REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL The ReFuelEU Aviation SAF flexibility mechanism
Date: 2025-02-27
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: air quality, air transport, aviation fuel, biofuel, greenhouse gas, reduction of gas emissions, supply, sustainable mobility

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 27.2.2025  COM(2025) 59 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL The ReFuelEU Aviation SAF flexibility mechanism  
 
 
Contents 
1 

Introduction ............................................................................................................................. 2 

2  Overview of the EU’s aviation fuel market ............................................................................ 5 

2.1 

2.2 

Conventional aviation fuel in the EU .............................................................................. 5 

Sustainable aviation fuels in the EU ............................................................................... 6 

3 

The ReFuelEU Aviation SAF flexibility mechanism ........................................................... 12 

4  Objectives and industry positions on possible improvements and additional measures to the 
SAF flexibility mechanism ........................................................................................................... 14 

4.1 

4.2 

Objectives ..................................................................................................................... 14 

Industry positions .......................................................................................................... 15 

5 

Possible improvements and additional measures to the SAF flexibility mechanism. .......... 24 

5.1 

5.2 

Potential improvements through changes in the Union Database for Biofuels (UDB)  24 

Potential improvements through the implementation of a SAF accounting mechanism
26 

6  Conclusions and recommendations....................................................................................... 30 

Assessment of the developments on SAF production and supply on the EU’s aviation 

6.1 
fuel market ................................................................................................................................ 30 

Assessment of possible improvements or additional measures to the existing SAF 

6.2 
flexibility mechanism with a view to further facilitate the supply and uptake of SAF for 
aviation during the flexibility period ........................................................................................ 31 

1 

 
 
 
 
 
1  Introduction 
The Communication from the Commission on the European Green Deal 1 sets out the targets of 
reducing greenhouse gas (GHG) emissions in transport by at least 90% by 2050 compared with 
1990, and ramping up the production and deployment of sustainable alternative transport fuels. 
Sustainable aviation fuels (SAF) are recognised as the biggest contributor to any short- to long-
term approach to reducing global aviation CO2 emissions. This is also reflected in the discussions 
and measures taken internationally by the International Civil Aviation Organisation (ICAO). In 
this context, the European Union has adopted Regulation (EU) 2023/2405 2 (ReFuelEU Aviation). 
ReFuelEU Aviation aims to decarbonise the aviation sector by mandating the supply of aviation 
fuels  containing  an increasing  minimum  share of SAF 3 –  blended SAF –  in  all  Union airports 
falling within the scope of the ReFuelEU Aviation 4, while avoiding potential distortions in the 
aviation internal market. The EU is leading the way globally in the deployment of SAF. ReFuelEU 
Aviation  exploits  the  EU’s  greatest  strength:  its  internal  market  –  particularly  regarding  the 
provision of air services – which is one of the most integrated and most efficient markets in the 
world and key to the EU’s global competitiveness. It sets out harmonised obligations, definitions 
and penalties throughout the EU preserving the level playing field. It is also consistent with the 
long-term global aspirational goal (LTAG) for international aviation of net-zero carbon emissions 
by 2050, which was adopted in 2022 by the 41st ICAO Assembly and with the ICAO aspirational 
goal of 5% GHG international aviation emissions reduction by 2030 agreed during the CAAF/3 5 
in 2023.  

ReFuelEU Aviation contributes to achieving the EU’s climate goal, which was set by the European 
Climate  Law,  of  becoming  climate-neutral  by  2050.  In  this  vein,  it is  expected  that  ReFuelEU 
Aviation alone will help reduce aviation’s CO2 emissions in the EU by at least 60% by 2050, with 
additional potential spillovers such as improving local air quality (notably around airports) and 
profiting from the lower non-CO2 emissions the use of blended SAF entails, notably to reduce the 
impact  of  contrails.  The  SAF  market  is  still  in  the  early  creation  stage.  However,  ReFuelEU 
Aviation’s  entry  into  force  has  already  boosted  the  current  momentum  of  investment  in  SAF 
production  in  the  EU6  and  significantly  contributed  to  solving  the  ‘chicken  and  egg’  situation 
regarding SAF supply and demand. ReFuelEU Aviation will be the key element in overcoming 
the EU’s challenge in widely deploying SAF, since: it allows for the free movement of these new 
aviation fuels in the internal market; opens new markets and opportunities; and introduces digital 
reporting tools and targeted flexibility to make life easier and faster for companies and investors. 
The aviation sector’s transition to blended SAF benefits not only the climate but also the EU’s 
economy. The regulatory certainty provided by ReFuelEU Aviation will unlock investment in new 
SAF production plants and increase the EU’s strategic energy supply autonomy due to the variety 

1 https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1588580774040&uri=CELEX%3A52019DC0640  
2 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32023R2405  
3 ‘SAF’ here refers to the synthetic blend component (SBC). This is a synthetic product manufactured and certified 
according to ASTM D7566. SBC is equivalent to SAF that is not blended with conventional aviation fuel. 
4 See Article 3(1) of ReFuelEU Aviation. 
5 https://www.icao.int/Meetings/CAAF3/Pages/default.aspx  
6 European Union Aviation Safety Agency (EASA), State of the EU SAF market in 2023, 2024 - 
https://www.easa.europa.eu/en/domains/environment/refueleu-aviation/eu-saf-market-report. 

2 

 
 
of  SAF  feedstock  and  production  pathways  that  can  be  produced  in  the  EU.  This  objective  is 
supported  by  the  Clean  Industrial  Deal  announced  by  President  von  der  Leyen  and  the  future 
Sustainable  Transport  Investment  Plan  referred  in  the  mission  letter 7  to  the  Commissioner  for 
Sustainable  Transport  and  Tourism,  Apostolos  Tzitzikostas.  ReFuelEU  Aviation  sets  uniform 
minimum levels for the supply share of blended SAF at EU level, thus creating a level playing 
field between aviation economic operators. It also sets out a path for the EU to seize the opportunity 
created by the aviation sustainable transition to strengthen  its energy security and reinforce  the 
industry in all Member States.  

It is worth noting that ReFuelEU Aviation’s obligatory minimum supply requirements only cover 
blended SAF. The existing aviation fuel quality standards do not allow SAF to be supplied and 
used  in  an  aircraft  without  them  first  being  blended  with  conventional  aviation  fuel 8.  Equally, 
ReFuelEU Aviation does not set a minimum obligatory level of uptake of blended SAF by aircraft 
operators. Aircraft operators and aviation fuel suppliers are free to decide on the amount of blended 
SAF  they  wish  to  trade  in  the  market  –  provided  that  aviation  fuel  suppliers  comply  with  the 
minimum obligatory supply shares of blended SAF and that aircraft operators comply with the 
refuelling obligation set in ReFuelEU Aviation, each year and at each Union airport.  

By way of exception, the SAF flexibility mechanism, for the period 2025-2034, allows aviation 
fuel suppliers to supply the minimum shares of SAF as a weighted average over all the aviation 
fuel it supplied across all Union airports in a given year. From 2035 onward, however, all aviation 
fuel supplied in Union airports must be blended SAF. Conventional aviation fuel will therefore no 
longer be available at Union airports. The SAF flexibility mechanism is intended to give the SAF 
industry, and in particular aviation fuel suppliers, sufficient time to scale up its production and 
supply capacities. It will also allow aviation fuel suppliers to meet their obligations cost-effectively 
and without having to reduce the overall environmental ambition of ReFuelEU Aviation. 

This report maps the developments in SAF production and supply on the EU’s aviation fuel market. 
It also presents the findings of the Commission services’ monitoring of the implementation of the 
SAF flexibility mechanism during these very early stages of ReFuelEU Aviation’s application, as 
required by Article 15(2) of ReFuelEU Aviation. For this purpose, an external support study 9 has 
also been carried out.  

Chapter 2 provides an overview of the current EU market for conventional as well as sustainable 
aviation fuels. Chapter 3 covers the functioning of the SAF flexibility mechanism in more detail 
and  analyses  its  expected  consequences  for  the  relevant  stakeholders  impacted  by  ReFuelEU 
Aviation. Chapters 4 and 5 explore potential improvements and additional measures to the SAF 
flexibility mechanism, with a view to further facilitating the supply and uptake of SAF at Union 
airports, as required by Article 15(2) of ReFuelEU Aviation. This analysis includes assessing the 
implementation or recognition of a SAF accounting mechanism. It addresses both the traceability 
and  the  tradability  of  SAF  under  the  EU  legislative  framework  that  could  enable  aviation  fuel 

7 https://commission.europa.eu/document/de676935-f28c-41c1-bbd2-e54646c82941_en  
8 Such standardisation work is ongoing to allow 100% SAF in the future. See Annex 1 for the current blending limits. 
9 Guidehouse, Assessment of the production and supply of SAF in Union airports and study on the feasibility of the 
creation of a system of tradability of SAF in the EU, 2024.  

3 

 
 
supply in the EU without it being physically connected to a supply site. Chapter 6 summarises the 
findings and sets out some recommendations from the Commission on the way forward. 

4 

 
 
 
2  Overview of the EU’s aviation fuel market 

Article 3(6) of ReFuelEU Aviation defines ‘aviation fuel’ as a drop-in fuel manufactured for direct 
use by aircraft. In the EU, Jet A-1 is produced and delivered according to the fuel quality standard 
used for aviation turbine fuels set by DefStan 91-091 10. This standard covers almost 100% of total 
aviation turbine fuel consumption in the EU. 

The  fuel  quality  standards  for  the  various  production  pathways  of  SAF  are  set  by  ASTM 
International  under  ASTM  D7566 11  and  are  adopted  in  DefStan  91-091.  Eight  SAF  pathways 
(ASTM  D7566)  and  three  SAF  co-processing  pathways  (ASTM  D1655 12)  have  already  been 
qualified and approved. Both standards (DefStan 91-091 and ASTM D1655) describe the quality 
specifications for the aviation turbine fuels to be used in commercial aviation. ASTM D7566 sets 
out  different  quality  specifications  for  each  of  the  SAF  production  pathways  as  well  as  the 
requirements  for  blended  SAF.  Once  both  the  SAF  and  the  conventional  aviation  fuels  are 
certified,  the  blend  of  both  may  take  place  while  taking  into  consideration  the  blending 
requirements  for  each  type  of  SAF  pathway 13.  Once  blended,  the  blended  SAF  must  undergo 
another fuel quality check to prove conformity with the ASTM D7566 blending requirements. If 
this check is passed, then the SAF blend is declared as DefStan 91-091 fuel and it can then be used 
in an aircraft. 

Article 3(7) of ReFuelEU Aviation defines SAF as ‘aviation fuels that are either synthetic aviation 
fuels, aviation biofuels or recycled carbon aviation fuels. These types of fuels are further defined 
in Article 3(12), 3(8) and 3(9) of ReFuelEU Aviation respectively. They all stem from Directive 
(EU) 2018/2001 14 (the RED). Aviation fuel suppliers can also decide to comply with the minimum 
shares of SAF and synthetic aviation fuels using renewable hydrogen for aviation and low-carbon 
aviation fuels as defined in Article 3(16) and 3(18) of ReFuelEU Aviation respectively. Regarding 
ReFuelEU Aviation, hydrogen for aviation is not defined as an aviation fuel because it is not a 
drop-in fuel manufactured for direct use by aircraft. Hydrogen for aviation is to be used in next-
generation aircraft that leverage innovative propulsion technologies. This report only  addresses 
fuels defined as SAF in the Regulation.  

2.1  Conventional aviation fuel in the EU  

The EU currently has 77 refineries in 21 Member States that refine crude oil. Conventional aviation 
fuel typically represented around 9% of their total production output in 2022. In that same year, 
the EU relied on net imports for more than 97% of its crude oil consumption 15, which illustrates 
the high dependence on non-EU countries for aviation fuels supply. 

for  Aviation  Turbine  Fuel  Containing  Synthesized  Hydrocarbons 

10 Defense Standard 91-091: Turbine Fuel, Kerosene Type, Jet A-1; NATO Code: F-35; Joint Service Designation: 
AVTUR - https://www.dstan.mod.uk/StanMIS/DefStan/Edit/8707. 
11 Standard  Specification 
https://www.astm.org/d7566-22.html. See also Annexes 1 and 2. 
12 Standard Specification for Aviation Turbine Fuels – https://www.astm.org/d1655-22a.html. 
13 See Annex 2. 
14 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02018L2001-20231120  
15 Eurostat (2024) – https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Oil_and_petroleum_products_-
_a_statistical_overview&oldid=315177.  

–

5 

 
 
Most of the refineries in the EU are located on the coast or close to waterways 16. A refinery’s 
location, the distance to the airports for which it produces conventional aviation fuel and the mode 
of transport used to deliver the fuels have an impact on the supply chain. This can ultimately have 
an impact on the price of aviation fuel at airports in the EU.  

