.8 
1062.7 
1060.5 

3.3% 
3.1% 
3.3% 
0.5% 
3.3% 
3.1% 

1146.9 
1401.9 
1393.0 
1401.9 
1195.1 
1402.1 
1393.1 

22.2% 
21.5% 
22.2% 
4.2% 
22.3% 
21.5% 

1246.1 
1653.5 
1651.4 
1653.6 
1332.6 
1653.5 
1651.2 

32.7% 
32.5% 
32.7% 
6.9% 
32.7% 
32.5% 

Source: Ricardo at al. Impact assessment support study; PRIMES Biomass and PRIMES-TREMOVE models, E3Modelling 

6.2.2.

Impacts on SAF supply logistics 

The design of POs have different impacts in terms of logistic costs, due to the way distribution of SAF-
blended jet fuel to airports takes place. SAF production in the early years of the obligation (from 2025 to 
2030) is expected to be centralised to a limited number of SAF production plants (see section 6.2.5). Imposing 
SAF distribution at each EU airport is possible, but may result in higher logistics costs. POs A1, A2, and B1 
follow this logic and incur roughly the same logistic costs (e.g. annual additional costs for 2030 are estimated at 
€14 million at EU level). PO B2 also incurs logistic costs following the same logic, but to a lower extent given 
the supply of lower SAF volumes. On the other hand, SAF supply is achieved in a more cost-effective way if 
fuel suppliers have the flexibility to focus their SAF distribution to a more limited number of airports, in 
particular airports connected to pipelines156. This is the case under POs C1 and C2 from 2025 to 2030, where no 
extra logistic costs are estimated. From 2030 to 2035, fuel suppliers retain a degree of flexibility in their SAF 
distribution, but must nevertheless supply all airports with a minimum of SAF. Over this period, logistic costs 
under POs C1 and C2 increase but would be lower than for POs A1, A2 and B1, since suppliers would still 
make best use of the flexibility to distribute in a cost-effective way. Towards 2040 and 2050, supplying all 
EU airports becomes less costly157, as SAF production is more de-centralised. As the number of SAF plants 
across the EU increases, with a more homogeneous spread across the EU, distances to blending facilities, oil 
terminals and airports are shortened, which reduces logistic costs. Therefore under all POs, the logistical costs 
per unit of SAF supplied decreases between 2040 and 2050. Annex 4 describes the methodology for calculating 
the logistics costs. The additional SAF supply logistics costs relative to the baseline, expressed as present value 
over the 2021-2050 horizon, are estimated at €0.27 billion in PO A1, A2 and B1, €0.09 billion in PO B2 and 
€0.19 billion in PO C1 and C2. 

6.2.3.

Impacts on the total cost of aviation 

All policy options lead to some small reductions in the total cost of aviation158 in 2030, compared to the 
baseline. The reduction is the highest in PO B2 (€1 billion or 0.3% lower relative to the baseline) and around 

156   Distributing SAF-blended jet fuel at airports that are connected with pipelines incurs low logistic costs per unit of fuel. All volumes of SAF 

can be shipped to the same location for introduction in the fuel system. 

157   Less costly on average per unit of fuel supplied. 
158   Total cost of aviation accounts for capital costs, fixed and variable non-fuel costs, and fuel costs. 

47 

 
 
 
 
 
 
 
                                                           
€0.5-0.6  billion  for  all  other  POs  (0.1-0.2%  lower  than  the  baseline).  This  is  primarily  due  to  the  somewhat 
lower passenger air transport activity compared to the baseline, which leads to lower capital and operation costs 
that outweigh the higher fuel costs. In the long term, by 2050, higher SAF blending rates result in higher 
total  aviation  cost  compared  to  the  baseline  estimated  at  €9-10  billion  (1.8-2.1%  increase  relative  to  the 
baseline). Only PO B2, due to the reduced scope of intervention, shows lower costs relative to the baseline in 
2050 (€1 billion or 0.2% decrease relative to the baseline).   

Over the entire time horizon up to 2050, the total costs of aviation (expressed as present value over the 
2021-2050 period) increase by EUR 14 to 20 billion relative to the baseline (0.2 to 0.3% increase compared 
to the baseline). PO B2 is the only option which shows lower costs due to its reduced scope. Expressed in terms 
of share of GDP these additional costs are however very limited at below 0.01% of GDP in all POs.   

Table 111 - Total costs for the air transport sector in the policy options relative to the baseline (present value over the 2021-2050 
period). 

Difference in costs compared to baseline - present value 2021-2050 
(bil. €'2015) 

Baseline (bil. 
€'2015) 

PO A1  PO A2  PO B1  PO B2  PO C1  PO C2 

Capital costs 
Fuel costs  
Operation costs 

2,442 
792 
3,064 
6,298 

-31.1 
103.5 
-52.9 
19.6 

-27.2 
88.3 
-47.2 
13.9 

-30.9 
102.7 
-52.6 
19.2 

-12.1 
14.7 
-23.5 
-20.9 

-31.0 
103.5 
-53.0 
19.5 

-27.2 
88.2 
-47.3 
13.8 

Total costs for the air transport sector 
Source: Ricardo at al. Impact assessment support study; PRIMES-TREMOVE, E3Modelling. 

Total aviation costs are lower in the policy options where the SAF targets are expressed in terms of jet 
fuel CO2 intensity reduction compared to those expressed in volume based terms. Indeed, POs A2 and C2 
lead  to  lower  additional  costs  of  €6  billion  (29%)  than  POs  A1  and  C1,  when  compared  to  the  baseline 
(expressed in present value terms). The lower cost projected for the jet fuel CO2 intensity reduction approach in 
this case is due to the flexibility allowed to fuel suppliers, even when considering the multiplier on RFNBOs, to 
choose the SAF fuel blend that delivers the required reduction in the CO2 intensity at lowest cost. This is also 
illustrated in section 6.1.1, showing that the share of RFNBOs in the jet fuel mix is lower under POs A2 and C2 
compared to POs A1 and C1. On the other hand, supporting the uptake of RFNBOs at early stages may have 
other benefits in terms of learning effects and lowering the demand pressure on the biomass feedstock to some 
extent.  

6.2.4.

Impacts on air ticket prices 

The impact on air ticket prices has been based on the following assumptions. First, the extra fuel cost due to 
SAF  purchase  is  fully  passed  on  to  the  passengers,  resulting  in  an  increase  of  the  ticket  price.  Ticket  price 
increases however can be lower should airlines absorb part of the additional costs, meaning that these impacts 
represent the maximum ticket price increase projected. Second, the share of fuel costs in total aviation costs is 
25%. This is the higher bound of the estimated range of the share of fuel costs in the total air transport costs 
that is most common in the literature, i.e. between 17% and 25%159. PO B2 results in significantly lower ticket 
price increase relative to the baseline when compared to all other options, since the SAF obligation applies only 
to intra-EU flights. As explained in section 6.2.2, this reduced scope lowers the fuel cost for the sector, hence 
the lower ticket price increases compared to the baseline. All other options show very similar increases in ticket 
prices relative to the baseline by 2050 (0.8% increase in 2030, 5.4-5.6% in 2040 and 8.1-8.2% in 2050). 

159   EUROCONTROL - Aviation Intelligence Unit – Think Paper #1 – June 2019. 

48 

 
 
 
 
                                                           
Table 122 – Changes in fuel costs and ticket prices in the policy options relative to the baseline.  

Fuel cost increase 

Ticket price increase 

PO A1 

PO A2 

PO B1 

PO B2 

PO C1 

PO C2 

2030 

3.3% 

3.1% 

3.3% 

0.5% 

3.3% 

3.1% 

2040 

22.2% 

21.5% 

22.2% 

4.2% 

22.3% 

21.5% 

2050 

32.7% 

32.5% 

32.7% 

6.9% 

32.7% 

32.5% 

2030 

0.8% 

0.8% 

0.8% 

0.1% 

0.8% 

0.8% 

2040 

5.6% 

5.4% 

5.6% 

1.1% 

5.6% 

5.4% 

2050 

8.2% 

8.1% 

8.2% 

1.7% 

8.2% 

8.1% 

Source: Ricardo at al. Impact assessment support study; PRIMES-TREMOVE, E3Modelling. 

6.2.5.

Impacts on SAF production capacity and investment needs 

All  POs  require  building  additional  SAF  production  capacity.  By  2030,  7  additional  SAF  plants160  are 
needed to meet the SAF obligation under all POs, except for PO B2 where only 3 additional SAF plants are 
needed. The increase is production capacity needs go up over time. By 2050, a total of 104-106 SAF production 
plants161 are needed across the EU to satisfy the SAF obligation under all options, except in PO B2 where only 
33 SAF plants are necessary across the EU. POs where the SAF obligation is expressed in CO2 reduction terms 
(A2 and C2) show slightly higher needs for plants producing advanced biofuels (ATJ and Gas+FT route), and 
less needs for RFNBOs production facilities.  

Figure 4 - Capital cost investments needed for SAF production plants (in € million). 

Source: Ricardo at al. Impact assessment support study. 
The  need  to  scale  up  SAF  production  capacity  in  the  EU  translates  into  significant  investment  needs 
under all POs. Investments needs over the period 2021 to 2050 amount to  €10.4-10.5 billion under all POs, 
except for PO B2 where they are around €3.3 billion. Overall, additional RFNBOs production sites, followed 
closely by advanced biofuels (Gas+FT route) require the highest investment needs. This is also the case under 
PO B2.  

160   7 additional plants, corresponding to an increase in production capacity of 2.2 million tonnes of SAF per year. 
161   104 to 106 additional plants, corresponding to an increase in production capacity of around 25.5-25.6 million tonnes of SAF per year for all 

POs, except for PO B2, 8.4 million tonnes of SAF per year. 

49 

 
 
 
 
 
  
 
                                                           
6.2.6.

Impacts on the EU’s energy dependence 

The EU reduces significantly its dependency on oil imports under all POs. All POs (except PO B2) lead to 
a reduction in fossil jet fuel use of about 7% (i.e. around 3 Mtoe) in 2030 and 65% (i.e. around 31 Mtoe) in 
2050 relative to the baseline. This is due to the substitution with SAF and to more limited extent caused by the 
lower overall energy demand in air transport. The reduction of fossil fuel use under PO B2 is lower, i.e. 3% by 
2030 and 22% by 2050 relative to the baseline. On the other hand, by 2030 and 2050, respectively 0.4 Mtoe and 
2.3-2.5 Mtoe of biofuels used are imported (see section 6.1.1). This represents less than 1% of EU’s total jet 
fuel use in 2030 and 3% to 6% of EU’s total jet fuel use by 2050. As such, the net reduction in energy imports 
remains substantial, driven by the significant reduction in oil imports, and in spite of a small increase in biofuel 
imports. Oil imports are largely substituted with feedstock and renewable electricity sourced in the EU. 
All the feedstock used to produce SAF in the EU is sourced in the EU. In other terms, no feedstock is imported 
in order to produce SAF in the EU under all POs. The renewable electricity required to produce RFNBOs is 
also sourced in the EU. As such, including RFNBOs,  EU-produced SAF represent 83% and 92% of total 
SAF use respectively in 2030 and 2050, under all POs. 

6.2.7.

Impacts on passenger air transport activity 

Under all POs, the intra-EU total passenger air transport activity grows steadily up to 2050, but less than 
in  the  baseline.  All  POs  have  similar  impact  on  the  internal  market’s  air  passenger  activity  (only  intra-EU 
flights). Indeed, under all POs, intra-EU passenger air transport grows by 80% by 2050 relative to 2015. The 
level of air transport passenger activity is slightly lower than in the baseline, i.e. by respectively 1.3% and 4.5-
4.7%  in  2030  and  2050  due  to  higher ticket  prices.  Total  passenger  air  transport  activity  however  grows 
steadily up to 2050 under all POs, but less than in the baseline. Passenger air transport activity on intra- and 
extra-EU flights is expected to grow under all POs, i.e. by around 77% by 2050 relative to 2015 (except for PO 
B2). In PO B2 the growth in activity during 2015-2050 is projected to be higher (81%), as the SAF obligation 
does not apply to extra-EU traffic. For all POs, the level of passenger activity on intra and extra-EU flights is 
however  lower  than  in  the  baseline,  by  1.9-2%  in  2030  and  3.4-5.9%  in  2050.  It  should  be  noted  that  the 
reduction in activity relative to the baseline is marginally higher in POs A1, B1 and C1 relative to POs A2 and 
C2. This is a consequence of the slightly higher increase in the ticket prices relative to the baseline in POs A1, 
B1 and C1 as explained in section 6.2.4. 

6.2.8.

Impacts on internal market and industry competitiveness 

Competitiveness of airlines. Under POs A1, A2, C1 and C2, all airlines (EU and non-EU) flying out of EU 
airports, will operate on a level playing field with regards to SAF. Indeed, under these POs, every litre of jet 
fuel supplied will be SAF-blended, which means airlines will have no alternative than to use SAF-blended jet 
fuel at EU airports. Airlines will have bargaining power to decide on the attribution of jet fuel supply contracts 
based  on  the  most  economically  attractive  bid  submitted  by  fuel  suppliers162.  This  market  dynamic  will 
contribute to keeping jet fuel prices at competitive levels. This means that EU and non-EU airlines alike will 
use  SAF  when  departing  from  EU  airports  and  will  operate  on  equal  footing.  POs  C1  and  C2  contain  a 
transition period, in the first phase of which (2025-2030) as not all airports may be supplied with SAF. This is 
not expected to affect the competitiveness of airlines since fuel suppliers, with a view to spread as evenly as 
possible additional fuel cost across the market, are expected to sell SAF to as many airlines as possible, at the 
majority of medium and large EU airports. Only airlines performing point to point operations between small 
airports, e.g. in remote areas may not have physical access to SAF at airports. Under POs C1 and C2, the level 
playing field between airlines is reinforced thanks to the jet fuel uplift obligation, which means that all airlines 
will  be  required  to  refuel  at  EU  airport  with  the  amount  of  fuel  needed  for  the  planned  flight.  With  this 

162   On a yearly basis, airlines issue calls for tender to receive jet fuel provision at their destination airports. Competition occurs between fuel 

suppliers who bid to provide airlines with the most economically attractive offer. 

50 

 
 
 
 
                                                           
safeguard, airlines cannot refuel more than needed outside of the EU in order to avoid the cost of refuelling at 
EU airports. Under PO B1, similar economic behaviour is expected between airlines and fuel suppliers. PO B2 
presents  risks  of  competitive  distortion  within  the  internal  market,  whereby  EU  airlines  performing  a  large 
share of international extra-EU traffic would be subject to the obligation to a much smaller extent than airlines 
operating mostly intra-EU routes. This could lead to a difference in average jet fuel costs between intra-EU and 
extra-EU flights increasing from 2.6% in 2030 to 20.5% in 2050. Under PO B2, EU airlines performing only 
intra-EU traffic would be put at a competitive disadvantage, as they would not be able to spread the increase in 
fuel costs over the cost of intra and extra-EU flights, as would be the case for airlines flying to and from the 
EU.  Under  all  POs,  a  risk  of  competitive  disadvantage  for  EU  airlines  compared  to  non-EU  airlines  is 
assessed as low at least by 2030. That could be the case where an EU airline operating long-haul flights from 
an  EU  airport  competes  on  a  similar  route  with  a  non-EU  airline  connecting  via  a  non-EU  hub  airport.  The 
competitive  disadvantage  for  the  EU  airline  could  come  from  extra  fuel  costs  due  to  SAF-blended  jet  fuel 
uptake.  For  non-EU  airlines  only  the  connecting  flight  to  the  non-EU  hub  would  need  to  operate  on  SAF, 
whereas the second leg of the journey (from non-EU hub to long-haul destination) could operate without SAF. 
However, additional fuel costs for airlines are expected to be passed on to passengers. As projected ticket price 
increase  are low  by  2030, i.e.  +1% relative  to the baseline.  Such  a  price increase  is  in itself  not expected  to 
justify a switch of customer behaviour from direct flights to connecting flights, or even to select an alternative 
hub  connection.  Therefore,  by  2030,  the  risk  of  competitive  disadvantage  for  EU  airlines  vis-a-vis  non-EU 
airlines is very low. By 2040, the risk of competitive disadvantage for EU airlines is more pronounced but 
it is mitigated by several factors. By 2040, the ticket price increase on flights departing from the EU would 
amount to +5% compared to the baseline.  The possible economic gain on fuel costs for non-EU airlines flying 
via non-EU hubs is mitigated by three factors mainly. (1) Connecting flights from the EU to the non-EU hub 
will  also  be  subject  to  a  price  increase  from  the  use  of  SAF.  This  comes  as  a  result  of  the  jet  fuel  uplift 
obligation (level playing field safeguard) that requires all airlines departing from EU airports to refuel with the 
jet fuel (SAF-blended) available at the airport. (2) Reaching a long-haul destination by connecting via a non-
EU hub instead of flying directly to the long-haul destination means flying a less direct route, hence additional 
fuel  burn  resulting  in  extra  costs  for  airlines.  (3)  While  airlines  operating  direct  long-haul  flights  from  EU 
airports will be able to claim economic benefits under CORSIA from their use of SAF, this will not be the case 
for  airlines  operating  long-haul  flights  from  non-EU  hubs  if  those  hubs  are  not  supplied  with  SAF.  The 
economic gain for non-EU airlines flying via a connecting non-EU hub may therefore be limited. As a result, 
the  risk  of  loss  of  competitiveness  for  airlines  exists  but  is  limited.  Moreover,  other  factors  could  further 
mitigate the risk. By 2040, while the ticket price increase will be relatively low (+5%), airlines flying from the 
EU  will  be  using  at  least  32%  of  SAF.  Flying  more  responsibly  could  encourage  passengers  to  incur  a  low 
ticket price increase. Nevertheless, the most effective avenue to prevent an erosion of competitiveness of EU 
airlines  will  be  to  promote  SAF  use  across  the  world,  thereby  promoting  climate  action  but  also  restoring  a 
level playing field. This will need to be a priority for EU action in coming years. Further, it is likely that by 
2040,  neighbouring  countries  will  have  developed  their  own  SAF  policies.  Several  strategic  aviation  third 
country partners - including the UK163 and the US164 - are accelerating their national reflections on the increase 
of SAF deployment for air transport. Should policy developments in these regions lead to an increase use of 
SAF  from  their  side,  this  would  further  provide  for  a  level  playing  field  for  airlines  operating  international 
flights and mitigate the risk for EU airlines. It is also not excluded that SAF use targets could be established at 
ICAO level in the future, or that more and more bilateral aviation agreements would include agreements on the 
use of SAF. Finally, it should be noted that the levels of ticket price increase raise competitiveness risks only 
towards 2040. This provides time and several opportunities for the Commission to report on the effectiveness 
of the legislation, as per usual practice. Should such reports conclude to a real risk of competitive disadvantage 

163   Source: https://www.gov.uk/government/news/new-regulations-to-double-the-use-of-sustainable-renewable-fuels-by-2020 
164   Source: 
https://juliabrownley.house.gov/brownley-introduces-sustainable-aviation-fuel-act/ 

51 

 
                                                           
beyond 2040, a review clause in the Regulation should allow to consider appropriate complementary measures 
and safeguards. As the potential impact on airlines competitiveness is assessed as limited, it is not expected to 
impact  the  effective  functioning  of  the  regulation.  Indeed,  as  explained  in  section  6.2.7,  the  air  transport 
sector is expected to keep growing by 2050, with a projected growth by 77% by 2050 relative to 2015. This 
means that the sector will be able to uptake gradually increasing levels of SAF while at the same time continue 
to function. It should be acknowledged that the present analysis is subject to uncertainties notably linked to the 
evolution of the jet fuel price. While section 6.2.1 provides exhaustive information on the most likely evolution 
of SAF prices and hence of the average jet fuel mix price, this is also dependent on the evolution of the price of 
fossil jet fuel. The price of fossil jet fuel expected to increase steadily over time by 2050, but could be subject 
to volatilities due to economic or geopolitical events out of the control of the regulator and independent of the 
air transport sector. It is not expected that the price gap between SAF and conventional jet fuel would increase 
(on the contrary it should decrease over time), but if this would happen, this could accentuate the phenomenon 
described  above  and  if  possibly  lead  to  competitive  distortions  or  put  EU  airport  hubs  and  EU  airlines  at 
competitive disadvantage with their competitors. For instance, in case of an important increase of the price gap 
between SAF and conventional fuel, non-EU airlines could benefit from an advantage compared to EU airlines, 
when flying ‘indirect’ long-haul flights via non-EU hubs. However, this would be easily assessed and should be 
considered under the review mechanism of the instrument in order to remedy the situation. 

Competitiveness of airports. By imposing SAF supply obligations at all airports, POs A1 and A2 bear the risk 
of  increasing  jet  fuel  prices  (due  to  logistics  costs)  at  remote  or  regional  airports  where  jet  fuel  prices  are 
already higher than average. This may reduce the economic attractiveness of small airports to the benefits of 
medium and large airports. This issue is expected to be mitigated under POs C1 and C2 where suppliers will 
distribute SAF-blended fuel in the most cost-effective way at the start of the obligation, i.e. until 2035. Under 
this scenario, suppliers will likely supply the majority of medium and large size airports. This means  airports 
competing in the same category range of traffic levels will be affected in the same way. Smaller airports are 
expected to be unaffected.  The risk of loss of competitiveness for EU hub airports with intercontinental 
traffic due to airlines’ re-routing is low. Under all POs (except PO B2 where the scope is reduced to intra-EU 
traffic), EU hub airports with large international traffic could be put at competitive disadvantage if passengers - 
for economic reasons, would choose to avoid direct long-haul flights from EU hubs but rather reach their long-
haul destination by re-routing and connecting via neighbouring non-EU hubs. This risk could materialise if the 
ticket price increase for flights departing from EU airports justifies it from a passenger perspective. However, 
as  explained  section  6.2.4,  the  ticket  price  increase  for  flights  departing  from  EU  airports  is  projected  to  be 
limited, i.e. +1% by 2030 and +5% by 2040 relative to the baseline. The same reasoning is valid as explained 
for airlines in the above section. As the potential impact on EU airports competitiveness is assessed as low, it is 
not expected to impact the effective functioning of the regulation. 

Impact  of  fuel  tankering  on  the  internal  market.  There  is  little  literature  available  or  concrete  evidence 
demonstrating  the  magnitude  or  impacts  of  fuel  tankering.  In  2019,  a  study  by  Eurocontrol165  estimated  that 
around 20% of flights in the ECAC area were able to perform fuel tankering. For the purpose of this impact 
assessment,  a  case  study  has  been  performed,  aiming  to  determine  at  what  point  in  time  airlines  would  be 
incentivised to tanker fuel outside the EU, given the increase of SAF content in the jet fuel, and the resulting 
price  changes.  The  case  study  considers  the  level  of  SAF  ramp  up  used  under  the  POs,  and  shows  that  the 
incentive  to  tanker  fuel  abroad  is  limited  until  2035.  By  2035,  it  would  become  interesting  to  tanker  fuel  in 
excess outside the EU on short-haul flights, e.g. Istanbul-Frankfurt or London-Dublin, where an airline could 
save respectively around 0.75% and 3% on fuel cost. By 2040, such practice may become also interesting  for 
long-haul flights where an airline could save around 1% on fuel costs when operating a New York-Paris route. 
The incentives to tanker outside the EU increase to more than 3% for long-haul flights and 10% for short haul 

165   Fuel Tankering: economic benefits and environmental impacts – Eurocontrol – June 2019. 

52 

 
                                                           
flights by 2050. While this suggests that the tankering issue gains in magnitude beyond 2035, the existence of a 
financial incentive to do so to the detriment of emission savings, warrants the need for a robust safeguard to be 
implemented  already  in  the  short  term.  The  level  playing  field  (anti-tankering)  safeguard  should  be 
implemented already by 2025 mainly for three reasons. First, it cannot be excluded that market prices for jet 
fuel  and  SAF  fluctuate  to  a  point  that  could  make  fuel  tankering  economically  interesting.  Moreover,  the 
prevention of tankering brings immediate benefits by removing avoidable emissions caused by the additional 
fuel carried, regardless of the reasons airlines may have for tankering. Finally, this measure allows to preserve a 
level playing field for all flights departing from EU airports, including extra-EU flights. Indeed, as all airlines 
(regardless of whether they are established in the EU or not) will be required to uplift the jet fuel available at 
EU airports, higher jet fuel costs will apply to all. This reduces the possibility of competitive disadvantage for 
EU airlines and for EU hub airports. The anti-tankering safeguard included in POs C1 and C2 is expected to 
reduce significantly aviation emissions caused by airlines carrying an excess of fuel. This reduction cannot be 
quantified  with  high  accuracy,  but  according  to  Eurocontrol,  it  could  avoid  an  estimated  average  136kg  of 
excess fuel burn per flight, representing 428kg of CO2. A study166 conducted by the International Council on 
Clean Transportation in 2021  concluded that additional tankering  stemming  from  the  SAF  blending  mandate 
could result in a 22% lower SAF uptake by airlines by 2035. In turn, this could reduce the CO2 benefits of the 
initiative by a quarter by 2035. Mitigation measures identified in the study include defining and prohibiting fuel 
tankering  on  flights  departing  from  EU  airports.  This  measure  can  be  easily  implemented,  as  airlines  keep 
records  of  their  tank  levels  and  levels  uplift  for  each  flight.  This  information  needs  to  be  transferred  to  a 
European organisation for control and reporting of manifest cases of excess fuel uplift. Airlines could also be 
requested to send such information aggregated per airport, instead of per flight. This safeguard is expected to be 
considered by the airline community as a positive step towards reinforcing the level playing field in intra- and 
extra-EU  air  transport  and  contribute  to  reducing  fuel  burn  and  the  emissions  of  the  aviation  sector.  It  may 
however face opposition from airlines currently performing fuel tankering or intending to benefit from access 
to  inexpensive  jet  fuel  out  of  the  EU.  It  should  be  noted  that  this  safeguard  would  a  priori  not  raise  legal 
challenges. 

Competitiveness  of  aircraft  manufacturers.  Under  all  POs,  aircraft  manufacturers  will  continue  to  benefit 
from the growth of the aviation sector by 2050, albeit at slightly lower pace than in the baseline scenario. The 
fact  that  SAF  are  drop-in  fuels  compatible  with  existing  aircraft  engines  is  a  significant  technological 
advantage,  as  it  means  that  there  will  be  no  necessity  for  aircraft  manufacturers  to  retrofit  existing  fleets  or 
disrupt their existing business model to develop new technologies for the purpose of SAF. This is expected to 
avoid substantial investments otherwise needed to adapt aircraft engines currently in use. While it is expected 
that aircraft manufacturers will invest and support the scaling up of SAF production, there is no indication that 
this  would  lead  to  a  displacement  of  investments  from  R&D  programmes  targeting  other  technologies 
(hydrogen, electric aircraft). Such programmes are expected to follow their course and intensify in the decades 
to come as aircraft manufacturers will aim to remain at the cutting edge of innovation. Flanking measures such 
as steering European funding towards SAF deployment or the creation of an EU strategic alliance for advanced 
biofuels  and  synthetic  fuels  will  further  contribute  to  the  best  possible  allocation  of  resources  towards  SAF 
deployment.  

Competitiveness  of  the  fuels  industry.  The  EU  (renewable)  fuel  industry  is  expected  to  benefit  from  this 
initiative, as it launches a new market with strong growth prospects. It is likely that SAF production at local 
level will develop, leading to the emergence of a diversity of producers  on the market and actors of the SAF 
supply  chain.  This  initiative  is  an  opportunity  for  the  fuels  industry  to  take  a  pioneering  and  leading  role  in 
scaling  up  SAF  at  global  level.  It  is  not  excluded  that  EU  SAF  production  could  also  attract  foreign  airline 
markets  wishing  to  green  their  own  domestic  operations.  On  the  other  hand,  for  reasons  of  resources 

166   https://theicct.org/publications/tankering-eu-SAF-mandate-apr2021 

53 

 
                                                           
availability  mentioned  previously,  it  is  likely  that  an  expansion  of  SAF  production  could  result  in  lower 
production of road biofuels produced from Part B feedstock. This could lead to a reduction of activity notably 
in the bio-diesel industry in the short to medium term. On the other hand, the road transport sector is projected 
to  be  largely  electrified  in  the  medium  to  long  term,  considering  the  analysis  underpinning  the  impact 
assessment accompanying the 2030 Climate Target Plan. This means that the demand for biofuels in aviation 
sector could create alternative business opportunities for the fuel industry.  

6.2.9.

  Impacts on administrative costs 

No  additional  administrative  costs  are  expected  on  the  side  of  fuel  suppliers  under  all  POs.  Additional 
administrative costs occur for airlines under POs C1 and C2, i.e. annually €16.8 million by 2025 and around 
€24 million by 2050. In terms of present value over the 2021-2050 horizon this is equivalent to €0.34 billion 
additional costs relative to the baseline. Additional costs for Member States range from €186 million (POs A1, 
A2 and B2) to €264 million (POs C1 and C2) and €293 million (PO B1). Additional costs for EU authorities 
range from €0.7 million (POs A1, A2 and B2), €2.0 million (PO B1) to €2.7 million (POs C1 and C2). In terms 
of  present  value  over  the  2021-2050  horizon  the  costs  for  the  public  authorities  relative  to  the  baseline  are 
estimated at €0.19 billion for PO A1, A2 and B2, at €0.27 billion for PO C1 and C2 and €0.3 billion for PO B1. 
More details on the administrative costs are provided in Annex 4. It should be noted that costs associated with 
the system of SAF transactions for accounting purposes is negligible, as it relies on the monitoring process of 
EU agency or the EU ETS (which costs are accounted for in the relevant POs under costs for EU authorities, as 
explained above in this paragraph), depending on the policy options and does not require the setting up of any 
additional  specific  IT  structure.  It  is  expected  to  consist  of  a  limited  number  of  transactions  per  year,  which 
costs would be marginal and cannot be estimated. 

6.3. 

Social impacts 

6.3.1.

Impact on employment 

Overall, all POs (except PO B2) lead to significant net job creation in the EU compared to the baseline in 
the long term. This net job increase is largely driven by the high employment needs of the SAF industry from 
2030 to 2050. Combining employment effects in the air transport and SAF industries, all POs (except PO B2) 
provide for net additional 95,700 (PO B1) to 96,800 (PO C2) jobs compared to the baseline scenario in 2040 
and  201,300  (PO  B1)  to  202,100  (PO  C1  and  C2)  in  2050.  In  PO  B2  the  impacts  would  be  more  limited 
(20,000 additional jobs in 2040 and 53,200 in 2050). The impacts of all POs would be more limited in 2030 in 
terms  of  net  additional  jobs  relative  to  the  baseline  (4,200  to  4,800  net  additional  jobs)  while  PO  B2  would 
show some net losses relative to the baseline (7,200). Still, even in PO B2 employment increases significantly 
relatively to the current levels.  

6.3.2.

Impact on public health 

All POs lead to a reduction of external costs of air pollution over time. The impacts on public health from 
air  pollution  are  quantified  in  terms  of  reduction  in  the  negative  externalities  compared  to  the  Baseline.  Air 
pollutants are projected to decrease in all POs compared to the baseline. The reduction of air transport activity, 
as a result of the more expensive fuel mix over time, leads to lower fuel burn. For all POs, this eventually leads 
to a reduction in the present value of external costs from air pollution of about €1.5 billion over the period 2020 
to 2050, compared to the Baseline. 

7.  HOW DO THE OPTIONS COMPARE? 

7.1. 

Effectiveness and efficiency 

The effectiveness of the options is examined against the policy objectives identified in Section 4. The criteria 
presented below are used to help assess the effectiveness. 

54 

 
 
 
Table 133 – The effectiveness of the options examined against the policy objectives.  
Specific objectives 

Indicator 

General objective 
Reduce aviation CO2 emissions in line with the 2030 and 2050 climate objectives of the EU, by transitioning away from fossil jet fuels and 
tap into the high sustainability potential of sustainable aviation fuels by establishing a competitive SAF market that ensures level playing 
field on the aviation internal market. 
Specific objective 1 
To achieve large-scale production and supply of SAF 
in the EU with high decarbonisation potential. 

Increase existing SAF plants output and develop new production facilities. 
Sufficiency  of feedstock  available  for  SAF  production  compared  to  overall  needs 
for  SAF  as  defined  in  the  impact  assessment  accompanying  the  Climate  Target 
Plan. 
Reduction of EU’s energy dependence on oil imports. 
Development  of  sustainable  and  cost-effective  SAF  pathways, 
technology-neutral approach. 
Reduction of well-to-wing CO2 emissions from air transport 
Increase uptake of SAF in line with the objectives of the 2030 Climate Target Plan 
of achieving at least 55% economy-wide emissions reductions by 2030. 

taking  a 

Specific objective 2 
To achieve a gradual and continuous uptake of SAF 
with high sustainability potential.  

Ensure that airlines have access to SAF at airports. 
Ensure a level playing field between airlines.  
Avoid carbon leakage resulting from increased fuel tankering. 

Table 144 – The expected key impacts of the policy options. 

 
Strongly negative 

 
Weakly negative 

PO A1 

PO A2 

Key: Impacts expected 
O 
No or negligible impact 
PO B1 
Effectiveness 

 
Weakly positive 

 
Strongly positive 

PO B2 

PO C1 

PO C2 

Increase existing 
SAF plants and 
developing new 
production facilities. 

 
25.6Mt of additional 

167

SAF capacity
deployed by 2050 
to match the SAF 
production 
necessary to meet 
the mandate. Minor 
portions of the SAF 
needed are 
imported. 

 
25.5Mt of additional 
SAF capacity 
deployed by 2050 
to match the SAF 
production 
necessary to meet 
the mandate. Minor 
portions of the SAF 
needed are 
imported. 

 
25.6Mt of 
additional SAF 
capacity deployed 
by 2050 to match 
the SAF 
production 
necessary to meet 
the mandate. 
Minor portions of 
the SAF needed 
are imported. 

 
8.3Mt of additional 
SAF capacity 
deployed by 2050, 
insufficient to meet 
the 2030 Climate 
Target Plan 
objectives by 2030 
and 2050 due to the 
reduced scope of 
the SAF mandate. 

 
25.6Mt of 
additional SAF 
capacity deployed 
by 2050 to match 
the SAF 
production 
necessary to meet 
the mandate. 
Minor portions of 
the SAF needed 
are imported. 

 
25.5Mt of additional 
SAF capacity 
deployed by 2050 
to match the SAF 
production 
necessary to meet 
the mandate. Minor 
portions of the SAF 
needed are 
imported. 

 
53% of UCO,11% 
of agri and wood 
residues and 12% 
of energy crops 
required by 2050. 

 
53% of UCO,11% 
of agri and wood 
residues and 12% 
of energy crops 
required by 2050. 

 
53% of UCO,11% 
of agri and wood 
residues and 12% 
of energy crops 
required by 2050. 

 
33% of UCO, 3% of 
agri and wood 
residues and 1% of 
energy crops 
required by 2050. 

 
53% of UCO,11% 
of agri and wood 
residues and 12% 
of energy crops 
required by 2050. 

 
53% of UCO,11% 
of agri and wood 
residues and 12% 
of energy crops 
required by 2050. 

 
5.5% of renewable 
electricity used for 
synthetic kerosene. 

 
4.7% of renewable 
electricity used for 
synthetic kerosene. 

 
5.5% of renewable 
electricity used for 
synthetic 
kerosene. 

 
1.8% of renewable 
electricity used for 
synthetic kerosene. 

 
5.5% of renewable 
electricity used for 
synthetic 
kerosene. 

 
4.7% of renewable 
electricity used for 
synthetic kerosene. 

Sufficiency of 
feedstock available 
for SAF production 
compared to the 
overall needs of 
biomass feedstock 
for achieving the 
2030 Climate 
Target Plan 
objectives. 
Sufficiency of 
renewable 
electricity for SAF 
production 
compared to overall 
needs of renewable 
electricity for 
achieving the 2030 
Climate Target Plan 
objectives. 

167 Assuming fully used capacity. 

55 

 
 
 
 
                                                           
 
Reduction in oil 
products used by 
air transport by 
65% (i.e. around 31 
Mtoe) by 2050. 
 
A technological 
neutral approach 
allows advanced 
biofuels and 
RFNBOs to emerge 
on the market 
earlier and account 
for the majority of 
SAF volumes by 
2050. 
 
Share of SAF in the 
aviation fuel mix 
achieved (63% by 
2050). 

Reduction of EU’s 
energy dependence 
on oil imports 
(compared to the 
baseline). 

Development of 
sustainable and 
cost-effective SAF 
pathways, taking a 
technology-neutral 
approach. 

 
Reduction in oil 
products used by 
air transport by 
65% (i.e. around 31 
Mtoe) by 2050. 
 
Advanced biofuels 
and RFNBOs 
emerge to the 
market earlier and 
account for the 
majority of SAF 
volumes by 2050. 

 
Share of SAF in the 
aviation fuel mix 
achieved (63% by 
2050). 

Achieve a gradual 
and continuous 
uptake of SAF in 
line with the 
analysis 
underpinning the 
impact assessment 
accompanying the 
2030 Climate 
Target Plan. 
Ensure that airlines 
have access to SAF 
at airports. 

O 
Delivering SAF at 
all airports means 
additional logistical 
challenges in the 
first years. 

O 
Delivering SAF at 
all airports means 
additional logistical 
challenges in the 
first years. 

Ensure a level 
playing field 
between airlines. 

O 
All airlines expected 
to be treated 
equally by fuel 
suppliers. Moderate 
risk of competitive 
disadvantage with 
non-EU airlines on 
some international 
routes. 

O 
All airlines expected 
to be treated 
equally by fuel 
suppliers. Moderate 
risk of competitive 
disadvantage with 
non-EU airlines on 
some international 
routes. 

Avoid carbon 
leakage resulting 
from fuel tinkering. 

Reduction of well to 
wing CO2 
emissions from air 
transport compared 
to the baseline in 
2050.  

 
Risks of fuel 
tankering for 
international traffic 
beyond 2035. 
 
115 Mt of CO2 
emission 
reductions. 

 
Risks of fuel 
tankering for 
international traffic 
beyond 2035. 
  
114 Mt of CO2 
emission 
reductions. 

 
Reduction in oil 
products used by 
air transport by 
65% (i.e. around 
32 Mtoe) by 2050. 
 
