COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Sustainable Transport Investment Plan
Date: 2025-11-05
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: EU investment, air transport, biofuel, carbon neutrality, clean technology, competitiveness, energy transition, maritime shipping, renewable energy, sustainable mobility

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 5.11.2025  COM(2025) 664 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Sustainable Transport Investment Plan   
 
 
1.  INTRODUCTION 

Mobility  and  transport  of  passengers  and  goods  is  the  backbone  of  industrial  growth  and 
competitiveness, connecting the EU to the rest of the world, offering the means for citizens to 
travel  and  companies  to  thrive  in  their  activities.  At  the  same  time,  the  EU  has  a  headline 
ambition to decrease transport greenhouse gas emissions (GHG) - which remain stubbornly high 
- by 90% by 2050. This can be achieved by increasing transport efficiency, including through 
multi-modal mobility, electrification, and switching to renewable and low-carbon fuels. Those 
fuels are particularly critical1 for the aviation and maritime sectors, which account for about 8.4% 
of total EU greenhouse gas emissions, since they can only marginally benefit from electrification. 
In the transition to a climate neutral economy, all modes of transport will depend on the use of 
renewable and low-carbon fuels to a different degree2. 

As highlighted in the Draghi report3, investing in renewable and low-carbon fuel technologies 
is  crucial  for  decarbonisation  and  boosting  industrial  competitiveness  as  well  as  energy 
security, decreasing our dependence on fossil fuel imports. The report underlines the need for a 
strategic framework bringing together supply and demand for these fuels in the EU.  

Key policy components of such a framework are already in place:  

•  The EU has a comprehensive regulatory framework to boost renewable and low-carbon 
technologies including the ReFuelEU Aviation Regulation4 (RFEUA) and the FuelEU 
Maritime Regulation5 (FEUM), the revised Renewable Energy Directive6 (RED) and the 
Alternative Fuels Infrastructure Regulation7 (AFIR). 

• 

International  policy developments  are pushing in the same direction:  the  International 
Maritime  Organization  IMO  has  committed  to  achieve  net-zero  by  2050  in  maritime 
transport through the Net-Zero Framework (NZF), however not adopted by IMO member 
states.  The  International  Civil  Aviation  Organization  ICAO  recognises  sustainable 
aviation fuels (SAF)8 as the main enabler to emission reductions.  

But this is not enough. Market investment conditions in the EU must improve. Otherwise, 
demand will be largely met by production outside the EU, creating new dependencies with the 
advanced production projects9. Investment in production facilities in regions outside the EU is 

1  Kousoulidou et al.2016, Biofuels in aviation: Fuel demand and CO2 emissions evolution in Europe toward 2030. 
2 According to the 2040 Climate Target Impact Assessment, passenger cars with an internal combustion engine will have a share 
of 26% in the EU’s cars stock, while BEVs make up 57-58%. Total energy consumption drops considerably due to the higher 
energy efficiency of electric vehicles at the same time, and while the demand for biofuels is seen to increase until 2030, it declines 
thereafter due to the growing shares of electrification.  
3 The Draghi report (2025): A competitiveness strategy for Europe.  
4 http://data.europa.eu/eli/reg/2023/2405/oj 
5 http://data.europa.eu/eli/reg/2023/1805/oj 
6 http://data.europa.eu/eli/dir/2014/53/oj 
7 http://data.europa.eu/eli/reg/2023/1804/2025-04-14 
8  SAF are aviation fuels that are approved under the ASTM 7566 standard and are designed to be a drop-in solution for traditional 
jet fuel, allowing aircraft to use it without modifications to engines or infrastructure. They can be produced from sustainable 
biological feedstocks under various pathways (bio-SAF). SAF can also be produced synthetically (eSAF). 

9 European Commission, 2024: Development of outlook for the necessary means to build industrial capacity for drop-in advanced 
biofuels. 

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accelerating10. Against this increasing competition, it is urgent to scale-up renewable and low 
carbon fuel production in the EU. European companies still hold 60 % of innovative patents in 
this area globally and possess most of the world’s commercial facilities for advanced biofuels. 
We should not lose technological leadership but shape this emerging global lead market instead.  