The  price  of  aviation  fuel  also  depends  greatly  on  the  fuel  procurement  arrangement  made  by 
aircraft operators. The most common commercial arrangement is for an aircraft operator and an 
aviation fuel supplier to sign a fuel supply agreement (FSA). This may for example be based on 
IATA’s  Aviation  Fuel  Supply  Model  Agreement 17,  which  sets  out  the  general  framework  and 
terms and conditions for the sale and purchase of fuel. The parties must also agree specific terms 
for  each  location  (i.e. airport)  where  fuel  is  supplied.  Each  location  agreement  (annexed  to  the 
FSA)  specifies  the  fuel  quality,  quantity,  price  and  other  key  terms.  The  price  of  conventional 
aviation fuel in the EU can vary significantly (as demonstrated by EUROCONTROL in 2019) 18. 

Some aircraft operators have established a self-supply entity which procures aviation fuel from 
aviation fuel producers or other traders and then sells it to the aircraft operating entity. In some 
specific  cases,  the  self-supply  entity  is  the  same  legal  entity  as  the  aircraft  operating  entity. 
ReFuelEU Aviation allows for a given legal entity to bear several obligations.  

Findings from the Airport Survey 19 conducted by Guidehouse in the context of the support study 
show  that  most  airports  have  between  one  and  five  aviation  fuel  suppliers  operating  on  their 
premises. A significant number of airports have only one or two aviation fuel suppliers. Different 
airports have different aviation fuel-supply rights-granting procedures (e.g. a tender procedure or 
a stake in the ownership of the airport fuel storage facility). On average, airports where aviation 
fuel supply rights are granted through a tender typically have fewer aviation fuel suppliers because 
such tenders often award exclusive aviation fuel supply rights to one or just a few aviation fuel 
suppliers for a number of years.  

2.2  Sustainable aviation fuels in the EU 

2.2.1  Production and supply of SAF 

SAF production capacity in the EU reached only 0.3 million tonnes (Mt) in 2023 20. This represents 
around  0.6%  of  the  EU  aviation  sector’s  fuels  consumption  and  demonstrates  a  market  failure 
when it comes to acquiring SAF. The market on its own was unable to scale up the production and 
supply of SAF and blended SAF which are vital for the future of the sector. However, since the 
entry into force of ReFuelEU Aviation in November 2023, the forecasted EU production, blending 
and supply capacities for aviation biofuels have been quickly ramping up, reaching levels above 
the minimum SAF blending obligatory share for aviation biofuels to be supplied until 2030. This 

16 Energy and Industry Geography Lab - https://energy-industry-geolab.jrc.ec.europa.eu/  
17 IATA - https://www.iata.org/en/programs/ops-infra/fuel/  
18 EUROCONTROL, Fuel Tankering: economic benefits and environmental impact, 2019 - eurocontrol-think-paper-
1-fuel-tankering.pdf. 
19 Guidehouse, Assessment of the production and supply of SAF in Union airports and study on the feasibility of the 
creation of a system of tradability of SAF in the EU, 2024. 
20 European  Union  Aviation  Safety  Agency 
https://www.easa.europa.eu/en/domains/environment/refueleu-aviation/eu-saf-market-report.  

the  EU  SAF  market 

(EASA),  State  of 

in  2023 

- 

6 

 
 
permits a cautiously confident look regarding the achievement of the EU’s uniform targets until 
2034 for these fuels. As shown in a recent report published by the European Union Aviation Safety 
Agency (EASA) on the state of the EU SAF market, SAF production capacity in the EU reached 
around 1.2 Mt in 2024. For reference, 2% of the total aviation fuel consumption at Union airport 
in  2025  is  expected  to  be  equivalent  to  around  0.9 Mt.  EASA’s  analysis  of  the  existing  and 
announced  EU  SAF  production  projects  also  shows  that,  in  a  realistic  scenario,  the  EU  SAF 
production  capacity  in  2030  should  amount  to  3.2  Mt.  However,  the  production  capacity  of 
advanced biofuels in the EU remains limited. As shown in a recent report published by DG RTD 21, 
the  feedstock  base  for  lignocellulosic  materials,  used  in  advanced  biofuels  production,  is 
substantially  broader than that for  used cooking  oil.  Thus, advancing  technologies that process 
lignocellulosic  materials  to  market  maturity  is  critical  for  achieving  high  biofuel  production 
volumes in the future. 

Greater uncertainty remains about the level of investment of aviation fuel producers in synthetic 
aviation fuel production plants in the EU to ensure the achievement of their dedicated minimum 
share  (0.7%)  and  dedicated  average  share  (1.2%)  between  2030  and  2032.  The  SAF  market  is 
quickly evolving, and aviation fuel producers based in the EU have announced projects that have 
sufficient planned capacity to allow them to meet their obligations regarding synthetic aviation 
fuels in ReFuelEU Aviation by 2034. However, at the time of this Communication, none of the 
announced projects have yet secured a final investment decision. There is nevertheless still enough 
time for those plants to become operational and many different economic operators are actively 
discussing the matter. It would be premature to conclude that there is possible scarcity regarding 
the  synthetic  aviation  fuel  sub-target  for  2030-2032.  This  market  segment  requires  close 
monitoring and possible further support in the context of the announced Clean Industrial Deal and 
Sustainable Transport Investment Plan. 

EASA’s  report  on  the  State  of  the  EU  SAF  market  in  2023  highlights  a  notable  geographic 
concentration of EU SAF production facilities in specific regions and Member States at this early 
stage. This contrasts with the more dispersed nature of conventional refineries. The Netherlands 
has the largest announced production capacity by 2030 with an estimated 1.6 Mt of SAF produced 
each  year.  Spain,  France,  Finland  and  Sweden  have  several  planned  and  under-construction 
facilities  that  employ  diverse  production  pathways.  Conversely,  many  central  and  eastern 
European Member States (e.g. Bulgaria, Latvia and Hungary) currently lack any SAF production 
capacity,  whether  already  operational  or  merely  announced.  12 Member  States  currently  have 
operational or announced SAF production capacity. They are all among the 21 Member States that 
have  conventional  aviation  fuel  refining  capacity.  This  disparity  between  western  and  eastern 
Member States is even more pronounced for synthetic aviation fuel production initiatives 22. The 
announced  synthetic  aviation  fuel  production  projects  are  all  located  in  Denmark,  France, 
Germany,  the  Netherlands,  Portugal,  Spain  and Sweden.  Further  developments  in  the  EU  SAF 

21  DG  RTD,  Development  of  outlook  for  the  necessary  means  to  build  industrial  capacity  for  drop-in  advanced 
biofuels, 2024 - https://op.europa.eu/en/publication-detail/-/publication/b1c97235-c4c3-11ee-95d9-01aa75ed71a1.  
22 Transport & Environment (T&E), E-fuels for planes : with 45 projects, is the EU on track to meet its targets, 2024 
-  https://www.transportenvironment.org/articles/e-fuels-for-planes-with-45-projects-is-the-eu-on-track-to-meet-its-
targets. 

7 

 
 
production capacity will be reflected in the yearly technical reports of EASA required under Article 
13 of ReFuelEU Aviation.  

The variation in the Member States’ existing SAF production capacities can be attributed to a range 
of factors, including the current availability of certain feedstock (e.g. used cooking oil, forestry 
residues  and  renewable  electricity)  and  their  price  competitiveness  as  well  as  the  investment 
environment in each Member State. Consequently, and based on the announcements made so far, 
the SAF production landscape in the early stages of ReFuelEU Aviation implementation and up to 
the date of this report varies considerably across the EU and differs from the production landscape 
of conventional aviation fuel. However, the fact that the SAF production landscape seems even 
more concentrated than the production of conventional aviation fuels in the EU is not a cause for 
concern per se. All 27 Member States are supplied with conventional aviation fuels today, even 
those with no refining capacity, and the SAF market is still in its early stages.  

Despite  the  geographic  concentration  of  SAF  production  facilities  in  some  Member  States, 
findings from the Airport Survey conducted by Guidehouse indicate that blended SAF are already 
being supplied to a broader geographic area. Furthermore, a substantial proportion of the surveyed 
airports that do not currently have a blended SAF offering are planning to make it available soon. 
This trend points towards an expected significant expansion of the geographic scope of blended 
SAF supply in the coming years, in line with the geographic scope of ReFuelEU Aviation. This 
also  demonstrates  the  readiness  of  the  industry  and  particularly  the  involvement  of  airport 
managing bodies in decarbonising aviation. 

Blended SAF and conventional aviation fuel have different feedstock procurement and production 
pathways, but they have the same supply chains. As mentioned above, SAF must be blended with 
conventional aviation fuel in order to meet ASTM D7566 blend requirements and must be declared 
as Jet A-1. Because of safety reasons 23 and except for small volumes, DefStan 91-091 24 currently 
recommends that the blending takes place upstream of the airport fuel storage depot. As the SAF 
industry grows, blending infrastructure will probably develop in synergy with the existing highly 
complex infrastructure network for conventional aviation fuel. This could be a subject for further 
research. 

Once  blended  and  certified,  the  blended  SAF  can  use  the  same  distribution  infrastructure  as 
conventional aviation fuel. This includes not only shipping and trucking but also interconnected 
infrastructure as defined by Implementing Regulation (EU) 2022/996 25, which allows liquid fuels 
to  be  transported  through  pipeline  networks  (e.g. NATO-CEPS 26  and  the  Exolum  Pipeline 
System 27) using a mass-balance distribution approach 28. Interconnected infrastructure will play a 
crucial role in the distribution of blended SAF. The fact that a large share of the aviation internal 
market is currently supplied through a network of pipelines makes the mass-balance approach a 

23 Blending SAF with fossil kerosene requires trained personnel and dedicated facilities. Having the blending step 
outside the airport limits the risk of off-spec fuels entering an aircraft.  
24 DEF STAN 91-091 - https://www.jig.org/documents/defstan-91-091-issue-15/  
25 https://eur-lex.europa.eu/eli/reg_impl/2022/996/oj  
26 https://www.nato.int/cps/en/natohq/topics_49151.htm  
27 https://exolum.com/en/  
28 Article 30 of the RED. 

8 

 
 
very efficient and cost-effective way of ensuring that blended SAF can reach many airports that 
are  currently  beyond  the  bigger  hubs  and  fuel  infrastructure  managers  should  not  raise 
administrative, procedural or any other kind of barriers to entry to render more difficult or prevent 
the supply of blended SAF through their interconnected infrastructure (e.g. fuel pipeline). Both the 
obligation  to  physically  supply  all  Union  airports  with  blended  SAF  by  2035  and  the  clear 
possibility for other airports  and aircraft operators to  opt into  the  scope of ReFuelEU Aviation 
provide aviation fuel producers and suppliers with the necessary legal certainty and time to ensure 
the provision of blended SAF instead of conventional aviation fuels throughout all their current 
networks. 

2.2.2  Supporting measures 

On  top  of  the  regulatory  certainty  provided  by  the  adoption  of  ReFuelEU  Aviation,  the 
Commission has put in place several supporting measures (described below) to help increase the 
availability of SAF inside and outside the EU; de-risk investments in SAF production in the EU; 
and narrow the price gap between SAF and conventional aviation fuel.  

Regulation  (EU)  2024/1735  (The  Net-Zero  Industry  Act) 29  lists  sustainable  alternative  fuels 
(which  include  both  sustainable  aviation  and  maritime  fuels)  among  the  net-zero  technologies. 
NZIA creates a regulatory framework to boost the competitiveness of EU industry and to advance 
technologies  crucial  for  decarbonisation  while  ensuring  strategic  resilience.  Moreover,  the 
Renewable and Low-Carbon Fuels Value Chain Industrial (RLCF) Alliance 30 was created by the 
Commission together with industry partners to advance the production and supply of renewable 
and  low-carbon  fuels  in  the  aviation  and  waterborne  transport  sectors.  In  2024,  the  Alliance 
launched its project pipeline 31 to help the industry in matchmaking with partners up-stream and 
down-stream, as well as connecting with potential finance providers.   

Both Horizon Europe and the Innovation Fund have provided grants to support SAF technology 
maturity.  So  far,  73  projects  related  to  sustainable  aviation  fuels  were  funded  under  Horizon 
Europe with a budget of about EUR 400 million. Of these, 37 projects and EUR 210 million are 
directly related to the aviation end fuel product. The Innovation Fund has already awarded more 
than  EUR  206  million  to  two  projects  producing  sustainable  aviation  fuels,  one  focusing  on 
synthetic aviation fuel production.  