Advanced biofuels 
and RFNBOs 
emerge to the 
market earlier and 
account for the 
majority of SAF 
volumes by 2050. 

 
Reduction in oil 
products used by 
air transport by 
22% (i.e. around 11 
Mtoe) by 2050. 
 
Advanced biofuels 
and RFNBOs 
emerge to the 
market earlier and 
account for the 
majority of SAF 
volumes by 2050. 

 
Reduction in oil 
products used by 
air transport by 
65% (i.e. around 
31 Mtoe) by 2050. 
 
Advanced biofuels 
and RFNBOs 
emerge to the 
market earlier and 
account for the 
majority of SAF 
volumes by 2050. 

 
Share of SAF in 
the aviation fuel 
mix achieved 
(63% by 2050). 

 
The share of SAF 
use in the fuel mix 
of approx. 20% is 
significantly lower 
than the 63% 
objective. 

 
Share of SAF in 
the aviation fuel 
mix achieved 
(63% by 2050). 

 
Reduction in oil 
products used by 
air transport by 
65% (i.e. around 31 
Mtoe) by 2050. 
 
A technological 
neutral approach 
allows advanced 
biofuels and 
RFNBOs to emerge 
on the market 
earlier and account 
for the majority of 
SAF volumes by 
2050. 
 
Share of SAF in the 
aviation fuel mix 
achieved (63% by 
2050). 

O 
Obligation on all 
traffic assumes 
equally 
challenging 
logistics in the first 
years. 
O 
All airlines 
expected to be 
treated equally by 
fuel suppliers. 
Moderate risk of 
competitive 
disadvantage with 
non-EU airlines on 
some international 
routes. 
 
Low risk of 
tankering due to 
SAF obligation on 
airlines. 
  
115 Mt of CO2 
emission 
reductions. 

O 
Obligation on intra-
EEA traffic 
assumes equally 
challenging logistics 
in the first years. 

 
Risks of competitive 
distortion between 
EU airlines within 
the single market. 

x 
Risks of fuel 
tankering for 
international traffic 
beyond 2035. 
 
33 Mt of CO2 
emission 
reductions. 

 
Flexibility on the 
supply means 
easier logistics in 
the first years. 

 
Flexibility on the 
supply means 
easier logistics in 
the first years. 

O 
All airlines 
expected to be 
treated equally by 
fuel suppliers. 
Moderate risk of 
competitive 
disadvantage with 
non-EU airlines on 
some international 
routes. 
 
Very low risk of 
tankering as a 
result of jet fuel 
uplift obligation. 
   
115 Mt of CO2 
emission 
reductions. 

O 
All airlines expected 
to be treated 
equally by fuel 
suppliers. Moderate 
risk of competitive 
disadvantage with 
non-EU airlines on 
some international 
routes. 

 
Very low risk of 
tankering as a 
result of jet fuel 
uplift obligation. 
   
114 Mt of CO2 
emission 
reductions. 

56 

 
 
Reduction of 
external costs of 
CO2 emissions 
relative to the 
baseline, expressed 
as present value 
over 2021-2050 
(accounting also for 
the increased 
external costs due 
to logistics). 
Reduction of 
external costs of air 
pollution relative to 
the baseline, 
expressed as 
present value over 
2021-2050. 
Benefits relative 
to the baseline 
(PV over 2021-
2050). 

Additional costs of 
jet fuel relative to 
the baseline, 
expressed as 
present value over 
2021-2050 -  
passed through to 
consumers.  
Reduction of 
operation and 
capital costs of air 
transport relative to 
the baseline, 
expressed as 
present value over 
2021-2050. 
Additional costs of 
logistics relative to 
the baseline, 
expressed as 
present value over 
2021-2050. 

 
€86.2 billion (i.e. 
€86.5 billion 
reduction due to the 
SAF uptake and 
€0.33 billion 
increase due to 
logistics). 

 
€85.7 billion (i.e. 
€86.0 billion 
reduction due to the 
SAF uptake and 
€0.33 billion 
increase due to 
logistics). 

 
€86.4 billion (i.e. 
€86.7 billion 

reduction due to the 
SAF uptake and 
€0.33 billion 
increase due to 
logistics). 

 
€29.7 billion (i.e. 
€29.8 billion 
reduction due to the 
SAF uptake and 
€0.11 billion 
increase due to 
logistics). 

 
€86.3 billion (i.e. 
€86.5 billion 
reduction due to 
the SAF uptake 
and €0.23 billion 
increase due to 
logistics). 

 
€85.8 billion (i.e. 
€ 86.0 billion 
reduction due to the 
SAF uptake and 
€0.23 billion 
increase due to 
logistics). 

 
€ 1.5 billion 

 
€ 1.5 billion 

 
€ 1.6 billion 

 
€ 1.5 billion 

 
€ 1.5 billion 

 
€ 1.5 billion 

 
€ 87.7 billion 

 
€ 87.2 billion 

 

€ 87.9 billion 

 
€ 31.2 billion 

 
€ 87.8 billion 

 
€ 87.3 billion 

Efficiency (values indicated represent NPVs over the reference period) 

 
€103.5 billion 

 
€ 88.3 billion 

 
€ 102.7 billion 

 
€ 14.7 billion  

 
€ 103.5 billion 

 
€ 88.2 billion 

Additional cost of 
supplying SAF. 

Additional cost of 
supplying SAF.  

Additional cost of 
supplying SAF. 

Additional cost of 
supplying SAF.  

Additional cost of 
supplying SAF.  

Additional cost of 
supplying SAF.  

 
- €83.9 billion 

 
- €74.4 billion 

 
- €83.5 billion 

 
- €35.6 billion 

 
- €84.0 billion 

 
- €74.5 billion 

O 
 €0.27 billion 

O 
 €0.27 billion 

O 
 €0.27 billion 

O 
€0.09 billion 

O  
€0.19 billion 

O  
€0.19 billion 

Cost of logistics to 
supply SAF to all 
EU airports. 

Cost of logistics to 
supply SAF to all 
EU airports. 

Costs of logistics 
to supply SAF to 
all airlines. 

Low logistic costs 
due to lower levels 
of SAF supply. 

Transition period 
allows for 
improved logistics. 

Transition period 
allows for improved 
logistics. 

Impact on SAF 
producers – cost 
passed through to 
suppliers. 

 
Total capital 
investments 
needed of € 10.5 
billion.  

 
Total capital 
investments 
needed of € 10.4 
billion.  

 
Total capital 
investments 
needed of € 10.4 
billion.  

O 
Total capital 
investments 
needed of € 3.3 
billion. 

 
Total capital 
investments 
needed of € 10.5 
billion.  

 
Total capital 
investments 
needed of € 10.4 
billion.  

Additional cost for 
consumers per 
ticket (i.e. increase 
in ticket prices 
relative to baseline 
in 2050). 

 
Low ticket price 
increase 
8.2% by 2050. 

 
Low ticket price 
increase 
8.1% by 2050. 

 
Low ticket price 
increase 
8.2% by 2050. 

O 
Very low ticket price 
increase 
1.7% by 2050. 

 
Low ticket price 
increase 
8.2% by 2050. 

 
Low ticket price 
increase 
8.1% by 2050. 

57 

 
 
Cost of uplift 
reporting for airlines 
relative to the 
baseline, expressed 
as present value 
over 2021-2050 -  
passed through to 
consumers. 
Costs for authorities 
relative to the 
baseline, expressed 
as present value 
over 2021-2050. 
Costs relative to 
the baseline (PV 
over 2021-2050). 
Net benefits 
relative to the 
baseline (PV over 
2021-2050). 

O 

O 

O 

O 

O  
Cost of uplift 
reporting €0.34 
billion 

O 
Cost of uplift 
reporting €0.34 
billion 

O 
Cost of monitoring 
and enforcement 
€0.19 billion. 

O 
Cost of monitoring 
and enforcement 
€0.19 billion. 

O 
Cost of monitoring 
and enforcement 
€0.30 billion. 

O 
Cost of monitoring 
and enforcement 
€0.19 billion. 

O 
Cost of monitoring 
and enforcement 
€0.27 billion. 

O 
Cost of monitoring 
and enforcement 
€0.27 billion. 

 
€ 20.1 billion 

 
€ 14.4 billion 

 
€ 19.8 billion 

  
- € 20.7 billion 

 
€ 20.3 billion 

 
€ 14.6 billion 

  
€ 67.6 billion 

  
€ 72.8 billion 

  
€ 68.2 billion 

  
€ 51.8 billion 

  
€ 67.5 billion 

  
€ 72.7 billion 

7.2. 

Coherence 

Coherence with  the  EU’s  high-level  objectives.  All  POs  except  B2  are  in  line  with  the  EU’s  objectives to 
decarbonise transport as set out in the Sustainable and Smart Mobility Strategy, in line with the 2030 Climate 
Target  Plan  and  the  EU  Strategy  for  Energy  System  Integration.  Similarly,  all  POs  succesfully  address  the 
objective of reducing the EU’s dependency on oil and increasing the EU’s energy security, as identified in the 
2018 “Clean Planet for All” Long Term Strategy. Finally, all POs further meet the objectives of promoting the 
use of renewable and low carbon fuels as one of the pathways available to decarbonise the transport sector as 
identified  in  the  European  Green  Deal  which  recognises  the  importance  of  increasing  the  production  and 
deployment of sustainable alternative transport fuels and makes this one of the priority areas for action. 

Coherence  with  existing  EU  rules.  All  POs  are  coherent  with  the  existing  EU  regulatory  framework  for 
transport,  energy  and  climate.  On  the  airlines  side,  all  POs  rely  to  a  large  extent  on  the  use  of  existing 
mechanisms in place, e.g. on the EU ETS for monitoring, reporting and verification purposes. In particular, all 
POs ensure coherence with the EU’s renewable energy policy. All POs are in line with the objectives of the 
Renewable Energy Directive to increase the share of renewable energy in transport. All POs are consistent with 
the  EU’s  renewable  energy  framework.  First,  SAF  eligible  under  this  initiative  are  required  to  be  compliant 
with  the  sustainability  framework  of  the  Renewable  Energy  Directive.  Second,  the  objective  of  supporting 
certain fuel types e.g. advanced biofuels and RFNBOs, is aligned with the objectives of RED II. Concretely, 
this  means  that  all  SAF  counting  towards  the  SAF  obligation  under  this  initiative  will  be  eligible  to  count 
towards  the  RED  II  overall  renewable  energy  target,  and  in  particular  the  RES-T  target  accounting  for 
renewable  energy  in  transport  (14%  by  2030  under  RED  II).  It  also  means  that  features  of  RED  II  such  as 
submandates, multipliers or caps that apply to certain categories of fuel will be fully applicable. For instance, 
advanced biofuel accounting for the present SAF obligation will be able to count towards the submandate for 
advanced biofuels across transport modes, as established under RED II. Similarly, Part B biofuels accounting 
towards the present SAF obligation will be subject to the cap established under RED II for accounting of Part B 
biofuels towards the target of renewable energy in transport. In addition, all POs gives supplementary direction 
to the fuel industry with respect to innovative and sustainable fuel technologies e.g. RFNBOs, in line with the 
overall  objectives  of  RED  II.  Third,  as  explained  in  detail  in  section  6.1.2,  there  is  no  issue  of  feedstock 
availability.  In  spite  of  increased  competition  for  access  to  feedstock  in  the  decades  to  come,  due  to  higher 
demand from sectors decarbonising with the use of bioenergy (+82% by 2050 relative to 2015), under all POs, 
the  analysis  shows  that  SAF  production  for  aviation  is  expected  to  require  less  than  10%  of  all  biomass 
feedstock  used  to  meet  bioenergy  demand  in  the  context  of  a  climate  neutral  economy  by  2050.  Fourth,  the 
initiative  relies  on  the  monitoring,  reporting  and  verification  framework  put  in  place  by  the  RED  II  (Union 

58 

 
 
Database) to ensure seemless monitoring and reporting on the supply side. Under all POs, there is no risk of 
double  regulation.  As  explained  under  section  2.2.3,  a  key  problem  driver  is  the  absence  of  regulatory 
framework  imposing  the  substitution  of  fossil  jet  fuel  with  SAF.  Under  RED  II  rules,  while  Member  States 
have  the  option  to  account  the  supply  of  SAF  towards  their  national  renewable  energy  targets,  there  is  no 
requirement on Member States to impose obligations on jet fuel suppliers to supply SAF in a harmonised way 
across the EU’s aviation internal market. Similarly, under the EU ETS, there is an option but no obligation for 
airlines to report their use of SAF. Finally, there are currently no rules requiring airlines to use SAF quotas or to 
report their jet  fuel  uplift on  a  flight  basis  prior  to  each  departure  from  EU  airports. Therefore,  all  measures 
envisaged notably in all POs would be strictly unique in EU rules and would not in any way conflict with other 
rules or lead to double regulation. 

Coherence with the other initiatives of the ‘Fit for 55’ package. This initiative aims to fill an important gap 
in  the  EU  regulatory  framework  on  sustainable  aviation  fuels.  By  imposing  mandatory  SAF  shares,  it  will 
oblige the market to reduce its dependence on fossil fuels and take up sustainable fuels, as was done in the past 
for the road transport sector. While the SAF blending mandate is expected to play an important role to deliver 
on the policy objectives of the present initiative, other pieces of EU legislation part of the ‘Fit for 55’ package, 
which also pursue as objectives the decarbonisation of transport, in some cases specifically air transport and are 
relevant to an increased role of SAF in the sector. Namely, these initiatives are the revision of the Renewable 
Energy Directive (RED II), the revision of the EU ETS, of the Energy Taxation Directive (ETD).  

Coherence  with  the  revision  of  RED  II.  The  overall  target  for  renewable  energy  in  transport  by  2030  is 
expected to increase. The submandate on advanced biofuels could be increased and a submandate for RFNBOs 
is expected to be introduced. Such developments would be fully in  line and complementary to the ReFuelEU 
Aviation  initiative.  Indeed,  ReFuelEU  Aviation  would  fill  a  gap  by  providing  for  an  aviation-specific  SAF 
obligation in a way that is consistent with the needs of the aviation internal market. SAF supplied towards the 
aviation-specific obligation could be accounted for by States in their RED targets. It is not clear whether the 
cap on the contribution of Part B biofuels to the renewable energy target would evolve. Further restrictions on 
this cap are however unlikely, since Part B biofuels are likely to be produced in the future by biofuel producers 
for the road and the aviation sector. On the other hand, a lifting of the cap is also unlikely, as the objectives of 
the cap include limiting risks of fraud and driving investments in advanced biofuels listed in Part A of Annex 
IX.  A  substantial  revision  of  the  biofuel  sustainability  criteria  is  not  expected  under  the  RED  II  revision. 
Similarly, it is not expected that the list of feedstock contained in Part A and Part B of Annex IX be restricted 
or limited. In fact, RED II revision could possibly lead to extending said lists to a limited number of additional 
sustainable feedstock. This would be supportive to the objectives of ReFuelEU Aviation as it would open more 
possibilities for SAF producers, thus reducing competition for access to feedstock between transport modes and 
limiting feedstock price increase. 

Coherence with the revision of the EU ETS. In the course of the revision, the allocation of free allowances to 
airlines could be reduced and the linear reduction factor could be increased. This means that airlines would be 
required  to  purchase  more  allowances  than  presently,  which  could  have  as  an  effect  to  increase  costs  of 
allowances. As a result, airlines would be further encouraged to decarbonise their activities. The incentive to 
use SAF under EU ETS is due to remain, i.e. airlines are not required to surrender allowances where they report 
the use of SAF, also referred to as “zero-rating” for SAF. Also, the eligibility of SAF under the EU ETS should 
remain  conditional  to  the  fulfilment  of  the  RED  sustainability  framework,  similarly  as  planned  under  the 
present  initiative.  Such  evolutions  of  the  EU  ETS  would  be  fully  supportive  and  complementary  to  the 
ReFuelEU Aviation SAF obligation. It would further encourage airlines to use SAF. Even if it is unlikely that 
the increased price of allowances would mean that EU ETS by itself would drive SAF to aviation (see section 
2.2.3,  the  price  of  a  tonne  of  carbon  would  need  to  be  around  EUR  160),  the  zero-rating  will  contribute  to 
making SAF more affordable for airlines. As the share of SAF in the aviation fuel mix would increase under all 
POs of the ReFuelEU Aviation initiative, the EU ETS for aviation would still have a major to play to cover the 

59 

 
emissions resulting from the combustion of the fossil jet fuel fraction of the fuel mix (the ‘zero-rating’ applies 
only to the ‘neat’ SAF fraction of the fuel mix). 

Coherence with the revision of the ETD. It is possible that taxation of jet fuel could be proposed. This could 
be done in a way to tax types of jet fuel according to their carbon intensity. This could lead to taxation of fossil 
jet  fuel  and  possibly  absence  of  or  very  low  taxation  rates  for  SAF.  Such  a  system  would  provide  fiscal 
preferential treatment for SAF. This could have as an effect to support further the uptake of SAF by airlines and 
be in line with this specific objective of ReFuelEU Aviation, by making SAF more economically interesting. In 
spite of possibly reducing the  price difference between SAF and fossil jet fuel, and hence making SAF more 
affordable for airlines relative to fossil fuel, the achievement of the SAF obligation under ReFuelEU Aviation 
is rather insensitive to the revision of the ETD. Indeed, as explained under section 5.4.2, the imposition of a 
SAF  blending  mandate  means  that  the  reduction  of  price  gap  between  SAF  and  fossil  jet  fuel  is  desirable 
(mostly if achieved thanks to a reduction of SAF costs) but is not a decisive factor for the attainment of the 
SAF obligation targets.  

Coherence  towards  bringing  down  SAF  prices.  This  impact  assessment  clearly  acknowledges  that  other 
pieces of the EU regulatory framework can play a complementary role in bringing SAF to the aviation market 
at competitive prices. In particular, it is clear that non of the following policy mechanisms: SAF obligation, EU 
ETS,  RED,  ETD  can  alone  bring  SAF  to  a  par  with  fossil  jet  fuel  prices.  However,  as  illustrated  below 
(representative of the evolution of SAF prices under all POs, except B2), the SAF blending mandate allows to 
bring SAF prices down from their current estimates. Over time, SAF become increasingly price competitive. 
This is explained as SAF production costs benefit from economies of scale and learning effects as the industry 
scales  up  over  time  (see section  6.2.1  and  Annex  16).  Figure 5  shows  that  other  measures  (e.g.  here the EU 
ETS168)  can  further  help  to  reduce  the  price  of  SAF  relative  to  conventional  fossil  jet  fuel.  Other  relevant 
measures  for  this  purpose  (not  represented  under  figure  5)  could  include  fossil  jet  fuel  taxation  under  the 
revision of the Energy Taxation Directive, as previously discussed. It is worth noting however, that in a context 
of POs C1 and C2, where all jet fuel available at EU airports is blended beyond 2035, the existence of a price 
gap between SAF and fossil jet fuel is no longer a factor on which SAF uptake depends. Indeed, airlines only 
have access to SAF-blended jet fuel, no longer to either SAF or fossil jet fuel. Therefore, whereas it is desirable 
from an economic point of view for airlines that the price difference between SAF and fossil jet fuel decreases 
over time (in particular as a result of a decrease of SAF prices) the reduction of this price gap is not a sine qua 
non condition for the successful uptake of SAF under this initiative. 

Figure 5 - Production cost development for SAF production pathways – Sensitivity with ETS and low production costs (in € per tonne of 
fuel). Note: black: fossil, grey: fossil with ETS, yellow: HEFA, green: ATJ, red: Gas+FT, blue: RFNBOs. 

168   A weighted average ETS mark-up is also produced for fossil fuel to align with the CTP expectation of an EU ETS allowances at the level 

of €44 per tonne of CO2 in 2030. This is 100% attributed to intra-EEA flights but only by 50% to extra-EEA flights. 

60 

 
 
                                                           
Source: Ricardo at al. Impact assessment support study. 

Various  ‘market’  climate  initiatives  affecting  aviation  (e.g.  ETS,  energy  taxation,  renewable  energy)  are 
coherent with the present initiative and their climate objectives are equally compatible. This is also the case as 
regards the objectives pursued by the present initiative. Indeed, the various ‘market’ initiatives allow to support 
SAF  uptake,  mitigate  fuel  price  increase,  lead  to  higher  fuel  efficiency  and  encourage  the  deployment  of 
innovative aviation technology. For instance, the EU ETS will support the present initiative thanks to its ‘zero-
rating’ mechanism for SAF. This will encourage airlines to take up SAF and at the same time will reduce SAF 
cost,  since  airlines  will  not  be  required  to  surrender  allowances,  as  a  result  of  SAF  use.  The  EU  ETS  also 
supports fuel efficiency and the deployment of newer aircraft technology, as airlines are required to purchase 
allowances in proportion to their carbon emissions. This contribution of the EU ETS would be accentuated if 
the amount of free allowances for airlines would be reduced in the course of the EU ETS revision. The same 
holds  true  for  the  role  of  the  energy  taxation  Directive,  which  would  encourage  the  uptake  of  SAF  and  the 
deployment of more innovative aircraft technologies if fossil jet fuel would become subject to a tax. 

Areas for further coherence with other initiatives. For the purpose of contributing to the policy framework 
aiming to boost the SAF market, adjustments under other pieces of the EU regulatory framework could also be 
helpful, although not strictly necessary. These adjustments could be considered under the upcoming revision of 
the relevant instruments or be considered at a later stage. For instance, the EU ETS emission reports template 
could  be  updated  to  allow  for  airlines  to  report  their  use  of  RFNBOs.  Finally,  adjustments  to  the  RED  II 
sustainability  criteria  for  SAF  could  be  considered  to  enhance  the  compatibility  with  CORSIA  and  facilitate 
SAF uptake by international airlines in the EU. 

7.3. 

Subsidiarity and proportionality 

All  POs  propose  EU  action  in  line  with  the  intervention  logic  described  in  sections  1  to  4.  The  subsidiarity 
dimension of the intervention is the same as that explained under section 3 and therefore is not repeated in this 
section.  

As proportionality, none of the POs go beyond what is necessary to achieve the objectives. PO B2, which scope 
is  reduced  to  intra-EU  flights,  falls  short  of  making  an  ambitious  contribution  to  the  decarbonisation  of  air 
transport and to the EU’s climate goals. All POs provide a reasonable lead-period before fuel obligations enter 
into force (2025), considering the time needed to scale up SAF production at the capacity needed. All POs also 
foresee additional lead-time before mandating the introduction of RFNBOs, recognising the time and resources 
needed for cutting-edge technologies to mature.  

Finally,  POs  C1  and  C2  provide  additional  flexibility  to  the  fuel  industry  at  the  early  stage  of  the  fuel 
obligation, accounting for the time needed for the production capacity to scale up at EU-level. 

7.4. 

The impact of the Covid-19 pandemic 

As  explained  in  section  5.1,  the  baseline  scenario  considers  the  impacts  of  the  COVID-19  pandemic  on 
transport activity, energy use and emissions. The pace of the recovery builds on the GDP projections but also 
considers some moderate structural changes due to limited shifts towards digital meetings. The overall impact 
of the COVID-19 pandemic on the air transport activity is significant, with lower growth projected relative to 
pre-COVID  projections  (i.e.  around  11  percentage  points  lower  growth  for  2015-2030  relative  to  the  pre-
COVID  projections  and  14  percentage  points  lower  growth  for  2015-2050).  At  this  stage,  the  COVID-19 
pandemic’s  long-term  effects  on  air  transport  activity  are  highly  uncertain  and  depend  on  the  ever-evolving 
global situation of the pandemic, the coordination of States to address it, and the ability of the aviation sector to 
restore  passenger confidence. Deeper structural changes may also take place due to the shifts towards digital 
meetings. 

61 

 
On  the  other  hand,  all  policy  options  are  either  defined  in  terms  of  a  minimum  share  of  SAF  (expressed  in 
volume terms) or in terms of a minimum reduction of the CO2 intensity (i.e. CO2 emissions per unit of energy) 
of  the  overall  jet  fuel  supplied,  which  proves  robust  to  changes  in  transport  activity.  For  example,  if  the  air 
transport activity were lower than projected in this impact assessment, the total energy use (and thus fuel sold) 
and  CO2  emissions  from  air  transport  would  also  be  lower  –  driven  by  the  lower  activity.  When  the  policy 
option  is  expressed  in  volume  terms,  despite  keeping  the  requirement  for  the  minimum  share  of  SAF 
unchanged,  the  absolute  volumes  of  SAF  that  are  required  to  meet  the  obligation  would  be  lower.  This  is 
because  of  the  lower  total  energy  use  in  air  transport.  When  the  policy  option  is  expressed  in  terms  of  a 
minimum reduction of the CO2 intensity of the overall jet fuel supplied, the outcome would be similar as the 
CO2 intensity is defined as the ratio between the CO2 emissions and total fuel use in air transport. As the lower 
air transport activity drives a reduction in both CO2 emissions and fuel use, the impact on CO2 intensity would 
be  only  determined  by  the  fuel  mix  and  thus  by  the uptake  of  SAF.  Similar  considerations  apply  in  case air 
transport activity would be higher than projected in this impact assessment, whereas the total energy use (and 
thus fuel sold) and CO2 emissions from air transport would also be higher. As a result, the ranking of the policy 
options is not expected to change in case of different developments in air transport activity.  

In addition, as already explained in section 1.3, an update of the pathway/scenario focusing on a combination of 
carbon  pricing  and  medium  intensification  of  regulatory  measures  in  all  sectors  of  the  economy,  while  also 
reflecting the COVID-19 pandemic, confirms that air transport effectively contributes to the EU climate goals 
while considering the 5% share of sustainable aviation fuels obligations in the air transport fuel mix by 2030 
and 63% by 2050. 

8.  PREFERRED OPTION 

PO B2 is not compatible with the level of climate ambition expected by the 2030 Climate Target Plan. It also 
raises important risks of distortion between airlines within the Single Market. POs A1 and A2 regulate only one 
side  of  the  market  (the  supply)  without  specific  safeguards,  which  is  likely  to  lead  to  undesirable  effects  of 
tankering  practices  by  2035.  Furthermore,  the  obligation  to  supply  SAF  at  all  airports  by  2025  is  deemed 
premature  at  the  early  stages  of  the  SAF  market,  and  may  lead to  unintended additional logistics  costs. This 
could also increase the price of SAF-blended jet fuel at small or remote airports. Finally, the acceptability of 
PO B1 is assessed to be its main weakness, as it may lead to controversial reactions from non-EU jurisdictions. 

POs C1 and C2 are considered the most efficient and effective to achieve CO2 reductions in the aviation sector 
in line with the EU’s climate goals. This corresponds to a reduction of well-to-wing emissions by 60.8% and 
60.2% by 2050, respectively for PO C1 and C2, relative to the baseline scenario. The difference in emissions 
savings achieved between both options is marginal and is due to the fact that the volume-based approach (PO 
C1) leads to a larger uptake of RFNBOs, compared to the CO2 intensity approach (PO C2). Both policy options 
allow to successfully scale up SAF production and uptake at EU level, i.e. by reducing the use of fossil jet fuel 
by around 65% by 2050, and substituting it with innovative and sustainable fuel technologies, which reach the 
market  much  earlier  than  in  the  baseline  scenario.  By  2050,  under  POs  C1  and  C2,  the  share  of  SAF  in  the 
aviation jet fuel mix amounts to 63%. By 2050, 92% of all SAF supplied to the EU market are produced in the 
EU, from feedstock and renewable electricity sourced in the EU. 

The  scale  of  the  challenges  at  stake  justifies  requirements  on  both  the  supply  and  the  demand  sides  of  the 
market to act in a co-ordinated way. POs C1 and C2 ensure that all airlines operating intra and extra-EU flights 
will contribute to SAF uptake and will be able to compete on equal footing. Both POs will ensure a harmonised 
framework for the EU aviation single market, leading to a uniform spread of costs across air service providers, 
and therefore will limit market distortions. The supply side obligation is designed in a way to allow the SAF 
industry to scale-up its production capacity by the time SAF-blended fuel supply is required at all airports. This 
will  contribute  to  avoiding  higher  SAF  prices  and  additional  emissions  due  to  unnecessary  logistics.  It  will 
avoid  putting  some  airports  e.g.  small  or  remote  airports  at  competitive  disadvantage.  SAF  suppliers  can 

62 

 
operate  transactions  between  over  and  under-achievers  for  accounting  purposes  towards  meeting  their  SAF 
obligation  during  the  transition  period,  i.e.  2025  and  2035.  This  will  allow  SAF  suppliers  to  meet  their 
obligations  in  a  more  cost-effective  way,  as  explained  in  section  5.4.4.  SAF  transactions  are  not  possible 
beyond 2035, since from that point in time all fuel suppliers will be required to supply airports with the exact 
minimum  of  SAF  shares,  as  defined  in  the  ramp-up.  Therefore,  it  is  not  desirable  to  allow  accounting 
transactions, whereby some suppliers could continue supplying low levels of SAF or only fossil fuel at certain 
airports  while  meeting  their  obligation  through  accounting  transactions.  It  should  be  noted  that  under  the 
preferred options there is no need for SAF transactions between airlines, as airlines are not subject to quantified 
SAF  obligations.  Gradually,  once  the  SAF  industry  has  developed  across  the  EU  by  2030  and  2035 
respectively,  all  airports  will  be  supplied  with  SAF.  This  will  reinforce  the  level  playing  field  within  the 
aviation  internal  market  since  all  airlines  (EU  and  non-EU)  will  have  no  alternative  than  to  use  the  SAF-
blended jet  fuel  available at all  airports.  POs  C1 and  C2  include  an important safeguard  against  the  possible 
effects  of  tankering,  as  all  airlines  will  be  required  to  refuel  before  each  departure,  with  the  amount  of  fuel 
needed to operate the planned flight. This is expected to strengthen fair competition between EU and non-EU 
airlines  on  international  routes,  and  contribute  to  reinforcing  the  level  playing  field  between  airlines  and 
airports in the EU aviation internal market. 

Therefore,  the  preferred  policy  options  are  C1  or  C2.  This  impact  assessment  considers  that  both  policy 
options allow to effectively and efficiently meet the policy objectives. As explained in detail in sections 5.3 and 
5.5.1,  the  difference  between  C1  and  C2  consists  of  the  definition  of  the  SAF  targets.  Under  C1,  the  SAF 
targets  are  expressed  in  SAF  volume  terms.  This  means  that  fuel  suppliers  are  required  to  supply  a  volume 
share of SAF as part of their total jet fuel supply, increasing over time (see section 5.4.3). Under C2, the SAF 
targets are expressed in CO2-intensity reduction terms. This means that fuel suppliers are required to supply jet 
fuel  to  EU  airports  with  a  CO2-intensity  decreasing  over  time  following  defined  targets.  The  other  notable 
difference between the two options is that PO C1 contains a specific sub-mandate for RFNBOs, whereas PO C2 
contains a specific multiplier for RFNBOs. The rationale for this difference is explained in section 5.5.1. It is 
essential to highlight that both C1 and C2 achieve the same reduction of CO2 emissions overall by 2030 and 
2050.  Therefore,  the  choice  between  C1  and  C2  does  not  determine  the  level  of  climate  ambition  of  this 
initiative.  Rather,  it  influences  how  the  market  reacts  and  it  orients  SAF  production  towards  scaling  up  the 
different SAF technologies. This is explained in full detail in section 6, and a direct comparison of the impacts 
of options C1 and C2 is provided in Table 14 under section 7.1. Overall, the impacts of the two options are very 
similar  on  a  wide  range  of  indicators  (including  the  amount  of  CO2  emissions  reductions  achieved,  the 
increased  SAF  production  capacity  in  the  EU,  the  capital  investments  needed  to  increase  SAF  production 
capacity, the reduction of EU’s imports of oil products, the logistics costs of supplying SAF, the increase on 
ticket  prices,  and  others).  The  notable  differences  on  the  impacts  between  C1  and  C2  are  the  following.  C1 
leads to a slightly higher supply and uptake of RFNBOs, as a result of the specific sub-mandate. On the other 
hand,  C2  results in  marginally  higher levels  of  advanced  biofuels. This leads  C1  to  requiring  slightly  higher 
amounts of renewable electricity for RFNBOs production and to inducing higher fuel costs for airlines. On the 
other hand, C1 presents the advantage of being easy to implement from a regulatory point of view, but more 
importantly from the side of the industry. Monitoring, reporting and verifying fuel volumes is generally easier 
than  fuel  CO2  intensity  reductions,  which  is  more  complex  from  a  methodological  standpoint.  There  is  no 
preference  expressed  for  C1  or  C2  as  both  POs  are  expected  to  deliver  very  similar  results  and  have  very 
similar impacts. Both POs would deliver on the policy objectives. 

Stakeholders  views  of  the  preferred  options.  The  large  majority  of  stakeholders  of  the  aviation  (airlines, 
airports,  aircraft  manufacturers)  and  fuel  industries,  Member  States  and  NGOs  support  establishing  a  SAF 
obligation as an effective policy mechanism to boost SAF production and uptake and successfully decarbonise 
the aviation sector. Stakeholders are quite divided on the specific design of the option but a majority of fuel 
suppliers, Member  States, NGOs,  airports  and  part  of  the airlines  support  a supply-side  SAF  obligation  with 

63 

 
flexibility in the fuel distribution, and covering jet fuel supplied for all flights departing from EU  airports. At 
the same time, the majority of stakeholders see the need for measures preventing carbon leakage and distortion 
in  the  aviation  internal  market.  A  majority  of  stakeholders  (airlines,  airports,  fuel  industry,  NGOs,  Member 
States) also support specific incentives to support RFNBOs. All these measures are included in POs C1 and C2. 
Following  wide  consultations  on  the  preference  between  C1  and  C2,  stakeholders  have  expressed  mixed 
views. In the context of the targeted consultation accompanying this impact assessment, 40 respondents out of 
73  favoured  a  volume-based  target  (C1),  while  47  respondents  out  of  73 favoured  a  CO2 intensity-reduction 
based target (C2)169. Member States show a clear preference for a volume-based system (C1), while NGOs have 
a clear preference for a CO2-intensity reduction based target (C2). There seems to be no consensus among the 
aviation industry nor among the fuels industry towards one or the other approach. 

The present initiative must be rolled out swiftly and efficiently, as a key deliverable of the European Green 
Deal  and  the  Sustainable  and  Smart  Mobility  Strategy,  and  as  a  necessary  building  block  towards  reaching 
EU’s climate goals by 2030 and 2050 by ensuring that the aviation sectors speed up its own decarbonisation 
without  jeopardising  the  well-demonstrated  benefits  of  a  highly  integrated  aviation  internal  market.  As 
explained  in  section  1.4  and  Annex  11,  this  can  be  achieved  most  successfully  by  directly  regulating 
economic  actors  at  EU  level  through  an  internal  market  Regulation.  Indeed,  common  rules  applying 
directly and uniformly to aviation and fuel market actors across the EU will provide clarity and uniformity. As 
the aviation single market is inherently integrated at EU level, it functions best when rules are applied to all 
airlines  in  the  same  way.  Imposing  the  same  requirements  to  all  market  players  reduces  the  risks  of 
distortion of competition and sends clear signals to non-EU aviation market actors, when flying in the EU. A 
uniform set of rules across the EU, as established under a Regulation, will allow to send loud and clear signals 
to the market. As the transition to SAF requires significant investments (see section 6.2.5), it is indispensable 
that the regulatory framework provides a single, long-term and robust set of rules to all investors EU-wide. In 
particular, it is crucial to avoid the creation of a patchwork of differing measures at national level, as would 
be the case if implemented under a cross-sectoral directive such as the Renewable Energy Directive. While this 
can function with transport modes like road or rail, it cannot be successful for transport modes that are so cross-
border  and  global as aviation. The  market  scale  of  most airlines  is  EU-wide  or even  global.  A  patchwork  of 
national  transpositions  could  reduce  the  effectiveness  of  the  policy  and  put  in  jeopardy  the  effective 
decarbonisation of air transport. It could also be conducive to different economic behaviours in the aviation and 
fuel industries from one Member State to another. This could lead to practices of cost avoidance (e.g. via fuel 
tankering)  that  would  undermine  the  functioning  of  the  Single  Market.  The  present  initiative  will  have  an 
important  impact  on  air  transport  actors  and  the  aviation  internal  market  as  a  whole.  It  is  essential  that 
obligations set on all airlines apply to all airlines uniformly, as can be ensured via a regulation. It is equally 
important for the effectiveness of this initiative that the fuel supply obligation be implemented and enforced in 
a  uniform  way.  Differing  fuel  supply  obligations  in  different  areas  of  the  EU  (e.g.  different  targets,  varying 
sustainability standards, etc.) would set differences of treatments between airlines and could induce competitive 
distortions between EU airports or put EU aviation actors at disadvantage with non-EU competitors. In terms of 
type  of legal  instrument,  the  present initiative  should  be implemented  as  a standalone  Regulation  in  order  to 
cater  for  the  specificities  and  complexities  of  the  aviation  single  market.  Such  detailed  provisions 
regulating the aviation market cannot be established under the Renewable Energy Directive, which scope goes 
only as far as energy matters are concerned. 

The  timing  of  this  initiative  is  an  essential  factor  of  success.  This  initiative  is  a  key  deliverable  of  the 
European Green Deal and a necessary building block towards reaching EU’s climate goals by 2030 and 2050. 
Regulatory certainty is needed imminently. Indeed, to reach the SAF objectives of around 2% by 2025, a lead-
time of 3-4 years is necessary for the industry to scale up its SAF production capacity. This means that a SAF 

169   Respondents were asked about their level of support 

64 

 
                                                           
regulatory framework must  be  in force in  Union law  by  2022. This  would be  very  difficult  to  achieve  if 
implemented  through  a  large  economy-wide  regulatory  framework  (e.g.  RED).  To  illustrate  this,  the  past 
experience of RED II shows that from adoption of the proposal by the Commission (2016), to transposition and 
entry into force in Member States (deadline for transposition is June 2021), the process took 5 to 6 years. Such 
a timeline of 5 to 6 years for the implementation of ReFuelEU Aviation would  mean that a SAF framework 
would  only  enter  into  force  at  Member  States  level  by  2026.  This  would  jeopardise  chances  of  effectively 
decarbonising aviation and contributing efficiently to the EU’s climate goals, as SAF would likely not reach the 
market before 2029-2030 (a lead time of 3 to 4 years is necessary for investments to flow and the fuel industry 
to scale up, which is the absence of a robust regulatory framework is unlikely to happen). On the other hand, if 
adopted  through  a  standalone  Regulation,  the  present  initiative  would  have  higher  chances  of  being  adopted 
swiftly. It could become applicable with immediate effect after entry into force as early as end of 2022.  