This  Sustainable  Transport  Investment  Plan  focuses  on  renewable  and  low-carbon  fuels  for 
aviation and waterborne transport and complements proposals that cover other transport modes. 
The  industrial  approach  for  road  transport  is  outlined  in  the  Industrial  Action  Plan  for  the 
Automotive sector11. The implementation of that Plan is ongoing, notably with the upcoming 
review of the CO2 standards for cars and vans, and the proposal on Clean Corporate Fleets. The 
upcoming  Battery Booster package  will support the electrification of several  transport modes 
and actions to accelerate the roll-out of infrastructure are foreseen. Measures related to heavy-
duty  vehicles  and  the  related  infrastructure  are  expected  within  the  next  months  as  well. 
Similarly, the EU is already comprehensively supporting the development of an effective and 
efficient rail system, namely through the revised Trans-European Transport Network (TEN-T) 
Regulation  including  through  financial  support  such  as  via  the  Connecting  Europe  Facility 
(CEF), and the High-Speed Rail Action Plan, published together with this plan.  

Aviation  and  waterborne  transport,  however,  still  almost  fully  rely  on  conventional  fuel. 
Focusing, in this plan, on the needs of aviation and maritime is urgent, as these sectors must meet 
ambitious emission reduction targets in 2030 and in order to decarbonise, they must rely mainly 
on renewable and low-carbon fuels.  

The moment to act is now. This Sustainable Transport Investment Plan (STIP) maps investment 
needs and outlines measures to make better use of existing EU financing programmes in support 
of  the  required  investments  with  the  focus  on  aviation  and  waterborne  sectors.  It  introduces 
measures to support the implementation of the regulatory framework and outlines measures to 
achieve greater market impact through improved coordination of support at Member State level 
and through better international collaboration.  

2.  SETTING THE COURSE OF ACTION FOR AVIATION AND WATERBORNE 

TRANSPORT  

2.1 Market challenges 

Targets under RFEUA and FEUM 

A sustained scaling up of current market volumes, including for e-fuels, is necessary to meet 
these targets, which is vital for Europe’s competitiveness and global leadership.  

Under  RFEUA,  the  share  of  SAF  supplied  at  EU  airports  needs  to  increase  from  2%  (equivalent  to 
roughly 0.9 Mt of SAF or 0.92 Mtoe) in 2025 to 6% in 2030, to 20% in 2035 and then 70% (32.5 Mt or 

10 International e-fuels observatory, 2025 edition & information based on expert consultation  Project Frontrunner in Texas is 
under  construction  (eSAF)  and  several  e-methanol  projects  in  China  have  passed  the  FID  stage  or  are  under  construction. 
https://www.sia-partners.com/en/insights/publications/international-e-fuels-observatory-2025-edition 
11 https://commission.europa.eu/topics/business-and-industry/boosting-european-car-sector_en 

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33.4 Mtoe) by 2050. The required minimum share for eSAF starts at 1.2% in 2030, rising to 5% (2.2 to 
2.3 Mt of eSAF, or 2.26 to 2.36 Mtoe) in 2035 and increases to 35% (16.25 Mt, or 16.7 Mtoe) in 2050.  

Under  FEUM, the  GHG  emissions  intensity reductions target  for 2035  is  14.5%,  but  reaches  80%  in 
2050. Sustainable maritime fuels (SMF) will play a substantial role in meeting FEUM targets (estimated 
amount is approximately 11.3 Mtoe of SMF for 2035)12. If by 2031 the share of RFNBOs13 (eSMF) is 
less than 1%, then from 1 January 2034 a mandatory quota of 2% RFNBOs shall apply (corresponding to 
0.56 Mt of eSMF). Electricity from onshore power supply (OPS) is expected to account for around 1.4% 
of total energy use on vessels by 2035.  

Current market conditions  

Many renewable or low-carbon fuel technologies currently have low market maturity. Regarding 
aviation fuels, the Hydroprocessed esters and fatty acids (HEFA) pathway is at present the most 
widely used for producing SAF. Many other technologies are at a pilot or demonstration stage14. 
For  maritime,  Fatty  Acid  Methyl  Esters,  (FAME)  technologies  are  widely  used  due  to  their 
overall environmental benefits on a Well-to-Wake approach, when blended with marine oil and 
gasoil. Bio-methane is also a mature technology. Regarding e-fuels, these are not available on a 
commercial scale in either mode.  