The  EU  further  supports  SAF  deployment  through  blended  finance.  The  European  Investment 
Bank  (EIB)  is  providing  a  EUR  120  million  loan  to  Repsol  to  support  the  construction  and 
operation  of  an  advanced  biofuels  production  plant  in  Spain 32.  The  bank also  signed,  with  the 
support of the InvestEU programme, a EUR 285 million loan with Moeve for the construction of 

29 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202401735  
30 https://transport.ec.europa.eu/transport-themes/clean-transport/alternative-fuels-sustainable-mobility-
europe/renewable-and-low-carbon-fuels-value-chain-industrial-alliance_en  
31 https://rlcf-alliance-platform.converve.io/pipeline_front.html  
32 https://www.eib.org/en/press/all/2022-551-repsol-and-the-eib-sign-a-eur-120m-loan-agreement-to-finance-the-
first-advanced-biofuels-plant-in-spain  

9 

 
 
another  advanced  biofuels  plant  in  Spain 33.  Moreover,  SAF  is  eligible  under  the  EU–Catalyst 
partnership.  This  public-private  partnership,  bringing  together  the  Commission,  the  European 
Investment  Bank  (EIB)  and  Breakthrough  Energy  Catalyst,  plans  to  mobilise  up  to  EUR  840 
million  between  2023  –  2026  to  accelerate  the  deployment  of  and  rapidly  commercialise 
innovative technologies that will help deliver on the European Green Deal ambitions34.  

Hydrogen can be used directly as a sustainable fuel in zero-emission aircraft or as feedstock in the 
production of SAF, notably of synthetic aviation fuels but is also an elementary component of the 
transition of the energy system. R&I investment in hydrogen is therefore correspondingly higher. 
The  EU  has,  through  the  three  most  recent  R&I  programmes,  initiated  776  projects  related  to 
hydrogen technology since 2007 with more than EUR 2.9 billion allocated. A strong increase in 
the amount of support provided was observed in 2023 35.  

The financial support provided under Directive 2003/87/EC (EU ETS) 36 through the zero-rating37 
of SAF and the additional support for uplift of eligible fuels 38 helps to narrow the price difference 
between conventional aviation fuels and SAF for aircraft operators. 20 million allowances (EUR 
1.6 bn at an allowance price of EUR 80) have been reserved to cover some, or all, of the price gap 
between  conventional  fossil  fuels  and  eligible  alternative  aviation  fuels  uplifted  from  January 
2024. It is important to note that only fuels used on flights covered by ETS compliance obligation 
will be supported 39. 

The Commission also provides technical support on SAF production to Member States through 
the Technical Support Instrument (TSI). For example, on their request, Estonia and Latvia will 
receive  technical  support  to  enhance  SAF  industrial  capabilities,  including  through  a  SAF 
feasibility study, policy recommendations and awareness building. The Commission stands ready 
to  provide  further  technical  support  to  Member  States  for  the  conception,  development  and 
implementation of reforms towards safe, smart and sustainable mobility. 

Moreover, the EU supports global production of SAF. To this end, the EU is providing EUR 4 
million in financial support for feasibility studies and capacity-building in 14 African states and 
India,  under  the  ACT-SAF  programme  implemented  with  ICAO  and  EASA.  The  EU  has 
designated SAF as a 2024 Global Gateway Flagship to support the development, production, and 
use of sustainable aviation fuels. The ACT-SAF project is the starting point for this flagship, with 
work ongoing to further operationalise the SAF Flagship with new activities and projects.  

information: 

https://op.europa.eu/en/publication-detail/-/publication/b82ce4e0-d215-11ee-b9d9-

33 https://www.eib.org/en/press/all/2024-227-eib-and-cepsa-sign-eur285-million-loan-to-finance-the-construction-
of-a-second-generation-biofuels-plant-in-spain  
34 https://ec.europa.eu/commission/presscorner/detail/en/qanda_21_5647  
35 More 
01aa75ed71a1/language-en/format-PDF/source-324740593. 
36 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02003L0087-20240301  
37 Incentive of approximately EUR 250 per tonne of SAF. 
38 This support is introduced under Article 3c(6) of Directive 2003/87/EC (EU ETS). The aim is to narrow the price 
difference between conventional aviation fuels and SAF. 
39 More information: https://climate.ec.europa.eu/document/download/9a82627a-8a5c-4419-93de-
e5ed2d6248eb_en?filename=policy_ets_allowances_for_saf_en.pdf  

10 

 
 
2.2.3  Traceability of SAF 

Due to the nature of aviation  fuels’ infrastructure (e.g. pipelines  and shared  airport  tanks), it is 
difficult to trace the specific molecules of a specific supply from the moment of production and 
until it reaches the aircraft. This issue of traceability is not unique to SAF blends but it is a common 
challenge across all blended transport fuels. To address this challenge, the EU has developed the 
Union Database for Biofuels 40 (UDB), which is an IT system established under Article 31a of the 
RED. It enables the tracing of liquid and gaseous renewable fuels and recycled carbon fuels even 
when they become part of a blended fuel. The UDB enables the affected economic operators to 
decide and verify how sustainable molecules are accounted for and where they are being supplied 
and used. This will ensure transparency, accountability, and safety throughout the supply chain 
until the product is released onto the market as either fully sustainable fuels or blended fuels. In 
accordance  with  Article  10  of  ReFuelEU  Aviation,  all  volumes  of  SAF  supplied  to  the  Union 
airports must be registered in the UDB by aviation fuel suppliers. Further possible extensions of 
the scope of the UDB to provide complete traceability on SAF transactions beyond the point of 
supply are discussed in later chapters of this report.  

40 https://wikis.ec.europa.eu/display/UDBBIS/Union+Database+for+Biofuels+-+Public+wiki  

11 

 
 
 
 
3  The ReFuelEU Aviation SAF flexibility mechanism 

To ensure the successful supply of minimum shares of SAF to the aviation market at the EU level 
while also  avoiding  local  blended SAF  supply shortages, ReFuelEU Aviation  has  introduced  a 
SAF flexibility mechanism for 2025-2034. This mechanism allows aviation fuel suppliers to reach 
the obligated minimum share of SAF as a weighted average over all the Union airports where they 
supply aviation fuel. In practice, this means that aviation fuel suppliers may supply aviation fuels 
containing  higher  shares  of  SAF  in  certain  Union  airports  (provided  those  are  compliant  with 
ASTM  7566  blending  requirements)  to  compensate  for  aviation  fuels  containing  zero  or  lower 
shares of SAF in other Union airports – provided that they supply the minimum total quantity of 
required SAF blend at the EU level. This flexibility is an option but not an obligation for aviation 
fuel suppliers. The range of their discretion includes the contractual agreements they may reach 
with  aircraft  operators  to  decide  how  to  best  use  the  provided  flexibility.  This  mechanism  is 
intended to provide the SAF industry, and especially aviation fuel suppliers, with sufficient time 
to scale up production and supply capacity, while also allowing aviation  fuel suppliers to meet 
their obligations in a cost-effective manner, without reducing the overall environmental ambition 
of ReFuelEU Aviation. However, it may deprive some airports not supplied with blended SAF of 
the positive effects of its use on local air quality. The mechanism also makes it easier for Union 
airports’ managing bodies, aviation fuel suppliers and aircraft operators to make the technological 
and  logistical  investments  in  the  supply  chain  that  are  needed  to  ensure  compliance  with  the 
minimum shares by 2035 in each Union airport – especially given that all aviation fuel supplied to 
Union airports must by then be blended aviation fuels with a significant minimum obligatory share 
of SAF.   

The level of flexibility provided to aviation fuel suppliers under the SAF flexibility mechanism 
also  depends on the interpretation  of the definition of  ‘fuel  supplier’ in  the national  legislation 
transposing the RED, on which ReFuelEU Aviation’s definition of aviation fuel supplier relies. 
Each Member State is responsible for identifying the aviation fuel suppliers whose compliance 
with  the  RED  and  ReFuelEU  Aviation  requirements  they  are  responsible  for  ensuring.  The 
Commission services have carried out extensive consultations with Member States on this matter 
within  the  framework  of  the  implementation  of  ReFuelEU  Aviation.  These  consultations  have 
revealed  that  aviation  fuel  suppliers  are  primarily  defined  at  Member  State  level  and  that  they 
predominantly operate within their respective jurisdictions (although a few operate in two or more 
Member States). The Commission services have been informed that fiscal rules may sometimes 
even require aviation fuel suppliers to have a fiscal residence in a given Member State in order to 
operate in its territory. This would oblige them to operate through a separate national subsidiary 
in that Member State. The Commission services will closely look into this and make sure any fiscal 
requirements comply with the freedom of establishment. ReFuelEU Aviation allows aviation fuel 
suppliers to operate in multiple Member States under the same legal entity.  

ReFuelEU  Aviation  does  not  prevent  aviation  fuel  suppliers  with  difficulties  to  fulfil  their 
obligations from coordinating with other aviation fuel suppliers that may exceed their obligations. 
Such  coordination  could  allow  those  benefiting  from  surplus  of  blended  SAF  at  given  Union 
airports to supply blended SAF on behalf of those facing difficulties. This would, however, require 

12 

 
a restructuring of the EU market of aviation fuel suppliers and such coordination might currently 
be prevented by national legislation or by long-term agreements between aviation fuel suppliers 
and Union airport managing bodies.  

Despite  the possibility  offered by the transitional flexibility  mechanism, aviation  fuel  suppliers 
have not expressed any intention of concentrating the supply of blended SAF at a limited number 
of Union airports. To the contrary, the rules and conditions laid down for aircraft operators when 
claiming the use of SAF in the EU ETS mean that there is greater incentive on the demand side 
for most if not all Union airports to be supplied with blended SAF as soon as possible. This interest 
in supplying as many airports as possible is increased by the fact that the infrastructure for the 
supply chains of both blended and non-blended aviation fuels is shared, especially during the last 
stage of the supply chain to the EU’s airports. Moreover, and as mentioned in the previous chapter, 
the  use  of  the  mass-balance  approach  to  distributing  blended  SAF  through  interconnected 
infrastructure allows aviation fuel suppliers  to reach a large share of Union airports efficiently, 
cost-effectively and without any additional infrastructure cost.  

All  these  market  features  considerably  restrict  opportunities  to  geographically  concentrate  the 
supply of blended SAF in a reduced number of Union airports and it is expected that blended SAF 
will be supplied in at least one Union airport in each Member State by the beginning of the supply 
obligations in 2025. They also point towards a quicker spread of the blended SAF in line with the 
minimum shares of SAF required in ReFuelEU Aviation. The 10-year flexibility period is much 
longer than the 5-year period initially proposed by the Commission. This factor – combined with 
the features of the market and the willingness shown by all stakeholders to facilitate the supply of 
blended SAF – suggest that the flexibility mechanism of ReFuelEU Aviation currently provides 
aviation fuel suppliers with enough flexibility to meet their obligations. The commitment of public 
and  private  investors  and  aviation  fuel  producers  to  speeding  up  the  production  of  synthetic 
aviation fuels in the EU remains crucial to achieving this aim. 

13 

 
 
 
4  Objectives and industry positions on possible improvements and 

additional measures to the SAF flexibility mechanism 

Article  15(2)  of  ReFuelEU  Aviation  requires  the  Commission  to  assess and  report  on  possible 
improvements or additional measures to the existing SAF flexibility mechanism with a view to 
further facilitating the supply and uptake of SAF during the 10-year flexibility period.  

The article differs from the scope of ReFuelEU Aviation in at least three aspects: 

•  Firstly, it requires the Commission to reflect and report on the tradability of SAF but not 
on the tradability of aviation fuel that contains shares of SAF (i.e. blended SAF) – as is the 
case for the supply obligations.  

•  Secondly,  this  reflection  process  must  cover  the  option  of  ‘setting  up  or  recognising  a 
system of tradability of SAF to enable fuel supply in the EU without it being physically 
connected to  a supply site’. In other words,  this  would be  a tradability system  for SAF 
sustainability certificates that could be decoupled from the traceability of their related SAF 
physical molecules.  

•  Thirdly, it requires the Commission to reflect on how such a system ‘could enable aircraft 
operators or fuel suppliers, or both, to purchase SAF through contractual arrangements with 
aviation fuel suppliers and to claim the use of SAF at Union airports’. The Commission is 
required to take into account the ability of aircraft operators to claim the use of SAF, even 
though they are not obliged to use minimum shares of SAF under this Regulation.  

It is worth noting that, under EU law, each quantity of SAF can be claimed for different purposes 
by  different  economic  operators.  Aviation  fuel  suppliers  can  claim  the  supply  of  SAF  for  the 
purposes of complying with their ReFuelEU Aviation obligations and contributing to the national 
RED  targets.  EU  law  does  not  prevent  a  batch  of  SAF  to  be  certified  under  more  than  one 
certification scheme (e.g. RED, CORSIA certified fuels). Aircraft operators can claim the use of a 
given quantity of SAF under one greenhouse gas reduction scheme, including the EU ETS and 
ICAO’s CORSIA. They can claim the same quantity of SAF also under the EU Taxonomy or the 
Flight Emissions Label 41. However, it is of paramount importance for the robustness, stringency 
and accuracy of the market that only one aviation fuel supplier and only one aircraft operator can 
claim any given quantity of SAF respectively.  