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The impacts of this initiative will be monitored on two fronts, i.e. the supply of SAF by fuel suppliers and the 
uptake  of  SAF  and  jet  fuel  by  airlines.  As  regards  the  supply  of  SAF,  this  will  be  performed  through  the 
existing  processes  set  out  under  RED  II  for  monitoring,  reporting  and  verification  of  biofuels  supply.  In 
particular,  the  Union  Database  will  serve  for  fuel  suppliers  to  directly  insert  their  data  on  SAF  supply.  The 
accuracy  of  such  data  will  be  verified  at  national  level  as  per  the  processes  and  requirements  already 
established  in  RED  II  rules.  This  data,  providing  information  on  SAF  supply  at  supplier  level,  will  then  be 
processed by an existing EU agency (e.g. EASA) in order to determine whether fuel suppliers have met their 
obligation and will be reported to the Commission. Enforcement will be carried out at national level. 

The  SAF  uptake  of  airlines  will  be  monitored  through  the  already  existing  monitoring,  reporting  and 
verification processes of the EU ETS. Airlines operating intra-EU flights will include information relative to 
their  SAF  uptake  as  part  of  their  Aviation  Emissions  Reports.  These  reports  will  be  made  available  to  an 
existing EU agency or European organisation (e.g. EASA, Eurocontrol) to compile the information relative to 
SAF  use  at  airline  level.  Regarding  the  jet  fuel  uplift  obligation  imposed  on  all  airlines  departing  from  EU 
airports, this be will monitored through a direct reporting by all airlines to an existing European organisation or 
EU  agency  (e.g.  EASA,  Eurocontrol).  The  information  on  jet  fuel  uplift  at  flight  level  per  airline  will  be 
processed to identify cases of fuel tankering and reported to the Commission. Enforcement will be carried out 
at national level. More detailed information on monitoring, reporting and verification is included in Annex IX. 

The monitoring of the implementation of the present initiative will be useful (and vice-versa) for the monitoring 
of other regulatory frameworks such as the EU ETS, RED II and ETD. For instance, data on the status of the jet 
fuel  market,  the  price  of  SAF,  and  the  level  of  uptake  by  airlines  will  be  fully  relevant  to  assess  the 
effectiveness of specific provisions of the EU ETS (e.g. the zero-rating for SAF) and other initiatives. Based on 
such  monitoring,  it  will  be  possible  to  assess  the  complementarity  between  the  present  initiative  and  others. 
This could also potentially provide useful insights on the need to review specific features of the EU regulatory 
framework to ensure further complementarity and that the various initiatives can continue to mutually reinforce 
each other.  

65 

 
 
 
 
 
 
 
Annex 1: Procedural information 

1.  LEAD DG, DECIDE PLANNING/CWP REFERENCES 

Directorate General for Mobility and Transport (DG MOVE), Unit E1 – Aviation Policy, is the lead DG for 
this legislative proposal – ‘ReFuelEU Aviation’ aimed at boosting the production and uptake of sustainable 
aviation  fuels  in  the  air  transport  sector.  This  initiative’s  Decide  reference  is  PLAN/2020/6623.The 
Inception Impact Assessment was published in March 2020.170  

2.  ORGANISATION AND TIMING 

This  impact  assessment  accompanying  the  legislative  proposal  ReFuelEU  has  been  consulted  within  the 
Inter-Service Steering Group (ISSG) comprising the following members:  Secretariat General (SG), Legal 
Service  (LS),  Directorate-General  for  Mobility  and  Transport  (MOVE),  Directorate-General  for 
Competition  (COMP),  Directorate-General  for  Environment  (ENV),  Directorate-General  for  Internal 
Market, Industry, Entrepreneurship and SMEs (GROW), Directorate-General for Climate Action (CLIMA), 
Directorate-General  for  Energy  (ENER),  Directive-General  of  Regional  and  Urban  Policy  (REGIO), 
Directorate-General for Taxation and the Customs Union (TAXUD), Joint Research Centre (JRC-ISPRA), 
Directorate-General  for  Defence  Industry  and  Space  (DEFIS).  In  total,  4  meetings  were  organised  to 
discuss  this  impact  assessment.  Some  meetings  were  held  by  phone  due  to  the  COVID-19  crisis.  Many 
written consultations of the ISSG took place by email at various stages and on various drafts of this impact 
assessment. 

3.  CONSULTATION OF THE RSB 

The Regulatory Scrutiny Board received the draft version of the impact assessment report on 18 December 
2020.  The  Board  meeting  took  place  on  20  January  2021.  On  22  January,  the  Board  gave  a  negative 
opinion  on  the  report.  The  Board  made  several  recommendations.    Those  were  addressed  in  the  revised 
impact assessment report as follows in the first table below. On 3 March 2021, the Board gave a positive 
opinion  on  the  report.  The  Board  made  several  recommendations  to  be  taken  into  account.  Those  were 
addressed in the impact assessment report, as follows in the second table below. 

RSB recommendations for IA 
resubmission 

Modification of the IA report 

Main considerations 

A new section (section 1.3) has been added to the report, to explain 
the ramp-up of SAF obligations. It also explains the compatibility 
with the overall EU 2030/2050 climate targets. In addition, section 
5.4.3 has been reinforced and now includes a qualitative assessment 
of the implications and feasibility of alternative ramp-up of SAF 
obligations. 

1.  The  report  is  unclear  about  how  it  has 
established  the  fuel  specific  targets  and 
pathways  for  the  aviation  sector,  and  what 
the key assumptions and uncertainties are. It 
does  not  show  how,  and  under  what 
conditions,  they  are  compatible  with  the 
overall  EU  2030/2050  climate  targets.  The 
report does not analyse the implications and 
feasibility  of 
and 
alternative 
pathways. 

targets 

2. The report is not sufficiently clear on how  A new section (section 1.4) has been added to the report to explain 

170   Source: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12303-Sustainable-aviation-fuels-ReFuelEU-Aviation  

66 

 
 
 
                                                           
it  ensures  coherence  with  the  other  ‘Fit  for 
55’  initiatives.  It  does  not  explain  how  it 
takes  into  account  the  uncertainty  on  the 
future  content  of  the  most  directly  related 
climate initiatives. 

the coherence with the other ‘Fit for 55’ initiatives. Additional 
explanation is provided in section 2.3 (How the problem will 
evolve) as well as in section 7.2 (Coherence with other initatives). 

the  present 

3. The report does not explain convincingly 
why 
initiative  cannot  be 
integrated  into  existing  instruments  that  are 
part of the ‘Fit for 55’ package. 

The report now contains a more in-depth analysis of the reasons 
why the present initiative cannot be covered by the RED. This is 
explained in section 1.4 on ‘Coherence with the Fit for 55 
initiatives’, in section 8 on the ‘Preferred Option’ and in more 
details in Annex 11. 

4.  The  report  is  not  always  clear  on  the 
content  of  the  options  and  how  they  will 
function. It does not explain why there is no 
preferred option. 

The relevant sections of the report (section 5.3 and 5.4.4) now 
provide more clarity on each policy option, including on elements 
such as the monitoring, SAF transaction system, anti-tankering 
measure, and others. 

Adjustment requirements 

A new section (section 1.3) has been added to the report, to explain 
the ramp-up of SAF obligations. It also explains that they will 
contribute towards the overall EU 2030/2050 climate targets and 
with the objective of decarbonising the aviation sector. Section 1.3 
also provides more context on the flexibility, which exists to decide 
on the exact level of ambition of individual measures such as 
ReFuelEU Aviation, given the corrective mechanisms offered under 
the ETS, the Effort Sharing Regulation, and other instruments to 
reach the EU’s climate targets, but also the possibility to revise the 
level of ambition of measures as we get closer to the delivery of EU 
climate targets. 

The new section 1.3 explains how the ramp-up of SAF obligations 
has been selected. In addition, section 5.4.3 has been reinforced and 
now includes a qualitative assessment of the implications and 
feasibility of alternative ramp-up of SAF obligations. 

A new section (section 1.4) has been added to the report to explain 
the  coherence  with  the  other  ‘Fit  for  55’  initiatives.  Additional 
explanation  is  provided  in  section  2.3  (How  the  problem  will 
evolve) as well as in section 7.2 (Coherence with other initatives). 

Section 5.1 (What is the baseline from which options are assessed?) 
clarifies  that  the  other  ‘Fit  for  55’  initiatives  are  not  part  of  the 
baseline. It further explains how coherence is ensured.  

(1) The  report  should  explain  how  the  fuel-
specific  targets  (or  parameters)  for  aviation 
were  chosen.  It  should  make  clear  how  the 
proposed  pathways  towards  these  targets 
align  with the GHG  reduction targets of the 
Climate Law, and how they follow or differ 
from  the  Climate  Target  Plan  modelling 
scenarios.  The  report  should  explain  the 
assumptions behind the aviation fuel targets, 
they  are 
and  under  what  conditions 
compatible  with 
the  other 
for 
transport sectors. 

targets 

(2) The report should justify why it does not 
include  any  alternative  aviation  fuel  targets 
and  pathways.  It  should  present  at  least  a 
qualitative  analysis  of  the  feasibility  and 
implications of deviating from the set target, 
including  for 
the  overall  ‘Fit  for  55’ 
package. 

(3) The report should better explain how the 
initiative  is  coherent  with  the  most  directly 
related  other  ‘Fit  for  55’  initiatives  (in 
particular  the  Renewable  Energy  Directive, 
the  Emissions  Trading  System,  and  the 
Energy  Taxation  Directive).  Would  this 
initiative  make 
the  others 
superfluous  in  the  aviation  sector?  As  the 
baseline  does  not  include  the  envisaged 
changes  of  the  other  ‘Fit  for  55’  initiatives, 
the  report  should  explain  why  it  does  not 
include  alternative  policy  scenarios  in  the 
options  to  reflect  the  uncertainty  on  the 
future of these other initiatives. 

some  of 

(4)  The  baseline  should  further  qualify  the 
impact  of  the  Covid-19  pandemic,  its  likely 
long-term  consequences,  and  the  degree  of 
uncertainty  of  these  estimates.  It  should 
conduct  a  sensitivity  analysis  to  assess  the 

Section 5.1 (What is the baseline from which options are assessed?) 
has been reinforced and provides more insights on the impact of the 
COVID-19  pandemic  relative  to  pre-COVID  projections.  More 
details  are  also  provided  in  Annex  4.  A  new  section  (section  7.4) 
has been added to the report that provides a qualitative assessment 

67 

 
possible  effects  of  different  Covid-19 
scenarios  on 
the 
initiative. 

the  effectiveness  of 

(5)  The  report  should  explain  why  this 
initiative  cannot  be  covered  by 
the 
Renewable  Energy  Directive,  given  that 
blending  of  jet  fossil  fuels  with  SAF  seems 
to  be 
technological 
option. 

the  only  (realistic) 

of lower/higher growth in air transport activity on the effectiveness 
of the initiative.   

The  report  now  contains  a  more  in-depth  analysis  of  the  reasons 
why  the  present  initaitive  cannot  be  covered  by  economy-wide, 
cross-sector  regulatory  frameworks  such  as  the  RED.  This  is 
explained in section 1.4, in section 8 on the ‘Preferred Option’ and 
in more details in Annex 11. 

(6) The report should provide more detail on 
how  far  scaling  up  of  SAF  demand  will 
contribute  to  reducing  costs  and  prices.  It 
should provide more detail about the sources 
of  greater  feedstock  supply  and  competing 
demands.  It  should  explain  better  the  cost 
differences  between  standard  and  advanced 
biofuels. 
also 
report 
acknowledge  the  high-energy  demand  for 
producing  biofuels.  The  impact  assessment 
should be explicit about how coherence will 
be  ensured  with the EU’s overall renewable 
energy  policy  (e.g.  for  competition  for 
feedstock,  or  accounting  of  total  renewable 
targets),  and  how  the  risk  for  overlapping 
regulation is avoided. 

should 

The 

(7)  The  report  should  further  specify  the 
content  of  the  options  and  how  they  will 
work.  For  instance,  it  should  clarify  the 
foreseen  monitoring  arrangements,  the  role 
and set-up of the foreseen Agency. It should 
explain the functioning of a SAF certificates 
trading system, and clarify  why it  would be 
needed under the preferred option. It should 
justify the choice of values for the renewable 
fuels  of  non-biological  origin  (RFNBO) 
multipliers.  It  should  explain  why  anti-
tankering  measures  should  already  be 
introduced  during 
transition  period, 
the 
when  the  risk  of  tankering  only  arises  after 
2035. 

The report now contains a new paragraph in section 6.2.1 and a new 
Annex 16 dedicated to providing the reader with more information 
on  the  contribution  of  economies  of  scale  to  decreasing  SAF 
production costs. The role of economies of scale is also explained 
in the problem definition in  section 2.2.2, including a reference to 
Annex  16.    The  annex  provides  in-depth  explanations  on  the  cost 
structure for the production of SAF pathways and elaborates on the 
key  differences  in  production  costs  between  Part  B  and  advanced 
biofuels. 

The  report,  section  6.1.2  now  contains  more  explanations  on  the 
sources  of  feedstock  used  for  Part  B  and  advanced  biofuels 
production.  It  also  explain  in  detail  what  would  be  the  feedstock 
requirements for SAF production, and how this would relate to the 
total  amount  of  feedstock  available  for  other  transport  and  energy 
sectors. In addition, section 6.1.2 now better acknowledges the high 
enegy demand for the production of RFNBOs and provides detailed 
figures  on  energy  needs,  including  with  respect  to  total  renewable 
energy  supply  in  the  EU.  Under  the  same  section,  figures  and 
information have also been added on the energy needs for biofuels 
production. 

The  report,  now  contains  a  new  section  1.4  that  explains  in  detail 
the coherence of the present initiative  with the initiatives from the 
‘Fit  for  55’  package.  In  addition,  section  7.2  on  ‘Coherence’  now 
contains  an  in-depth  analysis  of  the  coherence  of  ReFuelEU 
Aviation with the EU’s renewable energy policy, in particular with 
the  various  features  and  mechanisms  contained  in  the  RED  II. 
Section  7.2.  clearly  indicates  how  double  regulation  is  avoided.  It 
also  includes  information  on  the  interaction  with  other  relevant 
instruments  such  as  the  EU  ETS  and  ETD,  including  by  giving 
indications on the interactions of these instruments in view of their 
upcoming revision. 

Section 5.3 (description of the policy options) has been reworked to 
provide  more  information  and  clarity  on  the  functioning  of  each 
policy option. 

In particular, explanations have been added under the description of 
each  policy  option  in  section  5.3,  on  the  functioning  of  the 
monitoring,  reporting  and  verification  on  the  supply  side  and  the 
airlines side where relevant. Also, section 9 on how impacts will be 
monitored has also been reworked to provide more clarity. Finally, 
Annex 9 is entirely dedicated to the functioning of the monitoring, 
reporting and verification systems for each policy option. 

The  report  also  clarifies  the  role  of  the  existing  EU  agency  that 
would be required to process SAF supply/use data and report to the 
Commission. This is clarified in several instances, including section 
5.3 and Annex 9. 

The  report  (section  5.3  and  5.4.4)  provides  more  detailed 

68 

 
information  on  the  need  for  and  the  functioning  of  a  SAF 
transaction system for accounting purposes. It also clearly specifies 
whether  this  would  be  needed  on  the  side  of  fuel  suppliers  or 
airlines, and under which policy option. It gives information about 
how  such  a  system  could  be  implemented  and  would  function  in 
practice. 

The report now provides more detailed information on the choice of 
numerical  values  for  the  multipliers  applying  to  RFNBOs  under 
POs A2 and C2. This is explained in section 5.3.2, section 5.3.6 and 
section 5.5.1. 

The  report  now  contains  more  detailed  explanations  on  the  anti-
tankering  measure  under  sections  5.3.5  and  6.2.8.  In  particular,  it 
clarifies why this measure is necessary already 2025. 

The  report  now  provides  a  more  in-depth  analysis  of  the  risks  of 
loss  of  competitiveness  by  EU  hub  airports,  and  EU  airlines  as  a 
result  of  SAF  obligations.  This  is  included  in  section  6.2.8.  This 
section also provides indications on the effects this may have on the 
effectiveness of the ReFuelEU Aviation legislation. 

The  report  now  provides  a  more  in-depth  analysis  of  the  policy 
options  and  of  their  impacts  under  section  6.  In  particular,  under 
section  8,  it  discusses  in  detail  the  differences  between  the  two 
preferred  policy  options  C1  and  C2.  Section  8  also  now  clearly 
indicates  stakeholders  views,  also  indicating  the  views  of  various 
categories  of  stakeholders  on  the  various  aspects  of  the  preferred 
policy options.  

(8)  The  competitiveness  analysis  should 
elaborate  the  risk  that  airlines  will  re-route 
longhaul  flights  to  non-EU  hubs.  It  should 
the 
consider 
the 
effectiveness  of 
competitiveness 
and 
intercontinental airports. 

consequences 
the  Directive,  and 
of  EU 

airlines 

the 

for 

the 

analysis 

(9)  The  report  should  more  rigorously 
elaborate 
and 
impact 
comparison of options. It should clarify why 
it presents two alternative preferred options. 
To  better  inform  policy  makers’  choice,  it 
should  clarify  the  main  differences  between 
them and indicate stakeholders’ views. 

RSB recommendations after IA 
resubmission 

Modification of the IA report 

Improvements required 

(1)  The  report  should  briefly  explain  why 
the  transport  sector  should  reduce  its  CO2 
emissions  only  by  90%  by  2050.  It  should 
similarly  clarify  how  this  margin  has  been 
distributed across the transport sectors. 

The report now provides  with an explanation of  why the transport 
sector  is  required  to  reduce  its  emissions  only  by  90%  while  the 
economy  aims  at  carbon  neutrality.  An  explanation  is  included  on 
how  other  sectors  need  to  compensate  for  the  residual  emissions 
accountable to transport. This is contained at the top of section 3 of 
Annex 4. 

(2)  The  report  shows  that  various  climate 
initiatives  affecting  aviation  (e.g.  ETS, 
energy 
taxation,  renewable  energy)  are 
coherent  with  the  present  initiative  and  that 
their  climate  objectives  are  compatible. 
However,  it  could  still  better  demonstrate 
how  direct  regulatory  measures  (such  as 
compulsory  SAF  uptake) 
interact  with 
initiatives  based  on  market  incentives.  The 
report  could  further  develop  this  analysis 
and  clarify  how  the  various  instruments 
contribute  to  the  multiple  objectives  they 
pursue  (SAF  uptake,  mitigating  fuel  price 
increase,  fuel  efficiency,  promoting  future 
technologies).  The  report  should  better 

The report now provides further analysis on the combined role of 
direct measures (such as a SAF obligation) and market measures 
such as the energy taxation directive or the EU ETS. It is notably 
discussed how these measures can pursue the same objectives (SAF 
uptake, greater fuel efficiency, uptake of more innovative aircraft 
technologies, etc.) This is included in section 7.2. The report also 
now includes a new paragraph explaining how the monitoring for 
the present initiative and other relevant pieces of regulatory 
framework, pursuing the same objectives, can provide useful 
insights for each other and ensure complementarity. This could also 
be useful to assess the need for potential revisions of specific 
features of these instrument. This is explained in section 9. 

69 

 
 
 
explain  how  the  monitoring  and  evaluation 
arrangements 
ensure 
complementarity between the various policy 
iniatives over time. 

help 

will 

The report now clearly acknowledges that uncertainties exist in the 
analysis,  notably related to the evolution of the  price  gap  between 
SAF  and  conventional  aviation  fuels.  In  particular,  the  report 
explains that if the price gap increases (instead of decreasing, as the 
analysis projects), this could lead to providing non-EU airlines and 
non-EU  airport  hubs  with  a  competitive  advantage  and  put  at  risk 
the  competitiveness  of  the  EU  aviation  industry.  This  could  be 
assessed and remedied in the framework of the review clause of the 
instrument. This is explained in section 6.2.8. 

this  will  affect 

(3)  The  report  should  be  more  transparent 
about  uncertainities  underlying  the  analysis. 
For instance, the report should better reflect 
the uncertainty as to the likely price level of 
SAF  and  how 
the 
competitiveness  of  the  sector.  It  should 
consider the risks of an increasing price gap 
between  conventional  and  advanced  fuels 
for 
the  competitivenesss  of  European 
intercontinental  airport  hubs.  Given  that 
third  country  network  carriers  will  not  be 
subject 
to  EU  anti-tankering  and  SAF 
obligations  when  competing  for  “indirect” 
third 
longhaul 
cost-
country  hub, 
competitiveness  of  EU  network  carrier  and 
EU hubs should be better assessed. 

traffic  connecting  via  a 
impacts  on 

the 

The report now provides a paragraph to explain this point in section 
6.2.1 

(4) Regarding the competition for feedstock, 
the report should not only look at aviation’s 
share  in  fuel  production,  but  also  at  the 
possible  impact  on  fuel  prices  given  certain 
demand or supply price rigidities. 

4.  EVIDENCE, SOURCES AND QUALITY 

The  Commission  contracted  an  external,  independent  consultant  (Ricardo)  to  support  this  impact 
assessment.  Quantitative  and  qualitative  data  supporting  this  impact  assessment  has  been  collected  from 
Member States, airports, airlines and fuel suppliers. This report draws on the extensive consultations with 
stakeholders. 

70 

 
 
 
 
 
Annex 2: Stakeholder consultation 

1.  INTRODUCTION  

The  Commission  actively  engaged  with  stakeholders  and  conducted  comprehensive  consultations  throughout 
the impact assessment process.  This stakeholder consultation annex provides an overview of the consultation 
strategy and present a summary of stakeholder inputs. 

Stakeholder  involvement  was  vital  for  the  impact  assessment  in  order  to  collect  facts  and  data  enabling  the 
Commission to substantiate, validate, develop or modify the problems and their drivers, and the corresponding 
objectives  identified  in  the  inception  impact  assessment  and  to  elaborate  a  list  of  specific  possible  policy 
measures and policy options which could address each of the problem drivers identified, with a different level 
of  legislative  and/or  non-legislative  intervention.  The  information  collected  from  stakeholders  was  key  in 
allowing  the  Commission  to  assess  the  economic,  social  and  environmental  impacts  of  each  policy  option, 
compare them and determine which of the policy options is likely to maximize the benefits/costs ratio for the 
society.  

2.  CONSULTATION STRATEGY 

The objective of the consultation for this impact assessment aimed to gather the views of stakeholders on the 
problem definition, policy objectives, potential policy measures and expected impact of policy measures.  

The consultation strategy171 was developed from the start of the project and included as key stakeholders the 
following groups: (i) EU institutions and international organisations; (ii) Member States / national authorities / 
Civil Aviation Authorities; (iii) Air transport service providers; (iv) Fuel and feedstock producers, suppliers and 
retailers;  (v)  NGOs;  (v)  Other  (including  airports,  aircraft  manufacturers,  air  navigation  service  providers, 
aerospace research centres, employees, trade unions and professional organisations). Following the consultation 
process, the results were considered as part of the problem definition, the identification of different measures 
and policy options as well as the analysis of impacts and the design of the preferred policy option, to ensure 
that the views of key stakeholder groups were accounted for. The consultation results were used to support the 
identification  and  quantification  of  impacts,  building  on  the  findings  from  the  modelling  activities  and  desk 
research conducted as part of this study. 

Table  [x]  below  provides  an  overview  of  consultation  methods  and  the  extent  of  replies  and  engagement  of 
different stakeholder groups across them. 

Stakeholder category 

Inception Impact 
Assessment 
(IIA)172 

Open Public 
Consultation 
(OPC)173 

Interviews
174 

Survey
175 

Follow up 
survey177 

Workshops 
(4th March 
2020 and 10 
November 
2020)176 

171   Source: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12303-Sustainable-aviation-fuels-ReFuelEU-Aviation. 
172   The IIA open public consultation was open from 24 March 2020 to 21 April 2020 (four weeks). 
173   The Open Public Consultation was open from 5 August 2020 until 28 October 2020 (12 weeks). Respondents reside in 14 Member States: 
AT, BE, FI, FR, DE, HU, IE, IT, MT, NL, PL, PT, ES and SV) as well as Canada, Guinea, Hong Kong, Switzerland, the United Kingdom 
and the United States. Most responses were received from stakeholders from DE (29), BE (26), FR (14) and SV (14). 

174   In order to get early involvement of key stakeholders, four exploratory interviews were conducted between 27 July 2020 and 11 August 
2020  with  the  objective  to  help  to  better  assess  the  intervention  logic  and  policy  measures  that  were  considered  at  that  time.  These 
interviews were later supplemented by targeted interviews that took place 19 August 2020 and 9 October 2020 to obtain specific input from 
stakeholders on the identified problems and proposed policy objectives as well as to seek views on the expected impacts. Some interviews 
were followed up with email exchanges. 

175   A survey was developed to obtain the views of a wide range of stakeholders, including national authorities and industry. 
176   On  10  November  2020,  the  European  Commission  held  a  roundtable  discussion  on  SAF.  Participants  from  industry  and  Member  States 
were  invited  to  discuss  the  potential  impacts  of  different  policy  options,  which  were  based  upon  variants  of  a  blending  mandate  with 

71 

 
                                                           
 
EU institutions and 
international industry 
organisations 
Member State 
authority 
Fuel producer 
Airline 
NGO 
EU citizens 
Other178  
N/A 
Total 
(Source: Ricardo) 

4 

8 

46 
11 
8 
2 
34 
4 
117 

2 

14 

37 
24 
13 
0 
66 
4 
160 

2 

3 

7 
5 
2 
0 
2 
0 
21 

2 

2 

11 

13 
19 
1 
0 
27 
0 
73 

20 

14 
12 
2 
0 
16 
0 
 66 

2 

8 

11 
10 
1 
0 
10 
0 
42 

3.  SUMMARY OF INPUTS AND STAKEHOLDER VIEWS  

Stakeholders provided significant input that helped validate the definition of the problem and development of 
policy options. The sections below summarise the input provided across all stakeholder consultation activities. 
Input  came  primarily  from  the  OPC  and  targeted  consultation  activities  and  was  validated  through  the  IIA 
feedback and workshop. 

4.  POLICY CONTEXT 

Out of the airlines and airports responding to the targeted survey, less than half (8 out of 19 airlines and 2 out of 
6  airports)  responded  that  either  they  use  advanced  biofuels  or  electro-fuels  for  commercial  operations. 
Responses  in  the  targeted  survey  and  targeted  interviews  suggested  there  is  no  geographical  region  where 
advanced  biofuels  or  electro-fuels  are  being  used  more  than  others.  When  asked  what  percentage  of  fuel 
volumes  are  currently  SAF,  a  total  of  9  industry  stakeholders  (7  airlines  and  2  airports)  provided  responses 
ranging from less than 0.1% up to 1%.   

The importance of SAF is widely accepted as 148 of 160 respondents in the OPC indicated that SAF is relevant 
for decarbonisation of the aviation  sector and 112 respondents  believe  that  significant  SAF  uptake  is  needed 
prior to 2030 in order to achieve climate neutrality by 2050. Despite this, only 74 respondents could provide an 
example of a successful introduction of SAF in air transport.  

In  terms  of  which  specific  SAF  pathways  are  known  to  stakeholders,  55  of  73  respondents  in  the  survey 
indicated  they  are  familiar  with  Power-to-liquid  (PtL)  and  Hydroprocessed  Esters  and  Fatty  Acids  (HEFA-
SPK), followed by Biomass Gasification + Fischer-Tropsch (Gas+FT) and Co-processing oils/fats with 53 and 
52 positive responses, respectively.  Only 37 of 73 stakeholders were familiar with Catalytic Hydrothermolysis 
(CHJ). For most of the production routes, fuel/feedstock producers had the greatest share of respondents that 
were familiar with that particular route. Exceptions to this were Hydroprocessed fermented sugars to synthetic 
Isoparaffins (HFS-SIP) and CHJ, for which other aviation industry representatives showed the highest level of 
familiarity, and PtL, which was best known by stakeholders from the other category. 

supporting measures. In total, 45 industry organisations and 20 Member States were represented (AT, BE, BG, CY, CZ, FR, FI, DE, HU, 
IE,  IT,  LV,  LU,  MT,  NL  PL,  PT,  RO,  ES  and  SV).  In  the  first  part  of  the  workshop,  industry  stakeholders  were  invited  to  indicate  a 
preference  for  policy  options  presented,  providing  justification,  and  to  explain  the  potential  impacts  of  specific  mandate  criteria.  The 
second session was for Member States representatives only, who indicated their preference by reflecting on the earlier discussion. 

177   As a follow-up to the roundtable, the study team distributed a survey to consolidate the preferences of relevant stakeholders regarding the 
presented  policy  options.  The  survey  was  distributed  on  13  November  2020  and  was  open  for  responses  until  18  November  2020.  The 
objective of the survey was to acquire a conclusion to the discussions held at the workshop and allow participants to provide their final 
views on the ReFuelEU aviation initiative. 

178   Including  airports,  aircraft  manufacturers,  air  navigation  service  providers,  aerospace  research  centres,  employees,  trade  unions  or 

professional organisations. 

72 

 
                                                                                                                                                                                                     
5.  PROBLEM DEFINITION 

In the survey, 65 of 73 stakeholders identified ‘production and supply of SAF at reasonable costs in the EU is 
limited’ as an issue hindering the use of SAF in the EU and 48 of 73 similarly identified that ‘demand for SAF 
is low in current market conditions’ as an issue. The results from these targeted survey questions indicate that 
the use of SAF in the EU has been hindered due to issues on both the production and demand side.  

When exploring specific challenges for the production and uptake of SAF, 69 of 73 respondents in the survey 
either agreed or strongly agreed that ‘high market prices of SAF compared to conventional jet fuel’ are an issue 
with stakeholders indicating a price difference between 1.5 to 6 times the price of fossil jet fuel depending on 
the pathway. Furthermore, airlines noted further strain has been placed on the price differential challenge as a 
result of Covid-19. Similarly, 134 of 160 respondents in the OPC ranked the importance of this issue as 4 or 5 
(on a scale of 1 to 5). The price gap between SAF and conventional fuel was by far the greatest challenge raised 
by stakeholders on the uptake side in the IIA feedback.  

In the survey, the second most significant challenge identified was ‘high upfront capital and operational costs 
for novel conversion processes at an early commercial stage’, with 62 of 73 stakeholders agreeing or strongly 
agreeing.  This  is  in  line  with  the  OPC  results  where  the  second  most  significant  issue  was  ‘excessive 
production cost and high investment risk in SAF plants’. This is evidenced by the limited production capacity 
in Europe, indicating that a small number of facilities are operating at commercial scale. In the IIA feedback, 
the  most  significant  production  cost  raised  by  stakeholders  related  to  the  building  of  first-of-a-kind  (FOAK) 
facilities,  hence  driving  up  the  price  of  their  offtake  once  they  become  active  and  hampering  their  ability  to 
reach the critical mass of profitability. 

61 of 73 respondents in the survey also identified ‘lack of clear policy signals and limited impacts of existing 
legal framework  for the  aviation  sector’  as  a  challenge,  including  stakeholders from  both the  production  and 
demand side. From the production side, the absence of long-term policy in the EU drives producers to focus on 
the existing road market and on the demand side airlines noted the need for policy instruments to reduce the 
price differential. The absence of a regulatory framework and the lack of incentives were also a common barrier 
for  stakeholders  in  the  IIA  feedback  as  the  necessary  confidence  for  major  investments  in  large  scale  SAF 
production is challenging due to difficulty in building a business case that is competitive with traditional fuel. 

Price volatility of feedstock (an important part of the final fuel cost) was also a commonly cited barrier to the 
production of SAF in the IIA feedback. This contributes to the market uncertainty and acts as a disincentive to 
invest. 

The other key challenge identified by 59 of 73 survey respondents was ‘competitive air services market with 
low margins’, although all other challenges identified still had more than half of respondents either agreeing or 
strongly agreeing. However, in the OPC there were several challenges that were not seen as important including 
‘lack  of  relevant  infrastructure’,  ‘lack  of  certainty  on  the  environmental  added  value  of  SAF’  and  ‘lack  of 
technically mature SAF technologies’ with only 27, 32 and 40 of 160 respondents rating the importance four or 
5, respectively. 

Supply and distribution of SAF – stakeholder views confirming the need for policy intervention. Replies to the 
targeted  survey  indicated that  air transport service  providers  are  more  likely  to  either regularly  or  frequently 
supply fuel directly from fuel producers at each airport (8 out of 19); supply fuel from the airport operators at 
each  location  (6  out  of  19);  or  supply  fuel  from  intermediaries  that  do  not  produce  fuel  themselves  (fuel 
distributors) (6 out of 19). In a follow-up survey with fuel producers specifically focusing on SAF supply and 
distribution, stakeholders were clear that blending should happen prior to supply at the airport and is generally 
done either at the refinery or a pre-airport fuel terminal. As blending takes place in the storage tank, there is no 

73 

 
specialised infrastructure required beyond that present in the regular jet fuel system. Blending is either done by 
the SAF producer or by the fuel supplier responsible for distributing the jet fuel. 

Stakeholders have reported a limitation in using the NATO-operated Central European Pipeline System (CEPS) 
to supplying SAF to airports. The general understanding is that not all NATO members have approved the use 
of  SAF  within  their  military  hardware,  and  so  CEPS  cannot  approve  any  SAF  in  the  system.  Some  fuel 
producers point out that the formal reason is that one or a low number of older military aircraft have not been 
approved  for  SAF  blends  by  their  manufacturers,  and  that  some  decision  makers  from  the  national  military 
organisations  (notably  Germany)  regard  this  as  a  reason  to  not  authorise  CEPS  for  SAF  blends.  To  lift  the 
restriction, the member states concerned need to give their approval.  

In  the  case  of  an  obligation  for  suppliers  to  distribute  a  quota  of  SAF  to  all  EEA  airports,  there  was  some 
dispute over whether this would be technically feasible with the current infrastructure.  Some big fuel producers 
(2) stated that it is feasible, although it would rely on long supply chains, while another fuel/feedstock producer 
stated  that  the  only  barrier  is  the  NATO  pipeline  challenge.  Another  fuel  producer  explained  that  it  is  only 
feasible with NATO CEPS approving SAF and modifications to existing terminals to install blending facilities 
since these are nonstandard for most terminals. In terms of cost, one fuel producer has estimated logistics costs 
to be as high as USD 500 per tonne of SAF delivered for certain supply chains with long truck legs. However, 
this cost would largely be borne by more remote regional airport, with major airports able to be supplied as low 
as USD 10 per tonne. The majority of stakeholders in the OPC (102 of 160) indicated that policy action at EU 
level to take into account the logistics and infrastructure of SAF supply is either relevant or very relevant. 

Outlook, trends, views on the SAF production costs 

Over half of the respondents in the OPC (97 of 160) believe that uptake of SAF will increase by 2025 under the 
baseline, while 51 respondents indicated that SAF uptake would not deviate from the current levels. Similarly, 
in  the  survey,  stakeholders  believe  that  SAF  will  account  for  1%  of  aviation  fuels  in  2025.  However, 
stakeholders  see this figure  increasing  to 20%-35% by  2050,  with fuel/feedstock  producers  holding  the most 
optimistic view.  

In  the  OPC,  63  respondents  indicated  that  synthetic  fuels179  are  the  most  promising  liquid  SAF  versus  31 
respondents selecting  advanced biofuels180. However, 62 stakeholders answered with  other, arguing that both 
types of fuel are needed to decarbonise the aviation sector noting that advanced biofuels should be used in the 
near-term, while synthetic fuels are needed in the longer term. This was in line with the survey responses where 
fuel/feedstock producers identified many SAF routes as important for decarbonisation, namely HEFA-SPK, Co-
processing oils and fats, PtL, Gas + FT  and AtJ181. Amongst the fuel/feedstock producers interviewed, there 
was a general consensus that the importance of each pathway will evolve over time. 

In terms of availability of feedstock, stakeholders identified renewable energy, vegetable and animal lipids and 
solid  waste  as  being  the  most  available.  Conversely,  microalgae  oils  are  seen  to  be  the  least  available.  For 
HEFA  which  is commercially  available  now,  feedstock  availability  is  limited. Waste  oils,  which  provide the 
feedstock  in  the  HEFA  process,  are  already  utilised  in  high  quantities  to  produce  road  fuels  and  current  EU 
demand  has  already  necessitated  imports  from  abroad,  leading  to  some  allegations  of  fraud.  For  Gas+FT, 
lignocellulosic wastes, residues and energy crops have some existing uses, but there are large quantities in the 
EU  that  could  be  available  for  SAF  production  without  displacing  other  uses  or  causing  indirect  CO2 
emissions. Electrofuels have low water and land-use requirements but are constrained by price and availability 

179 Synthetic forms of kerosene made through the conversion of hydrogen to hydrocarbons.  
180 Fuels that can be manufactured from various types of non-food biomass. 
181 All fuels listed come under advanced biofuels, with the exception of PtL, which is a synthetic fuel.  

74 

 
                                                           
of renewable electricity. Furthermore, they require a carbon source, which in the future will have to be derived 
from direct air capture.    

Stakeholders  from  both  the  targeted  survey  and  targeted  interviews  agreed  that  the  SAF  costs  are  highly 
dependent on the production route but, in general, the costs consist of CAPEX for the production plant and the 
OPEX  costs  for  the  production  inputs  including  feedstock,  (renewable)  electricity  and  CO2.  For  HEFA-SPK 
fuels, the costs are 80-90% driven by the cost of feedstock, as used cooking oil and vegetable oil are expensive 
and the primary contributor to the levelised fuel cost. The cost drivers for producing electro-fuels are the high 
levelised costs of energy and the costs for electrolysis, as well as CO2-capturing and purification. The costs for 
the  other  production  routes  are  primarily  driven  by  the  upfront  capital  expenses  for  conversion  facilities. 
Stakeholders in the interview and survey were not clear on the certification process and there were some varied 
responses  with  regard  to  requirements,  cost  and  timeline.  While  fuel/feedstock  producers  recognised  the 
importance of safety and certification, there was a shared view that the current process is too lengthy, costly 
and there is some ongoing duplication.  