The  main  hurdle  for  ramping  up  the  market  is  the  significant  price  difference  between 
renewable  and  low-carbon  fuels  and  conventional  fuels.  Demand  for  low-carbon  and 
renewable fuels is lagging because using those fuels results in significantly higher operating costs 
for  airlines  and  shipping  operators.  The  price  difference  today  ranges  between  two  to  ten 
times15. Costs are expected to come down in the coming years, partially  due to economies of 
scale and new production technologies. However, uncertainties surrounding expected price and 
revenue are causing hesitation among investors. This is particularly true for eSAF and eSMF, 
where high capital costs and high price and revenue risks currently undermine the business case. 
More than 40 e-fuels production projects are at a planning stage in the EU. However, none has 
been able to reach a final investment decision so far. Different contracting needs present an 
obstacle for the market to take off. Fuel producers aim for long-term fuel offtake agreements 
to amortise costly investments, whilst operators are accustomed to short-term supply contracts 
to remain more flexible with respect to fuel pricing in competitive global markets. Reluctance to 
invest  is  further  fuelled  by  uncertainties  with  respect  to  available  biological  and  non-
biological feedstock and their overall access conditions.   

Limitations on biological feedstock 

12 SMF can be produced from various sources, including bio-based feedstocks, fossil waste or from renewable and low-carbon 
energy (e-SM). The sector is forecasted to demand 6.4 Mt of SMF and 4.6 Mt of eSMF to meet the 2035 targets under FEUM, 
see SWD/2024/63 final.  
13 As per the definition in the Renewable Energy Directive. 
14 Such technologies include Gasification + Fischer Tropsch (FT) and Alcohol to Jet (AtJ).  
15 EASA 2025, ReFuelEU Aviation Annual Technical Report, with e-fuels being the most expensive solution. 

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The limited availability of sustainable feedstock and competing demand from other sectors 
constrain the potential for the use of biofuels in the overall transport fuel mix16. 

The potential of biofuels 

The maximum domestic EU supply of sustainable feedstock for bioenergy17 in 2030 is estimated to be 
160  Mtoe  in  2030,  and  207  Mtoe  in  205018.  The  expected  final  bioenergy  demand  on  all  sectors  but 
transport by 2030 is estimated to be 114 Mtoe, which leaves an equivalent of 46 Mtoe in 2030 for the 
transport sector. This is a small fraction of the overall energy consumed by the transport sector at present, 
which amounts to 355 Mtoe, but it would serve for meeting the current RFEUA and FEUM targets for 
2030.  

In the longer-term, however, the available sustainable bioenergy potential is constrained and predicted 
supply  would  be  sufficient  to  meet  the  expected  bioSAF/bioSMF  share  of  the  aviation  and  maritime 
targets, leaving little room for further uses. Studies point  to a projected bioenergy demand from other 
sectors  of  170  Mtoe  in  2050,  which  would  result  in only  37  Mtoe  for  transport.  This  supply  is  to  be 
compared  with  an  expected  combined  energy  demand  for  aviation  and  maritime  transport  modes  of 
around 90-100 Mtoe in 205019, which underlines the relevance of eSAF and eSMF. Recently, studies 
came  to  a  more  positive  outlook  when  it  comes  to  the  availability  of  feedstock  and  the  potential  of 
advanced biofuels20. 

In view of the production capacity of 2 Mtoe at  present, it  is  therefore important  to  mobilise 
additional  sustainable  feedstocks  and  adopt  a  two-pronged  investment  strategy:  first,  in 
supporting innovative processing of additional advanced and waste-based feedstocks which are 
currently  not  commercially  available  and  second,  in  building  supply  chains  for  previously 
untapped  feedstocks,  while  also  improving  resource  efficiency  and  circularity  of  domestic 
residues. This transition must ensure that renewable fuel production makes full use of sustainable 
residues, by-products and waste streams, while respecting environmental safeguards and water 
resources.  Biomass  should  be  used  in  ways  that  maximise  long-term  economic  and 
environmental benefits, supporting resilient bio-based value chains and land sector carbon sink.  