4.1  Objectives 

As  required  by  Article 15(2)  of  ReFuelEU  Aviation,  the  Commission  will  assess  possible 
improvements and additional measures to the SAF flexibility mechanism explored in this report 
with a view to further facilitating the supply and uptake of SAF during the flexibility period. The 
assessment must include the potential set up or recognition of a system of tradability of SAF to 
enable fuel supply in the Union without it being physically connected to a supply site.  

41 Established under Regulation (EU) 2024/3170 - https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32024R3170.  

14 

 
 
The assessment must also consider and preserve the different objectives of ReFuelEU Aviation 
and of the SAF flexibility mechanism, namely:  

-  preserving  the  air  transport  market’s  level  playing  field  between  economic  operators 

- 

globally and across the EU (e.g. recital 3); 
ramping up the production, supply and uptake of SAF and blended SAF in the EU in line 
with the regulatory framework and commercial freedom (e.g. recital 2); 

-  promote industrial opportunities for all EU regions (e.g. recital 47); 
- 

strengthening  the  EU’s  energy  security  of  supply  and  decreasing  reliance  on  non-EU 
countries (e.g. recital 52); 
allowing Union airports’ managing bodies, aviation fuel suppliers and aircraft operators to 
make  the  technological  and  logistical  investments  needed  in  order  to  comply  with  the 
physical supply obligations at all Union airports as from 2035 (e.g. recital 45); 

- 

-  mitigating  any  risk  of  double-counting,  misuse  or  fraud  of  any  kind  of  sustainable 
certificates that accredit the production and use of a given batch of SAF in the  EU (e.g. 
recital 48). 

4.2 

Industry positions 

An  extensive  stakeholder  consultation  process  conducted  by  Guidehouse  and  the  Commission 
services has allowed the industry to share its concerns and expectations regarding the upcoming 
obligations  under  ReFuelEU  Aviation  and,  more  particularly,  regarding  the  SAF  flexibility 
mechanism.  This  consultation  made  it  possible  to  capture  a  clear  understanding  of  the  various 
industry positions on key issues. Two stakeholder workshops were organised and many bilateral 
meetings  were held.  Moreover, many industry associations and organisations have shared  their 
position  papers  and  technical  papers  on  the  potential  implementation  of  a  SAF  accounting 
mechanism that could enable virtual trading of SAF certificates between relevant operators. As 
highlighted in the Guidehouse support study, different parts of the industry (including within the 
same  stakeholder  groups)  have  expressed  different  and  sometimes  opposing  concerns  and 
expectations,  notably  regarding  the possibility of enabling virtual  trading  of SAF  sustainability 
certificates. The consultation revealed that there is no unified industry-wide position neither on the 
design or the necessity of implementing such an accounting mechanism system for the purposes 
of complying with current blended SAF obligations and of claiming their use under other pieces 
of EU law, such as the EU ETS. 

It  is  worth  noting,  however,  that  there  is  a  broad  consensus  across  the  industry  regarding  two 
parameters already imposed by ReFuelEU Aviation: (i) any further flexibility through any sort of 
SAF accounting mechanism would only be relevant while the blended obligatory shares of SAF 
remain  low  until  2035;  and  (ii) a  SAF  accounting  mechanism  could  only  ensure  the  necessary 
stringency, robustness and trust if it were to be kept within the boundaries of the EU’s territory, in 
line with the scope of ReFuelEU Aviation.  

The main issues captured during the consultation are summarised below in four categories: 

• 
• 

issues related to blended SAF availability at Union airports; 
issues related to SAF price; 

15 

 
issues related to the transparency and robustness of sustainability claims; 

• 
•  and  issues  related  to  the  possibility  of  trading  SAF  certificates  virtually  (either  on  the 

supply side or on both the supply and demand sides). 

4.2.1  Availability of blended SAF at Union airports 

As described in the previous chapter, the introduction of the SAF flexibility mechanism allows 
aviation fuel suppliers to supply aviation fuel containing higher shares of SAF in certain Union 
airports to compensate for the supply of aviation fuel with none or lower shares of SAF in other 
Union  airports.  Associations  of  aircraft  operators  have  expressed  their  concerns  regarding  the 
geographic  concentration  of  blended  SAF  in  just  few  Union  airports,  arguing  that  this  could 
potentially create distortions of competition between aircraft operators, notably due to the impact 
of such geographic concentration on their ability to decarbonise their operations and on the price 
of aviation fuel.  

The Commission finds that the risk of a significant geographic concentration of blended SAF in 
few Union airports is limited. Firstly (as highlighted in the previous chapter), it appears that most 
aviation fuel suppliers operate only within the borders of their respective Member State, so the 
possibility of significant geographic concentration is already largely limited to national markets. 
Secondly, many Union airport managing bodies have clearly communicated their intention to make 
blended  SAF  available  in  the  coming  years  on  their  premises.  Thirdly,  projects  for  new  SAF 
capacities are appearing in various locations across the EU and can be expected to feed into the 
existing regional supply chains of blended SAF. 

Some aircraft operators have nevertheless expressed concern that enabling virtual trading of SAF 
certificates through a SAF accounting mechanism could increase their willingness to sign long-
term offtake agreements with aviation fuel producers or suppliers, especially for synthetic aviation 
fuels. Aircraft operators argue that this could enable fuel producers to make a final investment 
decision  regarding  the  first  generation  of  projects.  However,  the  factors  that  prevent  aircraft 
operators from signing long-term offtake agreements are multiple and complex. Depending on the 
circumstances, aircraft operators’ appetite to conclude long-term offtake agreements with aviation 
fuel  suppliers  may  be  more  related  to  their  own  financial  situation  or  to  their  commercial  and 
business plans for their global and regional networks than to the availability of the fuel itself. It 
might also depend on their current commercial agreements with their aviation fuel suppliers for 
the  supply  of  blended  SAF  at  their  network  of  Union  airports  in  order  to  reduce  their  carbon-
footprint-related costs under the EU ETS and CORSIA. 

There is no guarantee that long-term offtake agreements would contain binding commitments from 
aircraft  operators  that  would  be  sufficient  to  make  the  synthetic  aviation  fuel  projects  more 
bankable.  There  is  also  no  guarantee  that  aircraft  operators  would  sign  long-term  offtake 
agreements just because they could virtually purchase SAF certificates – given that many other 
economic and operational considerations are central to such decisions, such as those related to the 
high costs of SAF and the uncertainty around the evolution of their price, the cyclical  aviation 
market fluctuations and even the level of experience of the procurement teams with those types of 
new fuels. A mechanism for the aggregation of demand and supply for hydrogen and its derivates 

16 

 
42 could facilitate conclusion of offtake agreements for synthetic aviation fuels covering the entire 
investment and commercial maturity of projects. Moreover, as examined in the EIB study on the 
sustainable liquid fuels 43, the early movers face challenges related to the higher production costs 
related  to  the  first-of-a  kind  industrial  scale  plants.  Targeted  actions  and  public  support  are 
therefore required to increase the bankability of SAF projects and de-risk investments (particularly 
for synthetic aviation fuels).  

Aircraft  operators  are  not  obliged  to  refuel  blended  SAF  under  ReFuelEU  Aviation,  so  the 
unavailability  of  blended  SAF  in  some  Union  airports  cannot  distort  competition.  Aircraft 
operators can secure their access to SAF and demonstrate their willingness to decarbonise their 
operations  through  contractual  commitments  with  aviation  fuel  producers  for  physical  blended 
SAF deliveries. This would greatly support the development of the EU’s SAF market. 

4.2.2  Prices of SAF 

4.2.2.1  Production and transportation costs of SAF 

The price of SAF can have a significant impact on the willingness of aircraft operators to uptake 
blended SAF – given that fuel costs currently represent between 25% and 30% of their operational 
costs. In 2023, Price Reporting Agencies (PRA) reported an average price of conventional aviation 
fuel in north-western European hubs of 816 EUR/tonne. Also in 2023, the average price of aviation 
biofuels (e.g. hydrotreated esters and fatty acids (HEFA)) in the EU was reported to be equal to 
2 768 EUR/tonne. Considering the current unavailability of synthetic aviation fuels on the market, 
EASA  has  developed  and  applied  a  bottom-up  levelized  cost  of  production  estimation-based 
methodology to determine the minimum fuel selling price of such fuels 44. Depending on the source 
of CO2 used in the production process, the production cost of synthetic aviation fuels is currently 
estimated  to  range  between  6  600  EUR/tonne  to  8  700  EUR/tonne.  The  high  price  range  is 
explained  by  the  many  challenges  faced  by  the  production  of  such  fuels,  such  as  the  cost  and 
availability of renewable electricity as well as the cost and availability of eligible CO2.  

When translated into the average blends required in 2030, the impact assessment 45 for ReFuelEU 
Aviation estimated a fuel cost increase for aircraft operators of 3.3% and a consequent increase in 
the ticket price of less than 1%. However, due to the SAF flexibility mechanism, the actual blends 
(e.g. level of blended SAF) may be much higher in some locations and much lower (or even zero) 
in  other  locations.  In  addition,  aviation  fuel  suppliers’  pricing  policies  may  differ,  between 
suppliers and between airports. It has been observed in past SAF mandates (e.g. in France), before 
ReFuelEU  Aviation  entered  into  force,  that  aviation  fuel  suppliers  sometimes  charge  the  same 
average  SAF  premium  fee  to  all  aircraft  operators,  regardless  of  where  the  blended  SAF  is 
physically supplied and of which aircraft operator will actually receive it. Such a pricing strategy 

42 https://energy.ec.europa.eu/topics/energy-systems-integration/hydrogen/european-hydrogen-bank/pilot-
mechanism-support-market-development-hydrogen_en 
43 EIB, Financing sustainable liquid fuel projects in Europe: Identifying barriers and overcoming them, 2024 – 
https://www.eib.org/attachments/lucalli/20240101_financing_sustainable_liquid_fuel_projects_in_europe_en.pdf 
44 EASA, State of the EU SAF market in 2023, 2024. 
45 Study supporting the impact assessment of the ReFuelEU Aviation initiative – https://op.europa.eu/en/publication-
detail/-/publication/46892bd0-0b95-11ec-adb1-01aa75ed71a1. 

17 

 
 
could result from the scarcity of SAF on the market and the absence of a centralised traceability 
tool, such as the UDB. Such a distribution of additional SAF costs between all aircraft operators 
is  expected  to  create  competitive  distortions  among  aircraft  operators  –  especially  when  one 
considers that the benefits of using SAF (e.g. the EU ETS benefits or the Flight Emissions Label) 
can  only  be  claimed  by  those  to  whom  SAF  is  physically  delivered.  Similar  consequences  are 
expected  to  be  observed  if  aviation  fuel  suppliers  decide  to  artificially  increase  the  price  of 
conventional  aviation  fuel  for  all  aircraft  operators  to  reduce  the  price  gap  for  those  aircraft 
operators supplied with the blended SAF. Commercial practices intended to artificially increase 
the price of conventional aviation fuel for all aircraft operators in order to reduce the burden on 
those getting the physical SAF – and claiming the economic benefits linked to its use – would 
distort  the  level  playing field  and  therefore  would  amount  to  unfair  commercial  practices.  The 
Commission services will pay particularly close attention to any complaints in this regard and take 
them into account in any possible future evaluation and impact assessment of ReFuelEU Aviation. 
The ramping-up of SAF production in the EU coupled with the implementation of the UDB, which 
will  trace  eligible  fuels  under  ReFuelEU  Aviation,  should  prevent  aviation  fuel  suppliers  from 
applying unfair or distortive pricing strategies.  

Aircraft operators have often expressed concerns about the high prices of SAF and the impact of 
ReFuelEU Aviation on their costs of operation. The scarcity of SAF on the market and their high 
prices were precisely singled out as drivers that justified the regulatory intervention of ReFuelEU 
Aviation. The goal of ReFuelEU Aviation is to scale up the supply and uptake of SAF through 
increased shares of SAF in aviation fuel. As shown in Chapter 2, the supply obligations provide 
the market certainty needed to trigger new SAF production and supply capacities and allow the 
creation of a more liquid market for SAF. The increase in scale will lead to economies of scale, 
production efficiencies and industrial maturity that are expected to reduce the prices of SAF and 
consequently the relative price of blended SAF throughout the EU market. ReFuelEU Aviation 
will ensure a level playing field where both aircraft operators and Union airports can compete to 
maintain the right level of connectivity at affordable prices for all EU regions. Moreover, on top 
of benefiting from the zero CO2-rating under the EU ETS, the use of SAF will also benefit until 
2030 of the 20 million allowances reserved for the uplift of eligible aviation fuels that will help to 
kick-start the market.  