6.  POLICY OBJECTIVES 

In the survey 63 out of 73 stakeholder responses indicated that they either agreed or strongly agreed with the 
proposed  policy  objective  A  (‘Support  large  scale  production  in  the  EU  of  SAF  with  high  sustainability 
potential  and  ensure  adequate  levels  of  supply  to  the  aviation  sector  at  competitive  costs’).  In  the  targeted 
interviews, three fuel/feedstock producers and two NGOs stated that ‘high sustainability potential’ needs to be 
precisely defined to only consider fuels that meet sustainability standards that provide long-term certainty. With 
regard to policy objective B (‘Ensure a gradual increase in the uptake of SAF with high sustainability potential 
by the aviation sector at competitive prices’), 66 out of 73 survey respondents also indicated that they either 
agreed  or  strongly  agreed.  Interviewees  were  also  in  agreement  with  this  policy  objective,  although  one 
national authority noted that competitive prices will be difficult to achieve without large amounts of subsidies. 
In the OPC, 101 out of 160 respondents stated that they believe that EU level regulatory intervention is best 
suited  to  achieve  decarbonisation  objectives,  followed  by  international  level intervention  (by  ICAO)  with  41 
respondents in support. 

7.  POLICY MEASURES 

This sections provides stakeholders views on some of the key measures underpinning the policy intervention. 

Blending mandate 

In  the  survey,  most  stakeholders  were  of  the  opinion  that  a  blending  mandate  would  be  either  somewhat  or 
highly successful in achieving policy objectives A and B (60 and 53 of 70, respectively). More than half of the 
160 stakeholders in the OPC (93) ranked the importance of this measure as very important. It can be concluded 
that a blending obligation is supported by a majority of stakeholders. Nonetheless, several concerns were raised 
by stakeholders in the surveys and interviews including competition distortion, only current technologies being 
used  and  passing  on  current  high  costs  onto  consumers  resulting  in  a  fall  in  demand.  In  the  roundtable 
discussion, the need for a blending mandate was recognised and supported by the vast majority of participants. 
A number of Member State experts argued that an EU mandate should be the minimum level of mandate and 
that  Member  States  should  be  allowed  to  put  forward  more  ambitious  targets  themselves.  In  general, 
respondents in the IIA feedback also agreed with the implementation of a blending mandate, with proponents 
arguing that mandates have proven to be effective and are quick to implement.  

SAF-approval process for fuel producers and SAF incentives 

75 

 
The  OPC  results  confirm  a  high  level  of  support  for  the  support  and  facilitate  approval  processes  for  fuel 
producers (92 out of 160) and the provision of specific incentives to use SAF, such as multipliers (81 out of 
160).  However,  all  other  policy  measures  given  in  the  survey  were  seen  to  be  either  somewhat  or  highly 
successful  in  achieving  both  policy  objectives  by  more  than  half  of  respondents,  indicating  that  all  types  of 
policy intervention would be welcomed by stakeholders and successful to some degree. Furthermore, the IIA 
feedback, the OPC and interview responses all indicated that a combination of policy measures are necessary to 
achieve increased production and uptake of SAF. Other policy measures suggested as supportive measures in 
the  targeted  interviews  include  feed-in-tariffs,  contracts-for-difference,  and  adjustments  to  the  certification 
process, carbon pricing, loan guarantees and ticket taxes. 

Obligated party 

More survey respondents indicated support or strong support for the supplier being the obligated party (45 of 
73),  compared  to  the  user  (36  of  73)  and  the  producer  (30  of  73).  Arguments  for  an  obligation  on  the  user 
included  the  sustainability  of  the  fuel  would  be  prioritised  and  issues  of  tankering  are  more  easily  avoided, 
while support for an obligation on the supplier was justified by the fact it is a proven concept that applies in 
sectors where mandates already exist and it would be easier to manage due to a smaller number of suppliers. 
Other  potential  obligated  parties  suggested  in  the  survey  included  national  authorities,  fossil  fuel  production 
and supply base, or multiple parties. In the OPC, however, an obligation on both the production/supply side and 
aviation demand side had the greatest support with 57 of 160 respondents in favour versus an obligation on the 
production/supply side with 36 and an obligation on the aviation demand side with 28. Many participants of the 
roundtable indicated a preference for the obligation to be on fuels suppliers only, while some also argued for 
flexibility  for  suppliers  to  organise  their  fuel  distribution  at  airports  of  their  choice  to  avoid  unnecessary 
logistics  constraints,  additional  costs  and  emissions  related  to  the  transport  of  SAF  to  all  airports.  However, 
other stakeholders argued that blending upstream in the value chain would have little impact on logistical costs. 
Nonetheless, there were participants in favour of a mandate on airlines and a mandate on both parties, although 
there some discussion over whether the later would introduce unnecessary complexity.  

Scope of the mandate (intra-EEA / extra-EEA flights) 

In terms of the scope of a mandate (i.e. covering intra-EEA and extra-EEA flights), there was no clear trend 
emerging in the roundtable discussion. Some argued that a reduced scope of the mandate to cover only intra-
EEA  flights  is  not  desirable  as  it  would  only  cover  around  a  third  of  overall  EU  emissions.  Furthermore,  it 
would apply to all flights of some airlines (e.g. low cost carriers flying mainly the EEA market), while applying 
to only a fraction of flights of other airlines (e.g. legacy carriers with strong long haul international networks), 
which could lead to market distortions. On the other hand, a full scope obligation on all airlines would run the 
risk  of  being  challenged  by  non-EU  countries  and  airlines.  Some  argued  that  a  full  scope  obligation  on  fuel 
suppliers  would  not  pose  the  same  issues,  an  option  favoured  particularly  by  NGOs.  Some  airlines  or 
representative organisations recalled that a global approach to SAF should be the end goal.  

Mandate – CO2-based / volume-based 

Stakeholder views in the survey on the subject of the mandate target were similar for each option, with 47 of 73 
supporting an obligation based on a CO2 emissions reduction target versus 40 of 73 supporting a volume based 
SAF target. The key argument in support of the former is that it will incentivise the use of feedstocks and fuels 
that have the greatest CO2 emissions reduction, while the latter is viewed as easier to measure and more likely 
to increase the availability of SAF at competitive prices. Furthermore, a percentage-based mandate would allow 
for easier implementation of sub-targets for certain categories of SAF. In the roundtable discussion, there was 
also  a  slight  preference  for  a  CO2-based  target.  It  was  also  noted  that  this  would  require  a  more  complex 

76 

 
methodology for auditing and accounting. Of the stakeholders that made reference to the basis of the target in 
the IIA feedback, all preferred a CO2-based target.  

SAF to be available at all airports / book-and-claim system 

There was very little difference in the survey between the support for all aviation fuel available at EU airports 
to  contain  a  percentage  of  SAF  versus  a  book  and  claim  system  with  38  and  37  of  73  indicating  support, 
respectively.  Air  transport  service  providers,  national  authorities,  fuel  or  feedstock  producers  and  ‘other 
stakeholders’ were very in favour of the book and claim system citing is essential to build investment in SAF. 
They believe it is not important whether that individual batch of fuel is green, but that green energy is fed into 
the system where possible, as this also avoids unnecessary transport. However, national authorities argued that 
all  aviation  fuel  should  be  sustainable  at  least  to  a  certain  degree  as  it  creates  a  level  playing  field  across 
Europe, booking can then be used by those who want higher levels than required. In the roundtable discussion, 
a  book  and  claim  system  was  deemed  necessary  by  the  majority  of  participants.  It  would  allow  airlines  to 
purchase tradeable SAF certificates even if they do not have physical access to SAF at airports. It would also 
allow fuel suppliers to trade obligations in order to meet the obligation in the most cost-effective way. Tracing 
the exact fuel blend composition in each flight was considered to be a challenging exercise, however. 

SAF ramp-up over time 

When asked in the targeted interviews about the target of the proportion of SAF blending in 2025, 2030 and 
2040, most interviewees felt that a very gradual and flexible mandate would be the best to accommodate for 
any changes in technology, supply and demand. Lufthansa stated that a low single digit intermediate target is 
possible  for  2025  (in  the  1-2%  range)  and  that  by  2025  there  will  be  a  much  better  understanding  of  the 
commercially viable technologies available to make long term plans. Sunfire believes that by 2030 a target of 
5% could be possible as the production pathways and plants would have matured along with the use of e-fuels. 
In  the  roundtable  discussion,  the  proposed  ramp-up182  was  generally  supported,  although  some  stakeholders 
argued  for  earlier  and  more  ambitious  targets.  All  stakeholders  in the  IIA  feedback  believe  that  the  mandate 
should be harmonised at EU level as it would affect all airlines in the same way. It was also advised by NGOs 
and  airlines  that  an  EU  wide  blend  mandate  is  announced  at  least  three  years  in  advance  to  allow  airlines, 
airports, and other stakeholders time to prepare for SAF use and ideally this mandate should last for at least 10 
to 15 years to generate confidence amongst investors and create an investible business case. 

Sub-targets for categories of SAF 

In the OPC 83 of the 160 respondents believe that it is relevant or very relevant to set sub-targets for the use of 
certain categories of SAF such as advanced biofuels or PtL fuels. In the roundtable discussion and interviews, 
some stakeholders stated that an e-fuels sub-mandate would be necessary in any case and that it could start as 
early as 2027. However, some Member State experts argued that a sub-mandate on e-fuels was premature. In 
addition, there were proponents for setting sub-targets for both REDII Part A and Part B feedstocks. 

Penalties for non-compliance 

In  the  roundtable  discussion,  penalties  for  non-compliance  were  deemed  a  key  element  of  policy  design  by 
several  participants.  Some  fuel  producers  explained  that  penalties  act  as  a  price  ceiling  and  should  be 
considered separate for specific sub-mandates. The need to think of the use of collected non-compliance fines 

182   The ramp-up for SAF as proposed in the workshop was: 2% for 2025 (advanced biofuel  only); 5% for 2030 (sub-mandates of 4.3% for 
advanced biofuels and 0.7% for synthetic fuels); 20% for 2035 (sub-mandates of 15% for advanced biofuels and 5% for synthetic fuels); 
32% for 2040 (sub-mandates of 24% for advanced biofuels and 8% for synthetic fuels); 38% for 2045; (sub-mandates of 27% for advanced 
biofuels and 11% for synthetic fuels); 63% for 2050 (sub-mandates of 35% for advanced biofuels and 28% for synthetic fuels). 

77 

 
                                                           
was brought up and there was significant backing for the money to be redistributed to funding support for SAF. 
The same suggestion had been made in the targeted interviews and surveys. 

Feedstocks – sustainability framework 

In the OPC, 96 out of 160 respondents either somewhat agree or fully agree that the RED II framework ensures 
that SAF would achieve significant emissions savings compared to conventional jet fuel. However, in the IIA 
feedback, several stakeholders stated that the existing sustainability criteria in the REDII are insufficient due to 
the  inclusion  of  unsustainable  feedstocks  in  Annex  IX  part  A  and  the  absence  of  accounting  displacement 
effects.  In  the  SAF  roundtable  discussion,  there  was  consensus  on  the  use  of  the  REDII  framework  (or  its 
successor) for sustainability. Some stakeholders stressed the need to align REDII sustainability framework for 
aviation  biofuels  with  the  CORSIA  sustainability  framework.  This  point  was  also  highlighted  by  several 
stakeholders in the OPC and IIA feedback. In the survey, 29 of 73 stakeholders believe that feedstocks in both 
Annex IX Part A and Part B should be incentivised, while 19 stakeholders responded that only Annex IX Part 
A feedstocks should be incentivised and only two stakeholders believe that only Annex IX Part B feedstocks 
should be incentivised. In the roundtable discussion, there was a general support for the choice of Part A, Part B 
and e-fuels. The bio-diesel industry voiced strong concerns on making Part B feedstock eligible (waste lipids), 
as this could displace it from road biofuel production and instead proposed to extend the scope to all waste and 
residues. Some fuel producers proposed to extend the scope to crop based fuels (except high indirect land use 
change  (ILUC)  crops),  but  this  was  strongly  opposed  by  NGOs.  Many  stakeholders  in  the  survey  were 
feedstock agnostic and stated that we should let the technology mature before funnelling investment into one 
area.  Importance  was  placed  on  the  ability  to  guarantee  emissions  savings.  The  aviation  industry  also  only 
relies on one fuel so having a broad selection of sources to feed this is critical to scale up production. In the 
OPC,  92  of  160  respondents  indicated  support  for  prioritising  aviation  for  the  access  to  feedstock  and 
production of SAF. 

Funding 

Respondents  in  the  survey  indicated  that  funding  measures  would  be  an  effective  contribution  for  achieving 
policy objectives. ‘Funding in support of SAF production deployment’ was seen to be successful for achieving 
policy objective A and B by 62 and 61 of 73 respondents and ‘Funding in SAF  research & development’ was 
seen  to  be  successful  for  achieving  policy  objective  A  and  B  by  66  and  53  of  73  respondents.  Stakeholders 
believe that this would address the issue of excessive production costs and facilitate the commercialisation of 
SAF technologies and pathways, as well as promote new technologies for the long-term. In line with the survey 
responses, 125 of 160 stakeholders in the OPC ranked the importance of ‘encourage investments and make use 
of public financial instruments’ as very important followed by ‘accelerate research and innovation in new SAF’ 
(111). Concerning the funding instruments that could be used to help reduce the investment risk or bridge the 
price gap, the greatest support in the OPC was for an EU Emissions Trading System Innovation Fund with 89 
respondents  out  of  160  ranking  it  as  effectiv.  Other  funding  instruments  that  were  seen  as  important  were 
NextGenerationEU (64) and Horizon Europe (63). A ‘modulation of air traffic control charges under the Single 
European Sky to create a fund’ and ‘an environmental levy on aviation’ were seen to be the least important, 
with 53 and 50 out of 160 respondents ranking these instruments less important, respectively. The responses in 
the survey were in line with those of the OPC, with the  instruments receiving the greatest support being ‘EU 
Emissions Trading System Innovation Fund’, ‘Horizon Europe’, and ‘a strategical industrial alliance bringing 
together all actors on the SAF value chain’ with 36, 33 and 33 of 73 respondents rating these  most relevant , 
respectively. Again, an ‘environmental levy on aviation’ was among the lowest scoring. Other instruments with 
low scores were the ’Just Transition Fund‘, ‘Connecting Europe Facility’ and a modulation of air traffic control 
charges under the Single European Sky to create a fund’ and with 12, 14 and 15 of 73, respectively.   

78 

 
8.  POLICY OPTIONS  

The  European  Commission  presented  its  detailed  policy  design  during  a  roundtable  workshop  held  on  10 
November 2020. The objective of the roundtable was to inform and exchange with Member States, aviation and 
fuel  industries,  international  organisations,  NGOs  and  academics  on  the  progress  of  the  RefuelEU  Aviation 
initiative.  In  addition,  the  workshop  provided  an  opportunity  to  discuss  the  possible  policy  options  under 
consideration  as  part  of  this  impact  assessment.  This  section  provides  details  of  the  stakeholders’  views  as 
expressed during the workshop on 10 November 2020. While the Commission presented its policy design in 
detail,  the  discussion  focused  on  some  key  elements  of  the  policy  design.  This  section  highlights  the  key 
discussion points and the observations made during the workshop.  

Elements common to all the options presented during the workshop: 

Sustainability 

There was consensus on the use on the REDII framework (or its successor) for sustainability. However, some 
member States believe that the sustainability framework should be aligned with that of CORSIA to ensure can 
be  claimed  under  the  relevant  schemes.  Another  Member  State  noted  that  some  promising  feedstocks  (e.g. 
animal fats) may be excluded if only RED II Annex IX is considered.  

Eligible SAF / feedstock 

There was a general support for the choice of eligible SAF (Part A, Part B feedstock, and E-fuels). The bio-
diesel  industry  voiced  concerns  on  making  Part  B  feedstock  eligible  (waste  lipids),  as  this  could  displace  it 
from road biofuel production and have negative effects on bio-diesel production plants. A fuel producer stated 
that the blending mandate as currently presented would result in the diversion of most waste-based lipids (used 
cooking oil and animal fats) from road transport to SAF at no real environmental value. This was reiterated by 
an airline.  One NGO suggested that with a 5% mandate in 2030 Annex IX part B feedstocks will be  diverted 
from  use  in  the  road  sector  to  the  aviation  sector  with  no  climate  benefit.  However,  another  fuel  producer 
argued that there is huge value in a shift from road to aviation as SAF is also reducing the non-CO2 effects of 
aviation. This was also supported by a manufacturer but disputed by an airline. An airport explained that non-
CO2  effects  include  no  sulphur  and  lower  particulate  matter  emissions  which  are  significant  particularly  in 
local conditions. An airline agreed that some biofuels reduce sulphur, however, the contrail effect remains. One 
fuel producer added that the only way to drive investment to developing technologies (part A of annex IX) is 
introduce a safeguard for part B of Annex IX, otherwise there will be no real incentive to invest as there will be 
already enough waste lipids volumes to meet the proposed sub-target for 2030. A fuel producer stated that this 
issue can be addressed by allowing all sustainable waste and residue lipids, not just the Annex IX, as well as 
expanding  to  cover  crops  and  farming  on  contaminated  and  degraded  land,  thus  further  increasing  the 
availability of sustainable feedstocks. Furthermore, limiting feedstocks to just Annex IX Part A will severely 
limit the feedstock pool. This was agreed by some other fuel producers. However, a fuel producer stated that 
the  volume  of  feedstock  from  just  Annex  IX  Part  A  would  be  sufficient  to  achieve  the  2030  mandate. 
Furthermore, an NGO stated that CO2 emission saving threshold as is does not include indirect land use change 
and  that  the  vast  majority  of  scientific  evidence  shows  that  food-based  feedstocks  do  not  provide  a  climate 
benefit  so  only  Annex  IX  should  be  considered.  One  stakeholder  raised  an  issue  with  restricting  the  eligible 
feedstocks to those in Annex IX, suggesting that this contradicts the most recent RED report. The inclusion of 
biofuels is important as it employs a large number in Europe, the feedstocks are sustainable and biofuels are 
cheaper than alternatives, thus reducing the economic burden for airlines. Another fuel producer added that by 
extending  to  feedstock  outside  of  RED  Annex  IX  to  allow  all  sustainable  non-ILUC  feedstocks  from  RED, 
there  are  enough  feedstocks  available  for  both  road  and  aviation  sectors.  This  statement  was  supported  by  a 

79 

 
manufacturer. One stakeholder disagreed with the inclusion of crop liquids because in the long-term HVO is 
not scalable without over-burdening vegetable oil markets. 

A fuel producer agrees that we need to limit the total volume of food and feed crops entering the EU  market. 
Whether or  not  that  means  further  lowering  the  limit  in  the  RED  for road and allowing  some  food  and feed 
biofuels into aviation or simply exclude these crops from an aviation mandate and keep road limits as they are 
is a matter for debate. Best to  avoid an aviation mandate increasing the total volume of food and feed crops 
given  the  possible  impacts  described  by  those  above,  until  such  time  as  global  markets  for  these  feedstocks 
mean the ILUC risk is reduced (if that ever happens). A Member State made a plea to include recycled carbon 
fuels  (e.g.  non-bio  municipal  solid  waste)  and  low  ILUC  crops  as  defined  by  RED  to  avoiding  penalising 
ongoing projects. 

Blending mandate 

The need for a blending mandate was recognised and supported by a large majority of participants, particularly 
by Member States. One fuel producer, one airport managing company and two Member States  argued that an 
EU mandate should be the minimum level of mandate and that Member States should be allowed to put forward 
more ambitious targets themselves and additional sub-targets to stimulate certain technologies. 

Funding mechanisms 

Several  other  stakeholders  stated  that  financial  incentives  (such  as  Contracts  for  Difference)  could  be 
considered.  These  measures  will  help  to  flow  capital  or  reduce  risk  of  investment  which  will  reduce  costs 
significantly  and  ensure  that  technologies  that  are  not  currently  mature  will  be  developed.  An  energy 
stakeholder  went  on  further  to  say  there  are  lessons  to  be  learned  from  feed-in-tariffs  and  contracts  for 
difference in the electricity market. However, another energy stakeholder argued that mandates are necessary to 
guarantee the offtake of the fuel and secure the baseline business case for investing in advanced technologies. 
This  would  need to  be  combined  with financial  support (loan  guarantees,  development  capital) to  ensure the 
technologies  are  successfully  commercialised.  Similarly,  a  fuel  producer  was  in  favour  of  a  mandate  but 
stressed  that  mandates  should  be  part  of  an  overall  policy  framework  supported  by  other  fiscal  measures  to 
support investment and first plants. Some airlines noted that it is important to consider the fast-moving field of 
zero-carbon technology and that airlines should not be obliged to divert funding away from these technologies. 
Another airline raised the question that if an airline is willing to purchase new aircraft with carbon reductions, 
would they be obligated in the mandate.   

SAF ramp-up and sub-mandates 

The following ramp-up was presented during the workshop: 

Shares in the fuel mix (%) 
SAF ramp-up  
Sub-mandate – green synthetic fuels 

2025 
2 
- 

2030 
5 
0.7 

2035 
20 
5 

2040 
32 
8 

2045 
38 
11 

2050 
63 
28 

The  proposed  ramp-up  was  generally  supported  although  some  stakeholders  argued  for  earlier  and  more 
ambitious targets. A fuel producer commented that the mandate could start earlier (2023) and that 5% in 2030 
is  too  low,  rather  it  should  be  10%.  By  targeting  10%  in  2030  and  45%  in  2045,  there  would  be  a  smooth 
uptake curve. Another fuel producer agreed with earlier targets, specifically for e-fuels, stating that projects are 
currently developing and the 0.7% could be reached earlier. The room for higher targets was also supported by 
some Member State experts. Some stakeholders questioned why the level of synthetic fuel remains low for the 
near-medium future given it will deliver the majority of CO2 reductions. A fuel producer stated that synthetic 
fuel production will be basically unlimited in terms of technology and feedstock availability in the long-run at 
competitive prices enabling much larger volumes. A stakeholder commented that the low targets for synthetic 

80 

 
 
fuels  after  2030  seem  counterintuitive.  Some  Member  States  are  in  favour  of  sub-quotas.  However,  a 
manufacturer said that a sub-target seems premature given the low level of supply at present. Furthermore, a 
NGO  stated that  too  high  a  mandate  for synthetic fuels  can  also  cause  displacement  of  renewable  electricity 
from sectors where it would have been more efficiently used. A Member State was reluctant to have sub-targets 
for synthetic fuels as it may make the mandate more expensive to fulfil and they prefer to have a technology 
neutral system.  One fuel producer stated that it is vital to have a sub-mandate for advanced biofuels to ensure 
that they are brought onto the market. However, the current proposal does not have a sub-mandate for second 
generation  SAF  (i.e.  AtJ  and  gasification/FT  pathways).  They  were  concerned  that  if  first  and  second 
generation SAF were grouped together, the mandate will only promote HEFA investments as this is cheaper. 
Another fuel producer and airlines agreed with this. However, other stakeholders pointed to the need to avoid a 
sub-mandate  for  Part  B  biofuels.  A  stakeholder  believes  that  HEFA  production  does  not  move  the  other 
technologies  forward  in  any  substantial  way  and  warned  that  a  significant  short-term  HEFA  mandate  would 
threaten investment in the higher capex alternatives. 

Monitoring, reporting and verifying  

Some  participants  pointed  to  the  need  for  a  robust  MRV  system  to  avoid  double  counting.  One  NGO  sees 
tankering as threat, particularly in a scenario where fuel is cheaper in larger airports. They stated that there is a 
need  for  robust  data  on  fuel  prices  because,  with  a  SAF  certificate  trading  system  there  is  potential  for 
inaccuracies, as such a registry should be established to know who is using which fuel. One airline  also stated 
it is important to have an appropriate registry to avoid risks of double counting. Up to now, mandate systems 
have not been transparent in terms of origins and sustainability of fuel. They noted that work done to improve 
traceability and visibility in CORSIA could be valuable in establishing a book and claim system. Apart from 
that,  the  proposal  to  use  the  RED  framework  for  supply  side  and  the  EU  ETS  framework  for  demand  side 
monitoring and reporting seemed uncontroversial. 

Elements distinguishing between the options presented during the workshop: 

Obligated party 

Many stakeholders indicated a preference for the obligation to be on fuels suppliers only. A fuel producer stated 
a  supply  mandate  will  work  if  measures  are  in  place  to  avoid  tankering.  Many  participants  also  argued  for 
giving flexibility to suppliers to organise their fuel distribution at airports of their choice, to avoid unnecessary 
logistics constraints, additional costs and emissions. Others though argued that blending upstream in the value 
chain  would  have  little  impact  on  logistical  costs.  In  the  supply  side  option,  the  impact  of  the  mandate  on 
tankering was also considered important by some. An airline went on further to say that competitive distortion 
is not limited to tankering. If there is a stopover outside of the EEA, only the first leg would be mandated, thus 
leading to competitive distortion with international airlines. Furthermore, evidence from Sweden suggests that 
an obligation on airlines may go against international agreements. Some favoured an obligation on airlines. An 
airline  stated that  it is  feasible  for  airlines  but  helped  by  a  functional  SAF certificates  trading  system  as  this 
creates a more competitive market for SAF procurement. A stakeholder was in favour of an obligation on both 
parties, providing the same scope applies for both supply and demand side. A fuel producer believes a mandate 
on  demand  or  both  parties  will  work  because  this  creates  demand  and  another  fuel  producer  thinks  that  the 
flexibility  of  this  option  would  reduce  cost.  However,  a  Member  State  does  not  want  an  obligation  on  both 
because  of  the  higher  administrative  costs.  Furthermore,  a  fuel  producer  stated  that  if  the  SAF  certificate 
trading system is used, only one part of the value chain needs to be obliged. Two obligated parties would be 
unnecessary as an airline mandate will interact with the supplier mandate. If a supplier surrenders the credit and 
releases the obligation, does the airline surrender the credit as well? This was supported by another stakeholder. 
An  airline  was  impartial  as  an  obligation  on  either  party  will  give  security  to  investments.  They  stated, 
however, that it is important that there is a right to access infrastructure.   

81 

 
 
Scope 

This  point  was  debated  at  length  with  no  clear  trend  emerging.  An  airline  was  in  favour  of  the  full  scope 
because limiting the scope to intra-EEA only would address only 33% of aviation emissions. Furthermore, they 
see it as important that the Commission is perceived to be making positive action by the rest of the world. This 
was supported by another airline. An NGO added that this approach would improve administrative simplicity. 
Furthermore, it is important to avoid an approach that applies to 100% of flights for some airlines and only 30% 
of other airlines.  On the other hand, a full scope obligation on airlines would run the risk of being challenged 
by non-EU countries and airlines. A Member State asked whether the Commission foresees diplomatic/political 
issues because of the distinction between intra and extra-EEA. An airline stated that the full scope policy could 
have  an  impact  on  connecting  traffic  in  the  EU,  suggesting  that  travellers  will  just  connect  outside  the  EU 
leading to carbon leakage and competitive disadvantage. Another airline agreed with this point. Nonetheless, a 
global approach to SAF should be the end goal. 

Target setting 

Participants were divided on this topic but there may have been a slight preference for a CO2 reduction based 
target over volume based targets as it is seen as incentivising the use of the best performing SAF in terms of 
achieving the goal of reducing CO2s. However, some participants explained that a CO2 based target requires a 
more  complex  methodology  notably  for  auditing  and  accounting.  A  stakeholder  agrees  that  CO2  emissions 
savings should be used as this is the same basis used for other schemes. Some other fuel producers agreed that a 
CO2  quota  is  better,  providing  there  is  a  robust  Life  Cycle  Analysis  methodology  and  audit  trail.  A  fuel 
producer stated that a volume/energy plus CO2 threshold is a proxy that is easier to audit and account. A fuel 
producer expressed concerns of just focusing on CO2 stating that, while it is the ultimate goal, it won't have the 
desired effect of bringing on the various generations of SAF. Volume and CO2 both need to be considered. An 
airport stated that in Norway a volume-based target is used, which NGOs approve of and suspect that issues 
may arise if a CO2-emissions target is established. A Member State was in favour of a volume target because it 
is easier to implement. An airline stated that it depends on who is the obligated party. A CO2 based mandate 
would make sense for a supplier mandate, but since airlines are looking at scope 1 emissions, the volume-based 
target would make sense for demand side obligation. An airport stated that both volume-based and CO2-based 
must be accompanied with clear rules that ensure sustainability. 

SAF certificate trading system versus every drop blended 

Overall a SAF certificate trading system was deemed necessary by the majority of participants. It would allow 
airlines to purchase tradeable SAF certificates even if they do not have physical access to SAF at airports. It 
would also allow fuel suppliers to trade obligations in order to meet the obligation in the most cost effective 
way.  A  stakeholder  was  in  favour  of  such  an  approach  allowing  for  SAF  supply  locations  to  roll-out 
progressively  because  transport  of  fuel  will  generate  additional  emissions  and  is  logistically  inefficient.  An 
airline went on further to say that there are no environmental benefits from every drop blended approach, and it 
ignores  the  work  underway  to  develop  a  functional  trading  process  which  is  intended  to  reduce  unnecessary 
inefficiencies  and  costs.  Another  airline  considered  the  physical  supply  of  SAF  to  all  airports  as  practically 
challenging.  It  is  technologically  unnecessary  as  the  fuels  are  drop  in  fuels  and  the  separate  and  additional 
logistics  are  economically  and  environmentally  disadvantageous.  An  airline  was  in  favour  of  a  SAF  trading 
approach if reliable verification is in place, citing that it has been used for years in green electricity and biogas 
markets.  Furthermore,  a  right  to  access  infrastructure  needs  to  be  integrated  to  ensure  that  all  producers  can 
bring  their fuel  to  the nearest reasonable  access  point  of  “the  fuel system”.  An  airport  (ACI)  raised  an issue 
concerning “the every drop blended” mandate and wanted clarification over whether the Commission foresees a 
continued  supply  of  SAF  to  all  European  airports  or  if  this  applies  over  a  certain  a  period  as  there  will  be 
different implications on the costs and effectiveness of logistics and airports need to be able to use the existing 

82 

 
 
fuel supply at airports. Furthermore, a stakeholder (Energy Transition Commission) was in favour of a blending 
obligation  for  all  fuel  supplied  for  a  company  over  a  1-year  period,  with  a  credit  trading  scheme  allowing 
compliance by selling and purchasing credits. A fuel producer (BP) added that the basis is dependent on who 
the obliged party is. In a supplier mandate there is no difference from who will buy the SAF under an "all fuel" 
option as in option A and a trading approach. The only difference is the additional costs of logistics of getting 
SAF volumes to all airports, which will increase/exacerbate the existing differential in fuel prices at remote and 
regional  airports.  This  will  increase  tankering  -  as  we  currently  see  today  on  fossil  jet  on  routes  to 
regional/remote airports. The same fuel producer (BP) added that with a trading scheme there will be a market 
of credits and a market for fuel but these won’t necessarily match. Anyone who passes a charge on in the value 
chain can use credits, and thus is able to be the obligated party, the only question is the volume and level of 
compliance.  They  also  stated  there  are  a  number  of  examples  of  traded  compliance  in  road  fuels.  A  fuel 
producer  (Enerkem)  raised  an  issue  that  a  “book  and  claim  system”  is  not  possible  under  RED  II  due  to 
concerns of fraud, rather a mass balance is allowed. An airport (ACI) stated that the objective of airport charges 
is  to  recover  airports’  internal  costs.  Airports  do  not  sell  fuel  and  don’t  in  most  cases  own  the  fuel  supply 
infrastructure, so SAF does not fall into their cost base. As such, it’s not clear how airports should intervene 
through  charges  to  address  tankering.  A  Member  State  (Malta)  was  concerned  how  a  SAF  trading  system 
would work in smaller airports. However, this was explained by an airport association (ACI) that can purchase 
SAF credits without physically burning SAF molecules. The MS (Malta) was also concerned that hedge funds 
will use the system to gain a profit. 

Penalties for non-compliance 

An airline (Lufthansa) asked that, in the case airlines are the obligated party, would there be an incentive for the 
supplier to provide their fuel at cost only slightly lower than the cost of the penalty. However, a fuel producer 
(BP) stated that any supplier charging more than the standard rate will lose out on competition and it is better to 
think of penalties as a price ceiling. An airline (IAG) and fuel producer (Shell) stated that penalties provide a 
signal for investment and there is a need to think about the floor price because that gives certainty to investors. 
An airline (IATA) agreed, as did another fuel producer (Velocys). A stakeholder (Cerulogy) agreed with this 
but  stated  that it  is  potentially  difficult  to  set  a  floor price  effectively.  A  fuel  producer  (SkyNRG)  raised the 
topic of how the income generated form penalties is redistributed for the good of the sector. An NGO (T&E) 
agreed  that  the  income  should  be  retained  for  industrial  policy  to  make  up  for  any  shortage  in  supply.  A 
Member State (Sweden) explained that the penalty for non-compliance in their country is around 0.6 EUR per 
kg CO2 that is missing from fulfilling the mandate, which is higher than the penalty in the road sector. Another 
Member State (France) stated that it is important to be able to modify the penalties based on how well they are 
working. 

83 

 
 
 
 
Annex 3: Who is affected and how? 

1.  IMPACTS ON AFFECTED STAKEHOLDER GROUPS 

The  ReFuelEU  Aviation  initiative  aims  at  reducing  CO2  emissions  from  the  aviation  sector  by  transitioning 
away from fossil jet fuel and increasing the production and uptake of SAF. The objective is to set the aviation 
sector on the trajectory to contribute to the European ambition of climate neutrality by 2050. 

The preferred policy options (POs C1 and C2) set an obligation on fuel suppliers to supply SAF at EU airports, 
and  an  obligation  on  all  airlines  to  uplift  jet  fuel  at  EU  airports  before  each  departure.  It  also  requires  EU 
airlines to report their SAF use. The following sections explains in detail how the preferred option will affect 
the main stakeholder groups. 

Airlines  

Airlines will play a major role under the present initiative, as they will be the market actor using SAF-blended 
jet fuel and bearing the cost for it. Although airlines do not per se have an obligation to use SAF-blended jet 
fuel, the obligation on fuel suppliers to supply SAF will be mirrored back to airlines as they will have no other 
option  than  to  use  it.  As  of  the  start  of  the  SAF  obligation,  airlines  will  be  presented  by  fuel  suppliers  with 
commercial  offers  including  SAF-blended  jet  fuel  as  part  of  the  jet  fuel  mixed  available  at  airports.  The 
competition between several fuel suppliers to offer SAF-blended jet fuel at specific airports means that airlines 
will  be  able  to  benefit  from  bargaining  power  and  have  access  to  SAF  at  acceptable  prices  defined  by  the 
dynamics of supply and demand. 

Whereas all airlines will have access to SAF at all airports as of 2030 (second stage of the transition period), 
some airlines may not have physical access to SAF at their destination airports in the first stage of the transition 
period,  i.e.  from  2025  to  2030.  This  is  expected  to  be  the  case  e.g.  at  remote  or  insular  airports  where  fuel 
suppliers  would  incur  higher  logistical  costs.  Airlines  flying  to  such  airports  will  nevertheless  be  able  to 
procure  SAF  by  purchasing  it  directly  with  a  fuel  supplier.  Purchased  SAF  volumes  will  be  introduced 
elsewhere  in  the  fuel  system,  but  the  airline  will  be  able  to  claim  its  use,  in  accordance  with  the  reporting 
system of the EU ETS that is based on SAF purchasing records. In general, airlines will be able to claim the use 
of SAF under the EU ETS or under CORSIA, as relevant with respect to the flights operated. 

Under  the  present  initiative,  airlines  are  expected  to  incur  higher  costs  for  jet  fuel.  It  is  expected  that  the 
increase of jet fuel cost due to the blending of SAF will be evenly spread across the airline market and affect all 
airlines  in  the  same  way.  The  increase  in  jet  fuel  cost  is  expected  to  be  fully  passed  on  to  passengers  and 
therefore  be  reflected  on  ticket  prices.  The  increase  of  ticket  prices  will  be  low,  but  nevertheless  result  in  a 
small  reduction  of  demand  for  air  transport  by  2050,  compared  to  the  baseline  scenario.  This  will  have  the 
effect to reduce the capital and operational costs of airlines.  

The increase in jet fuel cost will be partially compensated by a reduction in external costs of air pollution and of CO2 
emissions. As a result, the total cost for airlines, including external costs, decrease marginally by 2050 compared to the 
baseline scenario. 

Airports 

The  present  initiative  is  neutral  towards  airports.  Airports  are  not  expected  to  play  a  significant  role  in  the 
scaling-up of SAF supply and uptake. The fuel logistics at airports are generally fit for a future large increase of 
SAF-blended jet fuel supply. Indeed, SAF being fully fungible with conventional jet fuel, there is no expected 
need for larger fuel tanks at airports. Indeed, SAF volumes will substitute pure fossil jet fuel volumes. Logistics 
at airports are organised in a way that all jet fuel arrives blended at the airport and is mixed in common fuel 
tanks. SAF blending does not take place at the airport, or otherwise requires certification renewal. Therefore, 

84 

 
 
under the present initiative, it is not expected that major adaptations to the airports logistics will be necessary. 
Logistical  adaptations  will  be  required  in  the  upstream  parts  of  the  SAF  supply  chain,  as  explained  in  the 
following section, but this is not expected to affect airports. 

Fuel suppliers 

Fuel suppliers are obliged to supply physically supply SAF at all EU airports at all times, post-2035 (following 
a transition period). This means that every litre of jet fuel supplied to EU airports must be blended with SAF. 
Fuel suppliers (the number of market players who would qualify as fuel suppliers under this initiative is limited 
–  estimated  at less  than  30)  are individually  bound  by  this  obligation  with  increasing  targets  over  time.  This 
obligation  requires  fuel  suppliers  to  procure  SAF-blended  jet  fuel  from  SAF  producers  or  use  their  own 
production  (if  relevant)  and  integrate  it  to  their  fuel  mix  when  distributing  at  airports.  Fuel  suppliers  are 
expected to include SAF as part of their commercial offer to airlines, when responding to yearly calls for tender 
issued by airlines for the procurement of jet fuel at airports.  