The transport sector will be competing for the use of biomass. As regards maritime and aviation 
transport, the feedstock eligibility is limited to reduce risks of food security and land use change, 
by excluding e.g. food and feed biomass. At the same time, sustainable feedstocks for advanced 
biofuel production, such as lignocellulosic residues from agriculture, agrifood residues, manure 
residues and waste, are currently underexploited and could be scaled up. Furthermore, emphasis 
should be placed on synergies across sectors and transport modes which will also help increase 

16 More specifically, for maritime and aviation transport, the feedstock eligibility is limited to reduce risks of food and land use 
change, by excluding e.g. food and feed biomass. Additionally, factors like climate change could further disrupt and limit biomass 
availability. 
17SWD/2024/63 2040  
18 Feedstocks include food crops, lignocellulosic crops, agriculture residues, forest stem-wood, forest residues, waste and paper 
and pulp residues. 
19 Aviation and maritime demand is estimated at 45-50 Mtoe each in 2050. 
20 European Commission: Directorate-General for Research and Innovation and BEST, Development of outlook for the necessary 
means to build industrial capacity for drop-in advanced biofuels Annex 3 Report on Task 3, Publications Office of the European 
Union,  2024,  https://data.europa.eu/doi/10.2777/858956.  The  study  is  based  on  various  assumptions  related  to  feedstock 
availability, regulatory framework etc. However, the currently capacity is around 2 Mtoe/y currently, with a planned production 
up to 5-6 Mtoe/y. 

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volume and reduce price21. Finding production inputs that are not used by other sectors will help 
limit costs and price volatility and avoid pushing other sectors to unsustainable biomass. Proper 
feedstock handling, sustainability verification and traceability, along the entire value chain is key 
to ensure net emissions reductions and to avoid fraud22. 

In order to quickly scale up sustainable fuels, in particular for maritime and aviation sectors, it 
is important to identify and address challenges and risks faced throughout the supply chain and 
to  explore  integrated  approaches  from  sustainable  biomass  sourcing  to  advanced  biofuels 
production and use in the EU. The EU Bioeconomy Strategy will explore how to foster coherent, 
circular and sustainable value chains across Europe.  

Limitation on non-biological feedstock 

The production of eSAF and eSMF is dependent upon the availability of renewable hydrogen 
and  of  carbon  dioxide23.  There  are  currently  relatively  few  locations  in  the  EU  conducive  to 
producing renewable hydrogen economically. The scaling of e-fuels production is constrained 
by the availability, cost and maturity of renewable hydrogen, eligible carbon dioxide and carbon 
capture technologies as well as the energy intensity of clean hydrogen production. Conversion 
technologies for e-fuel production are still at the pilot stage and production plants which have 
both feedstock supply at scale and technology maturity are not yet established. Reducing the cost 
of electricity, renewable hydrogen and biogenic or direct air captured carbon dioxide is essential 
to lower the very high cost of e-fuels. 

2.2 Roadmap for the energy transition in aviation  

Commercial  aviation  emissions  account  for  about  123  million  tonnes  CO2,  or  13.1%  of  EU 
transport CO₂ emissions. As of 2024, only 0.6% of all jet fuel dispensed at EU airports was SAF, 
which led to greenhouse gas emission savings of 714 kt CO2

24. 

The  clear  roadmap  and  predictability  provided  by  the  legislative  framework  is  essential  for 
scaling up SAF production and uptake across the EU. Markets have responded positively to these 
targets  –  as  they  bring  predictability  and  stability  for  long-term  investments:  according  to 
EASA25, industry is on track to meet the overall bioSAF target of 4.8% in 203026 (mainly 
HEFA-based SAF). SAF production capacity is projected to increase to around 3.6 Mt by 2030 