Many aircraft operators have nevertheless claimed that enabling virtual trading of SAF certificates 
could  further  decrease  the  prices  of  SAF  by  concentrating  even  further  the  supply  in  a  small 
number of Union airports and could thus reduce logistics costs. The geographical concentration of 
SAF supply could potentially reduce transportation costs in a few Union airports that are located 
far  from  any  SAF  blending  or  production  facility  and  are  not  linked  to  any  interconnected 
infrastructure, but it is likely that the current conventional aviation fuel prices at such airports are 
already  higher  due  to  similar  supply-chain  challenges.  A  further  analysis  of  concrete  cases  is 
needed to demonstrate the  alleged  added difficulties and increases in  costs that a blended SAF 
supply could entail. Neither external consultants  nor the Commission  services themselves have 
been able to gather any data substantiating a significant increase of the fuel price attributable to 
the transport of SAF. In addition, and as mentioned in Chapter 3, ReFuelEU Aviation does not 
prevent  aviation  fuel  suppliers  experiencing  difficulties  in  accessing  blended  SAF  from 

18 

 
coordinating (as far as is legally permissible) with aviation fuel suppliers that have easier access 
to blended SAF, in order to benefit from their supply rights at given Union airports and supply 
blended SAF  in  their place. Lastly,  the geographic concentration of blended  SAF at  just  a few 
Union airports might slow down necessary investment (for instance, in the development of new 
SAF production and blending facilities throughout the EU) that would ensure the fulfilment of the 
uniform blended shares requirement at all Union airports as from 2035.  

Virtual trading of SAF sustainability certificates may bring new dynamics to the market on the 
demand side, but it is not clear whether this would have any real impact on the production side at 
this early stage. The possibility that prices may fall quicker than expected during the first years of 
the supply obligations may discourage aircraft operators -very sensitive to fuel-related operational 
costs-  into  entering  long-term  offtake  agreements  today,  for  fear  of  finding  themselves  at  a 
competitive disadvantage compared to late movers. Uncertainty regarding SAF production costs 
and SAF prices, notably for synthetic aviation fuels, seem to carry a greater risk of leading to a 
lack of commitment from the demand side to engage into long-term offtake agreements than the 
availability of the fuels  themselves  by 2030. In a virtual  market,  aircraft  operators with  higher 
financial capacity to sign long-term offtake agreements may secure larger amounts of SAF at better 
prices – while other aircraft operators may struggle with paying higher prices for the remaining 
SAF in the market or may be obliged to buy it through intermediaries, in the current context of 
SAF and synthetic aviation fuel scarcity.  

From the supply side – particularly but not only for synthetic aviation fuels – the biggest challenge 
faced  by  the  industry  seems  to  be  the  delay  of  final  investment  decisions  (FIDs)  for  the  fuel 
production  projects  related  to  the  offtake  challenge  rather  than  technical  or  technological 
challenge. Fossil fuel producers still seem to keep prioritising investments in the less risky area of 
current  fossil  fuel  technologies.  At  the  same  time,  small  synthetic  aviation  fuel  producers  are 
struggling  to  scale  up  their  operations  because  they  cannot  find  investors  ready  to  assume  the 
higher first-mover risks in a market where the range of price uncertainty is too large to make long-
term offtake agreements attractive on the demand side. Moreover, some fossil fuel producers have 
recently halted or delayed their publicly announced investment in aviation biofuels. The fact that 
the expected price of HEFA-based fuels may only be double – instead of triple – the current price 
of conventional aviation fuel (as some projections may have wrongly assumed) may have impacted 
their  decisions.  Other  possible  reasons  mentioned  by  the  industry  for  the  delay  in  first  final 
investment decisions (FIDs) for synthetic aviation fuel production facilities may be related to the 
lack of clarity regarding any possible public support to help de-risk early movers’ decisions on the 
demand  and/or  supply  sides,  and  the  uncertainty  regarding  the  scale  of  the  national  penalty 
schemes not yet adopted by the Member States 46. 

Stakeholders  have  not  been  able  to  demonstrate  how  a  virtual  market  could  help  solve  these 
financial and commercial obstacles and how it could stimulate the production of SAF more than 

46 In the absence of a synthetic aviation fuel market, the hypothetical price and level of penalties are to be calculated 
on the basis of a bottom-up production cost estimation. These costs can be up to four times greater depending on the 
assumptions. This means that investors do not yet know what would be the impact that penalties may really have on 
financial decisions.  

19 

 
 
the policy framework already in place. Close monitoring of the market and the effectiveness of the 
support  measures  is  necessary.  Further  public  support  to  de-risk  first  movers’  investments  (on 
either  or  both  demand  and  supply  sides)  may  be  considered  to  unlock  the  current  impasse  on 
investments. 

4.2.2.2  Market position of aviation fuel suppliers  

Several  aircraft  operators  have  expressed  concerns  about  the  market  position  of  aviation  fuel 
suppliers at Union airports and their capacity to impose higher shares of blended SAF than required 
by ReFuelEU Aviation or to impose significantly higher prices for aviation fuels (with or without 
supplying SAF blends). These aircraft operators argue that the high level of concentration (and in 
some cases the monopolistic nature of the aviation fuel market) combined with the legal obligation 
to refuel 47 force them into unequal commercial relationships with aviation fuel suppliers, resulting 
in  higher  prices  of  blended  SAF.  Some  of  these  aircraft  operators  see  the  implementation  of  a 
virtual  market  for  SAF  sustainability  certificates  as  an  opportunity  to  decrease  their  current 
reliance on local aviation fuel suppliers and thus improve the balance in negotiating power between 
the two sets of economic operators. 

The  Commission  could  only  gather  indirect  information  on  a  small  number  of  airports  in  two 
Member States, where only one or two aviation fuel suppliers are operating and where agreements 
between airport managing bodies and aviation fuel suppliers might have led to such a situation. It 
is, however, unclear how a SAF accounting mechanism could mitigate these concerns – given that 
aircraft operators are in any case required by Article 5 of ReFuelEU Aviation to uplift a minimum 
amount of aviation fuel when departing from a Union airport and are therefore already required to 
source physical aviation fuels from such an airport. In any event, all market participants (including 
aircraft  operators)  are  entitled  to  inform  the  authorities  (e.g. the  Commission  and  national 
competition and regulatory authorities) of any market behaviour by other participants that they 
believe to be in breach of EU or national competition law, including in relation to the obligation 
to refuel minimum quantities under Article 5.  

Union airport managing bodies must comply with their obligation under Article 6(1) of ReFuelEU 
Aviation  to  facilitate  to  aircraft  operators  the  access  to  aviation  fuels  containing  the  minimum 
shares of SAF. If a Union airport managing body fails to comply with that obligation (either by 
blocking the supply of blended SAF or by imposing the supply of blend levels higher than the legal 
obligation), aircraft operators may, as provided for in Article 6(2) of ReFuelEU Aviation, report 
to the competent authorities their difficulties in accessing aviation fuels that contain the minimum 
shares of SAF required by ReFuelEU Aviation. 

4.2.3 

Increased transparency and robustness of claims, including for the voluntary 
market 

Aircraft  operators  and  Union  airport  managing  bodies  have  highlighted  a  lack  of  transparency 
regarding the supply of blended SAF in the EU market. They state that they have difficulties in 
collecting the relevant documentation needed to claim the benefits associated with the use of SAF 

47 Article 5 of ReFuelEU Aviation. 

20 

 
 
and even in  collecting documentation  to  prove  that they are being  supplied with  blended  SAF. 
They argue that such a lack of transparency may reduce the efficiency of the incentives provided 
for the use of SAF under current EU law.  

Article 9(2) of ReFuelEU Aviation requires aviation fuel suppliers to provide, free of charge, the 
information  that  aircraft  operators  need  in  order  to  meet  their  reporting  obligations  under 
ReFuelEU Aviation or under a greenhouse gas scheme (e.g. the EU ETS, ICAO’s CORSIA). This 
information includes the amount of SAF and the type of SAF supplied. The UDB, which was set 
up under Article 31a of RED, could facilitate transparency and traceability for SAF transactions 
and consumption on the market. Moreover, in a context where the industry is shifting from mainly 
using a single product (conventional aviation fuel) to using a variety of products (SAF), traceability 
of such products along the entire value chain also ensures safe use.  

Several aircraft operators have requested that the sustainable fuel traceability requirement should 
be extended to the voluntary market. They argue that a centralised EU system that registers both 
obligated  and  voluntary  supply  of  SAF  would  increase  economic  operators’  and  citizens’ 
confidence in the SAF market. They also argue that it could promote not only the fulfilment of the 
obligatory shares but also the supply of blended SAF above the minimum shares of ReFuelEU 
Aviation. The voluntary market for blended SAF is closely linked to the Scope 3 emissions 48 of 
companies that use aviation services. Their readiness to pay a premium for the use of blended SAF 
may depend heavily on the transparency and robustness of the voluntary SAF market.  

4.2.4  Enabling  virtual  trading  of  SAF  sustainability  certificates  through  a  SAF 

accounting mechanism 

Many aircraft operators (particularly in the cargo and the general aviation sectors and long-haul 
aviation operators 49) are willing to take advantage of the momentum created by the early stages 
of developments in the SAF market to set up a system of tradability of SAF - or a SAF accounting 
mechanism - to enable a virtual market for SAF sustainability certificates which could share some 
similar features with the markets allowed under the RED in some Member States for land biofuels 
or  green  electricity  (e.g. the  Hernieuwbare  brandstofeenheden 50  (HBE)  system  in  the 
Netherlands). However, stakeholders have highlighted the point that such a virtual market for SAF 
sustainability certificates should not only be set up for the supply side (e.g. aviation fuel suppliers) 
but should also cover the demand side (e.g. aircraft operators). Aircraft operators would thus be 
able  to  claim,  under  relevant  EU  legislation,  the  benefits  of  using  SAF  based  strictly  on  the 
purchase of SAF sustainability certificates and regardless of where the blended SAF are physically 
delivered.  

The  stakeholders  mentioned  in  the  previous  paragraph  argue  that  a  virtual  market  for  SAF 
sustainability certificates would create a larger market for SAF than the current one. Any volume 
of SAF  supplied in  the EU could  be purchased  by any aircraft operator, regardless  of where it 
operates from in the EU. They argue that such a  market would increase  competition and could 

48 https://ghgprotocol.org/sites/default/files/2022-12/FAQ.pdf  
49 Air carriers with a large number of routes flying outside EEA and EU ETS scope. 
50 https://www.emissionsauthority.nl/topics/general---energy-for-transport/renewable-energy-units 

21 

 
 
therefore reduce the prices of SAF and upscale their production. The mass balance system which 
provides  flexibility  for  the  supply  and  uptake  of  blended  SAF  at  Union  airports  is  already 
improving the situation in much of the EU’s aviation market. However, aircraft operators argue 
that they often depend on only a few aviation fuel suppliers (or even just one) at each airport. This 
greatly restricts aircraft operators’ market power and ability to scale up purchases of blended SAF 
at lower prices. The Guidehouse Airport Survey showed that 43% of the airports surveyed have 
reported two or less aviation fuel suppliers operating at their facility.  

In general, airport managing bodies tend to support the idea of setting up a virtual market for SAF 
sustainability certificates. However, they have very different views on the scope and features of 
such a virtual market. They make two main points.  

-  A large majority of Union airport managing bodies and those intending to opt in are fully 
committed  to  the  decarbonisation  of  the  sector.  They  are  therefore  working  to  secure  a 
permanent supply of blended SAF on their premises – even if it is only virtual.  

-  Smaller  and  regional  airports  are  concerned  that  allowing  virtual  trading  may  prompt 
aviation fuel suppliers to decide, while SAF remains scarce, to concentrate all their supply 
in the bigger hubs. They argue that such a virtual market could put secondary airports at a 
competitive  disadvantage  compared  with  the  bigger  hubs  –  as  regards  ability  to  attract 
aircraft operators interested in using high shares of blended SAF.  

Aviation  fuel  suppliers  are  generally  less  vocal  regarding  the  potential  virtual  market  for  SAF 
sustainability certificates, but they generally do not express opposition. Some shared their concerns 
regarding  the  potentially  complex  implementation  of  a  regulated  virtual  market  for  SAF  and 
requested more simple and straightforward solutions. 

There is a large spectrum of possible features, requirements and technical tools necessary for the 
implementation of such a regulated virtual market, especially if the intention is to cover both the 
supply  and  demand  sides.  It  is  worth  noting  that  a  regulated  virtual  market  for  sustainability 
certificates for the demand side does not exist anywhere in the world for any kind of energy use. 
Even  if  the  private  sector  has  already  started  reflecting  on  similar  systems  for  the  voluntary 
volumes, none of them encompasses the scale and complexity required to cover both the supply 
and demand sides for a market as large as the EU’s aviation market – and on a regulated rather 
than merely voluntary basis.  