Fuel suppliers will need to ensure that their supply chain are fit for distributing SAF to all airports. This can be 
challenging and incur additional logistic costs, in particular in the first years of the obligation. For this reason, a 
transition period allows for some flexibility on the supply of SAF. From 2025 to 2030, fuel suppliers will have 
the flexibility to distribute SAF in the most cost effective way. This is expected to lead to a distribution of SAF 
mainly  at  medium  and  large  airports  already  benefitting  from  well-established  fuel  supply  chains.  Fuel 
suppliers will nevertheless be required to meet their supply obligation, and therefore it is expected that they will 
seek to spread their supply to a maximum number of airlines and airports, while still acting in the most cost-
effective way. From 2025 to 2030, suppliers will still have flexibility to supply in the most cost effective way, 
but will nevertheless be required to supply a minimum of 2% of SAF at all airports. This will encourage all fuel 
suppliers to develop the necessary supply chain and infrastructure to fulfil the obligation beyond 2035 where all 
airports need to be supplied to meet high SAF targets. 

In the early years of the SAF obligation, it is expected that fuel suppliers will not all be in the same position to 
meet the SAF supply obligation. While some may be able to supply SAF-blended fuel more than required - due 
to e.g. well established commercial partnerships with producers and well established logistics, others may fall 
short of meeting the obligation. This could be the case if e.g. meeting the last 10% of the SAF supply target 
would mean significant additional costs for e.g. expanding production capacity. In such cases, a SAF certificate 
trading system could allow fuel suppliers to meet their targets in the most cost-effective way. Over achievers 
(suppliers with an excess of SAF supplied) could sell SAF certificates to under achievers. Such a system could 
be  set  up  under  the  auspices  of  the  present  initiative,  or  alternatively  be  introduced  in  the  revision  of  the 
Renewable Energy Directive. Such a trading system represents an additional flexibility for the fuel industry to 
meet supply targets. 

Fuel  suppliers  will  incur  costs  partly  passed  on  to  them  by  fuel  producers,  i.e.  SAF  production  investments. 
These  costs  correspond  to  investments  expenditures,  and  are  one-off  investment  costs  necessary  to  build  the 
additional SAF production facilities needed to scale up the SAF industry in line with the SAF ramp-up over 
time. Fuel suppliers will incur higher fuel costs, corresponding to the procurement of SAF volumes. These will 
be  accompanied  by  additional  SAF  logistics  costs,  necessary  for  the  distribution  of  SAF  to  airports,  as 
explained  above.  The  net  impact  on  fuel  suppliers  is  neutral,  as  all  costs  incurred  by  fuel  suppliers  are 
considered to be passed on to airlines. 

Fuel producers 

Fuel  producers  will  play  an  essential  role  in  scaling  up  the  SAF  production  capacity  in  the  EU.  They  are 
expected to incur costs due to the investment needs to scale-up the SAF production capacity. These costs will 
be partly passed through to fuel suppliers.  

85 

 
EU Citizens / Society at large 

Society is expected to be the largest beneficiary of this initiative. European citizens will benefit from the fact 
that aviation becomes significantly more environmentally sustainable by 2050. The introduction of this policy 
instrument  leads  to  an  important  decrease  in  CO2  emissions  in  the  aviation  sector,  and  to  a  decrease  in  air 
pollutants. This means a reduction of aviation external costs of air pollution and greenhouse gas emissions.  

At the same time, due to the aviation becoming significantly greener, citizens will incur higher ticket prices as 
the  costs  borne  by  airlines  for  more  costly  jet  fuel  will  be  passed  through  to  passengers.  This  means  a  low 
increase of costs on a per-ticket basis, but overall the cost increase outweighs the reduction in external costs. 

The European society is expected to benefit from large indirect positive macroeconomic impacts in the form of 
significant  additional  employment.  Whereas  employment  in  the  aviation  sector  will  increase  at  a  slower  rate 
than  under  the  baseline  scenario  by  2050,  the  renewable  fuels  industry  is  expected  to  provide  significant 
additional employment to European workers. 

Member States 

Member States will incur slightly higher costs due to the implementation of this policy initiative. Indeed, the 
obligations on fuel suppliers and airlines under the preferred policy options translate into additional monitoring, 
reporting, verification and enforcement costs for Member States.  

2.  SUMMARY OF COSTS AND BENEFITS 

I. Overview of Benefits (total for all provisions) – Preferred Options - C1 and C2 (relative to the 
baseline, expressed as present value over 2021-2050) 

Description 

Amount 

Comments 

Reduction of air transport 
CO2 emissions (well to 
wing) in 2050 compared 
to the baseline 

Reduction of external 
costs of CO2 emissions 
from air transport 
relative to the baseline; 
additionally including the 
external costs of logistics 
(i.e. present value over 
2021-2050) 

Reduction of external 
costs related to air 
pollution relative to the 
baseline 
(i.e. present value over 
2021-2050)  

Direct benefits 

-60.8% (C1) 
-60.2% (C2) 

Direct benefit to society at large. It is the effect of 
the increasing participation of sustainable aviation 
fuel in the aviation jet fuel mix, in replacement of 
fossil jet fuel. 

EUR 86.3 billion (C1) 
EUR 85.8 billion (C2) 

EUR 1.5 billion 
(C1 and C2) 

Direct benefit to society at large. This reflects a 
reduction of air pollutant emissions (CO, NOx, PM). 
It results from a decrease in air transport activity by 
2050 relative to the baseline.  

Increased use in air 
transport of innovative 
fuel technologies with 
high decarbonisation 
potential (expressed in % 
of the jet fuel mix by 
2050, compared to the 

(C1) 
RFNBOs: 27.9% 
Advanced biofuels: 25.8% 

(C2) 
RFNBOs: 23.9% 
Advanced biofuels: 28.7% 

Significant increase of participation in the jet fuel 
mix of innovative technologies with high 
decarbonisation potential. These technologies are 
brought to the market earlier than under the baseline 
scenario. Prices of RFNBOs and advanced biofuels 
decrease over time compared to the current 

86 

 
 
baseline) 

estimates. 

Indirect benefits 

Employment (net 
additional jobs in 2050 
compared to the baseline) 

202,100 jobs 
(C1 and C2) 

Reduced dependence on 
oil imports in 2050 
relative to the baseline 

-65% (i.e. -31Mtoe) 
(C1 and C2) 

Share of SAF produced in 
the EU (expressed as a 
share of total SAF 
supplied in 2050) 

92% (C1 and C2) 

Increase in employment in the fuels industry 
compensate for employment reductions in air 
transport due to slight decrease of activity compared 
to the baseline. 

Benefits for the EU’s energy security and trade 
balance. Reduction of oil imports used for air 
transport, as a result of a decrease in fossil jet fuel 
use by 65% in 2050 (i.e. 31Mtoe) relative to the 
baseline. 

Benefits for EU renewable fuels’ industry and the 
EU economy at large. 92% of SAF supplied and used 
in the EU will be produced in the EU. 100% of 
feedstock and renewable energy used for SAF 
production will be EU-sourced. 

(1) Estimates are relative to the baseline for the preferred option as a whole (i.e. the impact of individual actions/obligations of the 
preferred  option  are  aggregated  together);  (2)  Please  indicate  which  stakeholder  group  is  the  main  recipient  of  the  benefit  in  the 
comment  section;(3)  For  reductions  in  regulatory  costs,  please  describe  details  as  to  how  the  saving  arises  (e.g.  reductions  in 
compliance costs, administrative costs, regulatory charges, enforcement costs, etc.; see section 6 of the attached guidance). 

II. Overview of costs – Preferred Options - C1 and C2 (relative to the baseline, expressed as present value 
over 2021-2050) 

Citizens/Consumers  

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

None 

Direct 
costs 
(relative 
to the 
baseline 
in present 
value 
over 
2021-
2050) 

Compliance 
with SAF 
obligation  

Indirect 
costs 

None 

Increase of 
ticket prices 

Capital 
investments in 
SAF production 
capacity by fuel 
producers 
EUR 10.5 
billion (C1) 
EUR 10.4 
billion (C2) 
- partly passed 
on to fuel 
suppliers 

Additional 
cost of fuel 
for airlines 
EUR 103.5 
billion (C1) 
EUR 88.2 
billion (C2) 

Additional 
administrativ
e costs for 
airlines for 
fuel uplift  
EUR 0.34 
billion (C1 
and C2) 

Additional 
SAF fuel 

87 

 
 
 
 
 
 
 
 
 
 
 
 
 
by 8.2% (C1) 
and 8.1% 
(C2) by 2050, 
compared to 
the baseline 

logistics costs 
EUR 0.19 
billion 
(C1 and C2) - 
relative to the 
baseline in 
present value 
over 2021-
2050 

Reduced 
capital and 
operational 
costs of air 
transport due 
to lower 
transport 
activity.  
EUR 84 
billion (C1) 
EUR 74.5 
billion (C2) - 
relative to the 
baseline in 
present value 
over 2021-
2050 

No additional 
costs. 

Fuel suppliers 
report in 
Union 
database. 

EU airlines 
report in EU 
ETS. 

Cost for non-
EU airlines to 
link to the new 
reporting 
stream on jet 
fuel uplift. 

Negligible. 

88 

Admin costs 
for Member 
States EUR 
264 million 
(relative to 
the baseline 
in present 
value over 
2021-2050) 

Admin costs 
for EU 
authorities 
EUR 2.7 
million 
(relative to 
the baseline 
in present 
value over 
2021-2050) 

Administrati
ve and 
enforcement 
costs   

Direct 
costs 

Indirect 
costs 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex 4: Analytical methods 

1.  DESCRIPTION OF THE MODELLING TOOLS USED  

The  analytical  framework  used  for  the  purpose  of  this  impact  assessment  draws  on  the  impact  assessment 
support  study183  and  builds  on  the  PRIMES  and  PRIMES-TREMOVE  models,  complemented  by  the 
assessment of the administrative costs for businesses, the costs for authorities, the costs of SAF logistics, etc. 

The main models used to produce the scenarios presented in  this impact assessment (PRIMES and PRIMES-
TREMOVE models) have a successful record of use in the Commission's energy, transport and climate policy 
assessments.  In  particular,  they  have  been  used  for  the  impact  assessment  accompanying  the  2030  Climate 
Target Plan184, the Staff Working Document accompanying the Sustainable and Smart Mobility Strategy, the 
Commission’s proposal for a Long Term Strategy185 as well as for the 2020 and 2030 EU’s climate and energy 
policy framework.  

The PRIMES and PRIMES-TREMOVE models are the core elements of the modelling framework for energy, 
transport  and  CO2  emission  projections.  In  addition,  the  POLES-JRC186  model  has  been  used  for  the  world 
energy price projections and the GEM-E3 model187 for the macro-economic developments by sector of activity, 
used in the baseline scenario.  

For the purpose of this impact assessment, PRIMES and PRIMES-TREMOVE models cover:  

  The entire energy (energy demand, supply, prices and investments to the future) and transport systems, 

and all GHG emissions and removals from the EU economy 

  Time horizon: 1990 to 2050 (5-year time steps) 

  Geography: individually all EU Member States 

 

Impacts:  on  the  energy  system  (PRIMES  and  its  satellite  model  on  biomass),  transport  (PRIMES-
TREMOVE). 

The modelling suite has been continuously updated over the past decade. Updates include the addition of a new 
buildings module in PRIMES, improved representation of the electricity sector, more granular representation of 
hydrogen (including cross-border trade188) and other innovative fuels, improved representation of the maritime 
transport sector, as well updated interlinkages of the models to improve land use and non-CO2 modelling. Most 
recently  a  major  update  was  done  of  the  policy  assumptions,  technology  costs  and  macro-economic 
assumptions. 

PRIMES model 

The  PRIMES  model  (Price-Induced  Market  Equilibrium  System)189  is  a  large  scale  applied  energy  system 
model  that  provides  detailed  projections  of  energy  demand,  supply,  prices  and  investment  to  the  future, 
covering the entire energy system including emissions. The distinctive feature of PRIMES is the combination 

183   Ricardo at al., Study supporting the impact assessment of the ReFuelEU Aviation initiative. 
184   SWD/2020/176 final. 
185   Source: https://ec.europa.eu/clima/sites/clima/files/docs/pages/com_2018_733_analysis_in_support_en_0.pdf  
186   The  POLES-JRC  model  provides 
https://ec.europa.eu/jrc/en/poles. 

the  global  energy  and  climate  policy  context  and 

is  operated  by 

the  JRC.  Source: 

187   E3Modelling (https://e3modelling.com/) is a private consulting, established as a spin-off inheriting staff, knowledge and software-modelling 

innovation of the laboratory E3MLab from the National Technical University of Athens (NTUA). 

188   While  cross-border  trade  is  possible,  the  assumption  is  that  there  are  no  imports  from  outside  EU  as  the  opposite  would  require  global 

modelling of hydrogen trade. 

189   More information and model documentation: https://e3modelling.com/modelling-tools/primes/  

89 

 
                                                           
of  behavioural  modelling  (following  a  micro-economic  foundation)  with  engineering  aspects,  covering  all 
energy  sectors  and  markets.  The  model  has  a  detailed  representation  of  policy  instruments  related  to  energy 
markets and climate, including market drivers, standards, and targets by sector or overall. It simulates the EU 
Emissions Trading System in its current form.  It handles multiple policy objectives, such as GHG emissions 
reductions, energy efficiency, and renewable energy targets, and provides pan-European simulation of internal 
markets for electricity and gas.  

PRIMES  offer  the  possibility  of  handling  market  distortions,  barriers  to  rational  decisions,  behaviours  and 
market  coordination  issues  and  it  has  full  accounting  of  costs  (CAPEX  and  OPEX)  and  investment  on 
infrastructure  needs.  The  model  covers  the  horizon  up  to  2070  in  5-year  interval  periods  and  includes  all 
Member States of the EU individually, as well as neighbouring and candidate countries. PRIMES is designed to 
analyse complex interactions within the energy system in a multiple agent – multiple markets framework.  

Decisions  by  agents  are  formulated  based  on  microeconomic  foundation  (utility  maximization,  cost 
minimization  and  market  equilibrium)  embedding  engineering  constraints  and  explicit  representation  of 
technologies  and  vintages;  optionally  perfect  or  imperfect  foresight  for  the  modelling  of  investment  in  all 
sectors. 

PRIMES  allows  simulating  long-term  transformations/transitions  and  includes  non-linear  formulation  of 
potentials  by  type  (resources,  sites,  acceptability  etc.)  and  technology  learning.  Figure  6  shows  a  schematic 
representation of the PRIMES model. 

It  includes  a  detailed  numerical  model  on  biomass  supply,  namely  PRIMES-Biomass,  which  simulates  the 
economics  of  supply  of  biomass  and  waste  for  energy  purposes  through  a  network  of  current  and  future 
processes.  The  model  transforms  biomass  (or  waste)  feedstock,  thus  primary  feedstock  or  residues,  into  bio-
energy commodities which undergo further transformation in the energy system e.g. as input into power plants, 
heating  boilers  or  fuels  for  transportation.  The  model  calculates  the  inputs  in  terms  of  primary  feedstock  of 
biomass  and  waste  to  satisfy  a  given  demand  for  bio-energy  commodities  and provides  quantification  of the 
required production capacity (for plants transforming feedstock into bioenergy commodities). Furthermore, all 
the costs resulting from the production of bioenergy commodities and the resulting prices are quantified. The 
PRIMES-Biomass  model is a key link of communication between the energy system projections obtained by 
the  core  PRIMES  energy  system  model  and  the  projections  on  agriculture,  forestry  and  non-CO2  emissions 
provided by other modelling tools (CAPRI, GLOBIOM/G4M, GAINS).  

90 

 
 
Figure 6: Schematic representation of the PRIMES model 

PRIMES is a private model maintained by E3Modelling190, originally developed in the context of a series of 
research  programmes  co-financed  by  the  European  Commission.  The  model  has  been  successfully  peer-
reviewed, most recently in 2011191; team members regularly participate in international conferences and publish 
in scientific peer-reviewed journals. 

Sources for data inputs 

A summary of database sources, in the current version of PRIMES, is provided below: 

•  Eurostat  and  EEA:  Energy  Balance  sheets,  Energy  prices  (complemented  by  other  sources,  such  IEA), 
macroeconomic  and  sectoral  activity  data  (PRIMES  sectors  correspond  to  NACE  3-digit  classification), 
population  data  and  projections,  physical  activity  data  (complemented  by  other  sources),  CHP  surveys, 
CO2  emission  factors  (sectoral  and  reference  approaches)  and  EU  ETS  registry  for  allocating  emissions 
between ETS and non ETS 

•  Technology  databases:  ODYSSEE-MURE192,  ICARUS,  Eco-design,  VGB  (power  technology  costs), 

TECHPOL – supply sector technologies, NEMS model database193, IPPC BAT Technologies194 
Power Plant Inventory: ESAP SA and PLATTS 

• 

190   Source: https://e3modelling.com/  
191   SEC(2011)1569 : https://ec.europa.eu/energy/sites/ener/files/documents/sec_2011_1569_2.pdf  
192   Source: https://www.odyssee-mure.eu/  
193   Source: https://www.eia.gov/outlooks/aeo/info_nems_archive.php  
194   Source: https://eippcb.jrc.ec.europa.eu/reference/  

91 

 
 
                                                           
•  RES  capacities,  potential  and  availability:  JRC  ENSPRESO195,  JRC  EMHIRES196,  RES  ninja197,  ECN, 

DLR and Observer, IRENA 

•  Network infrastructure: ENTSOE, GIE, other operators 
•  Other databases: District heating surveys (e.g. from COGEN), buildings and houses statistics and surveys 
(various sources, including ENTRANZE project198, INSPIRE archive, BPIE199), JRC-IDEES200, update to 
the EU Building stock Observatory201 

PRIMES-TREMOVE model  

The  PRIMES-TREMOVE  transport  model  projects  the  evolution  of  demand  for  passengers  and  freight 
transport,  by  transport  mode,  and  transport  vehicle/technology,  following  a  formulation  based  on 
microeconomic foundation of decisions of multiple actors. Operation, investment and emission costs, various 
policy  measures,  utility  factors  and  congestion  are  among  the  drivers  that  influence  the  projections  of  the 
model. The projections of activity, equipment (fleet), usage of equipment, energy consumption and emissions 
(and other externalities) constitute the set of model outputs.  

The  PRIMES-TREMOVE  transport  model  can  therefore  provide  the  quantitative  analysis  for  the  transport 
sector  in  the  EU,  candidate  and  neighbouring  countries  covering  activity,  equipment,  energy  and  emissions. 
The model accounts for each country separately which means that the detailed long-term outlooks are available 
both for each country and in aggregate forms (e.g. EU level). 

In the transport field, PRIMES-TREMOVE is suitable for modelling soft measures (e.g. eco-driving, labelling); 
economic measures (e.g. subsidies and taxes on fuels, vehicles, emissions; ETS for transport when linked with 
PRIMES;  pricing  of  congestion  and  other  externalities  such  as  air  pollution;  accidents  and  noise;  measures 
supporting R&D); regulatory measures (e.g. CO2 emission performance standards for new light duty and heavy 
duty  vehicles;  EURO  standards  on  road  transport  vehicles;  technology  standards  for  non-road  transport 
technologies, deployment of Intelligent Transport Systems) and infrastructure policies for alternative fuels (e.g. 
deployment  of  refuelling/recharging  infrastructure  for  electricity,  hydrogen,  LNG,  CNG).  Used  as  a  module 
that contributes to the PRIMES model energy system model, PRIMES-TREMOVE can show how policies and 
trends  in  the  field  of  transport  contribute  to  economy-wide  trends  in  energy  use  and  emissions.  Using  data 
disaggregated per Member State, the model can show differentiated trends across Member States.  

The  PRIMES-TREMOVE  has  been  developed  and  is  maintained  by  E3Modelling,  based  on,  but  extending 
features of, the open source TREMOVE model developed by the TREMOVE202 modelling community. Part of 
the  model  (e.g.  the  utility  nested  tree)  was  built  following  the  TREMOVE  model.203  Other  parts,  like  the 
component on fuel consumption and emissions, follow the COPERT model. 

195   Source: https://data.jrc.ec.europa.eu/collection/id-00138   
196   Source: https://data.jrc.ec.europa.eu/dataset/jrc-emhires-wind-generation-time-series   
197   Source: https://www.renewables.ninja/   
198   Source: https://www.entranze.eu/   
199   Source:  http://bpie.eu/   
200   Source: https://ec.europa.eu/jrc/en/potencia/jrc-idees   
201   Source: https://ec.europa.eu/energy/en/eubuildings  
202   Source: https://www.tmleuven.be/en/navigation/TREMOVE    
203   Several model enhancements were made compared to the standard TREMOVE model, as for example: for the number of vintages (allowing 
representation of the choice of second-hand cars); for the technology categories which include vehicle types using electricity from the grid 
and fuel cells. The model also incorporates additional fuel types, such as biofuels (when they differ from standard fossil fuel technologies), 
LPG,  LNG,  hydrogen  and  e-fuels.  In  addition,  representation  of  infrastructure  for  refuelling  and  recharging  are  among  the  model 
refinements, influencing fuel choices. A major model enhancement concerns the inclusion of heterogeneity in the distance of stylised trips; 
the  model  considers  that  the  trip  distances  follow  a  distribution  function  with  different  distances  and  frequencies.  The  inclusion  of 
heterogeneity was found to be of significant influence in the choice of vehicle-fuels especially for vehicles-fuels with range limitations. 

92 

 
                                                           
Data inputs 

The  main  data  sources  for  inputs  to  the  PRIMES-TREMOVE  model,  such  as  for  activity  and  energy 
consumption,  comes  from  EUROSTAT  database  and  from  the  Statistical  Pocketbook  "EU  transport  in 
figures204.  Excise  taxes  are  derived  from  DG  TAXUD  excise  duty  tables.  Other  data  comes  from  different 
sources such as research projects (e.g. TRACCS project) and reports. 

In the context of this exercise, the PRIMES-TREMOVE transport model is calibrated to 2005, 2010 and 2015 
historical data. 

2.  BASELINE SCENARIO 

Main assumptions of the Baseline scenario 

The baseline scenario used in this impact assessment builds  on the baseline scenario underpinning the impact 
assessment  accompanying  the  2030  Climate  Target  Plan  and  the  staff  working  document  accompanying  the 
Sustainable and Smart Mobility Strategy, but it additionally considers the impacts of the COVID-19 pandemic 
and the National Energy and Climate Plans.  

Economic assumptions: The modelling work is based on socio-economic assumptions describing the expected 
evolution of the European society. Long-term projections on population dynamics and economic activity form 
part  of  the  input  to  the  energy  and  transport  model  and  are  used  to  estimate  transport  activity  and  energy 
demand in transport. Population projections from Eurostat205 are used to estimate the evolution of the European 
population  that  is  projected  to  change  very  little  in  total  number  in  the  coming  decades.  Macro-economic 
projections draw on DG ECFIN.206 In particular, the Commission’s Spring Economic Forecast 2020 projected 
that the EU economy would contract by 7.4% in 2020 and pick up in 2021 with growth of 6.1%. By 2030, real 
GDP in 2030 could be approximately 2.3% lower compared to the pre-COVID estimates, based on the Autumn 
Forecast 2019. 

Energy prices assumptions: The COVID pandemics has had a major impact on international fuel prices. As a 
large  part  of  the  world  went  into  lockdown,  fossil  fuel  prices  collapsed  with  crude  oil  spot  prices  halved 
compared to last year levels. The oil price is projected to gradually recover over time, reaching 80USD/bbl in 
2030 and 118USD/bbl in 2050. It is however projected to remain below the projected pre-COVID-19 pandemic 
levels.207 Figure 7 shows the fuel prices projections used in the baseline scenario. 

Figure 7: International fuel prices assumptions  
in USD'15 per boe 

‘15 

‘30 

Oil 

Gas (NCV) 

in €'15 per boe 

52.3 

43.7 

‘15 

80.1 

40.9 

‘30 

‘40 

97.4 

52.6 

‘40 

‘50 

117.9 

57.8 

‘50 

204   Source: https://ec.europa.eu/transport/facts-fundings/statistics_en  
205   Source: https://ec.europa.eu/eurostat/web/population-demography-migration-projections/population-projections-data  
206   The long-term evolution of economic activity was estimated from three sources: DG ECFIN’s short term economic forecast, updated t+10 
projections up to 2029 and the 2018 Aging Report projections elaborated by the European Commission. For the short-term (2020-2021), the 
projections are based on growth forecast by the Directorate General for Economic and Financial Affairs (Spring 2020 Economic  Forecast). 
Projections  up  to  2029  use  the  associated  t+10  work  from  DG  ECFIN,  which  is  based  on  projections  of  potential  output  growth  and  a 
closure of output gap in the medium term. The long-term per capita GDP growth projections of the 2018 Ageing Report are used for the 
period  2030-2050,  available  at:  https://ec.europa.eu/info/publications/economy-finance/2018-ageing-report-economic-and-budgetary-
projections-eu-member-states-2016-2070_en 

207   Communication from the Commission ‘Stepping up Europe’s 2030 climate ambition - Investing in a climate-neutral future for the benefit of 

our people’, COM(2020) 562 final. 

93 

 
                                                           
Oil 

Gas (NCV) 

47.2 

38.7 

72.2 

36.2 

87.8 

46.6 

106.3 

51.2 

Source: Derived from JRC, POLES-JRC model, Global Energy and Climate Outlook (GECO) 

Source: Derived from JRC, POLES-JRC model, Global Energy and Climate Outlook (GECO) 

Technology assumptions: Modelling scenarios on the evolution of the energy and transport system is highly 
dependent on the assumptions on the development of technologies  - both in terms of performance and costs. 
For  the  purpose  of  the  impact  assessments  related  to  the  “Climate  Target  Plan”  and  the  “Fit  for  55”  policy 
package,  these  assumptions  have  been  updated  based  on  a  rigorous  literature  review  carried  out  by  external 
consultants in collaboration with the JRC208.  

Continuing  the  approach  adopted  in  the  long-term  strategy  in  2018,  the  Commission  consulted  technology 
assumption with stakeholders in 2019. In particular, the technology database of the main model suite (PRIMES, 
PRIMES-TREMOVE,  GAINS,  GLOBIOM,  and  CAPRI)  benefited  from  a  dedicated  consultation  workshop 
held on 11th November 2019. EU Member States representatives had also the opportunity to comment on the 
costs  elements  during  a  workshop  held  on  25th  November  2019.  The  updated  technology  assumptions  are 
published together with the EU Reference Scenario 2020. 

Policies included in the Baseline scenario 

The Baseline scenario projects developments under the current EU and national policy framework. It embeds in 
particular the EU legislation in place to reach the 2030 climate target of at least 40% compared to 1990, as well 
as national contributions to reaching the EU 2030 energy targets on Energy efficiency and Renewables under 
the  Governance  of  the  Energy  Union.  It  thus  gives  a  detailed  picture  of  where  the  EU  economy  and  energy 
system in particular would stand in terms of GHG emission if the policy framework were not updated to enable 
reaching the revised 2030 climate target to at least -55% compared to 1990 proposed under the Climate Target 
Plan209. 

In addition to the headline targets, some of the policies included in the baseline scenario are: 

  The EU Emissions Trading System210 (EU ETS) covers 45% of EU greenhouse gas emissions, notably from 
industry, the power sector and aviation. Emissions for the sectors under the system are capped to reduce by 
43%  by  2030  compared  to  2005.  The  baseline  scenario  additionally  assumes  that  the  Market  Stability 
Reserve (MSR) will ensure that the ETS contributes to the achievement of the overall target cost-effectively. 
MSR  functioning  is  set  to  be  reviewed211  in  2021  and  every  five  years  after  to  ensure its aim  of  tackling 
structural supply-demand imbalances. 

  Aviation emissions are also covered by the EU ETS. The EU, however, decided in 2014 to limit the scope of 
the  EU  ETS  to  flights  within  the  EEA  until  2016 to  support the  development of  a  global  measure  by  the 
International  Civil  Aviation  Organization (ICAO).212  In  light  of the  adoption  of a Resolution  by  the  2016 
ICAO  Assembly  on  the  global  measure, the  EU  has  decided  to  maintain  the  geographic  scope  of  the  EU 
ETS limited to intra-EEA flights from 2017 until the end of 2023.213 The EU ETS for aviation is subject to a 
new review in the light of the international developments related to the operationalisation of CORSIA. This 
review  considers  how  to  implement  the  global  measure  in  Union  law  through  a  revision  of  the  EU  ETS 

208   JRC118275 
209   COM/2020/562 final 
210   Directive 2003/87/EC. 
211   Decision (EU) 2015/1814. 
212   Regulation (EU) 421/2014. 
213   Regulation (EU) 2017/2392. 

94 

 
                                                           
legislation.  In  the  absence of  a  new  amendment,  the EU  ETS  would revert  back  to  its  original  full scope 
from 2024.  

  For aviation, in addition to implementation of the EU Emission Trading Scheme, the Baseline reflects the 
Union-wide  air  transport  performance  targets  for  the  key  performance  area  of  environment,  Clean  Sky, 
Single European Sky and SESAR, and aircraft CO2 emissions standards, as part of the so-called “basket of 
measures” that aim to reduce emissions from the sector.  

  The  revised  Renewable  Energy  Directive214  entered  into  force  in  2018.  It  establishes  a  new  binding 
renewable energy target for the EU for 2030 of at least 32%, with a clause for a possible upwards revision 
by 2023. 

  The  Fuel  Quality  Directive215  requires  a  reduction  of  the  greenhouse  gas  intensity  of  transport  fuels  by  a 

minimum of 6% to be achieved by 2020. 

  CO2  emission  standards  for  new  cars  and  vans216  and  for  new  trucks217  have  been  defined,  and  will 
contribute towards reducing emissions from the road transport sector. Besides the post-2020 CO2 standards 
for  new  light  duty  and  heavy  duty  vehicles,  the  Clean  Vehicles  Directive  and  the  Directive  on  the 
deployment  of  alternative  fuels  infrastructure  contribute  to  the  roll-out  of  recharging  infrastructure. 
Furthermore,  the  uptake  of  sustainable  alternative  fuels  is  supported  by  the  Renewables  Energy  Directive 
and  Fuel  Quality  Directive.  Improvements  in  transport  system  efficiency  (by  making  the  most  of  digital 
technologies  and  smart  pricing  and  further  encouraging  multi-modal  integration  and  shifts  towards  more 
sustainable  transport  modes)  are  facilitated  by  e.g.  the  TEN-T  Regulation  supported  by  CEF  funding,  the 
fourth  Railway  Package,  the  Directive  on  Intelligent  Transport  Systems,  the  European  Rail  Traffic 
Management System European deployment plan, the Regulation establishing a framework for the provision 
of port services, and others. 

  For  maritime  shipping,  in  addition  to  emissions  being  monitored  under  the  Regulation  on  Monitoring, 
Reporting and Verification of Maritime Emissions218, the Baseline scenario reflects the Energy Efficiency 
Design  Index  (EEDI)  and  the  Ship  Energy  Efficiency  Management  Plan  (SEEMP)  adopted  by  the 
International Maritime Organisation, as well as the Sulphur Directive. The Baseline also accounts for other 
initiatives addressing air pollution from inland waterways vessels, as well as road safety, and thus reducing 
the external costs of transport. 

  The Effort Sharing Regulation219 (ESR) sets binding annual reduction targets for member states, with an aim 
to  reduce  emissions  by  30%  compared  to  2005  by  2030.  The  ESR  targets  are  set  according  to  national 
wealth and cost-effectiveness. The ESR allows for flexibilities such as transfers between member states.  

The  Baseline  scenario  considers  existing  national  policies  and  those  reflected  in  the  National  Energy  and 
Climate Plans.   

The Baseline scenario models the policies already adopted, but not the target of net-zero emissions by 2050. As 
a result, there are no additional policies introduced driving decarbonisation after 2030. However, climate and 
energy policies are not rolled back after 2030 and several of the measures in place today continue to deliver 
emissions reduction in the long term. 

Main results of the Baseline scenario 

214   Directive 2018/2001/EU. 
220   SWD(2020) 176 
220   SWD(2020) 176 
220   SWD(2020) 176 
220   SWD(2020) 176 
220   SWD(2020) 176 

95 

 
                                                           
EU total passenger transport activity is projected to grow at a rate of 1% per year on average between 2010 
and  2050,  despite  the  significant  impact  of  the  COVID-19  pandemics.  Growth  rates  per  mode  of  transport 
would however be different (see  Figure 9). The modal share of road transport (i.e. passenger cars, buses and 
coaches, and 2-wheelers) is projected to reduce from 69% in 2015 to 61% in 2050.  

Air traffic (intra and extra-EU) would increase by 43% by 2030 and 88% by 2050, relative to 2015, following 
the  recovery  from  the  COVID-19  pandemic.  That  is  despite  the  steep  reduction  in  its  activity  due  to  the 
COVID-19  pandemics  in  2020  (i.e.  a  reduction  of  46%  in  2020  relative  to  2015  levels),  as  the  sector  is 
projected  to  recover  beyond  2015  activity  levels  by  2025.  The  pace  of  the  recovery  builds  on  the  GDP 
projections from DG ECFIN but also considers some moderate structural changes due to limited shifts towards 
digital  meetings.  The  overall  impact  of  the  COVID-19  pandemics  on  the  air  transport  activity  is  however 
significant (see Figure 8), especially by 2030, with lower growth projected relative to pre-COVID projections 
(i.e.  around  11  percentage  points  lower  growth  for  2015-2030  relative  to  the  pre-COVID  projections  and 14 
percentage points lower growth for 2015-2050). The pre-COVID projections draw on the baseline scenario of 
the common economic assessment underpinning the 2030 Climate Target Plan and the Sustainable and Smart 
Mobility Strategy220,221. 

Figure 8 Air transport activity (intra and extra EU) in EU27 in the Baseline scenario and pre-COVID projections (% growth relative to 
2015) 

Source: PRIMES-TREMOVE model, E3Modelling  

The modal share of aviation (intra and extraEU) in passenger transport activity would go up to 32% by 2050, 
compared to 24% in 2015, despite the increasing modal share of passenger rail.  

220   SWD(2020) 176 
221   SWD(2020) 331 

96 

0%20%40%60%80%100%120%Pre-COVIDBaselinePre-COVIDBaseline20302050growth in transport activity relative to 2015 
 
                                                           
Figure 9 Passenger transport activity in EU27 in the Baseline scenario 

Source: PRIMES-TREMOVE model, E3Modelling  

Energy demand in transport (passenger and freight, excluding international shipping) is projected to reduce 
by about 60 Mtoe (or 20%) between 2010 and 2020 as a result of reduced transport activity due to the COVID-
19 pandemics. As the activity recovers, the energy demand in the sector increases, peaking at around 280 Mtoe 
in 2030. The decline that is projected thereafter is  mainly driven by the implementation of the CO2 emission 
performance  standards  for  new  light  duty  and  heavy  duty  vehicles  post-2020,  supported  by  the  roll-out  of 
recharging and refuelling infrastructure and also by the shift towards more energy efficient modes such as rail 
and waterborne transport.  

The  energy  demand  in  aviation  is  projected  to  grow  from  around  40  Mtoe  in  2015  to  50  Mtoe  in  2050, 
following the significant decrease estimated for 2020 (to 21 Mtoe) due to the COVID-19 pandemic Extra-EU 
flights are responsible for about two-thirds of energy consumption in aviation. Aviation is projected to remain 
almost entirely reliant on conventional jet fuel by 2050 in the Baseline scenario. The projected uptake of SAF is 
limited to 0.1 Mtoe in 2030, increasing gradually to close to 1.5 Mtoe in 2050, which would account for 0.2% 
of total fuel consumption in aviation by 2030 and 2.9% by 2050. 

Transport  tank-to-wheel  (TTW)  CO2  emissions  (including  international  shipping)  are  projected  to  decrease 
from approximately 994 Mtons in 2015 to about 888 Mtons in 2030 and 713 Mtons in 2050, or by 11% and 
28%, respectively. The reduction in CO2 emissions is primarily achieved in road transport due to the roll-out of 
efficient internal combustion engine vehicles and the uptake of electric vehicles, especially in the period after 
2030,  but  also  due  to  the  shift  to  rail.  Specifically,  the  emissions  of  road  transport  are  projected  to  decrease 
from 732 Mtons in 2015, to 588 Mtons in 2030 (or 20% compared to 2015) and to 386 Mtons in 2050 (or 47% 
compared to 2015). Emissions from rail transport also decrease, by 3 Mtons in 2050 (or 65% compared 2015). 
The reduction in these segments compensates  for the increase of CO2 emissions in aviation, which from 120 
Mtons in 2015, increases to 140 Mtons in 2030 (by 17%) and 144 Mtons in 2050 (by 21%), and international 
shipping that increases its emissions by 42 Mtons between 2015 and 2050. The share of air transport in the total 
transport CO2 emissions222 is projected to go up from around 12% in 2015 to 20% in 2050. 

222   Total transport CO2 emissions including international maritime. 

97 

20102020203020402050Extra-EU aviation959612163719242154Intra-EU aviation398244655764850Rail444274577653728Road4579396052225476574501,0002,0003,0004,0005,0006,0007,0008,0009,00010,000Gpkm 
 
                                                           
CO2 emissions from air transport (see Figure 10) are however projected to grow at lower pace than in the pre-
COVID projections (17% for 2015-2030 relative to 25% in the pre-COVID projections and 21% for 2015-2050 
relative to 30% in the pre-COVID projections), driven by the lower transport activity projections.  

Figure 10 CO2 emissions from air transport (intra and extra EU) in EU27 in the Baseline scenario and pre-COVID projections (% 
growth relative to 2015) 

Source: PRIMES-TREMOVE model, E3Modelling  

Well-to-wheel  (WTW)  emissions  (including  those  from  international  maritime)  are  projected  to  follow  a 
similar declining trend. In the Baseline scenario they decrease from 1,118 Mtons CO2eq in 2015, to 1,019 Mtons 
CO2eq in 2030 and 838 Mtons CO2eq in 2050.  