21Biorefineries  enable  the  processing  and  conversion  of  biomass  into  a  wide  range  of  valuable  products,  including  biofuels, 
biochemicals, biomaterials, as well as heat and electricity production. The production of advanced bio-SAF creates a by-product 
market for green diesel (for trucks, for the non-electrified part of rail, for fishing vessels, inland waterways, off-road machinery 
etc) and naphtha (for ships or as blending component in road transport).  
22 Some fraud allegations have been reported to the Commission concerning imported biofuels allegedly fraudulently classified 
as advanced biofuels produced from used cooking oil. Although these claims could not be verified by the Commission, they 
highlight the importance of strengthening safeguards against fraud in the biofuels market.  
23 Under current regulation, the use of CO2 from fossil sources for the production of e-fuels will not allow the respective fuels 
to meet the required 70% emission savings after 2041. 
24 EASA, 2025, ReFuelEU Aviation Annual Technical Report 
25EASA, 
downloads/EASA_EAER_2025_Book_v5.pdf 
26 Based on expert feedback the Commission estimates the current annual SAF production capacity in the EU is just above 1 
million tonnes (Mt). Almost all this SAF production is HEFA and does not account for co-processing production using sustainable 
feedstock in fossil fuel plants, for which there is not enough reliable information. 

https://www.easa.europa.eu/sites/default/files/eaer-

Environmental  Report, 

European  Aviation 

2025, 

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under EASA’s realistic scenario27. However, meeting the sub-target for eSAF (1.2%) in 2030 
remains uncertain. Beyond 2030, all RFEUA targets  increase sharply. At present, available 
and forecasted volumes of bio- and particularly of eSAF are not sufficient to meet the post-
2030 RFEUA targets. Therefore, production capacity needs to extend, and extensively for eSAF 
as they are set to play a major role in the decarbonisation of aviation due to their high scalability 
potential and high climate added value.  

Investment needs 

For 2035, the RFEUA SAF target is 20%, out of which 5% needs to be eSAF. It is estimated to 
require investment in the range of EUR 56.93 billion to EUR 66.75 billion28. 

For 2050, the RFEUA SAF target is 70% out of which 35% needs to be eSAF. It is estimated to 
require investment in the range of EUR 267.9-376.2 billion29.  

2.3 Roadmap for the energy transition in waterborne transport  

Waterborne transport accounts for  almost 13.3% of the EU’s CO₂ total transport emissions30, 
given that 94%31 of fuels used in the sector are conventional liquid petroleum products. 

The FEUM regulation sets a clear roadmap for the decarbonisation of the maritime sector. This 
regulatory framework has triggered an increased interest in renewable and low carbon fuels, as 
noted in the context of the Renewable and Low-Carbon Fuels (RLCF) Alliance, which includes 
synthetic fuels, while also encouraging the use of direct electrification in the limited cases where 
it  is  feasible32.  The  waterborne  transport  sector  is  to  make  use  of  different  technologies 
(including  wind  assisted  propulsion)  and  a  broad  basket  of  SMF,  including  LNG  as  a 
transitional fuel. LNG, with effective methane slip mitigation technologies, can reduce also GHG 
emissions.  

Coastal  ships  operating  in  small  and  medium  ports  can  use  electric/hybrid  propulsion 
accompanied by bio-  and in  the future  e-diesel,  while ocean-going  ships are moving towards 
methane (LNG, bio-methane and in future e-methane). Some ships operating in the largest hubs 
are  expected  to  shift  to  biodiesel-  or  e-methanol  and  also  to  ammonia  in  the  longer  term. 
Moreover, the shipping  sector is  diverse,  and many SMEs form  its backbone, with  diverging 
operations  and  fuels  need.  A  strategy  needs  to  account  for  the  characteristics  of  all  shipping 
segments. 

27 EASA, 2025, ReFuelEU Aviation Annual Technical Report 
28 Estimations are calculated by the Commission based on current announced prices for the CAPEX costs to produce biobased 
fuels (approx. at 3 bn EUR/Mt) and e-fuels (approx. at 20 bn EUR/Mt). In house EC calculations considered the progression of 
the technology maturity as SAF pathways reach higher TRLs (8-9); the decrease of CAPEX for the more mature technologies 
and the growth of the aviation sector based on the latest EUROCONTROL data. The effect of economies of scale was considered.  
29 Corresponding to yearly investments of EUR 1.27-2.04 billion for bio-SAF and of EUR 9.45-13.00 billion for eSAF. 
30  EU  transport  in  figures:  Statistical  pocketbook  2025.  Data  from  2023 
https://op.europa.eu/s/Aac0 
31 EMSA, EMTER 2025 Report.  
32 On shore power supply and for some limited shipping use cases at present. 

international  bunkers 

including 

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However,  there  is  a  risk  that  current  market  investments  will  not  be  sufficient  to  support 
production of the estimated 11.3 Mtoe of SMF that are forecasted to be needed for 2035 under 
FEUM. The constraints affecting European feedstocks for biofuels and the 2% target for eSMF 
under FEUM require the quick upscaling of e-SMF. 