Many concerns shared by stakeholders (particularly aircraft operators) – which they expect the 
implementation of a SAF accounting mechanism in the EU to address and mitigate – appear to be 
linked to traceability issues rather than to tradability as such. The Commission has not yet obtained 
any evidence that the virtual trading of SAF sustainability certificates would be a decisive factor 
to really increase production in the EU, improve the physical availability of blended SAF across 
the EU or reduce their prices. Moreover, the impact of such a virtual market (particularly on the 
demand side) would require further assessment of several pieces of EU legislation and their related 
national  transpositions  (e.g. the  RED,  EU  ETS,  ReFuelEU  Aviation  and  Directive  (EU) 

22 

 
2024/1788 51 (the Gas Directive)). For instance, the EU ETS does not allow aircraft operators to 
claim the use of blended SAF if these are not physically delivered to them. 

As  already  explained  in  Chapter 3,  aviation  fuel  suppliers  have  not  expressed  any  intention  or 
shown any sign of actively seeking to supply blended SAF to only a limited number of airports at 
this stage, and they are obliged to supply to all as of 2035. Moreover, most airport managing bodies 
are actively working to facilitate access to blended SAF on their premises. Possible bottlenecks 
due to a lack of blending facilities near refineries and fuel transportation networks may be better 
and more efficiently cleared through administrative and financial help rather than by setting up a 
virtual market for SAF sustainability certificates. The potential negative effects of anticompetitive 
behaviour by market participants can be mitigated by enhancing market transparency and through 
the intervention of relevant competition authorities. 

The positive impacts on price of a virtual market remain uncertain in this new and low volume 
market. Such a virtual market might have a detrimental impact on smaller airlines and regional 
airports  that  would  not  be  able  to  compete  for  the  currently  limited  supply  of  blended  SAF. 
Moreover,  a virtual  market  could  attract  new intermediaries and  the emergence of  a secondary 
market dominated by a few investors that could exploit the benefits of economies of scale without 
necessarily  passing them  on to  the aircraft  operators. Those intermediaries could  make  it more 
difficult for aviation fuel suppliers to purchase the SAF shares they need to fulfil their obligations 
under ReFuelEU Aviation. They could also establish themselves in a strong position during the 
early stages of the new market and exclude future entrants to the market, leaving no space for new 
aviation fuel suppliers at airports and without achieving the goal of broader competition in blended 
SAF supply at airports that is demanded by aircraft operators. 

51 https://eur-lex.europa.eu/eli/dir/2024/1788  

23 

 
 
 
 
5  Possible improvements and additional measures to the SAF 

flexibility mechanism. 

The  flexibility  options  explored  in  this  chapter  are  intended  to  address  the  risks  and  concerns 
identified  in  Chapter  4  for  all  stakeholders,  while  also  respecting  the  objectives  of  ReFuelEU 
Aviation.  The  aim  is  not  only  to  facilitate  the  supply  and  uptake  of  SAF  during  the  flexibility 
period (2025-2034) – but also to preserve the environmental benefits of EU regulations and the 
level playing field for operators across the EU and globally, and to support the aviation fuel supply 
industry in preparing its supply chain to comply with the mandatory physical supply of blended 
SAF  at  all  Union  airports  from  2035  onward.  To  this  end,  this  chapter  focuses  on  (i) possible 
improvements related to the traceability of SAF and their sustainability certificates; and (ii) the 
impact of the possible virtual tradability of such certificates. 

5.1  Potential improvements through changes in the Union Database for Biofuels (UDB) 

The UDB, which has been established under Article 31a of the RED, ensures market transparency, 
traceability, and safety in the supply chain for renewable and low-carbon fuels – mitigating the 
risks  of  irregularities,  fraud  and  double-counting  related  to  such  fuels  and  thereby  supporting 
efforts  to  meet  the  EU’s  ambitious  decarbonisation  targets.  The  system  globally  traces,  on  a 
transaction basis, fuels  that  are  supplied on the  EU market  from  the point  of origin  of the  raw 
materials  to  the  point  that  they  are  released  on  the  EU  market  for  final  consumption.  Since 
15 January 2024,  the  UDB  has  been  open  for  online  registration  by  the  relevant  economic 
operators of transactions of biofuels in the EU. It will be extended to other types of fuels eligible 
under  the  RED  and  the  Gas  Directive,  effectively  covering  all  types  of  eligible  fuels  under 
ReFuelEU Aviation. Notably, Article 31a of the RED obliges the Commission to set up the UDB 
by  21 November 2024  to  enable  tracing  of  all  renewable  fuels  and  recycled  carbon  fuels. 
Moreover,  Article 9(11)  of  the  Gas  Directive  requires  tracing  of  low-carbon  fuels  through  the 
UDB.  

Article 10(d)  of  ReFuelEU  Aviation  requires  aviation  fuel  suppliers  to  report  the  content  of 
aromatics and naphthalene by percentage volume and of sulphur by percentage mass in aviation 
fuel supplied by batch, by Union airport and at EU level. This requirement implies that aviation 
fuel  suppliers  must,  as  part  of  their  UDB  reporting,  provide  a  reference  to  and  a  copy  of  the 
certificates of quality received at the conventional aviation fuel production or blending point (or 
equivalent certificate), so that they can prove the authenticity of the information reported for both 
the fossil and the blended SAF batches. This requirement also helps to ensure the safety of using 
such fuels, but the reporting obligation equally implies that there is no requirement to re-test the 
blended  batches  at  the  delivery  sites  –  because  the  information  encoded  in  the  UDB  with  the 
certificates should be enough to demonstrate the quality of the fuel supplied in line with recital 30 
of ReFuelEU Aviation.  

The current design of the UDB already provides valuable traceability to all relevant stakeholders, 
but additional improvements to the database could further address and mitigate their concerns.  

24 

 
5.1.1  Extend traceability of SAF to aircraft operators 

SAF  traceability  in  the  UDB  currently  ends  when  aviation  fuel  suppliers  release  the  SAF  for 
consumption at Union airports. The system does not trace the identity of the buyers (in this case, 
the aircraft operators). Under Article 9(2) and (3) of ReFuelEU Aviation, aviation fuel suppliers 
are required to provide, free of charge, relevant and accurate information about all aviation fuels 
supplied to aircraft operators. This improves aircraft operators’ ability to view the volumes of SAF 
they are supplied with. However, the information-sharing process could be made more efficient 
and  further  streamlined  to  easily  provide  accurate  real-time  information  on  SAF  transactions 
between  aviation  fuel  suppliers and aircraft operators regarding  the provided  sustainability  and 
fuel quality certificates that prove the authenticity of the reported information.  

Aircraft operators’ lack of real time visibility of blended SAF deliveries is a significant barrier to 
the ramping-up of SAF uptake. It also makes it more difficult to properly implement and enforce 
the Regulation. Enlarging the scope of the UDB to extend SAF traceability to the final consumers 
(i.e. the  aircraft  operators)  could  provide  stakeholders  with  accurate  information.  This  would 
improve their ability to report and account for the fuels supplied – thus avoiding the risk of double-
claiming, irregularities and fraud as well as facilitating compliance and enforcement. This could 
also facilitate the transfer of relevant documents for claiming benefits for the use of SAF under 
GHG reduction schemes such as the EU ETS, in line with Article 9 of ReFuelEU Aviation. This 
extended traceability would also support the reporting and verification of SAF volumes purchased 
and claimed under the EU Taxonomy or the Flight Emissions Label. 

5.1.2  Extend coverage of the UDB to voluntary volumes of SAF supply 

Voluntary supply of SAF refers to volumes of SAF supplied to Union airports that are not claimed 
by aviation fuel suppliers for the purpose of legal compliance with SAF supply obligations under 
ReFuelEU Aviation. Some aircraft operators, typically cargo and business aviation airlines, have 
expressed the importance of differentiating voluntary from mandatory SAF supply for their clients 
that wish to reduce their indirect emissions when using aircraft operator’s flying services (i.e. their 
scope 3 emissions). Aircraft operators claim that such clients are interested and willing to pay the 
SAF  premium  cost  provided  that  the  SAF  volumes  are  supplied  above  the  minimum  shares 
required under ReFuelEU Aviation. It is expected that the SAF production capacity will exceed 
the minimum required volumes in the first years of application of the Regulation, so the voluntary 
market may have an important role to play in the market’s development. 

The  UDB  does  not  currently  differentiate  between  voluntary  and  mandatory  blended  SAF 
volumes, leaving aircraft operators unable to verify from the UDB if specific SAF volumes were 
used  to  meet  the  supplier’s  obligations.  However,  in  some  cases,  aircraft  operators  need  this 
information in order to fulfil the requests of their customers who would be willing to pay additional 
premium  fees  for  volumes  of  blended  SAF 52.  Aircraft  operators  currently  have  to  rely  on  the 
willingness  of  aviation  fuel  suppliers  to  provide  them  with  this  information,  which  is  most 
probably not verified by any authority. Aircraft operators’ customers are therefore entirely reliant 
on the integrity of the aircraft operators and aviation fuel suppliers with whom they are dealing. 

52 Often in order to reduce their Scope 3 emissions – https://www.wri.org/initiatives/greenhouse-gas-protocol. 

25 

 
 
Aircraft  operators  explain  that  this  current  lack  of  monitoring  and  certification  is  reducing 
customers’ readiness to buy extra blended SAF volumes. 

Enabling  aviation  fuel  suppliers  to  differentiate  between  voluntary  and  mandatory  volumes  of 
blended SAF in the UDB could increase the industry’s and customers’ trust in the voluntary market 
and could potentially increase uptake as it would facilitate the reduction of Scope 3 emissions by 
third  economic  operators 53.  Such  an  improvement  to  the  UDB  would  address  one  of  the  most 
common requests from stakeholders. It could (i) centralise the identification and reporting of all 
volumes of SAF within a single system through the UDB; (ii) potentially increase the blended SAF 
supplied  and  purchased  on  the  EU  market;  and  (iii) support  the  reporting  and  verification  by 
national competent authorities. 

It is important to note that this information should always be used by aircraft operators and their 
customers in compliance with other relevant GHG reporting standards and Union law, including 
with rules on avoiding double-counting.  

5.1.3  Extend UDB traceability to CORSIA 54 eligible fuels (CEF) under the EU ETS 

The UDB is set to cover the traceability of all eligible fuels under ReFuelEU Aviation. However, 
the UDB does not currently cover CORSIA eligible fuels (CEF) that can be claimed by aircraft 
operators under the scheme for their  international  extra-EEA  flights.  CORSIA  requests aircraft 
operators to prove the GHG emission reduction of the CEF they claim by supplying copies of the 
CEF purchase bills accompanied by their CEF certificates. Without a proper IT tool to trace CEF 
supplies to aircraft operators, it may be administratively complex for them to substantiate their 
claims once CEF volumes increase. This could create risks of fraud and double-counting for the 
same batch of fuel under more than one GHG scheme (e.g. EU ETS, CORSIA).  

CORSIA is implemented in EU law through the EU ETS. Aircraft operators with an air operator 
certificate or equivalent provided by the EU or any of its Member States must already report their 
yearly  amount  of  emissions  on  international  routes  (inside  and  outside  EEA)  to  their  national 
competent  authorities.  They  must  also  demonstrate  the  use  of  CEF  certified  under  CORSIA’s 
Standards and Recommended Practices and related implementing acts. An option to extend the 
traceability of these fuels in the UDB when they are supplied in the EU could facilitate both the 
reporting of EU aircraft operators and the broad uptake of higher-quality SAF, because it will be 
easier to demonstrate the higher level of GHG emission reductions in each batch of CEF purchased. 
Extending the traceability of the UDB to CEF would also ensure the safe use of such fuels.  

5.2  Potential improvements through the implementation of a SAF accounting mechanism 

As described earlier, a SAF accounting mechanism can involve different possible designs options 
and  parameters.  The  Commission  therefore  hired  Guidehouse  to  assess  the  different  possible 
options. This section relies on the analysis described in detail in  Section 8.2 of the Guidehouse 
support  study.  The  following  assumptions  apply  for  each  of  the  possible  options  for  a  SAF 
accounting mechanism. 

53 In accordance with the GHG Protocol for Project Accounting - https://ghgprotocol.org/project-protocol.  
54 https://www.icao.int/environmental-protection/CORSIA/Pages/default.aspx 

26 

 
 
-  The scope of the mechanism is  the same as ReFuelEU Aviation (e.g. legal,  geographic, 

eligible fuels, stakeholder definitions, etc.).  

-  The physical volumes linked to the virtually traded SAF sustainability certificates must be 

physically supplied to a Union airport as blended SAF.  

-  The SAF sustainability certificates can only be claimed once by aviation fuel suppliers for 
the purpose of complying with the ReFuelEU Aviation and RED obligations. Similarly, 
the SAF  sustainability certificates can only  be claimed once by aircraft operators under 
GHG or financial support schemes.  