The Baseline scenario results are closely aligned to those of the EU Reference scenario 2020. Figure 11 Tank-to-Wheel CO2 emissions 
by transport mode and Well-to-Wheel emissions in transport in the EU27 in the Baseline scenario 

Source: PRIMES-TREMOVE model, E3Modelling  

98 

0%5%10%15%20%25%30%35%Pre-COVIDBaselinePre-COVIDBaseline20302050growth in CO2 emissions relative to 201520102020203020402050Extra-EU aviation7743969899Intra-EU aviation3619444545Int. maritime15098145157169Inland navigation1610121313Rail73321Road746614588452386Well-to-Wheel (CO2eq)117487810198938380200400600800100012001400Mtons CO2 
 
  
Figure 12 Reduction of Tank-to-Wheel CO2 emissions by transport segment in the EU27 between 2010 and 2050 in the Baseline 
scenario 

Source: PRIMES-TREMOVE model, E3Modelling  

3.  METHODOLOGICAL NOTES AND ADDITIONAL RESULTS OF THE POLICY OPTIONS 

The European Green Deal has set the key objective to deliver a 90% reduction in transport-related greenhouse 
gas  emissions  by  2050,  drawing  on  the  in-depth  analysis  underpinning  the  2050  long-term  strategy223.  The 
common scenarios underpinning the Impact Assessment accompanying the 2030 Climate Target Plan224 and the 
Staff  Working  Document  accompanying  the  Sustainable  and  Smart  Mobility  Strategy  confirmed  that  for 
achieving climate neutrality by 2050 transport emissions (including intra-EU aviation and intra-EU maritime) 
would need to decrease by 95-96% by 2050 relative to 2015 (94-96% relative to 1990). When considering all 
intra-EU and extra-EU maritime transport, the emissions reductions are projected at around 91-92% relative to 
2015 (89-90% relative to 1990). The lower emissions reductions in transport relative to other sectors like for 
example  power  generation  is  in  recognition  of  the  fact  that  emissions  in  some  transport  modes,  in  particular 
aviation and maritime, are more difficult to abate. The EU’s pathway towards climate neutrality, covering all 
sectors of the economy, is provided in Figure 13. 

223 COM (2018) 773 
224 SWD/2020/176 final 

99 

713 
 
 
 
 
 
                                                           
Figure 13- The EU’s pathway to sustained economic prosperity and climate neutrality, 1990-2050 

Source:  COM(2020)  562  final.  Commission  Communication  “Stepping  up  Europe’s  2030  climate  ambition  Investing  in  a  climate-
neutral future for the benefit our people 

Among the transport modes, road and rail transport would need to be almost fully decarbonised by 2050. Lower 
emissions  reductions  are  projected  in  aviation  and  maritime,  due  to  the  more  limited  technological  options 
available for these sectors. Nevertheless, air transport sector would need to achieve emissions reductions of at 
least  52-59%  by  2050  relative  to  2015  (equivalent  to  14-25%  reduction  relative  to  1990)  and  international 
maritime of at least 84-86% (equivalent to 80-82% emissions reductions relative to 1990). 

Methodological approach for modelling Policy Options 

For  the  quantification  of  the  Policy  Options,  first  the  PRIMES-Aviation  submodule  was  used  in  order  to 
simulate in detail the changes in the travel demand induced by the changes in the cost of fuels driven by the 
SAF  blending  obligations.  For  this  step,  an  initial  set  of  assumptions  on  the  biokerosene  prices  was  used. 
Subsequently,  the  PRIMES-TREMOVE  model  was  used  in  order  to  assess  the  impacts  on  all  transport 
segments.  The  demand  for  biokerosene  that  was  estimated  using  PRIMES-TREMOVE,  was  provided  to  the 
PRIMES Biomass supply model. The model was subsequently used to estimate the price of biokerosene that 
reflected the production costs based on the deployed biokerosene production pathways. The iterative process of 
the model runs was then repeated once again, Subsequently, the price of biokerosene was used in the PRIMES-
Aviation  submodule,  re-iterating  the  PRIMES-TREMOVE  and  PRIMES-Biomass  model  runs  in  order  to 
provide the quantified output for each Policy Option. 

The  price  of  biokerosene  is  based  on  the  PRIMES  Biomass  supply  model  for  two  separated  contexts  that 
depend on the demand levels of biokerosene over time: the high biokerosene demand context is representative 
for  Policy  Options  A1,  A2,  B1,  C1,  and  C2  and  the  low  biokerosene  demand  context  is  representative  for 
Policy Option B2. This distinction is necessary since Policy Option B2 considers mandates only for the intra-
EU  air  traffic,  leading  to  substantially  lower  demand  for  SAF  and  biokerosene  compared  to  the  rest  of  the 
Policy  Options.  Biokerosene  production  costs  are  estimated  based  on  feedstock  costs,  annualised  capital 
investments (taking into account the utilisation of each conversion technology in each time period), operational 
expenditures  (fixed  and  variable  costs).  Fixed  operating  costs  account  for  the  operating  and  maintenance, 

100 

 
 
 
labour, taxes, overhead and administrative costs. Variable costs include energy costs, and process inputs such 
as  enzymes,  catalysts,  hydrogen  and  non-energy  utilities  (e.g.  water,  waste  treatment).  The  price  is  then 
determined based on a profit margin of 10% assumed for the producer. 

SAF  prices  projections  are  fully  embedded  in  the  2030  Climate  Target  Plan  policy  context,  where  the  EU 
economy is moving towards carbon neutrality by 2050. This leads to strong competition for biomass feedstock 
with  other  energy  and  transport  sectors.  Feedstock  and  renewable  electricity  are  considered  to  be  sourced 
predominantly in the EU, in order to support the reduction in energy dependence. This further contributes to 
driving feedstock prices upwards. 

In modelling, the assumption was made that the RFNBOs only can fulfil the aviation synthetic fuels obligations 
in 2030 and afterwards, which is in line with REDII currently in force. Low-carbon electricity for production of 
synthetic fuels could be considered in line with Energy System Integration Strategy. This may have impacts on 
some modelling results. 

Methodological notes on Policy Option C 

In  Policy  Option  C,  during  a  transition  period  that  lasts  until  2035,  it  is  assumed  that  fuel  suppliers  may 
organise their logistics, distributing the jet fuel blend to different airports in the most cost-effective way, while 
meeting the overall blending mandate for sustainable aviation fuels at the EU level, whether prescribed (as in 
Policy Option C1) or determined on the basis of CO2 emission intensity of the fuel blend (as in Policy Option 
C2). In 2030, the SAF fuel supply in each airport may range between 0% and 50%, and in 2035 between 2% 
and 50%. The Policy Option C assumes that the largest airports, and those with proximity to blending facilities 
will be supplied with most of the jet fuel blends. After the transition period, the EU-wide blending mandates 
apply also to individual MS. 

As such, the distribution of the sustainable aviation fuel blends up until 2035 will differ per MS. For the 
development of this Policy Option, the EU27 blending share for biokerosene and synthetic kerosene is 
distributed among the different MS, in line with the different weighing factors for key indicators (Table 15). In 
this respect, a multicriteria analysis has been employed, in which the different MS score differently on the two 
criteria considered. The criteria are then weighted to derive a single metric so as to rank the various MS in 
terms of their overall performance. The weighting factors were determined based on information deriving from 
questionnaires submitted to fuel suppliers.225 In this way, the present analysis associates the weights with 
information from the market actors. As a proxy for the size of airport hubs, passenger air traffic in each MS is 
used, based on EUROSTAT data for 2019. As a proxy for proximity to blending facilities with biokerosene, it 
is assumed that it is more likely these to be developed in areas where there is feedstock availability. Feedstock 
production data for biomass feedstock availability per MS where used as a proxy, based on PRIMES Biomass 
model. In 2030, availability of UCO is assumed to be the key feedstock and for years leading to 2050, the 
proximity to solid biomass is prioritized. Ultimately, based on the weighing factors and the data for each MS, 
the scoring matrices presented in Source: Ricardo at al. Impact assessment support study 

Table 16 and Table 17 where used to distribute the fuel blends across MS.  

Table 15 Weighing factors for different assessment criteria used for the distribution of jet fuel supply to different MS 

Indicator 

Availability of UCO 

Availability of Solid biomass feedstocks 

2030 

50% 

- 

2050 

- 

25% 

225   Responses received from BP, Fulcrum, Nest, Shell and SkyNRG representing both SAF and conventional fuel suppliers. 

101 

 
 
                                                           
Synthetic kerosene production 

Passenger traffic in airports 
Source: Ricardo at al. Impact assessment support study 

- 

50% 

25% 

50% 

Table 16 Scoring matrix for the distribution of jet fuel blends to different MS in 2030 

Proximity to feedstock 

Airport traffic 

Total score 

UCO 

Solids 

E-fuels 

DE 

FR 

IT 

ES 

SE 

PL 

NL 

BE 

AT 

RO 

PT 

EL 

DK 

FI 

IE 

CZ 

HU 

BG 

HR 

SK 

CY 

LT 

LV 

SI 

LU 

EE 

2.5 

2.5 

2.5 

2.5 

2.5 

2 

2 

2 

2 

2 

1.5 

1.5 

1.5 

1.5 

1 

1.5 

1 

1 

1 

1 

0.5 

0.5 

0.5 

0.5 

0.5 

0.5 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

MT 
Source: Ricardo at al. Impact assessment support study 

0.5 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

2.5 

2.5 

2.5 

2.5 

2 

2.5 

2 

1.5 

1.5 

1.5 

2 

2 

1.5 

1.5 

2 

1 

1 

1 

1 

0.5 

1 

0.5 

0.5 

0.5 

0.5 

0.5 

0.5 

5.0 

5.0 

5.0 

5.0 

4.5 

4.5 

4.0 

3.5 

3.5 

3.5 

3.5 

3.5 

3.0 

3.0 

3.0 

2.5 

2.0 

2.0 

2.0 

1.5 

1.5 

1.0 

1.0 

1.0 

1.0 

1.0 

1.0 

Table 17 Scoring matrix for the distribution of jet fuel blends to different MS in 2050 

Proximity to feedstock 

Airport traffic 

Total score 

DE 

FR 

IT 

PL 

ES 

SE 

RO 

PT 

FI 

UCO 
0 

0 

0 

0 

0 

0 

0 

0 

0 

Solids 
1.25 

1.25 

1.25 

1.25 

1 

1 

1.25 

0.5 

1 

E-fuels 
1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

102 

2.5 

2.5 

2.5 

2.5 

2.5 

2 

1.5 

2 

1.5 

5.0 

5.0 

5.0 

5.0 

4.8 

4.3 

4.0 

3.8 

3.8 

 
 
  
  
 
  
 
  
  
 
 
IE 

NL 

AT 

EL 

DK 

HU 

BE 

CZ 

BG 

HR 

LT 

LV 

CY 

SK 

EE 

SI 

LU 

Proximity to feedstock 

Airport traffic 

Total score 

UCO 
0 

Solids 
0.5 

E-fuels 
1.25 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0.25 

0.75 

0.25 

0.5 

1 

0.25 

0.75 

0.75 

0.75 

1 

0.75 

0.25 

0.5 

0.5 

0.25 

0.25 

1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

1.25 

2 

2 

1.5 

2 

1.5 

1 

1.5 

1 

1 

1 

0.5 

0.5 

1 

0.5 

0.5 

0.5 

0.5 

0.5 

3.8 

3.5 

3.5 

3.5 

3.3 

3.3 

3.0 

3.0 

3.0 

3.0 

2.8 

2.5 

2.5 

2.3 

2.3 

2.0 

2.0 

2.0 

MT 
Source: Ricardo at al. Impact assessment support study 

0 

0.25 

The shares of biofuels and RFNBOs in Policy Options C1 and C2 are provided in the tables below.   

Table 18: Share of biofuels in the EU air transport energy use in PO C1 and PO C2 

Share of biofuels (in 
%) 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PO C1 

PO C2 

2025 

1.4% 

1.4% 

0.8% 

0.5% 

1.0% 

2.3% 

1.1% 

0.2% 

1.4% 

2.3% 

1.1% 

2.3% 

0.8% 

0.8% 

1.1% 

2.3% 

0.2% 

0.2% 

0.2% 

0.2% 

1.7% 

2030 

3.2% 

3.2% 

1.8% 

1.8% 

2.1% 

5.0% 

2.5% 

1.9% 

3.2% 

5.0% 

2.5% 

5.0% 

1.8% 

1.8% 

2.5% 

5.0% 

1.9% 

1.9% 

1.9% 

1.9% 

3.8% 

2035 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

2050 

32.3% 

30.8% 

30.8% 

29.2% 

30.8% 

36.9% 

31.7% 

28.6% 

32.3% 

36.0% 

33.2% 

36.9% 

30.8% 

31.7% 

33.2% 

36.9% 

30.2% 

27.7% 

29.2% 

27.7% 

32.3% 

103 

2025 

1.4% 

1.4% 

0.8% 

0.5% 

1.0% 

2.3% 

1.1% 

0.2% 

1.4% 

2.3% 

1.1% 

2.3% 

0.8% 

0.8% 

1.1% 

2.3% 

0.2% 

0.2% 

0.2% 

0.2% 

1.7% 

2030 

3.3% 

3.3% 

1.9% 

2.0% 

2.3% 

5.1% 

2.7% 

2.1% 

3.3% 

5.1% 

2.7% 

5.1% 

1.9% 

1.9% 

2.7% 

5.1% 

2.1% 

2.1% 

2.1% 

2.1% 

3.9% 

2035 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

2050 

36.3% 

34.7% 

34.7% 

33.2% 

34.7% 

40.9% 

35.6% 

32.6% 

36.3% 

40.0% 

37.2% 

40.9% 

34.7% 

35.6% 

37.2% 

40.9% 

34.1% 

31.6% 

33.2% 

31.6% 

36.3% 

 
  
  
 
 
 
PO C1 

PO C2 

Share of biofuels (in 
%) 

PL 

PT 

RO 

SE 

SI 

SK 

2025 

2.0% 

1.4% 

1.4% 

2.0% 

0.2% 

0.5% 

2030 

4.3% 

3.2% 

3.2% 

4.3% 

1.9% 

1.8% 

2035 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

15.0% 

2050 

36.9% 

33.2% 

33.9% 

34.5% 

27.7% 

28.6% 

2025 

2.0% 

1.4% 

1.4% 

2.0% 

0.2% 

0.5% 

2030 

4.4% 

3.3% 

3.3% 

4.4% 

2.1% 

2.0% 

EU27 
Source: Ricardo at al. Impact assessment support study; PRIMES-TREMOVE model, E3Modelling 

35.0% 

15.0% 

2.0% 

4.3% 

2.0% 

4.5% 

2035 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

17.1% 

Table 19: Share of RFNBOs in the EU air transport energy use in PO C1 and PO C2 

Share of RFNBOs 
(in %) 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

PO C1 

PO C2 

2025 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

2030 

0.5% 

0.5% 

0.3% 

0.2% 

0.3% 

0.8% 

0.4% 

0.1% 

0.5% 

0.8% 

0.4% 

0.8% 

0.3% 

0.3% 

0.4% 

0.8% 

0.1% 

0.1% 

0.1% 

0.1% 

0.6% 

0.7% 

0.5% 

0.5% 

0.7% 

0.1% 

0.2% 

2035 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

5.0% 

2050 

25.8% 

24.6% 

24.6% 

23.4% 

24.6% 

29.5% 

25.4% 

22.9% 

25.8% 

28.8% 

26.6% 

29.5% 

24.6% 

25.4% 

26.6% 

29.5% 

24.1% 

22.2% 

23.4% 

22.2% 

25.8% 

29.5% 

26.6% 

27.1% 

27.6% 

22.2% 

22.9% 

2025 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.00% 

0.00% 

0.00% 

0.00% 

0.00% 

0.00% 

0.00% 

0.00% 

0.00% 

2030 

0.4% 

0.4% 

0.1% 

0.0% 

0.2% 

0.7% 

0.3% 

0.0% 

0.4% 

0.7% 

0.3% 

0.7% 

0.1% 

0.1% 

0.3% 

0.7% 

0.0% 

0.0% 

0.01% 

0.01% 

0.47% 

0.55% 

0.36% 

0.36% 

0.55% 

0.01% 

0.03% 

EU27 
Source: Ricardo at al. Impact assessment support study; PRIMES-TREMOVE model, E3Modelling 

28.0% 

0.0% 

0.0% 

5.0% 

0.7% 

0.6% 

2035 

2.9% 

2.9% 

2.9% 

2.9% 

2.9% 

2.9% 

2.9% 

2.9% 

2.9% 

2.9% 

2.9% 

2.9% 

2.9% 

2.9% 

2.9% 

2.9% 

2.9% 

2.9% 

2.92% 

2.92% 

2.92% 

2.92% 

2.92% 

2.92% 

2.92% 

2.92% 

2.92% 

2.9% 

Methodological note on the cost of SAF logistics 

104 

2050 

40.9% 

37.2% 

37.8% 

38.4% 

31.6% 

32.6% 

38.9% 

2050 

21.9% 

20.7% 

20.7% 

19.4% 

20.7% 

25.6% 

21.4% 

18.9% 

21.9% 

24.9% 

22.6% 

25.6% 

20.7% 

21.4% 

22.6% 

25.6% 

20.2% 

18.2% 

19.4% 

18.2% 

21.9% 

25.6% 

22.6% 

23.1% 

23.6% 

18.2% 

18.9% 

24.0% 

 
 
 
The  required  distribution  of  SAF  to  Member  States  (i.e.  in  PO  A1  and  PO  A2)  is  different  from  the 
economically  more  flexible  distribution  in  PO  C1  and  C2  (presented  in  the  tables  above).  In  the  later,  SAF 
would be used flexibly to fulfil SAF obligations of suppliers across the EU expecting the obligated parties to 
make the more economically beneficial choices. This means SAF supply lines would be developed earlier to 
supply either airports with large jet fuel demand, economic logistics or those in proximity to SAF production 
(and feedstock) capacity226.  

By comparing the allocation of SAF supply to different EU Member States under the different Policy Options, 
the  additional  logistics  effort  required  to  meet  the  fuel  obligations  can  be  identified.  The  calculation  of  the 
additional capacity assumes that countries presenting with a larger than required SAF usage in the PO C1 and 
C2,  have  a  production  surplus  while  countries  that  have  a  lower  usage  have  a  SAF  production  deficit. 
Additional logistics costs may also be induced within each Member State, however the working assumption is 
that within each country, SAF supply is expected to enter the conventional fuel supply chain with a reasonable 
level of logistic costs as more difficult to reach airports are exempt from the mandate obligation. 

To calculate the additional logistics effort of transporting SAF between Member States, the SAF surplus has 
been allocated from the net-supplier to the net-user Member States. Excess supply has been distributed starting 
from  the  net-supplier  countries  that  have  less  available  markets  of  net-user  countries  in  proximity  and  then 
progressively moving to allocate the excess SAF supply of countries with more access. Average Member State 
distances have been used from the TERCET database227 to both indicate SAF supply Origin-Destination pairs 
of MS and to account for the average distances SAF fuel would need to be transported.  

In calculating the cost of fuel logistics, the usage of 35 tonne trucks is assumed with a diesel consumption of 35 
litres  per  100  km  (Lloyd,  2019)  resulting  in  a  fuel  consumption  of  €  1.07  per  100  tonne-km.  Other  truck 
operating costs are derived from the average road freight transport costs as estimated for the countries exporting 
SAF in the national reports issued by CNR (Comité national routier, 2019). External costs of these additional 
logistics  operations  are  calculated  on  a  tonne-km  basis  using  the  unit  value  for  external  costs  of  freight 
transport as estimated in the 2019 Handbook on external costs228.  

Impact on energy use in air transport  

The introduction of increasing shares of SAF in the aviation fuel mix leads to an overall decrease in jet 
fuel consumption relative to the baseline. This is driven by a decrease in air transport activity due to higher 
ticket  prices  (see  section  6.2).  By  2030,  the  energy  use  in  air  transport  decreases  for  all  POs  by  around  2% 
compared to the baseline, and by 8-9% by 2050 (except for PO B2). Small differences can be observed between 
POs,  depending  on  the  target  setting  (volume  approach  versus  CO2  intensity  approach).  The  reduction  in 
energy use in air transport is slightly lower when the obligation is defined in terms of jet fuel CO2 intensity 
reduction (POs A2 and C2) compared to the volume-based obligations (POs A1, B1 and C1). This is explained 
by the slightly lower cost of the jet fuel blend in the CO2 intensity reduction approach versus the volume based 
approach,  that  is  passed  through  to  the  ticket  prices  and  results  in  slightly  lower  reduction  in  air  transport 
activity. There is a notable difference in the reduction of energy use for PO B2 compared to other POs, where 
total jet fuel use is only reduced by 5% in 2050 compared to the baseline. This is due to the lower reduction in 
air transport activity in PO B2. 

Table 20 - Changes in energy use in air transport in POs relative to the baseline 
Air transport energy use (% change to 

Baseline (Mtoe) 

PO A1 

PO A2 

226   Ricardo at al., Study supporting the impact assessment of the ReFuelEU Aviation initiative. 
227   Source: https://gisco-services.ec.europa.eu/tercet/flat-files  
228   Source: Handbook on the external costs of transport - Publications Office of the EU (europa.eu) 

105 

 
 
                                                           
Baseline) 

Air transport energy use  

Air transport energy use (% change to 
Baseline) 

Air transport energy use  

Air transport energy use (% change to 
Baseline) 

Air transport energy use  

2030 

2040 

2050 

2030 

2040 

2050 

2030 

2040 

2050 

47 

48 

50 

-2.1% 

Baseline (Mtoe) 

-4.2% 
PO B1 

-8.5% 

-2.1% 

-4.0% 
PO B2 

-8.1% 

2030 

2040 

2050 

2030 

2040 

2050 

2030 

2040 

2050 

47 

48 

50 

-2.2% 

Baseline (Mtoe) 

-4.3% 
PO C1 

-8.6% 

-2.1% 

-3.0% 
PO C2 

-5.3% 

2030 

2040 

2050 

2030 

2040 

2050 

2030 

2040 

2050 

47 

48 

50 

-2.1% 

-4.2% 

-8.5% 

-2.1% 

-4.0% 

-8.1% 

Source: Ricardo at al. Impact assessment support study; PRIMES-TREMOVE, E3Modelling 

The introduction of increasing shares of SAF in the aviation fuel mix leads to a marginal decrease in the energy 
use in transport (excluding international maritime) in 2030 and 2050 for all POs compared to the baseline. This 
is  mainly  due  to  the  lower  air  transport  activity. The  decrease in  energy  use  in  transport  is  relatively  similar 
across options, i.e. a decrease of 0.3 to 0.4% by 2030 and by 1.1 to 1.9% by 2050 (1.1% for PO B2 and 1.8-
1.9% for the other POs).  

Administrative costs 

Administrative costs for businesses 

Reporting for fuel suppliers 

Under  all  POs,  the  reporting  of  fuel  supply  can  be  done  via  Union  Database  which  is  being  developed  as  a 
requirement of the Renewable Energy Directive recast (Article 28). It should be ensured that the database takes 
into  account  the  reporting  needs  as  defined  by  the  aviation  mandate    and  is  consistent  with  CORSIA  MRV 
requirements  for  SAF.  Therefore,  it  is  assumed  that  no  additional  administrative  burden  will  be  caused  for 
businesses via this initiative. 

Reporting for air transport service providers 

In  the  Policy  Options  that  include  a  demand  side  mandate  (Policy  Options  B1,  B2),  air  transport  service 
providers are the obliged body. They are in this respect required to report on their SAF uptake. For intra-EEA 
flights,  the  reporting  stream  established for the aviation  ETS  foresees  the  reporting  of  SAF  uptake.  Utilising 
this data stream means that no additional administrative burden will be required for reporting on this obligation. 
For extra-EEA flights under Policy Option B1, airlines will report SAF use to their administering state. For EU 
airlines,  his  information  will  be  collected  by  EU  States  and  could  be  made  available  with  no  additional 
administrative  burden for air transport  service  providers.  However,  for  non-EU  airlines, this  data  will  not be 
sent to  EU  authorities  pursuant to  CORSIA  rules.  It  is  therefore  needed  to  request  non-EU  airlines  to report 
directly SAF use to an EU agency (a new data stream will need to be established). This is not expected to incur 
significant additional costs as the data required are already available.   

Additionally,  for  Policy  Options  C1  and  C2,  fuel  users  will  need  to  report  on  the  amount  of  fuel  they  have 
uplifted before each flight taking off from an EEA airport to showcase that they have uplifted the amount of 
fuel necessary for their upcoming trip (no more, no less  – all safety and operation margins considered). This 
reporting  could  be  done  under  the  EU  ETS  reporting  system  for  intra-EEA  flights  (via  an  adaptation  of  the 
reporting template) and via a new reporting stream for extra-EEA flights, where airlines report directly to an 
EU agency. It is expected that this reporting process should not take more than a couple of minutes per flight.  

We assume a high estimate of 5’ needed to report per flight and considering the EU hourly average transport 
wage (€18.4/hour). These amount to annual costs of a total of €16.8 million for the first year of the mandate 
application in 2025 and around € 24 million in 2050 for both Policy Options. The calculation of the number of 
flights considers as a base year the 10.56 million flights counted in 2019 and the projected recovery until 2025 

106 

 
 
 
by  Eurocontrol.  From  2025  onwards,  the  number  of  flights  is  considered  to  increase  proportionally  to  the 
projected air transport activity as modelled by the PRIMES-TREMOVE model runs.229 

 Table 21 Annual administrative costs for air transport service providers (in € million) 

Policy Option 

Baseline 

Policy Option A1 

Policy Option A2 

Policy Option B1 

Policy Option B2 

Policy Option C1 

Policy Option C2 

2025 

- 

- 

- 

- 

- 

16.8 

16.8 

Source: Ricardo at al. Impact assessment support study  

Costs to authorities: 

SAF supply enforcement and verification at MS and EU level 

2050 

- 

- 

- 

- 

- 

24.2 

23.5 

The  costs  to  authorities  for  the  options  with  a  supplier  mandate  (A1,  A2,  C1  and  C2)  regard  the  cost  of 
enforcing the mandate and the cost of monitoring via administering the information collection at an EU level 
and  reporting  on  its  implementation.  Enforcing  the  mandate  would  be  delegated  to  individual  Member  State 
authorities who would need to verify that suppliers meet their obligation on the individual fuel batches supplied 
by performing inspections to check compliance with the regulation. The FQD evaluation collected information 
from  Member  States  regarding  the  costs  of  inspecting  fuel  suppliers  and  examining  fuel  samples,  something 
that would need to be done by national accreditation bodies. The cost per Member State have been estimated in 
that respect to be between €173,000 and €650,000. For the purposes of this assessment, a central value from 
this range (€411,500) is applied to all MS as a conservative estimate. This leads to annual administrative costs 
of €11.1 million for the whole of the EU27.  

The EU-level collection and reporting of the relevant information would be a task best assigned to a European 
organisation  that  would  compile  the  information  submitted  in  the  Union  Database  into  a  reporting  at  a  fuel 
supplier level. When asking stakeholders about the time they expect such a reporting would require, there has 
been  limited  reported  experience.  France  has  been  the  only  Member  State  to  estimate  the  effort  they  put  in 
monitoring SAF supply to being around 0.5 FTE. A4A has also responded to collect and report on SAF usage 
by their member airlines. This they reported would not take more than a couple of days a year so we assume 
that the effort estimation provided by France would include also other relevant tasks. Since the data stream is 
expected to be digitalised, a level of effort similar to that reported by France (0.5 FTE) would seem reasonable 
to  monitor,  verify  and  report  on  the  implementation  for  the  supply  mandate.  The  labour  cost  for  this 
administrator category is calculated to be approximately €82.000 per year230 leading to an overall estimation of 
administrative cost for the EU-level collection and reporting of information of €41.000 per year. 

SAF demand enforcement and verification at MS and EU level 

When it comes to administering the demand side mandate (Policy Options B1, B2) and the obligatory reporting 
of SAF consumed (Policy Options C1 and C2), Member States would again be assigned to verify the reporting 
and enforce the compliance of air transport service providers with the mandate provisions. For Policy Options 
B1 and B2, this process would similarly to the supply side mandate, require competent authorities to perform 
inspections and take fuel samples to check compliance with the obligation. As the number of regulated entities 
would  be  larger  than  in  the  supply  side  mandate,  a  higher  enforcement  cost  than  what  is  estimated  for  the 

229   Source: https://www.eurocontrol.int/publication/eurocontrol-five-year-forecast-2020-2024 
230   Assuming the average labour costs in Belgium (€ 48.4/hour) for the category of professional, scientific and technical activities (lc_lci_lev)  

107 

 
                                                           
supply side mandate can be expected for Policy Option B1 that is involving both intra- and extra-EU. For this 
Policy Option the high cost estimate of the FQD evaluation is considered (€ 650,000 per Member State). For 
the Policy Option involving only intra-EU flights (B2), a lower estimated effort can be expected to inspect the 
smaller number of regulated airlines/flights and so the central value of the cost range is considered (€411.500 
per MS). While for Policy Options C1 and C2 where Member State enforcement limits to verifying the data 
reported,  this  activity  can  be  expected  to  be  less  burdensome  and  be  closer  to  the  lower  band  of  the 
administrative burden reported by the FQD evaluation (€173.000) 

Monitoring the application of the regulation would be best performed at an EU level assigning the collection of 
this  information to  a  European  organisation to  compile it  at  an  airline  level.  According  to  the  scope  of  each 
Policy  Option,  the  activities  assigned  to  this  EU  agency  would  vary.  Specifically,  under  Policy  Option  B1, 
where the EU agency would be required to i) compile data for SAF usage submitted through the EU ETS for 
intra-EEA  flights,  ii)  compile  data  for  SAF  usage  submitted  under  CORSIA  for  extra-EEA  flights  of  EU 
carriers, and iii) compile date re reported by non-EU carriers related to extra-EEA flights. For the latter, the EU 
would  need  to  build  the  digital  infrastructure  for  non-EEA  airlines  to  report  on  the  SAF  usage  for  extra-EE 
flights. Only the first point of the above is relevant for Policy Options B2, C1 and C2. Drawing a parallel to the 
effort estimated for combining reporting of data submitted via one database for the supply side mandate, Policy 
Options  B2,  C1  and  C2  are  expected  to  produce  a  similar  administrative  burden  to  that  of  POs  A1  and  A2 
(€41.000 per year) while the combination of data from three different data streams can be expected to cause a 
proportionally higher effort under PO B1 (€123.000 per year) 

Jet fuel uplift obligation  

The verification of this obligation (under Policy Options C1 and C2) would, similar to the previous, better take 
place  at  an  EU  level  by  a  relevant  appointed  agency.  The  verification  of  relevant  information  would  as 
explained be submitted to this body for intra-EEA flights via the adapted ETS reporting structure and directly 
to the agency via a new reporting stream for extra-EEA flights. For verifying and compiling the  information 
from  the  two  data  streams,  and  accounting  for  the  fact  that  this  will  require  reporting  on  a  flight  level,  the 
administrative  burden  estimated  for  compiling  and  verifying  the  submitted  data  can  be  expected  to  be  a  bit 
more  burdensome  than  what  is  expected  for  the  demand  side  reporting  obligation.  Thus,  we  assume  an 
administrative burden of about 1 FTE per year (€82.000 per year) for the EU body assigned with the task.  

A  summary  of  the  administrative  costs  for  authorities  is  provided  in  Error!  Reference  source  not  found. 
while Table 23 provides the Present Value estimation of these costs (in 2015 constant prices) 

Table 22 Annual administrative burden for authorities (in €) 

Present Value 

PO A1 

PO A2 

PO B1 

PO B2 

PO C1 

PO C2 

SAF supply MS enforcement and 
verification – per MS  
SAF supply EU info compilation 

SAF demand MS enforcement and 
verification  
SAF demand enforcement and 
verification at MS and EU level 
Jet fuel uplift obligation - EU level 

€411,500 

€411,500 

€41,000 

€41,000 

- 

- 

- 

- 

€411,500 

€411,500 

€41,000 

€41,000 

- 

- 

€ 650,000 

€411,500 

€173,000 

€173,000 

€123,000 

€41,000 

€41,000 

€41,000 

€82,000 

€82,000 

Source: Ricardo at al. Impact assessment support study  

Table 23 Net Present Value of costs for authorities in 2020-2050 (in € million 2015 constant prices) 

Present Value 

Administrative cost for MS 
authorities 
Administrative cost for EU authorities 

PO A1 

 186  

0.7 

PO A2 

PO B1 

PO B2 

PO C1 

 186 

0.7 

 293 

2.0 

186 

0.7 

264 

2.7 

PO C2 

 264  

2.7 

108 

 
 
 
 
 
 
 
 
Source: Ricardo at al. Impact assessment support study  

Impacts on employment 

Employment  in  air  transport  is  expected  to  keep  growing  until  2050,  but  slightly  less  than  under  the 
baseline scenario. As air transport activity in the EU is projected to keep growing under all options between 
2030 and 2050, direct employment from air transport will follow the same trend. While a total of 408,000 jobs 
were directly provided by the aviation sector in 2019, all POs show very similar results, i.e. a gain of around 
62,400 jobs by 2030, or an increase by around 15%. This increase is however lower than under the baseline 
scenario,  where  72,000  jobs  would  be  created  from  2019  to  2030.  Finally,  comparing  the  situation  between 
2030 and 2050, all POs show an increase of direct jobs of around 26%, except for PO B2 where the impact is 
estimate  at  around  29%.  All  POs  mean  slightly  lower  job  creation  between  2030  and  2050  compared  to  the 
baseline,  which  foresees  around  31%  increase.  Aviation  creates  around  three  times  as  many  indirect  jobs  as 
direct jobs. Therefore, the amount of indirect jobs created under all POs is expected to follow the same trend as 
for direct jobs, also with slightly lower job creation than in the baseline scenario. It is worth noting that under 
POs A2 and C2, slightly higher levels of job creation are achieved, compared to POs A1, B1 and C1. This is 
explained  by  the  fact  that  the  level  of  passenger  air  transport  activity  is  marginally  higher  over  time  in  the 
former set of options. 

The SAF industry is expected to be a significant source of job creation in the EU by 2030 and 2050. With 
the increased SAF production and the fact that the majority of the SAF used are projected to be produced in the 
EU,  all  POs  are  expected  to  lead  to  job  gains.  Under  all  POs,  the  SAF  industry  provides  more  than  17,600 
additional jobs by 2030 compared to the baseline scenario, except for PO B2 where an additional 5,300 jobs are 
created.  By  2050,  under  all  POs,  the  SAF  industry  could  be  responsible  for  providing  as  high  as  248,100 
additional jobs compared to the baseline scenario, and around 79,700 under PO B2. 

109 

 
 
 
Annex 5: Policy measures 

A  broad  list  of  policy  measures  has  been  developed  based  in  particular  on:  (i)  Original  ideas  on  options 
included in the Commission’s Inception Impact Assessment (IIA); (ii) Targeted stakeholder consultations that 
enabled stakeholders to present their views (details on stakeholder consultation are included in Annex 2)231; (iii) 
the  European  Green  Deal  and  Smart  and  Sustainable  Mobility  Strategy  Communications;  (iv)  independent 
support study developed by the external consultant. 

POLICY MEASURES 

Obligation to supply SAF-blended jet fuel. This measure imposes on fuel suppliers an obligation to supply 
SAF-blended jet fuel at EU airports with a view to reaching a determined target, expressed either in terms of 
SAF ratio with respect to total jet fuel supply, or in terms of total jet fuel GHG intensity reduction. This target 
increases  over  time  from  2025  to  2050,  in  line  with  the  expected  trajectory  of  the  SAF  market  ramp  up 
according  to  the  2030  Climate  Target  Plan.  The  obligation  can  require  suppliers  to  achieve  the  target  by 
physically  supplying  SAF-blended  jet  fuel  at  each  individual  airport  (some  airports  may  be  exempted),  or 
alternatively, with the flexibility to achieve the target on average over their total jet fuel supply (at least during 
a transition period).  

Obligation to use SAF-blended jet fuel. This measure consists of imposing on airlines an obligation to use a 
share  of  SAF (expressed  in  volumes),  increasing  over  time  with  respect to  their  total jet  fuel use. The  target 
increases  over  time  from  2025  to  2050,  in  line  with  the  expected  trajectory  of  the  SAF  market  ramp  up 
according to the 2030 Climate Target Plan (see section 5.4.3). The scope of the obligation can cover either jet 
fuel  used  for  all  flights  departing  from  EU  airports  (all  airlines  are  covered  regardless  of  their  country  of 
registration), or it can cover jet fuel used for flights between EU airports (mainly EU airlines are covered).  

Obligation to  uplift  jet fuel. This  measure  aims  to  prevent  fuel tankering.  It  consists  of  obliging  airlines  to 
refuel before departure at every EU airport, with a, amount of jet fuel corresponding to that necessary to operate 
the  next  flight  (e.g.  between  90%  and  110%  of  the  fuel  necessary  to  operate  the  next  flight  –  fuels  safety 
margins being respected).  This prevents airlines from carrying excessive amounts of jet fuel from one airport 
to  another  with  the  aim  to  avoid  higher  fuel  costs,  which  leads  to  additional  fuel  burn  and  emissions,  while 
undermining the level playing field between airlines. 

Obligation to report SAF use. Airlines operating intra-EEA flights are required to report their use of SAF as 
per the EU ETS Monitoring and Reporting Regulation (MRR). 

Sub-obligation  on  RFNBOs.  Fuel  suppliers  or  airlines  are  obliged  to  supply  synthetic  fuels  as  part  of  the 
overall  SAF  supply  or  use  obligation,  with  a  view  to  meet  a  gradually  increasing  targets.  This  measure  is 
relevant when the target of the SAF obligation is expressed in terms of SAF volumes. 

Multiplier  on  RFNBOs.  A  multiplier  applies  to  synthetic  fuels,  in  order  to  bridge  the  high  production  cost 
between advanced biofuels and synthetic fuels. 