Similarly  to  the  maritime  sector,  a  broad  set  of  possible  alternatives  to  fossil  fuels  are  being 
considered for inland waterways (IWW), smaller short-sea shipping and fishing vessels as 
well as for recreational craft33. The IWW sector and recreational craft experience a low pace of 
penetration of new vessels (only 15%-20% renewal of the fleet by 2050). With no mandatory 
targets in place, at least 90% of vessels, will still use diesel (relatively low quantity currently 
estimated  at  1.7  million  tonnes),  which  may  progressively  be  replaced  by  renewable  drop-in 
fuels. This is equally true for the fisheries sector34. 

Investment needs 

By 2035, the FEUM GHG emissions intensity reductions target is 14.5%. While the sector has a broad 
mix of possible alternatives (different fuel technologies as well as different possibilities for blending 
with  conventional  fuels  for  existing  and  emerging  powertrains),  it  is  estimated  that  the  induced 
production of bio-SMF and e-SMF will require investments35 in between EUR 34.7 billion and 
EUR 46.7 billion by 203536.  

Decarbonisation of the inland waterways and fisheries sectors will require around an additional 3.1 
Mt, approximately, reaching a total of 23.1 Mt by 2035. 

3.  ACTIONS TO BOOST INVESTMENTS  

For aviation and waterborne transport combined, around 20 Mt of renewable and low-carbon 
fuels will be needed by 2035. To comply with the requirements, around EUR 100 billion37 in 
investment is needed38 by 2035, with a large majority from the private sector. Public support at 
both  European  and  national  level  is  needed  to  help  derisking  the  massive  private 
investments that are required for building large-scale renewable and low-carbon fuel plants. 
Our  policies  need  to  be  aligned  and  be  better  targeted.  This  plan  focuses  on  the  short-  and 
medium-term measures to help kick-off the first investments. 

33  These  include  hydrotreated  vegetable  oils  (HVO),  liquefied  biomethane  (LBM),  green  methanol  or  green  hydrogen  in 
combination with fuel cells, internal combustion engines (ICEs), and green electricity in combination with batteries. 
34 The fisheries sector consumed over 1.60 billion litters of marine diesel in 2022 (around 1.4 Mtoe) and emitted 4.2 million 
tonnes of CO2. Investment is constrained in a sector with fleet's average age of 36.5 years, a shrinking size, minimal renewal 
rates (less than 1%), and technological uncertainties. The unique requirements of fishing vessels and the sector’s small market 
size also deter investors. It is equally true for the aquaculture industry. A roadmap on energy transition in fisheries and aquaculture 
is foreseen in 2026. 
35 This range is attributed to the fact that estimating investment is difficult in view of the broad mix of fuel technologies available 
and blending possibilities that can be used by existing and emerging powertrains/propulsion systems and infrastructure.  
36 2040 Climate targets Impact Assessment. Investment needs for maritime are calculated under the assumptions that all fuels 
will  be  EU  sourced.  Under  the  FEUM  scope,  in  total  28  Mt  of  fuels  will  be  required.  Calculations  considered  the  PRIMES 
forecast necessary by 2035, realistic investment needs for advanced fuels and eSMF, electricity at 1.4% share towards reaching 
the FEUM GHG emissions reductions targets, and fulfilling the sunrise clause of RFNBOs target (2%). 
37 Commission estimates indicate a split in the range of EUR 57 billion to EUR 67 billion for aviation and EUR 35 billion to 
EUR 47 billion EUR for maritime transport.  
38 Without considering the investment required for vessels, aircrafts, and the relevant infrastructure. 