-  The UDB can accommodate a SAF accounting mechanism that enables virtual trading of 

SAF sustainability certificates. 

5.2.1 

Impact on ReFuelEU Aviation 

A virtual market for SAF sustainability certificates implemented within  the legal boundaries of 
ReFuelEU Aviation could enable aviation fuel suppliers with insufficient access to SAF to comply 
with their obligations by purchasing virtual SAF sustainability certificates from other aviation fuel 
suppliers  with  more  supply  than  they  need.  Aircraft  operators  could  therefore  also  be  able  to 
purchase virtual SAF sustainability certificates from aviation fuel suppliers on the virtual market. 
However (as highlighted in the next section on impacts on the EU ETS), aircraft operators might 
have very limited ability to use virtual SAF sustainability certificates under EU law. Several design 
options for such a  SAF  accounting mechanism are presented in  Section 8.2 of the Guidehouse 
support study.  

With a SAF accounting mechanism, the obligation on all aviation fuel suppliers to supply physical 
volumes of blended SAF to Union airports would be removed during the flexibility period, because 
they  could  use  virtual  SAF  sustainability  certificates  instead.  This  approach  is  similar  to  the 
flexibility  allowed  under  the  RED  for  fuel  suppliers  and  sustainable  road  transport  fuels  (as 
mentioned  in  Chapter  4).  Aviation  fuel  suppliers  that  face  difficulties  in  the  production  or 
procurement  of SAF and blended SAF would have 10  years to  upgrade their supply chain and 
physically comply with the minimum share requirements as from 2035. 

A virtual market for SAF sustainability certificates implemented under ReFuelEU Aviation could 
allow  aircraft  operators  to  claim  the  purchased  virtual  certificates  under  the  Flight  Emissions 
Label. Aircraft operators could also leverage virtual certificates to purchase voluntary volumes of 
SAF  on  the  market  and  sell  them  to  customers  willing  to  reduce  their  Scope 3  emissions.  It 
nevertheless  appears that the use of such virtual  certificates is  limited to  aircraft operators and 
might therefore decrease their willingness to purchase such certificates.  

However, such a virtual market could geographically concentrate the physical stocks of SAF in a 
few airports located close to the production and blending facilities which are, as seen in Chapter 2, 
mainly  located  in  western  and  northern  Member  States.  The  Guidehouse  support  study  also 
concludes that such a SAF accounting mechanism could delay investment in the development of 
the  EU  SAF  supply  chain  because  there  would  be  no  incentive  for  aviation  fuel  suppliers  to 
transport or produce SAF across the EU during the flexibility period. This could send the wrong 
signal to the industry, which must prepare its supply chain to be ready to supply a minimum share 
of 20% of SAF to all Union airports by 2035. This concern is also shared by some Union airport 

27 

 
managing bodies, which are keen to see SAF production and supply developing everywhere in the 
EU to preserve a level playing field for industry stakeholders and Member States in the EU. The 
geographic concentration of blended SAF supplied only to airports near production facilities would 
deprive a significant share of EU territory of the non-CO2 benefits that the use of SAF can offer, 
in terms of air quality around airports and reduction of contrails in given air routes. 

The  beneficial  impact  of  a  SAF  accounting  mechanism  on  blended  SAF  prices  for  all  aircraft 
operators and across all regions in the EU remains unclear. The argument that a virtual market for 
certificates  would  lead  to  reduced  SAF  transportation  costs  and  emissions  has  not  been 
substantiated. Extra transportation costs depend only on the distance between the place where SAF 
is  produced  or  imported  into  the  EU  and  the  blending  facility.  The  Guidehouse  support  study 
demonstrates that this concern should lessen over time due to the development of the SAF industry. 
From the blending point onward, transportation is identical to that for conventional aviation fuels 
and should not result in a significant logistical cost increase.  

Furthermore,  facilitating  the  virtual  trading  of  SAF  could  de-motivate  developing  domestic 
industrial capacity in particular for emerging SAF, such as advanced biofuels and synthetic fuels, 
while  using  the  flexibility  period  for  safeguarding  industry’s  profit.  This  period  is  however  of 
critical importance to develop industrial capacity in the EU for SAF production. Once they are 
produced at scale and sufficient quantities, trading them in the EU would not be a barrier. 

Regarding voluntary volumes, nothing in ReFuelEU Aviation prevents aviation fuel suppliers from 
virtually selling their excess SAF above the mandatory minimum to interested customers for any 
use  that  is  not  legally  required  and  that  respects  the  current  legal  framework.  Some  private 
initiatives are underway. The Commission will monitor the developments of these initiatives and 
assess their compliance with EU legislation. A robust and transparent virtual market for voluntary 
volumes of blended SAF that could help customers to reduce their Scope 3 emissions (particularly 
if they are fully traceable through the UDB) could bolster the general public’s confidence in the 
decarbonisation  of  aviation  and  could  reduce  greenwashing  risks  without  the  need  for  further 
regulatory intervention. 

Aviation fuel suppliers have not expressed concerns regarding their supply obligations that would 
justify the implementation of such a virtual market by law during the flexibility period. Aviation 
fuel suppliers are already free under the current regulatory framework to trade physical volumes 
of SAF and blended SAF with each other before supplying it to the market.  

5.2.2 

Impact on other relevant pieces of legislation 

5.2.2.1  Directive (EU) 2018/2001 (the RED) 

The RED allows Member States to grant some flexibility to their fuel suppliers when complying 
with  their  obligations  through  the  purchase  of  compliance  tickets.  However,  virtual  SAF 
sustainability  certificates  that  are  traded  internationally  would  not  be  recognised  by  Member 
States’  competent  authorities  because  the  supply  must  happen  within  the  borders  of  a  given 
Member State. This means that aviation fuel suppliers that decide to comply with their obligations 
under ReFuelEU Aviation in a virtual manner would not be able to count those virtual certificates 
for the purpose of helping to meet the national RED targets.  

28 

 
5.2.2.2  Directive 2003/87/EC (EU ETS) 

Aviation has been part of the EU ETS since 2012. Under the EU ETS, aircraft operators monitor, 
report and verify (MRV) emissions from flights performed within the geographical scope of the 
EU  ETS.  Aircraft  operators  must  therefore  surrender  EU  allowances  to  cover  all  of  these 
emissions. The MRV system relies on physical uplift and actual fuel burn of all fuel types – SAF 
included – and on a mass-balance system (including the proportionality principle) if the physical 
uplift of certain fuels cannot be determined (e.g. in the case of interconnected infrastructure such 
as  pipeline  systems).  This  means  that  aircraft  operators  cannot  currently  claim  virtual  SAF 
sustainability certificates under the scheme. 

Enabling virtual supply of SAF under ReFuelEU Aviation without allowing aircraft operators to 
claim  virtual  certificates  under  the  EU  ETS  could  lead  to  further  significant  distortions  of 
competition in the EU market. On the one hand, aircraft operators operating from Union airports 
where only virtual certificates are available would not be able to claim any benefits under the EU 
ETS while on the other hand, aircraft operators operating from Union airports where blended SAF 
is physically supplied will have the opportunity to claim the benefits of using SAF under the EU 
ETS  and  will  incur  reduced  costs  linked  to  the  surrender  of  EU  allowances  and  the  additional 
support  for  uplift  of  eligible  fuels.  Without  a  robust  mechanism  for  tracing  SAF  sustainability 
certificates to the final consumer, it would also greatly increase the risks of fraud with aviation 
fuel suppliers potentially selling SAF sustainability certificates twice to different aircraft operators 
– once at the place of virtual supply and once at the airport of physical supply.  

The stakeholder consultation revealed that most economic operators from both the demand side 
(e.g. aircraft  operators)  and  the  supply  side  (e.g. aviation  fuel  suppliers)  consider  the  ability  of 
aircraft  operators  to  claim  the  use  of  virtual  SAF  sustainability  certificates  as  a  primary 
requirement for the  implementation  and well-functioning  of a  SAF  accounting mechanism  that 
enables  virtual  trading  in  such  certificates  in  the  EU.  Implementing  such  a  mechanism  within 
ReFuelEU Aviation alone would limit the benefits of the virtual market strictly to the supply side 
and might create inconsistencies within EU law. 

29 

 
 
 
6  Conclusions and recommendations 

6.1  Assessment of the developments on SAF production and supply on the EU’s aviation fuel 

market 

The recent developments in the EU SAF market  allow to conclude, at this early stage, that the 
current SAF flexibility mechanism of 10 years, paired with the recent increase in SAF production 
capacity in the EU, is adequate for ensuring the availability and supply of the minimum shares of 
blended SAF in a significant number of Union airports from 2025 until 2035, certainly for aviation 
biofuels. It also allows the industry to make the necessary technological and logistical investments 
to upgrade the supply chain and ensure compliance with the supply of minimum shares by 2035 
to all Union airports.  

The Commission will nevertheless continue to support and create the right conditions for aviation 
fuel producers’ investments in SAF in three ways. 

• 

• 

• 

It will maintain the legal certainty regarding the ReFuelEU Aviation supply obligations of 
minimum shares of SAF in 2030 and beyond. The Commission considers that both the SAF 
target and the synthetic aviation fuels subtargets for 2030 and 2035 set by the Regulation 
are realistic, proportionate, and crucial to achieving the objectives of the Fit for 55 package 
and the recently published Climate Target Plan for 2040 55. 
It  will  implement  the  supporting  measures  mentioned  in  Chapter  2  of  this  report  in  the 
simplest, fairest, and most cost-efficient way. 
It  will  continue  to  urge  Member  States  to  adopt  national  legislation  defining  the  rules 
related to penalties in the Regulation as soon as possible 56 and will not hesitate to take 
action should this be necessary. EASA recently published its report on the State of the EU 
SAF  market  in  2023.  The  report  describes  the  methodology  to  determine  aviation  fuels 
prices. The level of penalties set in Article 12 of ReFuelEU Aviation is clear, proportionate 
and dissuasive enough to facilitate a coherent and harmonised level of penalties throughout 
the internal market.   

The Commission will monitor developments in the sustainable aviation fuel sector and particularly 
the development  of  advanced aviation  biofuels  and  synthetic aviation  fuels  production projects 
across the EU. The Commission is aware that aviation fuel producers (particularly aviation fossil 
fuel  producers)  have  not  yet  launched  the  required  investments  for  the  upscaling  of  synthetic 
aviation  fuel  production  plants.  The  Commission  notes  that  –  given  the  constrains  on  the 
availability of biomass feedstock such as used cooking oil (UCO) – developing and scaling up 
advanced aviation biofuels and synthetic aviation fuels production and supply in the EU as from 
2030 will be necessary so that the aviation sector can significantly reduce its emissions and achieve 
its own decarbonisation goals and roadmaps by 2050. R&I and early movers support to new SAF 
technologies  is  thus  necessary  to  increase  EU  competitiveness  and  security  of  the  domestic 
production by mitigating the SAF supply chain risks. Moreover, demand and supply aggregation 

55 Impact  assessment  on  a  2040  Climate  Target  –  https://climate.ec.europa.eu/eu-action/climate-strategies-
targets/2040-climate-target_en#documents. 
56 Article 12(1) of ReFuelEU Aviation. 

30 

 
 
mechanism could further facilitate market development for synthetic aviation fuels. If necessary, 
the Commission will intervene to support the scaling-up of such fuels and address the risk profile 
of these projects by mitigating regulatory, market and technology risks and making them more 
attractive to investors with a view to enabling the timely development of industrial scale facilities 
in the EU before 2030. The Clean Industrial Deal and Sustainable Transport Investment Plan will 
foster  investment  in  and  scale  up  of  clean  energy  technologies  and  prioritise  investment  in 
transport  decarbonisation  solutions  that  are  crucial  for  the  decarbonisation  of  ‘hard-to-abate’ 
modes like aviation and that are key to many EU regions and citizens’ mobility. As announced in 
the  Clean  Industrial  Deal,  the  Commission  will  come  forward  with  a  Sustainable  Transport 
Investment Plan later in 2025, outlining a strategic approach to scale-up and prioritise investments 
in transport decarbonisation solutions, including SAF. 

There are  a number of ways to  support these projects  and contribute to the EU’s sustainability 
ambitions  in  aviation:  (i) improving  market  conditions  and  keeping  regulatory  certainty; 
(ii) reducing complexity and administrative burden; (iii) increasing awareness of the necessity and 
benefits  of  synthetic  aviation  fuels  among  stakeholders;  and  (iv) designing  effective  financial 
support mechanisms. Investment  in  SAF  capacity-building  must happen in  the EU  to reinforce 
reindustrialisation  and  strategic  energy  security  of  supply  throughout  the  entire  EU.  The 
Commission will make sure that the right framework is in place to attract investment in SAF and 
particularly in synthetic aviation fuels. For this purpose, the Commission will work with public 
and private actors  to  unlock the financing  needed for the transition. The Commission will  also 
continue to support the development of the EU SAF market in the coming years through the Clean 
Industrial Deal, in which SAF are considered as a main contributor to the decarbonisation efforts 
in the EU.  