Transactions of SAF for accounting purposes. This measure is intended to allow the fuel industry to meet the 
supply obligation overall in a more cost effective way possible and/or to allow airlines with no access to SAF at 
airports,  or  wish to  use  more  SAF  than  available,  to  do  so.  Indeed,  while  some  suppliers  may  be  in  a  better 
position  than  others  to  meet  or  even  exceed  the  obligation  (e.g.  large  production  capacities,  mature  supply 
chain, etc.), a mechanism would allow certain suppliers to over-supply, while others would under-supply. This 

231   In  designing  and  assessing  the  Options,  the  Commission  consulted  stakeholders  on  detailed  individual  measures  aimed  at  tackling 

individual aspects of the problems identified in the evaluation.  

110 

 
                                                           
measure  is  only  relevant  where  the  supply  obligation  is  defined  with  the  flexibility  that  not  all  airports  are 
required  to  be  physically  supplied  with  SAF-blended  jet  fuel.  Otherwise,  there  would  be  a  risk  that  certain 
suppliers (under achievers)  supply  lower  levels  of  SAF  or  pure fossil jet  fuel, in  a  context  where  only  SAF-
blended jet fuel must be supplied at all airports. Similarly, airlines operating at airports with no or very reduced 
SAF supply may benefit of this system to fulfil their SAF use obligation.  

Monitoring,  reporting  and  verifying.  Fuel  suppliers  shall  report  SAF  supply  quantity  and  quality 
(characteristics of the SAF supplied) into the Union database. Airlines operating intra-EEA flights report their 
use  of  SAF  (and  characteristics  of  the  SAF  used)  as  per  the  EU  ETS  MRR.  An  EU  Agency  is  required  to 
compile the SAF supply and use report data. An EU Agency is required to provide a yearly consolidated report 
to the Commission. A new reporting stream is created where all airlines report their jet fuel uplift per flight. An 
EU agency is required to verify the reports, detect cases of fuel tankering and report to the Commission on a 
yearly basis. 

Penalties for non-compliance. Obligated parties (i.e. fuel suppliers and/or airlines) are subject to penalties for 
non-compliance  in  case  of  failure  to  meet  their  obligation. The level  of the  penalty  is  harmonised  across the 
single market, determined at EU level, and can be reviewed every year to be adjusted to the developments of 
the  SAF  market  and  evolution  of  fuel  market  prices.  Funds  collected  from  non-compliance  penalties  are 
injected in an EU fund for the development of SAF, e.g. EU ETS Innovation Fund. 

111 

 
 
 
 
Annex 6 - Flanking measures 

Intensify European efforts at ICAO level to raise ambition on SAF use. This non-regulatory measure aims 
to  accelerate  ongoing  work  and  discussions  at  ICAO  level  on  the  role  of  SAF  towards  the  long-term 
decarbonisation  of  aviation.  While  SAF  is  recognised  as  an  important  lever  for  reducing  emissions  of 
international aviation, there is still a high level of reluctance by certain influential ICAO States to commit to 
specific measures for the use of SAF on international routes. Such measures would allow to reduce the risks of 
competitive distortion between EU and non-EU air carriers, as well as to reduce the risks of fuel tankering and 
carbon  leakage.  Furthermore,  European  action  at  ICAO  level  should  ensure  that  the  general  ambition  on  the 
role  of  fuels  as  a  pillar  for  decarbonisation  of  aviation  remains  focused  on  fuels  with  high  sustainability 
potential, not on lower-carbon fossil fuels. 

Steer financial support towards SAF development in the EU. This measure consists of identifying relevant 
funding mechanisms and sources that can be put in place to support increased production and uptake of SAF in 
the EU. In particular in the present crisis context, funding will be particularly necessary to support research and 
development of innovative, sustainable and cost-effective SAF pathways and feedstock supply. It will also be 
relevant to support the development, scaling up and deployment of SAF production capacity and distribution 
infrastructure in the EU. High technology risk and high capital costs related to the not yet commercially SAF 
production pathways, notably from advanced biofuels and RFNBOs, could be supported by innovative financial 
products for the purpose of developing the production up to the commercialise stage. A combination of grants 
with financial instruments such as “contracts for difference” could be interesting to reduce the technology risks 
for investors. 

Funding has an important role to play in developing and upscaling SAF production and deployment. It can take 
different forms and serve different purposes.  

  As highlighted by Problem Driver 1 and Specific Objective 1, research and development is necessary to 
allow  new  innovative,  sustainable  and  cost-effective  pathways  to  emerge  and  reach  the  market. 
Funding R&D, pilot and demonstration projects up to commercialisation can speed the path to maturity 
for  certain  technologies.  It  can  prove  helpful  for  developing  less  mature  technologies  like  advanced 
biofuels and RFNBOs. 

  As  highlighted  in  Problem  Driver  2  and  3,  and  Specific  Objective  1  and  2,  substantial  private  and 
public investments will be necessary in the years and decades to come to reduce the gap between SAF 
prices and conventional jet fuel prices. This can be done by supporting CAPEX and or OPEX costs of 
new  industrial-scale  SAF  production  sites,  at  least  in  the  first  stages  while  the  price  gap  remains  a 
market barrier.  

Aside from private investments, which are expected to play a major role in upscaling SAF production, public 
funding from Member States and the EU budget could be put to contribution in various ways. 

  Funding from specific EU instruments can help to support boosting SAF production and uptake. The 

below instruments would be relevant for this purpose. 

o  Horizon Europe is the European Union’s research framework programme with a budget €100 
billion  for  the  period  2021-2027.  It  is  highly  relevant  to  support  R&D  on  SAF,  as  it  targets 
research projects including on innovative transport and energy with climate dimension.  

o  Connecting Europe Facility (CEF) supports deployment of high performing, sustainable and 
efficiently interconnected trans-European networks in the fields of transport and energy, among 
others  with  a  budget  of  €21.38  billion  for  transport  over  the  period  2021-2027.  CEF  is  very 
relevant to support SAF distribution projects in the EU. 

112 

 
 
o  InvestEU  will  bring  together  the  European  Fund  for  Strategic  Investments  and  thirteen  EU 
financial  instruments  currently  available.  This  will  provide  an  EU  budget  guarantee  of  €75 
billion in support of various investment areas. Of relevance are sustainable infrastructure and 
research,  innovation  and  development  windows  to  support  the  scaling  up  of  production,  and 
also SMEs window  to support the emergence of new players in the SAF supply chain, notably 
for feedstock supply. 

o  NextGenerationEU aims to support public investments for Member States efforts to recover 
from  the  COVID-19  crisis,  with  a  focus  on  recovering  by  accelerating  the  green  transition. 
With  a  €750 billion envelope,  it is  highly  relevant to support the  roll out  of  SAF  production 
capacity  in  Member  States,  notably  via  the  Recovery  and  Resilience  Facility,  based  on  the 
respective national Recovery and Resilience Plans. 

o  Innovation Fund under EU ETS is a €10 billion fund over the period 2020-2030, aiming to 
drive  low-carbon  technologies  to  the  market  with  a  special  focus  on  industrial  sectors  in  the 
scope of EU ETS and renewable energy and carbon capture use (CCU) and storage (CCS). It is 
highly relevant to support demonstration plants for advanced biofuels and RFNBOs.  
  European  industrial  alliances  and  state  aid  schemes  and  could  also  be  highly  relevant  to  providing 

financial support  

o  Important Projects of Common European Interests (IPCEI) can provide significant support 
to  emerging  industries,  if  aligned  with  EU  strategic  objectives.  IPCEIs  (e.g.  batteries, 
microelectronics)  are  largely  bottom-up  initiatives  of  Member  States,  highly  ambitious  on 
research and innovation, supported by private and public investments, including from the EU 
budget. SAF could be highly relevant for the creation of a new IPCEI, with the involvement of 
MS and relevant industrial actors. The creation of a European strategic alliance for SAF (see 
below) would be an excellent opportunity to put in place such an IPCEI.  

Create  a  European  strategic  alliance  for  Renewable  and  Low  Carbon  Fuels.  This  measure  consists  of 
setting up a strategic industrial alliance, with the objective to create a competitive production value chain in the 
EU  with  advanced  biofuels  (Part  A  biofuels)  and  RFNBOs  at  its  core.  To  support  a  smooth  transition  away 
from the dependence on fossil fuel, prevent a new technological dependence on our competitors and capitalise 
on the jobs, growth and investment potential of advanced biofuels and RFNBOs, the EU has to move fast in the 
global race. This alliance would consist of a cooperative platform gathering notably the European Commission, 
interested  EU  countries,  European  financial  institutions,  key  industrial  stakeholders,  and  research  and 
innovation  actors.  It  could  include  in  its  scope  financial  mechanisms  to  boost  the  production  of  SAF  at  EU 
level, such as the establishment of contracts for difference schemes or an IPCEI. 

Facilitate  SAF  certification.  As  described  in  Section  2,  the  certification  of  new  SAF  production  pathways 
performed  by  the  ASTM  International232  or  the  DefStan233  is  a  rigorous  and  lengthy  process  that  involves 
significant financial, time, logistical and human resources (see problem driver 1). In the US, the FAA has set up 
a dedicated “Clearing House” that accompanies fuel producers in their process of obtaining ASTM approval for 
their  product.  Support  could  also  be  provided  to  SAF  producers  in  the  EU  in  a  similar  way.  It  could  take 
different  forms.  Either,  it  could  consists  of  increased  European  cooperation  with  the  existing  US  Clearing 
House  and  e.g.  appointing  an  EU  representative.  The  EU  representative  would  act  as  a  contact  point  and 
provide support to EU SAF producers. On the other side of the spectrum, the EU could decide to establish its 
own EU Clearing House, by replicating the US undertaking.  

232   Source: https://www.astm.org/ 
233   UK Defence Standardization - https://www.gov.uk/guidance/uk-defence-standardization 

113 

 
 
 
                                                           
114 

 
 
 
Annex 7 - Differences between policy options 

This section provides additional elements to those already referenced in section 5.5 of this document. 

1.  DIFFERENCES IN THE SUPPLY OBLIGATION 

Under  policy  options  A1  and  A2,  fuel  suppliers  distributing  jet  fuel  at  EU  airports  are  required  to  supply  a 
minimum  level  of  SAF-blended  jet  fuel  to  airlines  at  all  EU  airports.  This  means  that  every  litre  of  jet  fuel 
supplied  and  available  at  EU  airports  will  contain  at  least  a  minimum  percentage  of  SAF.  This  obligation 
applies to all jet fuel delivered in the EU. Certain categories of airports, such as remote or insular airports may 
request to be exempted. Airlines (regardless of their origin or destination) have no alternative than to use the 
SAF-blended jet fuel as the only jet fuel available when refuelling at EU airports. 

Under policy options B1 and B2, there is no direct obligation on fuel suppliers. 

Under  policy  options  C1  and  C2,  fuel  suppliers  are  obliged  to  supply  physically  a  minimum  share  of  SAF 
(expressed in volumes) at all EU airports at all times, post-2035 (following a transition period). This means that 
every litre of jet fuel supplied to airports must be blended with at least a minimum share of SAF. Airlines (EU 
and non-EU) operating on intra-EU and extra-EU routes taking off from airports located on EU territory have 
no alternative than to use SAF-blended jet fuel. This minimum share of SAF to be supplied corresponds to the 
trajectory  of  the  SAF  market  ramp  up  according  to  the  impact  assessment  accompanying  the  2030  Climate 
Target Plan and is the same as in PO A1 and PO B1.  

In order to allow for a more cost-effective SAF supply in the first years of the supply obligation, a two-stage 
transition period applies from 2025 to 2035.  

  From  2025  to  2030,  fuel  suppliers  are  required  to  meet  the  ramp  up  target  and  can  supply  EU 
airports with jet fuel containing SAF in the range 0% - 50% (which corresponds to the maximum 
limit for certified SAF blends). This means that fuel suppliers are not required to distribute SAF at 
all  airports,  as  long  as  the  overall  ramp  up  target  is  achieved.  Fuel  suppliers  are  nevertheless 
required to individually meet the target, i.e. the SAF ramp up. 

  From 2030 to 2035, fuel suppliers are required to meet the ramp up target (i.e. 5% in 2030 and 20% 
in 2035) but must all supply EU airports with jet fuel containing SAF in the range 2% - 50%. This 
means that every litre of jet fuel supplied to all airports must be blended with at least 2%234 of SAF. 
Fuel suppliers are required to supply overall 0.7% of RFNBOs from 2030, and every litre of jet fuel 
supplied at airports must contain RFNBOs in the range 0.3%235 - 50%. 

2.  DIFFERENCES IN THE DEMAND OBLIGATION (AND UPLIFT OBLIGATION) 

Under policy options A1 and A2, there is no legal obligation on airlines to use SAF-blended jet fuel.  

Under policy option B1, airlines are required to use a certain level of SAF-blended jet fuel with respect to their 
total jet fuel consumption on all intra-EU and extra-EU flights departing from EU airports. As certain airlines 
may not have physical access to SAF-blended jet fuel at their destination airports, a system of SAF transaction 
(for  accounting  purposes)  allows  airlines  to  secure  the  purchase  of  SAF  volumes  in  order  to  meet  their 
obligation.  

234   The choice of 2% as a minimum of SAF to be supplied at all airports was retained as it is a reasonable, attainable target by 2030. It allows 
all suppliers to smoothly transition to a system where all airports must be supplied with SAF-blended jet fuel, and gradually develop their 
supply chain for this purpose.  

235   The choice of 0.3% for RFNBOs follows the same logic. The ratio is the same between 0.3% and 0.7%, as it is between 2% and 5%. 

115 

 
 
                                                           
Under policy options B2, the same obligation applies but it concerns only air traffic operating intra-EU flights.  

C1 and C2 do not have a SAF obligation, but rather a jet fuel uplift obligation. 

3.  TARGET SETTING: VOLUME OR CO2 INTENSITY REDUCTION 

Under policy options A1, B1, B2 and C1, economic operators subject to the obligation (fuel suppliers and/or 
airlines) are required to supply/use at least minimum share of SAF, expressed as a volume percentage of the 
relevant total jet fuel supply/use, over the course of a reporting period of one year. All volumes of SAF that are 
compliant  with  the  sustainability  requirements  (see  section  5.3.1)  are  treated  equally,  and  can  contribute 
towards meeting the obligation in the same way. This approach encourages suppliers/airlines to supply/use SAF 
in terms of absolute quantity. It is currently the approach used under RED II236 and to some extent under the EU 
ETS for aviation. 

Under policy options A2 and C2, economic operators subject to the obligation (fuel suppliers and/or airlines) 
are required to supply/use jet fuel that achieves a minimum CO2 intensity reduction compared to a baseline for 
fossil fuel over the course of a reporting period of a year.  

4.  INCENTIVES FOR RFNBOS: SUB-MANDATE OR MULTIPLIER 

When the obligation is volume-based, i.e. under policy options A1, B1, B2 and C1, RFNBOs are subject to a 
gradually  increasing  sub-mandate  as  of  2030.  This  means  that  economic  operators  subject  to  the  obligation 
(fuel suppliers and/or airlines) are required to supply/use a minimum volume share of RFNBOs in order to meet 
their  obligation.  The  sub-mandate  on  RFNBOs  is  justified  by  the  high  potential  of  this  fuel  technology  to 
deliver important climate benefits, their high production costs, and the need for a swift scale up of production 
capacity. 

When  the  obligation  is  CO2  intensity  reduction-based,  i.e.  under  policy  options  A2  and  C2,  RFNBOs  are 
subject to a multiplier. Its value is 1.6 and 1.2 respectively in 2030 and 2040. From 2045, its value is 1. This 
means  that  RFNBOs can  count “more” towards the CO2  intensity  reduction target, than  other  types  of  SAF. 
Such  multipliers  are  traditionally  used  to  make  a  specific  technology  more  attractive  to  economic  operators 
because  it  has  high  potential  to  deliver  the  expected  policy  objectives.  In  the  present  case,  RFNBOs  are 
expected  to  play  a  key  role  as  of  2030  in  delivering  on  EU’s  climate  objectives  for  aviation,  but  market 
penetration is hampered by high prices and lower industrial maturity compared to other types of SAF, and even 
higher  prices  compared  to  conventional  jet  fuel.  Hence,  the  proposed  multiplier  is  expected  to  contribute 
bridging the price gap with advanced biofuels and increase RFNBOs economic attractiveness on the market. 

236  Although  when  transposing  RED  II  into  national  legislation,  member  States  have  the  possibility  to  use  a  GHG  intensity  reduction  based 

target. 

116 

 
 
 
 
                                                           
Criteria 
Sustainability 

Market 
readiness 

Feedstock or 
resources 
availability 

Costs 

Criteria 
Sustainability 

Market 
readiness 

Feedstock or 
resources 
availability 

Costs 

Annex 8 – Criteria for policy choice on SAF 

Advanced Biofuels 
Very high potential. 
Emissions savings can 
reach e.g. 94% when 
using forestry residues, 
91% when using bio-
waste. 
No ILUC 
At the stage of 
commercial pilots 

High potential 
availability of feedstock 
e.g. bio-waste, 
agricultural and forestry 
residues. Potential 
competition with 
maritime. 
Production costs are 
currently around 2-4 
times the price of fossil 
jet fuel237 

Crop based fuels 
Low potential. Resource 
intensive. Accountable 
for ILUC. 
Mature and available at 
commercial scale for the 
road transport sector 

Availability of crop 
based feedstock is 
constrained by the used 
of land. 
Production costs are 
around 2 times the price 
of fossil jet fuel240 

Part B Biofuels 
High potential. 
Emissions savings can 
reach e.g. 85% when 
using used cooking oil 
or 76% when using 
tallow. No ILUC 

RFNBOs 
Very high potential. 
Emissions savings can 
reach 100% when 
CO2 is captured 
directly from the air. 
No ILUC 

Already mature and 
available at commercial 
scale for road transport. 
Limited availability of 
used cooking oil and 
tallow. Strong 
competition with road 
transport sector.  

Production costs are 
currently around twice 
the price of fossil jet 
fuel238  

In development 

Growing share of 
renewable electricity 
in the EU energy mix 
towards 2050. Source 
of CO2 is potentially 
unlimited with direct 
air capture. 
Production costs are 
currently around 3-6 
times the price of 
fossil jet fuel239 

Green hydrogen 
Very high potential. 

Green electricity 
Very high potential 

Research stage. 
Expected to play a role 
in commercial aviation 
by 2040 
Very limited availability 
for aviation by 2050. 

Research stage. 
Expected to play a role 
in commercial aviation 
by 2040 
Very limited 
availability for aviation 
by 2050. 

No reliable information  No reliable information 

237   ICCT – The cost of supporting alternative jet fuels in the EU. 
238   Ibid. 
239   Ibid. 
240   Ibid.  

117 

 
 
 
 
 
                                                           
Regarding sustainability, all three SAF categories have high to very high sustainability potential. For instance, 
Part B biofuels produced through the HEFA pathway with used cooking oil and advanced biofuels produced 
with  bio-waste  can  achieve  respectively  85%  and  91%  emissions  savings  compared  to  conventional  jet  fuel. 
RFNBOs can achieve as high as 85% emissions savings compared to conventional jet fuel. Whereas hydrogen 
and  electricity  are  equally  expected  to  have  high  sustainability  potential,  the  sustainability  of  crop  based 
biofuels is undermined by indirect land use chance effects, which tend to increase their life cycle emissions241.  

Regarding  market  readiness,  SAF  are  drop-in  fuels  and  compatible  with  existing  aircraft  engines  and  fuel 
supply infrastructure. Being either already commercially mature or at pilot stage, SAF can be deployed already 
in the short to medium term, i.e. by 2025 (advanced and Part B biofuels) or 2030 at the latest (RFNBOs). This 
is  not  the  case  of  hydrogen  fuel  cells  and  electric  batteries,  both  of  which  require  major  changes  of  aircraft 
engine design and technology, and are expected to become a meaningful market reality in commercial aviation 
at the earliest by 2040.  

Regarding feedstock availability, Part B feedstock (waste lipids) availability is expected to remain limited in 
the  future,  advanced  biofuels  feedstock  is  expected  to  be  abundant  in  the  years  and  decades  to  come242. 
RFNBOs will also benefit from an expected increase of renewable electricity in the EU power generation mix 
by 2030 and 2050243.  

Regarding production costs, for SAF these vary from 2-6 times that of conventional jet fuel depending on the 
production  route  and  the  feedstock  used.  However,  SAF  production  costs  are  expected  to  decrease  as  the 
market  becomes  more  established  over  the  years.  As  regards  electricity  and  hydrogen,  at  present  there  is  no 
reliable information available on the expected cost impact for airlines. Crop based biofuels production costs are 
usually estimated at around twice that of conventional jet fuel.  

Finally, regarding regulatory fitness, while advanced biofuels and RFNBOs are promoted under RED II, Part 
B biofuels are subject to a cap244. Crop based biofuels are also subject to a cap245, and in case of high indirect 
land-use change-risk, are due to be phased out by 2030.  

241   See Part A of Annex VIII of the recast Renewable Energy Directive. 
242   World Economic Forum – Cleans Skies for Tomorrow feasibility study. 
243   2030 Climate Target Plans MIX scenario. 
244   Under the recast Renewable Energy Directive Art 27(1b), biofuels produced from feedstock listed in Part B of Annex IX cannot contribute 

towards the overall renewable energy target in transport for more than 1,7%. 

245   The share of biofuels and bioliquids, as well as of biomass fuels consumed in transport, where produced from food and feed crops, shall be 
no  more  than  one  percentage  point  higher  than  the  share  of  such  fuels  in  the  final consumption  of  energy  in  the  road  and  rail  transport 
sectors in 2020 in that Member State, with a maximum of 7 % of final consumption of energy in the road and rail transport sectors in that 
Member State. 

118 

 
                                                           
119 

 
Annex 9 – Monitoring, Reporting, Verification 

Monitoring,  reporting  and  verification  (MRV)  is  an  essential  part  of  ensuring  that  the  regulatory  framework 
functions  properly,  that  economic  operators  fulfil  their  obligations,  to  detect  and  avoid  fraud,  and  to  track 
indicators  on  the  success  of  the  policy  objectives.  It  is  essential  that  each  of  the  policy  options  under 
consideration  cater  for  a  robust  MRV  system  on  the  fuel  supply  side  and  on  the  airlines’  fuel  use  side.  The 
existing  EU  regulatory  framework  already  contains  MRV  systems  on  both  sides,  under  the  RED  II  (supply 
side)  and  the  EU  ETS  (fuel  users’  side).  The  following  table  explains  for  each  policy  option  how  the 
monitoring, reporting and verification of the SAF flows across the EU would function. 

All  POs  require  an  existing  EU  agency  (e.g.  EASA)  or  European  organisation  (e.g.  Eurocontrol)  to  perform 
data processing and to report to the Commission on the fulfilment of stakeholders’ obligations. EASA could be 
well  suited  to  be  responsible  for  MRV  purposes  in  connection  with  the  SAF  supply  side  and  the  Union 
Database  established  under  RED  II,  as  EASA  has  performed  in  2019  extensive  work246  on  possible  ways  to 
improve SAF monitoring in the EU. Eurocontrol could be well suited to be responsible for MRV purposes in 
connection with the demand side, as being involved already in the MRV of the EU ETS. 

Option 
A1 

Obligation247 
Suppliers must supply 
minimum % of SAF-
blended fuel at all 
airports 

Suppliers must report 
supply into Union database. 
(art 28(2)RED) 

Reporting 

Verifying 

No obligation on 
airlines 

Airlines report SAF use 
under ETS (art 14) with 
proof of jet fuel purchase 
and SAF sustainability 
certificate 

A2 

Suppliers must supply 
SAF to all airports  to 
decrease jet fuel CO2 
intensity by % 

Suppliers must report 
supply into Union database 
(art 28(2)) in terms of CO2 
intensity reduction  

Member States 
enforcement. 
SCS verify compliance 
with sustainability (art 
28(4) RED). 
Suppliers must arrange 
for auditing and prove it 
(art 30(3) RED). 
Member States ensure 
that emission reports 
(AERs) are verified (art 
15, ETS) 

Member States 
enforcement. 
SCS verify compliance 
with sustainability (art 
28(4)). 
Suppliers must arrange 
for auditing and prove it 
(art 30(3)). 
Member States ensure 
that emission reports are 
verified (art 15, ETS) 

Monitoring 
Existing EU agency (e.g. 
EASA) must have access 
to Union database and 
compile data on fuel 
supply 

Airlines monitor their jet 
fuel use (art 14(3), ETS) 
MS must transmit AERs 
to existing EU agency 
(e.g. Eurocontrol) for to 
compile data on fuel use 
Existing EU agency (e.g. 
EASA) must have access 
to Union database and 
compile data on fuel 
supply 

Airlines monitor jet fuel 
use (art 14(3)) 
MS must transmit AERs 
to existing EU agency 
(e.g. Eurocontrol) for to 
compile data on fuel use 
Monitoring by the 

No obligation on 
airlines 

B1 

No obligation on fuel 

Airlines report SAF use as 
per normal procedure under 
ETS (art 14(3)) with proof 
of jet fuel purchase and 
SAF sustainability 
certificate 
Suppliers report supply into  Member States 

246   Sustainable Aviation Fuel ‘Monitoring System’ – EASA - 2019 
247  The  terminology  and  presentation  of  the  policy  options  in  this  column  are  simplified.  Section  5  of  this  document  provides  the  accurate 

description of the policy options.   

120 

 
 
 
 
 
 
                                                           
suppliers 

Union database (art 28(2)) 

Airlines must use 
minimum % SAF-
blended jet fuel 
overall intra-EEA 
consumption 

B2 

No obligation on fuel 
suppliers 

Intra-EEA flights; Airlines 
shall report SAF use as per 
normal procedure under 
ETS (art 14(3))  

Extra-EEA flights: airlines 
report SAF use as part of 
CORSIA MRV system, as 
established under ICAO 
SARPs Annex 16 Volume 
IV, Chapter 2. 
Suppliers report supply into 
Union database (art 28(2)) 

Airlines must use 
minimum % SAF-
blended jet fuel 
overall total 
consumption on intra-
EU routes 
Suppliers must supply 
minimum % of SAF-
blended fuel at all 
airports (with 
transition period) 

Airlines report SAF use on 
intra-EU routesunder ETS 
(art 14(3))  

Suppliers must report 
supply into Union database 
(art 28(2)) 

C1 

Airlines must take up 
jet fuel for next flight 
at EU airports 

New reporting system 
requiring all airlines to 
report fuel use per flight  

Airlines must report 
SAF use on intra-EEA 
flights 

C2 

Suppliers must supply 
SAF to all airports to 
decrease jet fuel CO2 
intensity by % 

Airlines report SAF use  as 
per normal procedure under 
ETS (art 14(3))  with proof 
of jet fuel purchase and 
SAF sustainability 
certificate 
Suppliers must report 
supply into Union database 
(art 28(2)) in terms of CO2 
intensity reduction 

Commission (Art 33) 

Airlines monitor jet fuel 
use (art 14(3)) 
MS must transmit AERs 
to EU agency for to 
compile data on fuel use 
EU agency must compile 
data on SAF use 

Monitoring by the 
Commission (Art 33) 

Airlines monitor jet fuel 
use (art 14(3)) 
Existing EU agency must 
have access to Union 
database an compile data 
on fuel supply 
Monitoring by the 
Commission (Art 33) 
Existing EU agency must 
have access to Union 
database an compile data 
on fuel supply 

EU agency must compile 
data on fuel use and 
report to Commission any 
cases of tankering 
Airlines shall monitor jet 
fuel use (ETS art 14(3)) 
EU agency must compile 
data from ETS on fuel 
use 

Existing EU agency 
(e.g.EASA) must have 
access to Union database 
and compile data on fuel 
supply 

enforcement. 
SCS verify compliance 
with sustainability (art 
28(4)). 
Suppliers must arrange 
for auditing and prove it 
(art 30(3)). 
Member States ensure 
that emission reports are 
verified (art 15, ETS) 

CORSIA rules require 
that aeroplane operators 
emission reports be 
verified by accredited 
bodies. 

Member States 
enforcement. 
SCS verify compliance 
with sustainability (art 
28(4)). 
Suppliers must arrange 
for auditing and prove it 
(art 30(3)). 
Member States ensure 
that emission reports are 
verified (art 15, ETS) 

Member States 
enforcement. 
SCS verify compliance 
with sustainability (art 
28(4)). 
Suppliers must arrange 
for auditing and prove it 
(art 30(3)). 
Existing EU agency (e.g. 
Eurocontrol) verifies data 
submitted by airlines 

Member States ensure 
that emissions reports are 
verified (ETS art 15) 

Member States 
enforcement. 
SCS verify compliance 
with sustainability (art 
28(4)). 
Suppliers must arrange 
for auditing and prove it 
(art 30(3)). 

121 

 
 
 
 
Airline must take up 
fuel for next flight at 
EU airports 

New reporting system 
requiring all airlines to 
report fuel use per flight  

Existing EU agency (e.g. 
Eurocontrol) verifies data 
submitted by airlines 

Airlines must report 
SAF use on intra-EEA 
flights 

Airlines report SAF use 
under ETS (art 14(3)) 

Member States ensure 
that reports are verified 
(ETS art 15) 

Existing EU agency (e.g. 
Eurocontrol) must 
compile data on fuel use 
and report to Commission 
any cases of tankering 
Airlines monitor jet fuel 
use (ETS art 14(3)) 
Existing EU agency (e.g. 
Eurocontrol) must 
compile data from ETS 
on fuel use 

122 

 
 
 
Annex 10 – Interaction with ongoing revisions 

Renewable Energy Directive 

The  ReFuelEU  Aviation  initiative  sets  out  the  objective  to  increase  the  supply  and  uptake  of  sustainable 
aviation fuels (SAF) at EU level in the aviation market. This objective converges with that of the Renewable 
Energy  Directive  (RED)  framework,  which  is  –  among  others,  to  increase  the  share  of  renewable  energy  in 
transport. The following section explains how the ReFuelEU Aviation SAF obligation and the RED framework 
(currently under revision) would interact, complement and mutually support each other in several areas.  

Sustainability framework 

The  ReFuelEU  Aviation  initiative  relies  on  the  sustainability  framework  of  RED  2.  This  means  that  SAF 
qualifying to meet the obligation under all POs would be eligible if they meet the sustainability criteria defined 
under  RED  2.  This  is  essential  to  maintain  uniformity  in  the  EU  regulatory  framework  and  importantly,  to 
provide  the  fuels  industry  with  clear  and  consistent  rules  for  all  transport  biofuels.  Should  the  RED  2 
sustainability criteria be revised, the revision would be also carried over and apply to the rules set out under the 
ReFuelEU Aviation initiative. The same applies as regards the definition of the types of SAF eligible. Should 
definitions of ‘biofuels’, ‘advanced biofuels’ or RFNBOs  be revised, or should the types of feedstock listed in 
Annex IX Part A or B be revised, this revision would de facto be carried over to apply equally under the SAF 
obligation.  This  can  be  achieved  easily  in  the  ReFuelEU  Aviation  legislative  proposal  by  making  a  cross 
reference to the relevant provisions of the RED rules.  It should be noted that there would be strong  merit in 
aligning  the  RED  sustainability  criteria  for  biofuels  as  close  as  possible  to  those  of  CORSIA.  This  would 
provide  more  clarity  to  the  SAF  and  aviation  markets  and  support  SAF  uptake  by  all  airlines  on  intra-  and 
extra-EU flights. 

Monitoring, reporting and verification 

The  RED  framework  establishes  clear  provisions  for  the  monitoring,  reporting  and  verification  of  renewable 
fuel supply. The POs proposed under ReFuelEU Aviation rely to a very large extent on this existing system. 
Indeed,  through  cross  references  to  the  relevant  provisions  of  RED  2  (e.g.  Art  28),  the  legislative  proposal 
would ensure SAF are treated in the same way as other transport  biofuels. The objective is to avoid creating 
parallel  reporting  schemes  that  would  add  layers  of  administrative  burden  and  increase  risks  of 
misreporting/accounting. In particular, the use of the Union Database (established under RED 2) should be the 
support for SAF suppliers to report the relevant data. This includes information on the transactions made and 
the sustainability characteristics of SAF, including their life-cycle greenhouse gas emissions starting from their 
point of production to the fuel supplier that places that fuel on the market. The information submitted by fuel 
suppliers  should  be  verified  under  the  authority  of  Member  States  as  per  RED  2  requirements.  As  the 
ReFuelEU  Aviation  obligation  is  imposed  directly  on  the  fuel  suppliers,  it  is  necessary  that  an  EU  agency 
compiles the information provided in the Database at fuel suppliers-level, and reports to the Commission on the 
fulfilment of the obligation by each regulated entity.  

Fuel supply obligations 

RED  sets  out  an  overarching  renewable  energy  obligation  with  a  target  that  is  set  as  a  share  of  renewable 
energy in road and the rail sectors, but is aiming to support renewable to some extent also in the aviation and 
maritime  sector.  It  does  not  contain  an  aviation-specific  obligation,  but  contains  a  multiplier  of  1.2  on  the 
contribution  of  aviation  biofuels  to  the  overarching  target,  although  much  smaller  than  the  multiplier  of  the 
road sector (4). The introduction of an aviation-specific target under the ReFuelEU aviation initiative does not 
contradict the overall objectives of the RED. On the contrary, it complements the RED framework by targeting 

123 

 
 
specifically  a  sector  which  can  currently  only  use  a  very  limited  range  of  renewable  energies  and  whose 
decarbonisation poses specific challenges. It thereby contributes to increasing the share of renewable energy in 
transport. With an aviation-specific target introduced under ReFuelEU Aviation, it would be possible, but not 
necessary to revise the design of the overarching RED target. Indeed, in the absence of change, Member States 
would be able to account for the supply of SAF to the aviation market on their territory towards meeting their 
national target for renewable energy in transport. All POs, including POs C1 and C2, foresee a rather uniform 
share  of  SAF  to  be  supplied  across  all  Member  States.  The  decisions  taken  under  the  ReFuelEU  Aviation 
initiatives would have to be taken into account in the approach taken to support renewable and low carbon fuels 
under the RED, which will be subject to a revision. 

Incentives for fuel technologies 

The RED 2 framework supports various fuel technologies in different ways. It is important that the ReFuelEU 
Aviation initiative takes a coherent approach towards those fuel. 

  Conventional biofuels: RED 2 recognises the eligibility of such fuels (food and feed crop-based fuels) 
to  meet  the  renewable  energy  target  but  their  contribution  to  the  target  is  capped  to  7%  of  final 
consumption of energy in the road and rail transport sectors in that Member State and does not apply 
the  1.2  multiplier  to  such  fuels  if  consumed  in  the  aviation  sector.  Further,  the  contribution  to  the 
target  of  such  fuels  that  have  high  ILUC  risk  is  phased  out  by  2030.  In  coherence  with  the  RED  2 
approach, the ReFuelEU Aviation initiative does not make eligible biofuels produced from food and 
feed crops. 

  Part A ‘advanced’ biofuels: RED 2 supports the production and supply of such fuels, notably with 
sub-mandates of 0,2 % in 2022, at least 1 % in 2025 and at least 3,5 % in 2030. A multiplier of 2 also 
applies to the supply of all such fuels. ReFuelEU Aviation supports such fuels, which are expected to 
make an important contribution to the aviation fuel mix under all POs. The high SAF obligation targets 
under  ReFuelEU  Aviation  send  a  policy  signal  to  the  market  that  a  major  scale  up  of  these  fuels  is 
necessary.  The  incentives  under  RED  2  are  expected  to  further  reinforce  this  signal.  A  dedicated 
submandate for Part A biofuels under ReFuelEU Aviation could provide further assurance that their 
deployment is necessary in aviation.  

  Part B biofuels: RED 2 supports such fuels with a multiplier of 2. However, their contribution to the 
renewable  energy  target  is  capped  at  1.7%  of  the  energy  content  of  transport  fuels  supplied  for 
consumption or use on the market. ReFuelEU Aviation support the use of such fuels, but they are not 
subject to any specific incentive. Their role is expected to be limited from 2025 to 2050. As such fuels 
are currently used almost exclusively in the road transport sector, it is not excluded that there would be 
a  shift  of  Part  B  biofuels  from  road  to  aviation.  However,  this  potential  shift  would  be  of  small 
magnitude, as explained under section 6.1.2. 

  RFNBOs: these fuels are supported under RED 2. However, work is ongoing through the preparation 
of  a  Delegated  Act  to  further  define  the  conditions  of  their  eligibility,  notably  when  it  comes  to 
technical aspects on the accounting of the renewable electricity used for their production. ReFuelEU 
Aviation  supports  such  fuels  with  a  specific  sub-mandate  under  POs  A1,  B1,  C1,  and  a  multiplier 
under  POs  A2  and  C2  and  will  apply  the same  conditions  as  set  out  under  RED  II  and  the  relevant 
delegated acts. Specific incentives are necessary to bring them to the market earlier than expected in 
the absence of regulatory action (emergence by 2050 in the baseline scenario). 

EU Emissions Trading System 

The EU ETS contains provisions aiming to encourage SAF uptake by airlines, i.e. the “zero emissions-rating” 
of  aviation  biofuels.  As  explained  under  section  2.2,  the  mix  of  incentives  to  increase  the  uptake  of  SAF, 
among which the EU ETS, has not successfully led to an increase in the use of SAF, the main reason being that 

124 

 
the price of greenhouse gas emission allowances has remained significantly lower than what would have been 
necessary to make up for the additional the price of SAF. The EU ETS is under revision and the Commission is 
due to adopt legislative proposals by June 2021 to revise it. The revision of the general EU ETS Directive is 
likely to include and increase the linear emission reduction factor, in line with the adoption of the climate target 
for 2030, which is updated to reductions of 55% in comparison to 1990 levels. Additionally, the proposal for a 
revision of the EU ETS for Aviation, also due for June 2021, is likely to include a reduction in the share of 
allowances distributed for free and measures to implement additional elements of CORSIA in Union law.  

Even if the EU ETS is unable to by itself trigger the uptake of SAF, it can still contribute to lowering the costs 
of the options under consideration in this impact assessment.  The “zero emissions-rating” of aviation biofuels 
can help airlines recuperate part of the additional cost. A second way is through the ETS allowance purchases 
that  airlines  have  done  over  the  years248  which  to  a  large  extent  have  helped  funding  the  conversion  from 
generation of fossil fuel-based power to renewable electricity thus both increasing the availability of renewable 
electricity for the production of electro-fuels and reducing its cost. A third potential way is through the ETS 
Innovation Fund that could help finance innovative and less costly SAF pathways. In this regard, the EU ETS 
(and likely also its upcoming revision) can be considered complementary to all the options under consideration. 