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The EU has a broad range of EU funding programmes and instruments at its disposal39. These 
programmes, together with funding from Member States, have already supported the transition 
to renewable and low-carbon fuels, but with limited market impact so far. Projects too often fail 
to progress beyond the demonstration phase, and technologies do not scale up to full industrial 
and commercial deployment.  

This plan is expected to mobilise at least EUR 2.9 billion until end of 2027, making particular 
use  of  the  InvestEU,  the  Innovation  Fund  and  Horizon  Europe.  It  will  be  implemented  in 
partnership  with  Member  States  and  by  triggering  and  activating  market  support  from  the 
European Investment Bank (EIB) Group and other financial institutions.  

The  next  multiannual  financial  framework,  and  in  particular  the  European  Competitiveness 
Fund,  notes  the  importance  of  renewable  and  low-carbon  fuels.  The  foreseen  national  and 
regional partnerships plans are also expected to support this area. For strong market growth in 
the  longer  term,  it  will  be  critical  to  set  up  a  new  market  intermediary  mechanism  that  can 
facilitate short-term (end user) and long-term (fuel producer) contracts, provide price stability 
and reduce risks through double-sided auctions.  

3.1 Actions to mobilise EU investment support in the short-term 

Innovation Fund  

Up until now, the Innovation Fund has supported 39 projects  focusing  on the production of 
innovative sustainable fuels, including methanol, ammonia and hydrogen, with a total of EUR 
2.1 billion. The Commission has been actively working with project promoters and industry, also 
in the context of the RLCF Alliance, to help advance a stronger project pipeline.  

Since 2020, the Innovation Fund has supported SAF projects with EUR 286 million. As part of 
the last overall Innovation Call, the Commission is awarding this week EUR 153 million to four 
eSAF projects and EUR 293 million to five SMF projects. They will contribute to developing 
the urgently needed first generation of eSAF/[e]SMF projects in the EU and strengthen Europe’s 
industrial  manufacturing capacity.  In addition,  11 aviation  and  16  maritime  fuel  projects that 
scored above the Innovation Fund evaluation thresholds will be awarded the STEP Seal40. The 
Commission is inviting Member States and financing institutions to consider providing support 
for these high-quality projects, including in the context of the mid-term review of the Cohesion 
policy or through  the use of national  revenues from  the Emission Trading Scheme (ETS) for 
climate purposes.  

Building  on  these  results,  the  Commission  will  open,  in  early  December  2025,  another 
European  Hydrogen  Bank  auction  with  a  dedicated  budget  of  EUR 300  million  for  the 
production of hydrogen with off-takers in the maritime and aviation sectors. The Innovation 
Fund will also continue to support innovative projects in both the maritime and aviation sectors, 

39 Including the EU ETS’ Innovation Fund, InvestEU, Horizon Europe (including support for the European Innovation Council), 
the Connecting Europe Facility, financing under the Cohesion policy funds and the recovery and resilience plans. 
40  The STEP  Seal  is  a  quality  label  for  excellent  and  high-potential  projects.  It  enables  to  get  extra  visibility  and  explore 
possibilities for additional EU public and private funding and support services.  

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including SAF and SMF production, via the general call for proposals, in which projects in the 
maritime  sector  will  receive  beneficial  conditions  (a  bonus  point)  for  their  potential  to 
decarbonise and reduce climate impacts. 

In  collaboration  with  the  EIB  Advisory,  the  Commission  will  also  focus  on  improving  the 
technical and financial maturity of pioneering low-carbon e-fuel facilities in the EU. 

InvestEU  

The  recent  agreement  between  the  Council  and  the  European  Parliament  on  enhancing  the 
InvestEU programme increases the EU guarantee by EUR 2.5 billion unlocking nearly EUR 55 
billion in additional public and private investments. This can support projects in clean tech and 
clean  mobility,  including  projects  across  the  whole  value  chain  from  fuel  production  to 
distribution  and  use.  Altogether,  the  Commission  expects  to  mobilise  investment  of  around 
EUR  2  billion  for  the  sustainable  alternative  fuel  sector  in  the  2026-2027  period.  The 
InvestEU  Implementing  Partners41  will  play  a  key  role  in  helping  to  stimulate  substantial 
investment in renewable and low-carbon fuel projects for maritime and aviation. 