In parallel, the Commission will remain especially vigilant in ensuring that aviation fuel suppliers 
do  not  pass  the  cost  of  penalties  for  underachieving  the  supply  obligations  onto  airlines  and 
ultimately onto passengers – as an alternative to investing in the necessary production of SAF and, 
more specifically, synthetic aviation fuels. The Regulation deters such behaviour by cumulatively 
carrying over any supply shortfall to subsequent years. 

Through  EU  programmes  for  infrastructure  (e.g. TEN-T),  the  Commission  will  support  the 
development of blended SAF infrastructure to facilitate compliance in all Union airports with the 
minimum share requirements, before or at the latest at the end of the flexibility period in 2035. 

6.2  Assessment of possible improvements or additional measures to the existing SAF 

flexibility mechanism with a view to further facilitate the supply and uptake of SAF for 
aviation during the flexibility period 

In  anticipation  of  the  2025  supply  obligations,  some  industry  stakeholders  (mainly  aircraft 
operators)  have  expressed  concerns  regarding  the  SAF  market  ramp-up  and  the  associated 
premium costs. Issues such as SAF availability and traceability at Union airports, prices of SAF 
and the dominant position of certain aviation fuel suppliers were highlighted. The Commission has 
explored several options to address these concerns.  

31 

 
6.2.1 

Improvements through the changes in the Union Database for Biofuels (UDB) 

The  Commission  finds  that  enlarging  the  scope  of  the  Union  Database  for  Biofuels  (UDB)  to 
extend SAF traceability to the final consumers – the aircraft operators –  could improve market 
transparency, safety, and the ability of aircraft operators to report and account for the SAF supplied 
and reduce the administrative burden. It is especially vital for the proper implementation of the 
Flight Emissions Label to allow aircraft operators to attribute the right fuel mix (and its related 
GHG  emissions  level)  to  any  given  flight.  This  could  also  facilitate  the  transfer  of  relevant 
documents for the purpose of claiming benefits for the use of SAF under GHG reduction schemes 
such as the EU ETS or the ICAO’s CORSIA under Article 9 of ReFuelEU Aviation. It could also 
greatly  facilitate  compliance  with  and  enforcement  of  all  articles  of  ReFuelEU  Aviation  by 
stakeholders and competent authorities.  

Enabling the economic operators to  differentiate between mandatory  and voluntary volumes of 
SAF in the UDB could increase the confidence of stakeholders and customers in the voluntary 
market and could potentially increase the supply of voluntary volumes. Such an improvement to 
the UDB could centralise all volumes of SAF within a single system and could facilitate reporting 
and verification by Member States’ competent authorities. 

The Commission considers that extending the scope of the UDB to include CORSIA certified fuels 
(CEF) could further incentivise the uptake of such fuels at Union airports. Such an improvement 
to the UDB is crucial for the success of the CORSIA initiative, which was recently implemented 
through the EU ETS and would contribute to ICAO’s collective global aspirational vision of using 
SAF to reduce CO2 emissions in international aviation by 5% by 2030.  

As part of its support for facilitating and incentivising the supply and uptake of blended SAF at 
Union airports, the Commission will implement the necessary changes to the UDB to extend SAF 
traceability on a voluntary basis to aircraft operators by 2025. The Commission expects that these 
improvements  will  address  most of the concerns  and  requests expressed  by stakeholders in  the 
context of a tradability system for SAF (as described in Chapter 4). The Commission will also, in 
cooperation  with  EASA,  prepare  the  business  and  technical  documents  needed  to  prepare  the 
implementation  of  the  two  other  improvements.  These  changes  will  greatly  improve  SAF 
traceability  in  the  EU,  thus  strengthening  the  competitiveness  of  the  EU’s  sustainable  fuels 
industry. 

6.2.2  Relevance of a virtual market for SAF sustainability certificates under ReFuelEU 

Aviation  

The  virtual  tradability  of  SAF  sustainable  certificates  enabled  through  a  SAF  accounting 
mechanism could benefit the few aviation fuel suppliers that might face difficulties in accessing 
SAF during the flexibility period. However, a regulatory intervention that would require a revision 
of ReFuelEU Aviation and potentially other pieces of legislation at this early stage of the newly 
regulated  market  does  not  appear  justified,  especially  considering  that  private  initiatives  are 
possible for any voluntary trade on both the supply side and the demand side. As Guidehouse has 
concluded, enabling aviation fuel suppliers to comply with their obligations in the short-term by 
trading virtual certificates increases the risk that they will not be ready to supply physical SAF to 

32 

 
every Union airport by 2035. This would imply concentrating the beneficial effects of SAF for 
local communities to just a handful of airports and Member States, jeopardising efforts to improve 
air quality  around airports  and to  decrease non-CO2 effects,  namely contrails.  It could  also  de-
motivate the industry from building domestic industrial capacity of SAF and from optimally using 
the flexibility period. This ten-year period is however of critical importance to develop industrial 
capacity  in  the  EU  for  SAF  production.  Moreover,  stakeholders  remain  unclear  regarding  the 
preferred design and parameters that such a mechanism should have. It is also important to note 
that  the  scope  of  implementation  of  a  SAF  accounting  mechanism  would  greatly  impact  its 
effectiveness and relevance for stakeholders. Implementing such a mechanism within ReFuelEU 
Aviation alone could create unwanted inconsistencies. 

The initial mandatory amounts of SAF to be blended are relatively modest. This limits the adverse 
risks of unexpected market developments and provides an opportunity to observe actual market 
performance during the first years of the supply obligations. Continued market monitoring in the 
coming years will be crucial to determine whether regulatory intervention is necessary in order to 
achieve the EU’s aims regarding the aviation sector’s contribution to achieving the 2030 and 2050 
climate goals. 

6.2.3  Other mitigations 

The Commission takes note of aircraft operators’ concerns regarding perceived disproportionate 
differences  in  the  price  and  availability  of  blended  SAF  at  certain  airports.  The  Commission 
services will in particular pay close attention to any unfair pricing practices of aviation fuels at 
Union  airports  by  aviation  fuel  suppliers.  If  any  infringements  of  EU  law  are  observed,  the 
Commission  will  take  any  measures  needed  to  address  the  issues  in  line  with  its  enforcement 
policy. The report reviewing of ReFuelEU Aviation in 2027 will allow the Commission to identify 
those Union airports where blended SAF is not yet available and where the market structure and 
the position of aviation fuel suppliers may have an impact on the price and availability of SAF. 
The  Commission  will  gather  information  on  current  concession  agreements  and  other  kinds  of 
commercial agreements that may clarify relations between airport managing bodies, aviation fuel 
suppliers and aviation fuel ground-handlers. This will help it understand their economic and legal 
relations and the impact they may have on the quality and price of blended SAF at Union airports. 
A  better  understanding  of  the  different  roles  of  each  stakeholder  and  of  the  decision-making 
process regarding the volumes and the quality of aviation fuels made available at Union airports 
is required to address the concerns expressed by aircraft operators. It will also help the Commission 
to monitor commercial practices in this new market context, where multiple types of blended SAF 
will soon be available with substantial price differences. 

The Commission will continue the technical and feasibility study on SAF accounting mechanisms 
within  the  EU  regulated  framework  (including  those  that  enable  virtual  trading  of  SAF 
sustainability  certificates)  through  a  preparatory  action  that  has  started  in  December  2024,  in 
collaboration with EASA. The work under this preparatory action will also cover the assessment 
of  the  business  and  the  technical  requirements  and  related  costs  of  the  two  above-mentioned 
improvements to the UDB. The outcome of the preparatory action with EASA may inform any 

33 

 
future evaluation or impact assessment for a possible revision (where justified) of relevant pieces 
of EU law, especially as regards the use of virtual SAF certificates under EU law.  

34 

 
 
Annex 1: Overview of sustainable aviation fuels (SAF) type (non-exhaustive) 

SAF 
type 

HEFA 

Feedstock 

Bio-oils, animal 
fat, recycled oils 

ASTM 
specifica
tion 

Max. 
blend 
ratio 

D7566 

50% 

Producers in EU 
(including planned 
projects) 

Neste (Finland, and 
Netherlands 
planned),  
ENI (Italy), Preem 
(Sweden), SkyNRG 
(Netherlands site),  
Shell (Netherlands),  
TotalEnergies 
(France)  

Offtakers (airlines) 

Users (airports) 

Lufthansa, KLM, IAG, 
Finnair, UPS and 
Amazon Prime Air 
(Neste) 

Rotterdam The 
Hague Airport 
(Shell production 
on site) 
Paris Charles de 
Gaulle (Total) 
Le Bourget 
Airport (Total) 
Rome Fiumicino 
(ENI) 

CHJ 

FT 

SIP 

AtJ 

HC-
HEFA 

Co-
processi
ng 

Syntheti
c 
aviation 
fuels 

Triglycerides: 
soybean, jatropha, 
camelina oil, etc.  
Biomass  

D7566  

50% 

D7566 

50% 

Enerkem/Shell 
(Netherlands), 
Repsol (Spain), 

British Airways 
(Velocys 
investor/offtake 
agreement) 

D7566 

10% 

D7566  

50% 

Biomass from 
sugar production  
Biomass from 
ethanol or 
isobutanol 
production  

LanzaJet (Sweden), 
SkyNRG 
(Netherlands) 

Algae  

D7566  

10% 

FT and HEFA 
feedstocks  

Renewable 
energy, water, 
carbon 

D1655  

5% 

AirBP (Germany), 
Repsol (Spain) 

50% 

SkyNRG (NL) 

Scandinavian Airlines, 
Iberia Airlines (Gevo 
offtake agreement), 
British Airways 
(LanzaJet 
investor/offtake 
agreement), 
Virgin Atlantic 
(LanzaJet offtake 
agreement) 

35 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex 2: Sustainable aviation fuels (SAF) production routes 

Hydrotreated esters 
and fatty acids 
(HEFA) 

HEFA production includes the use of hydrogen for refining vegetable oils, waste oils or fats. The 
first step is to remove the oxygen from the fats. The straight paraffinic molecules are then thermally 
cracked and isomerised to jet-fuel chain length. 

Fischer-Tropsch (FT) 

The FT synthesis technology can be used to gasify any carbon-containing material to produce 
carbon monoxide and hydrogen – known as syngas. The syngas acts as a building block to be used 
in SAF production. The syngas is liquified via catalytic reaction with iron, cobalt, nickel and 
ruthenium. It is then thermally cracked into smaller molecules to produce a final kerosene product. 
There are two certified pathways for SAF production using FT technology: (i) synthetic paraffinic 
kerosene (SPK) produces a straight paraffinic jet fuel; and (ii) SKA produces synthetic kerosene 
from additional aromatic compounds. 

Catalytic 
hydrothermolysis 
(CHJ) 

CHJ converts fatty acid esters and free fatty acids into SAF via catalytic hydrothermolysis. The SAF 
are further processed by any combination of hydrotreatment, hydrocracking, or hydroisomerisation 
and fractionation. 

Synthesised iso-
paraffins (SIP) 

SIP ferments and converts sugars into six closely-related chemical compounds called farnesene. The 
farnesene is then treated with hydrogen and can be used in SAF. 

Alcohol to Jet (AtJ) 

AtJ converts alcohols into SPK jet fuel by removing the oxygen and linking the molecules together 
to get the proper carbon chain length. 

Hydroprocessed 
hydrocarbons, esters 
and fatty acids (HC-
HEFA) 

In the HC-HEFA process, which is similar to the HEFA process, free fatty acid esters and free fatty 
acids are upgraded for use in SAF. The hydrocarbon molecules are saturated and all oxygen is 
removed via hydroprocessing. One recognised bio source is the Botryococcus braunii species of 
alga. 

Synthetic aviation 
fuels 

Synthetic aviation fuel is derived from a power-to-liquid process. Water is broken down into 
hydrogen and oxygen via electrolysis using renewable energy. The hydrogen is then paired with 
carbon dioxide to form carbon monoxide and water. Using the FT synthesis process, the hydrogen 
and carbon monoxide are converted into a wax. This wax acts as a synthetic crude oil which is 
upgradeable to different fuels, including synthetic aviation fuel. Synthetic aviation fuel only emits 
the carbon input during its production process when it is burned. Using carbon from carbon capture 
means that the fuel is carbon-neutral.  

Co-processing 

Co-processing is not a dedicated SAF pathway but a co-process in conventional crude oil refining. 
FT or HEFA feedstocks are fed into existing jet-fuel refining processes. Co-processed FT uses FT 
wax, which is a by-product of the FT process. Co-processed HEFA is made using vegetable oil, 
waste oil and fat feedstocks. 

36