This measure has the potential to help reducing the price gap between SAF and conventional jet fuel as SAF are 
considered CO2 emission free under the EU ETS, thus providing an economic benefit for airlines, which are 
covered by EU ETS (currently only in respect of their intra-EEA flights). The EU ETS could serve to create the 
necessary  medium-  to  long-term  carbon  price  signal  with  the  aim  to  drive  further  decarbonisation. 
Strengthening the EU ETS is likely to include a decrease of quantities of free allocation to the aviation sector as 
well as steepening the linear reduction factor that defines the annual reduction of the cap beyond the current 
factor of 2.2%. This measure is currently being considered under the revision of the EU ETS. However, it is not 
a SAF specific measure and is unlikely to provide by itself the economic incentive for airlines to purchase SAF. 
In  the  context  of the increase  of  ambition  for  emissions  reductions  for  2030,  the  price  of  ETS  allowances  is 
expected to grow, further pushing operators to find ways to reduce emissions. 

As made clear above, the EU ETS on its own is not sufficient to drive SAF to the aviation market. The global 
market-based measure CORSIA will generate offsetting requirements from 2025, and it is not clear that it will 
constitute a meaningful driver for the uptake of SAF. The price of eligible offset units is likely to remain lower 
than  that  of  ETS  allowances.  Therefore,  similarly  as  for  the  EU  ETS,  it  is  not  expected  to  be  sufficient,  by 
itself, to drive SAF to the aviation market. 

 Revision of the Fuels Quality Directive 

The  Fuels  Quality  Directive  (FQD)  is  a  regulatory  framework  setting  quality  standards  for  fuels  (including 
biofuels) used in the road transport sector and in non-road mobile machinery. Aviation is not included in the 
scope of the FQD. The Commission services are currently working jointly on the revision of Article 7 of the 
FQD, which revised provisions will be included in the revision of the RED II framework, due for a legislative 
proposal by June 2021.  

Alternative Fuels Infrastructure Directive (AFID) 

This AFID creates a common framework of measures for the deployment of alternative fuels infrastructure in 
the EU. Building-up such infrastructure is meant to reduce oil dependence and mitigate environmental impacts 
specifically  of  road  and  waterborne  transport.  It  should  support  a  single  market  for  alternative  fuels 

248   Reaching 

over 

tonnes 
(https://ec.europa.eu/transport/sites/transport/files/2019-aviation-environmental-report.pdf)  and  32,5  million  allowances 
(https://ec.europa.eu/clima/news/emissions-trading-greenhouse-gas-emissions-reduced-87-2019_en).  

100  million 

reductions) 

allowances 

of  CO2 

period 

2013 

over 

(i.e. 

the 

to 
2017 
in  2019 

125 

 
                                                           
infrastructure 

infrastructure  along  urban  areas  and  nodes  and  the  core  network  of  the  Trans-European  Transport  Network 
(TEN-T).    The  revision  of  AFID  will  seek  to  ensure  the  availability  and  usability  of  a  dense,  wide-spread 
the  EU.  All  users  of  alternatively-fuelled 
throughout 
network  of  alternative  fuel 
vehicle/vessel/aircraft shall circulate at ease across the EU, enabled by key infrastructure such as motorways, 
ports  and  airports.  It  should  be  noted  however,  that  the  AFID  places  a  strong  focus  on  the  deployment  of 
infrastructure for the road and maritime sectors. For aviation, the Directive may continue to explore the need to 
install electricity supply at airports e.g. for stationary aircraft. As explained in the present impact assessment, 
SAF  are  fully  fungible  with  conventional 
jet  fuel  and  do  not  require  any  specific  refuelling 
stations/infrastructure in addition to what currently exists for conventional jet fuel. It is therefore not expected 
that the revision of AFID should play a role in facilitating SAF deployment in the EU. 

Carbon Border Adjustment Mechanism 

In  the  absence  of  binding  global  targets  on  the  use  of  SAF  in  international  aviation,  an  additional  option  to 
avoid an uneven playing field for European jet fuel producers from fuel tankering, and to prevent the associated 
carbon leakage, could be the application of a Carbon Border Adjustment Mechanism (CBAM). As set out in the 
European  Green  Deal:  “should  differences  in  levels  of  ambition  worldwide  persist,  as  the  EU  increases  its 
climate ambition, the Commission will propose a carbon border adjustment mechanism, for selected sectors, to 
reduce the risk of carbon leakage”. A proposal on such a mechanism is envisaged for June 2021. An ongoing 
study  is assisting  the  Commission  in identifying  the most  appropriate sectors.  Initially,  the risk  of  additional 
tankering is expected to be limited, as explained in section 6.2.8. The risk of fuel tankering is very low in POs 
C1 and C2, as it is mitigated by the anti-tankering safeguard. 

Revision of the Energy Taxation Directive 

The Commission is due to adopt a proposal on the revision of the Energy  Taxation Directive (ETD) by June 
2021. The inception impact assessment249 for this revision recognises the problem that the use of a number of 
new energy products, such as advanced alternative fuels in transport, is currently discouraged since they can be 
taxed in the same way as the conventional fuels. The revision also recognise the problems related to the non-
taxation of the aviation sector. The ETD revision will aim - among others, to help reach the EU’s climate policy 
objectives. The impact assessment is supported by a study on the taxation of the air transport sector, which has 
not been finalised at the time of the submission of this impact assessment. The study considers policy options 
for  introducing  intra-EU  harmonised  fuel  tax  and/or a  harmonised  ticket  tax,  with  a  possibility  to  exempt  or 
apply reduced tax rates for SAF in a context where the products will be taxed on the basis of energy efficiency 
and climate considerations. Currently under the ETD, the minimum excise duty rate for kerosene as a motor 
fuels is €0,33/litre. It can be assumed that properly differentiated tax rates could help to some extent make SAF 
more economically interesting to airlines compared to fossil jet fuel and lead to greater uptake of SAF.  

Reform of the Single European Sky 

The Commission proposal for a revised Single European Sky regulatory framework contains an obligation for 
air  navigation  service  providers  to  modulate  their  charges  to  improve  the  environmental  performance  of 
aviation. In particular, this could be done based on the use of SAF by airlines. This could be useful to further 
help bridging the price gap between SAF and conventional jet fuel. This measure is being discussed as part of 
the ongoing legislative process. 

249   Source: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12227-Revision-of-the-Energy-Tax-Directive- 

126 

 
                                                           
Annex 11 – Features of the legal instrument to implement ReFuelEU 
Aviation 

The preferred policy options (C1 and C2) consist on the one hand of obligations on airlines to uptake jet fuel, 
report jet  fuel  uptake  and SAF  uptake; and on  the  other  hand  on  an obligation on  aviation  fuels  suppliers  to 
supply SAF-blended jet fuel to airlines at EU airports. This section discusses the important aspects to take into 
consideration to decide on the best suited legal instrument to implement the preferred policy options. It explains 
the  reasons  why  ReFuelEU  Aviation  would  more  successfully  achieve  the  policy  objectives  if  implemented 
through  a  standalone  Regulation,  rather  than  through  an  economy-wide,  cross-sectors  framework  (e.g.  the 
Renewable Energy Directive (RED). 

The aviation market is one of the most integrated internal markets in the Union, where the European dimension 
has  become  essential  for  business  to  thrive,  and  citizens  to  connect  and  enjoy  the  advantages  of  the  Union. 
However, regarding its potential to consume renewable energy, its size is small if compared with land transport, 
construction  or  agriculture.  Besides,  the  range  of  renewable  energy  sources  available  for  aviation  are  today 
much  narrower  than  for  those  other  bigger  economic  sectors,  and  those  existing  request  a  second  layer  of 
refinement or technological process than the same kind of renewable energy used for instance in land transport.  
These traits turn aviation market into a “niche” market which does not respond well to mandates or incentives 
through  horizontal  approaches.  When  confronted  with  horizontal  targets,  producers  naturally  focus  on  those 
allowing them the bigger economies of scales and the  most reduced costs, making aviation a less interesting 
sector for  them.  When confronted  with  a target Member states  as  well incentivise  measures  on  those sectors 
where the target can be easier achieved and where the impact is bigger. Since aviation is a very small market 
both in terms of capacity to absorb renewable energy and in share of carbon emissions, it is by nature ignored 
or  relegated  to  the  last  mile  while  a  horizontal  target  is  at  stake.  This  is  part  of  the  reason  why  previous 
horizontal  targets  (e.g.  under  RED  I  and  RED  II)  have  failed  until  now  to  incentivise  the  use  of  SAF  in 
aviation. 

The  present  initiative  must  be  rolled  out  swiftly  and  efficiently,  as  a  key  deliverable  of  the  European  Green 
Deal  and  the  Sustainable  and  Smart  Mobility  Strategy,  and  as  a  necessary  building  block  towards  reaching 
EU’s climate goals by 2030 and 2050 by ensuring that the aviation sectors speed up its own decarbonisation 
without  jeopardising  the  well-demonstrated  benefits  of  a  highly  integrated  aviation  internal  market.  As 
explained in section 1.4 and Annex 11, this can be achieved most successfully by directly regulating economic 
actors at EU level through a Regulation. Indeed, common rules applying directly and uniformly to aviation and 
fuel market actors across the EU will provide clarity and uniformity. As the aviation single market is inherently 
integrated  at  EU  level, it  functions  best  when  rules  are  applied  to  all  airlines  in  the  same  way.  Imposing  the 
same requirements to all market players reduces the risks of distortion of competition and sends clear signals to 
non-EU  aviation  market  actors,  when  flying  in  the  EU.  A  uniform  set  of  rules across  the  EU,  as established 
under a Regulation, will allow to send loud and clear signals to the market. As the transition to SAF requires 
significant investments (see section 6.2.5), it is indispensable that the regulatory framework provides a single, 
long-term and robust set of rules to all investors EU-wide. In particular, it is crucial to avoid the creation of a 
patchwork of differing measures at national level, as would be the case if implemented under a cross-sectoral 
directive such as the Renewable Energy Directive. While this can function with transport modes like road or 
rail, it cannot be successful for transport modes that are so cross-border and global as aviation. A patchwork of 
national  transpositions  could  reduce  the  effectiveness  of  the  policy  and  put  in  jeopardy  the  effective 
decarbonisation of air transport. It could also be conducive to different economic behaviours in the aviation and 
fuel industries from one Member State to another. This could lead to practices of cost avoidance (e.g. via fuel 
tankering)  that  would  undermine  the  functioning  of  the  Single  Market.  The  present  initiative  will  have  an 

127 

 
 
important  impact  on  air  transport  actors  and  the  aviation  internal  market  as  a  whole.  It  is  essential  that 
obligations set on all airlines apply to all airlines uniformly, as can be ensured via a regulation. It is equally 
important for the effectiveness of this initiative that the fuel supply obligation be implemented and enforced in 
a  uniform  way.  Differing  fuel  supply  obligations  in  different  areas  of  the  EU  (e.g.  different  targets,  varying 
sustainability standards, etc.) would set differences of treatments between airlines and could induce competitive 
distortions  between  EU  airports  or  put  EU  aviation  actors  at  disadvantage  with  non-EU  competitors.  The 
present initiative  should  be  implemented  in  a  standalone  regulation  in  order  to cater  for  the  specificities  and 
complexities of the aviation single market. Such detailed provisions regulating the aviation market cannot be 
established  under  the  Renewable  Energy  Directive,  which  scope  goes  only  as  far  as  energy  matters  are 
concerned. 

Timing is an essential factor 

The timing of this initiative is an essential factor of success. This initiative is a key deliverable of the European 
Green Deal and a necessary building block towards reaching EU’s climate goals by 2030 and 2050. Regulatory 
certainty is needed imminently. Indeed, to reach the SAF objectives of around 2% by 2025, a lead-time of 3-4 
years is necessary for the industry to scale up its SAF production capacity. This means that a SAF regulatory 
framework  must  be  in  force  in  Union  law  by  2022.  This  would  be  very  difficult  to  achieve  if  implemented 
through a large economy-wide regulatory framework (e.g. RED). To illustrate this, the past experience of RED 
II shows that from adoption of the proposal by the Commission (2016), to transposition and entry into force in 
Member States (deadline for transposition is June 2021), the process took 5 to 6 years. Such a timeline of 5 to 6 
years for the implementation of ReFuelEU Aviation would mean that a SAF framework would only enter into 
force at Member States level by 2026. This would jeopardise chances of effectively decarbonising aviation and 
contributing efficiently to the EU’s climate goals, as SAF would likely not reach the market before 2029-2030 
(a lead time of 3 to 4 years is necessary for investments to flow and the fuel industry to scale up, which is the 
absence  of  a  robust  regulatory  framework  is  unlikely  to  happen).  On  the  other  hand,  if  adopted  through  a 
standalone  regulation,  the  present  initiative  would  have  higher  chances  of  being  adopted  swiftly.  It  could 
become applicable with immediate effect after entry into force as early as end of 2022.  

128 

 
Annex 12 – Measures contributing to reducing the climate impact of 
aviation 

There is no silver bullet to decarbonise aviation. Reducing the climate impact of aviation therefore relies on a 
mix  of  various  policy  instruments.  At  the  international  level,  the  International  Civil  Aviation  Organization 
(ICAO)  “basket  of  measures”  is  pursued,  which  is  based  on  four  pillars:  market-based  measures,  aircraft 
technology  improvements,  operational  improvements  and  sustainable  aviation  fuels.  At  the  EU  level,  those 
have been implemented through a set of policy measures. The key essential policy instruments pursued by the 
EU under the first three pillars are described below, while the forth pillar of the basket of measures is addressed 
by this initiative.  

Recognising the need for long-term sustainability of aviation and the commitment to continue efforts to reduce 
aviation sector’s negative environmental impacts, European associations of the air transport sector collectively 
representing  the  entire  European  aviation  called  in  2020  for  an  EU  Pact  for  Sustainable  Aviation.  Through 
collaboration between all stakeholders in the aviation eco-system and policy-makers, the Pact is to contribute to 
the  implementation  of  the  European  Green  Deal,  by  reaching  the  objectives  of  significant  CO2  emission 
reductions by 2030 and net-zero CO2 emissions by 2050 from all flights within and departing from the EU. The 
Pact will also consider the feasibility of making 2019 the peak year for CO2 emissions from European aviation 
while  enabling  the  sector  to  continue  delivering  its  social  and  economic  benefits.  In  this  context,  the 
stakeholders’ report highlighted the urgent need for a comprehensive EU legislative framework to promote the 
uptake  and  deployment  of  SAF,  as  a  key  opportunity  to  accelerate  the  decarbonisation  of  aviation.250  The 
important role of SAF in the decarbonisation of aviation is also recognised and assessed in the stakeholders’ 
decarbonisation roadmaps, such as ATAG’s Waypoint 2050251, and European aviation stakeholders Destination 
2050. 

The  below  graph  from  ATAG’s  Waypoint  2050  illustrates  two  scenarios  for  the  future  contribution  of  each 
measure to the decarbonisation of the global aviation.  

250 European Aviation Round Table Report on the Recovery of European Aviation, November 2020. 
251 Source: https://aviationbenefits.org/environmental-efficiency/climate-action/waypoint-2050/ 

129 

 
 
                                                           
Other key policy instruments pursued by the EU under the basket of measures: 

Pillar I on market-based measures, includes EU ETS and CORSIA.  

Pillar II on aircraft technology improvements, includes CO2 standards and Clean Sky Joint Undertaking. The 
EU adopted new standards for aircraft CO2 emissions, which entered into force in 2019252 and follow the global 
standards adopted by ICAO in 2017. They provide additional requirements into the aircraft design process to 
focus on fuel efficiency. In parallel, to develop the green and cutting-edge aircraft technology of the future the 
EU has supported the Clean Sky Joint Undertaking, with a budget of €4 billion (2014-2024) and composed of 
over  600  entities  from  27  countries.  The  EU  will  continue  this  initiative  with  Joint  Undertaking  for  Clean 
Aviation under the Horizon Europe programme. European stakeholders from aeronautics industry and research 
community have proposed a Strategic Research and Innovation Agenda (SRIA) for the envisaged partnership. 
It sets the ambition to have new disruptive technologies ready by 2030, creating the opportunities for industry 
to  market  these  technologies  towards  2035.  The  SRIA  specifically  identifies  three  main  technology  strands, 
setting  the  focus  on  disruptive  solutions  for  hybrid-electric  flying,  on  ultra-efficient  propulsion  and  aircraft 
configurations for the short and medium range and on hydrogen-powered aviation. 

Pillar III on operational improvements, includes Single European Sky and SESAR. The Single European Sky 
framework aims to make European skies more efficient, and can deliver important environmental benefits. The 
SESAR  project,  sponsored  by  the  EU  and  the  aeronautical  industry,  contributes  to  develop  and  deploy 
innovative  air  traffic  management  solutions  with  a  potential  to  further  reduce  emissions.  In  2013,  the 

252 Commission Delegated Regulation (EU) 2019/897 of 12 March 2019 amending  Regulation (EU) No 748/2012 as regards the inclusion  of 
risk-based compliance verification in Annex I and the implementation of requirements for environmental protection. 

130 

 
 
 
                                                           
Commission proposed to complete the SES through amendments that could allow to decrease emissions up to 
10%.  

131 

 
 
 
 
 
 
Annex 13 – Non-CO2 emissions 

When aromatics are present in fuels, they encourage non-volatile Particulate Matter (nvPM) formation during 
combustion. Hence, lower aromatics in fuels provide a cleaner burn and reduced nvPM emissions, which are 
directly linked to contrail cirrus formation that have a net positive (warming) climate forcing effect253.  

Sustainable Aviation Fuels (SAF) typically have lower aromatic concentrations and thus the overall aromatics 
concentration of fuels could be reduced through blending certain SAF with conventional Jet A-1 fuel, as long as 
the aromatics content in the fossil part of the blend does not increase and offset the benefits. In addition, the 
reduction in aromatics improves the energy density of the SAF, which can reduce the mass of fuel needed for a 
specific flight. Estimates suggest potential aircraft fuel efficiency gains of approx. 1%. Finally, SAF can also 
have lower sulphur content resulting in lower SO2 emissions. 

A harmonised approach within the EU to promote the uptake in the use of SAF, while avoiding an increase in 
aromatics  within  traditional  fossil-based  kerosene,  would  contribute  to  reduce  the  non-CO2  climate  change 
impacts. In this respect, engagement with the main fuel specification standardisation committees (e.g. ASTM, 
DEF STAN) would be useful to discuss the climate benefits of low aromatic fuels. 

253   Updated analysis of the non-CO2 climate impacts of aviation and potential policy measures pursuant to the EU Emissions Trading System 

Directive Article 30(4). https://ec.europa.eu/clima/news/updated-analysis-non-co2-effects-aviation_en 

132 

 
 
 
  
 
 
                                                           
Annex 14 – ASTM Certification process 

ASTM  D7566,  the  specification  controlling  alternative  fuel  blends,  has  evolved  to  meet  the  challenge  of 
introducing  new  raw  materials,  processing  and  blends254  that  are  wholly  compatible  with  distribution  and 
aircraft  hardware.  Each  Annex  in  ASTM  D7566  is  linked  to  a  specific  raw  material,  process  and  eventual 
feedstock.  This  division  and  specificity  is  to  mitigate  the  risks  of  new  products  causing  problems.  Once 
produced and blended in compliance with ASTM D7566 the fuel is then designated as ASTM D1655 Jet A or 
Jet A-1 and handled as per conventional fuel. This is on the basis that these new blends have been shown to be 
technically equivalent to conventional fuels. Note also that jet distribution systems and aircraft hardware only 
allow Jet A/A-1 as approved.  

ASTM  D4054255  defines  the  process  by  which  a  new  feedstock,  defined  by  raw  material,  transformation 
process and finishing requirements, must be evaluated before approval and inclusion within ASTM D7566 as a 
new Annex. Extensive testing on the feedstock and final blends is required to ensure the fuel is fit for purpose 
and performs within expected norms. Once approved, the new feedstock is codified within ASTM D7566  and 
the specification up-issued to incorporate the new material. 

In summary D4054 is a tiered process that requires testing with increasing complexity, scale and therefore cost: 

  Tier 1 - Basic standard specification testing. 
  Tier  2  -  Fit  for  Purpose  testing  which  includes  mainly  laboratory  scale  testing  of  a  wider  range  of 
properties, compositional analysis (bulk and trace), material compatibility and performance properties, 
etc. 

  Tier  3  –  Rig  scale  testing  to  assess  behaviour  under  simulated  airframe  and/or  engine  conditions  to 
cover  such  parameters  as  thermal  stability,  cold  flow,  combustion  under  adverse  conditions 
(operability), etc. 

  Tier 4 – full engine testing to assess impact on performance, durability, emissions, etc. 

The ASTM D4054 has to be run with key industry stakeholder engagement as an integral part of the process. It 
has to be noted, that not all the tests are mandatory but is rather a list of tests that should be considered within a 
rational  test  programme  design.  Thus,  testing  requirements  may  be  reduced  for  products  similar  to  those 
already approved, or occasionally, more extended and/or bespoke testing may be required for products that are 
outside experience. 
In any case, a key barrier to new entrants is the requirement to make significant (industry scale) volumes of fuel 
either  for  testing  per  se  but  also  to  demonstrate  the  production  process  at  scale  and  show  that  it  has  a  high 
enough technology readiness level. 
ASTM  introduced  the  so-called  “Fast  Track”  process  aims  to  reduce  some  of  this  burden.  This  rationalised 
process comprises a set of very stringent controls on any new blendstock which is to be submitted to Fast Track 
evaluation and approval. If the product meets these requirements (in summary: declaration of raw materials and 
processing, bulk properties, bulk hydrocarbon composition and purity, and down selected fit-for-purpose tests) 
then approval by the usual ASTM D4054 route is allowed but only Tier 1+ testing is required. 

254   ASTM  D7566-19,  Standard  Specification  for  Aviation  Turbine  Fuel  Containing  Synthesized  Hydrocarbons,  ASTM  International,  West 

Conshohocken, PA, 2019, www.astm.org. 

255   ASTM  D4054-19,  Standard  Practice  for  Evaluation  of  New  Aviation  Turbine  Fuels  and  Fuel  Additives,  ASTM  International,  West 

Conshohocken, PA, 2019, www.astm.org. 

133 

 
 
 
                                                           
134 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex 15 – SAF Production Routes 

Hydroprocessed Esters and Fatty Acids (HEFA)  

This route was certified by ASTM as HEFA-SPK. HEFA-SPK is the only SAF currently used commercially 
(TRL 9, depending on sources) due to its simplicity and its low-cost production. The blend with kerosene is 
limited to 50%, which is the highest blend allowed under RED II.  

Alcohols to Jet (AtJ)  

This route, currently at TRL 7-8, is certified by ASTM as ATJ-SPK and consists of converting alcohol into jet 
fuel.  The  alcohol  is  the  product  resulting  from  the  fermentation  of  sugar  or  starch  crops  (corn,  sugarcane, 
wheat).  Alternatively,  the  alcohol  can  also  result  from  processed  lignocellulosic  feedstock  (agricultural  and 
forest  residues).  Regardless  of  the  feedstock  used,  hydrogen  is  required  in  the  process.  The  certification 
currently limits the blend of alcohol in jet fuels to 50%.  

Biomass Gasification + Fischer-Tropsch (Gas+FT) (Part A biofuels) 

This route was certified by the ASTM as FT-SPK and currently stands at TRL 6-8. Biogas, is obtained from the 
gasification of the feedstock followed by Fischer-Tropsch synthesis (E4tech, 2019). Blending is limited to 50%. 
Common feedstocks include energy crops (for example, miscanthus, willow, poplar), lignocellulosic biomass 
and solid waste. When energy crops are used as feedstock, CO2 emissions savings can reach up to 85-90%, and 
can reach even higher levels (95%) when forestry residues are used (Bosch, et al., 2017).  

Summary  

Table  24  presents  a  summary  of  the  different  advanced  bio-fuels’  main  characteristics. Table  42  presents  a 
summary of the different advanced bio-fuels’ main characteristics.  

Table 24: Summary of certified advanced biofuels and their technological maturity 

Route  

Feedstocks  

Certification  

TRL  

Hydroprocessed Esters and 
Fatty Acids (HEFA)  
Alcohols to Jet (AtJ)  

Vegetable and animal 
lipids  
Sugar, starch crops, 
lignocellulosic biomass  

HEFA-SPK, up to 
50% blend  
ATJ-SPK, up to 
50% blend  

Biomass Gasification + 
Fischer-Tropsch (Gas+FT)  

Energy crops, 
lignocellulosic biomass, 
solid waste  

FT-SPK, up to 
50%  

RFNBOs (synthetic fuels)  

CO2 
emissions 
savings  
20-69%257  

9  

7-8  

37-70%259   

6-8  

85-95%260   

Production capacity 
(kilotonne/year)256    

Operational: 5,000 per 
year258 
Operational: 30  
In commissioning: 20  
Planned: 324  
Under construction: 40  
Planned: 215  

Synthetic  fuel  are  sustainable  aviation  fuels  based  on  non-biologic  origin,  where  the  source  of  energy  is  not 
based  on  crops,  or  residues  or  waste,  but  obtained  from  renewable  electricity.  The  development  and 

256   Data available as of June 2019. 
257   Varies based on feedstock: soy (20-54%), jatropha (37%), camelina (46%) and used cooking oil (69%) 
258   This is the global production of HEFA, of which only 100 kilotonne was produced for the aviation sector. This amount also includes the 

HEFA produced through the co-processing route. 

259   Varies based on feedstock: corn (37%), corn stover (60%), sugarcane (70%). 
260   Varies based on feedstock: energy crops (80-90%) and forestry residues (up to 95%). 

135 

 
 
  
  
                                                           
commissioning  of  the  first  production  plants  for  synthetic  fuels  on  a  relevant  industrial  scale  seems  to  be 
feasible on a technical basis in 6 to 10 years from today (Ausfelder & Dura, 2019).  

The  below  table  presents  a  summary  of  the  different production  pathways  with  critical  technical  processes 
which have not reached commercial availability. Possible CO2 emission savings are not included in the table as 
they are mainly influenced by the characteristics of the electricity used for fuel production. A critical element 
for all electrofuel processes is the availability of sustainable CO2 as a  Direct air capture (DAC) technology is 
at  TRL  3-6  and  energy  consuming  compared  to  more  concentrated  CO2  sources. CO2  emissions  from  fossil 
point sources will have to decrease over time to meet EU’s CO2 mitigation targets and the technical maturity of 
capturing CO2 from combustion and industrial processes is at TRL 5-9 (depends on the process).  

Table 25: Summary of electrofuel production pathways and their critical processes 
Certification  

Route  
FT route (LT electrolysis)  

FT route (HT electrolysis)  

Methanol route (two-step 
methanol synthesis / LT 
electrolysis  
Methanol route (two-step 
methanol synthesis / HT 
electrolysis  

FT-SPK, up to 
50%  
FT-SPK, up to 
50%  

Not certified   

Not certified  

Methanol route (one-step 
methanol synthesis / LT 
electrolysis  
Methanol route (one-step 
methanol synthesis / HT 
electrolysis  

Not certified   

Not certified  

Critical technical processes   
Reverse water gas shift reaction (TRL 5-6)  

Solid oxide electrolysis (TRL 4-7)   
Reverse water gas shift reaction (TRL 5-6)  
or  
Co-Electrolysis (TRL <5)  
Reverse water gas shift reaction (TRL 5-6)  
Final conversion to jet fuel (TRL 7-8)  

Reverse water gas shift reaction (TRL 5-6)  
Final conversion to jet fuel (TRL 7-8)   
Solid oxide electrolysis (TRL 4-7)  
or  
Co-Electrolysis (TRL <5)  
Final conversion to jet fuel (TRL 7-8)   
Methanol synthesis (TRL 6-7)  
Final conversion to jet fuel (TRL 7-8)  

Methanol synthesis (TRL 6-7)  
Final conversion to jet fuel (TRL 7-8)   
Solid oxide electrolysis (TRL 4-7)  

136 

 
 
 
 
 
Annex 16 – SAF production costs and economies of scale 

Evolution of SAF production costs 

This  section  presents  the  expected  development  of  the  cost-structure  of  biofuel  production  per  pathway  and 
over time. The cost components are aggregated in main categories, which include capital costs, feedstock costs, 
fixed  operational  and  variable  costs (e.g.  costs  of  energy,  enzymes,  catalysts,  waste  management).  The  costs 
presented here exclude the profit margin that was used to form the price of SAF. The cost-structure is presented 
per pathway from the first year of the technology implementation (i.e. 2025 for HEFA and ATJ, and 2035 for 
Gasification  and  FT)  and  the  subsequent  10-year  periods  leading  to  2050.  The  cost-structure  is  based  on 
PRIMES Biomass. 

The  cost-structure  of  the  HEFA  route  remains  relatively  unchanged  over  the  time  horizon,  with  the  cost  of 
HEFA jet showing small increase mainly driven by feedstock costs. The development of capital costs is in line 
with literature that expects minimal developments in capital cost component of the technology (ICCT 2019). 
Higher feedstock costs over time are a direct result of higher demand of jet fuel and the use of UCO. Feedstock 
costs and variable costs account for more than 90% of the HEFA production costs. 

Figure 14 Cost-structure of biofuel production from the HEFA route in all POs except PO B2. 

Source: PRIMES Biomass 

Two drivers shape the slightly increasing trajectory of biokerosene production costs from the ATJ route and the 
Gas+FT  route.  The  first  driver  is  the  decrease  of  non-feedstock  components,  such  as  capital  costs,  fixed 
operational costs and variable costs as a result of economies of scale, learning and technology utilisation. This 
becomes evident when comparing the capital and variable costs of the two routes, from the year they emerge 
with those of subsequent periods. Capital unit costs of the Gasification and FT route decrease by 30% between 
2035  and  2040,  and  those  of  the  ATJ  route  by  10%  between  2025  and  2040.  In  both  routes,  variable  costs 
decrease by about 2-3% in the same period. 

A counterbalancing driver is the increase in production costs driven by feedstock costs. In early years, when the 
demand  for  bioenergy  is  lower,  inexpensive  feedstock  (e.g.  agricultural  residues)  are  used  by  the  two  SAF 
production  pathways.  However,  as  bioenergy  demand  increases,  competition  for  inexpensive  feedstock  rises 
from  the  energy  sector  and  other  transport  sectors.  As  the  modelling  exercise  is  in  the  context  of  the  2030 

137 

 
 
 
 
Climate  Target  Plan  ambition  for  carbon  neutrality,  it  also  considers  the  effort  from  other  sectors  to 
decarbonise. As such, the lowest-cost feedstock are quickly depleted and the need for more expensive feedstock 
emerges, increasing the cost of feedstock used for SAF. This is reflected by the increasing share of feedstock in 
the cost structure of bioenergy in the years leading to 2050. 

Figure 15 Cost-structure of SAF production from the ATJ route in all POs except PO B2.  

Source: PRIMES Biomass 

Figure 16 Cost-structure of SAF production from the Gas+FT route in all POs except PO B2. 

Source: PRIMES Biomass 

Differences in production costs between Part B biofuels and Part A (advanced) biofuels 

Annex IX Part B biofuels are produced through the HEFA production route that uses waste lipids as feedstock, 
such  as  used  cooking  oil.  This  is  a  mature  technology/pathway  with  production  capacity  estimated  at  2.3 
million tonnes per year. This production route is very similar to the one used to produced HVO (biofuels for the 
road sector) and therefore has benefited from cost reductions due to the surge of demand for HVO biodiesel in 

138 

 
 
 
 
 
the past decade. However, there is currently no production through this pathway going to aviation as a result of 
economic  choices  made  by  fuel  producers,  for  the  reasons  detailed  in  sections  2.2.2  and  2.2.3.  On  the  other 
hand, the production technologies of advanced biofuels (also referred to as Annex IX Part A biofuels) from the 
ATJ and/or Gas+FT routes face industrial challenges and are not yet available at commercial scale, and require 
investments in first-of-a-kind plants and their scale-up to benefit from economies of scale, learning effects and 
resulting lower costs.  
As  shown  in  Table  24  below,  current  cost  estimates  available  in  literature  for  Part  B  and  Part  A  biofuels 
provide  ranges  which  reflect  larger  uncertainty  on  the  production  costs  of  advanced  biofuels.  Cost  estimates 
provide  more  certainty  for  Part  B  biofuels.  Table  24  below  and  Figure  11  above  show  the  cost  difference 
between the two categories of biofuels.  

Table 26 - Current SAF price ranges from literature and industry consultation. 

Production route 

Estimated production 
cost261 in 2020 (k€/tonne) 

Fossil jet 
fuel 

HEFA 

Gas+FT 

ATJ 

RFNBOs 

0.6 

0.95-1.14 

1.7-2.5 

1.9-3.9 

1.8-3.5 

Besides  capital  costs,  looking  into  other  cost  components  provides  additional  insights  in  understanding  the 
differences between Part B and advanced biofuels. First, the use of expensive enzymes or catalysts increases 
the variable costs of advanced biofuels production relative to that of Part B biofuels. Indeed, in absolute terms, 
the variable costs of Part B biofuels production is significantly lower than that of advanced biofuels. Second, 
advanced  biofuels  require  higher  amounts  of  biomass  feedstock  input  compared  to  Part  B  biofuels  that  are 
produced  from  waste  lipids,  which  leads  to  overall  higher  feedstock  costs  of  advanced  biofuels  compared to 
Part B biofuels. 

Sensitivity analysis on variable costs for advanced biofuels production 

As highlighted in the above section, the contribution of variable costs in the production cost of Part B biofuels 
such  as  those  of  energy,  catalysts,  enzymes,  other  utilities  and  waste  management  is  between  35%  and  47% 
depending on the year and the technology262. Additional reductions of variable costs may be achieved due to 
faster  technology  developments  or  higher  economies  of  scale.  To  assess  the  sensitivity  of  advanced  biofuels 
prices to economies of scale and faster technological development, we use the cost reduction trajectory as per 
the work263 performed by McKinsey on SAF variable costs. Following this approach, by 2050, variable costs 
decrease  by  30%  for  the  ATJ  route  and  by  14%  for  the  Gas+FT  route,  relative  to  2020.  Based  on  these 
trajectories, the effect on advanced biofuels prices are estimated as shown in  Error! Not a valid bookmark 
self-reference.  below.  Price  for  advanced  biofuels  are  lower  by  about  10%  for  ATJ  and  by  about  5%  for 
Gas+FT, bringing the price of advanced biofuels under the 2,000 €/tonne mark over time. It should be noted 
that the variable cost reduction assumed in the work performed by McKinsey occurs primarily early in the time 
horizon (by around 2030), and thereafter a slower improvement rate is shown. This is similar with the findings 
of  the  present  analysis  that  shows  a  drop  of  current  theoretical  costs  by  2030,  and  a  rather  constant  price 
trajectory thereafter. 

261   Based on rough estimates sources from Clean Skies for Tomorrow: SAF feasibility and sustainability – McKinsey study – September 2020. 

Values have been converted from USD/tonne to EUR/tonne at an exchange rate of 1USD for 0.85EUR. 
262   Such contribution levels are in line with literature (Baker et al., 2017; de Jong 2015, IRENA 2016, WEF2020) 
263   Clean Skies for Tomorrow: SAF feasibility and sustainability – McKinsey study – September 2020. 

139 

 
 
 
                                                           
 
Figure 17 Sensitivity of biokerosene price on variable costs 

Note: Own calculations based on input from PRIMES-Biomass and literature review 

Explanation of economies of scale 

The  analysis  assumes  that  advanced  biofuel  producers  implement  measures  with  a  view  to  improve  their 
production process, which results in scale-up production at lower cost. This is especially relevant for advanced 
biofuel production routes (ATJ and Gas+FT routes) that are not deployed at commercial scale. The uptake of 
SAF already contributes to the reduction of scalable cost components such as capital and variable costs. Such 
cost reductions are expected to take place in particular in the short term, i.e. between 2020 and 2025-2030. This 
is the case because SAF production costs evolve from the current state of the market where SAF production is 
in  its  infancy  and  SAF  production  capacity  is  extremely  limited.  At  the  moment,  SAF  production  consists 
essentially of demonstration projects where SAF outputs are negligible, hence production costs and resulting 
prices are very high. A regulatory intervention such as a SAF blending mandate, forcing one side of the market 
to supply SAF provides the necessary long-term certainty for investments to take place to develop new SAF 
production capacity. This translates directly into conversion of demonstration plants into full-size commercial 
plants and thereby helps achieving economies of scale, bringing SAF prices down. This can be seen on figure 
11  below.  The  modelling  shows  a  reduction  of  9%  and  5%  for  the  capital  and  variable  costs,  respectively, 
between 2025 and 2035 for the ATJ route. Capital and variable costs for the Gas+FT route decrease by 30% 
and 5%, respectively, between 2035 and 2040.  

140 

 
 
 
Figure 18 - Production cost development for SAF production pathways – Sensitivity with ETS and low production costs (in € per tonne 
of fuel). Note: black: fossil, grey: fossil with ETS, yellow: HEFA, green: ATJ, red: Gas+FT, blue: RFNBOs. 

On the other hand, this effect is counterbalanced by an increase of feedstock costs driven by the demand for 
biofuels, primarily by the demand of biomass feedstock from other sectors. It is highlighted that the modelling 
of  the  bioenergy  routes  has  been  established  within  the  2030  Climate  Target  Plan  ambition  context,  which 
means  that  significant  quantities  of  bioenergy  are  needed  by  other  transport  sectors  (including  international 
maritime)  and  energy  sectors.  Hence,  the  biomass  system  is  pushed  towards  more  expensive  feedstock, 
outweighing to some extent the benefits from the scaling of production. Similarly to advanced biofuel routes, 
the demand for synthetic kerosene drives an increase in hydrogen demand and eventually leads to large-scale 
deployment of hydrogen generation technologies. The modelling considers learning-by-doing effects, reducing 
the costs of electrolysers, which is a critical cost component. 

141