European Investment Bank Group 

To date, the EIB Group, including through the support of the InvestEU programme, has been 
providing  more  than  EUR 1  billion  to  renewable  and  low  carbon  fuel  plants  projects42.  This 
financial support to production facilities is complemented by support to the wider ecosystem and 
technical advice by EIB Advisory. These are good initial steps, but more needs to be done. 

The Commission has been intensively working with the EIB Group to understand the challenges 
in supporting the innovation and development of renewable and low carbon fuels. It will intensify 
this  work  to  mobilise  additional  investments,  including  through  the  EIB  Group’s  TechEU 
programme, which is expected to mobilise EUR 250 billion by 2027 in key important areas for 
Europe’s competitiveness such as clean tech. Backed also by InvestEU, TechEU will provide a 
wide range of tools to the whole renewable and low carbon value chain with the clear intention 
to increase the number of projects in this area. 

The  Commission,  including  through  the  RLCF  Alliance,  will  offer  greater  support  to  project 
promoters  with  the  aim  of  improving  project  maturity  and  bankability,  through  knowledge-
sharing  activities,  identifying  best  practices,  and  connecting  top-tier  project  promoters  with 
financial institutions. 

Horizon Europe  

41 EIB Group, National Promotional Banks, Multi-lateral Development Banks, and Regional Development Banks. 
42 For example, a EUR 1 billion large-scale biofuel project from MOEVE in Andalucia received a loan of over € 400 million 
from EIB under the InvestEU mandate. The INERATEC ERA One e-fuel production facility, the largest of its kind in Europe, 
signed a EUR 40 million venture debt loan with the EIB and received a EUR 30 million grant from the Breakthrough Energy 
Catalyst Venture Programme. 

9 

 
 
 
As  announced  in  the  Clean  Industrial  Deal,  the  Commission  will  launch  a  flagship  Horizon 
Europe call of around EUR 600 million under the 2026-2027 work programme to support fit-
for-deployment projects, including for renewable and low carbon fuels. 

The  next  Horizon  Europe  call43  for  2026  will  provide  a  total  of  EUR 63.5  million.  EUR 33 
million will be available for projects focused on the large-scale production of liquid advanced 
biofuels and RFNBO, and another EUR 8 million for projects securing advanced biofuels and 
RFNBO  value  chains.  EUR 22.5  million  will  go  towards  supporting  innovative  solutions  for 
energy  conversion  and  safety  of  low  and  zero-carbon  fuels  in  maritime  transport.  Emerging 
renewable fuel solutions will also be supported. The upcoming Horizon Europe work programme 
for 2026-2027  should  include topics to  establish interregional value  chains of renewable fuel 
technologies  across  the  EU,  as  well  as  to  de-risk  renewable  fuel  technologies  through 
transnational  pre-commercial  procurement  of  renewable  fuel  industrial  value  chains.  For  the 
upcoming new work programme of Horizon Europe for 2026-2027, the Commission intends to 
present two SET Plan Flagship topics covering sustainable alternative fuels with an estimated 
amount of EUR 70 million. 

The European Innovation Council 

The  European  Innovation  Council’s  (EIC)  calls  can  support  renewable  and  low-carbon  fuels 
developers  by  funding  early-stage  research  through  ‘EIC  Pathfinder’  and  facilitating  market 
readiness via ‘EIC Transition’. Additionally, the ‘EIC Accelerator’ and its ‘STEP Scale Up call’ 
can support the scaling  of companies  developing sustainable fuel  innovations.  The EIC 2025 
work programme offered EUR 50 million for ‘Breakthrough innovations for future mobility’.  

Under the 2026 EIC work programme, to be adopted today, these projects will continue to be 
eligible from the EIC Scale Up call of EUR 300 million 44. The Commission is also considering 
replicating this in  the programme of 202745, with  a similar budget, which could  help  support 
renewable and low-carbon fuel developers. 

ETS support to sustainable and low-carbon fuels  

Under the EU Emission  Trading  Scheme  (ETS),  20 million  allowances estimated at  EUR 1.6 
billion  are  reserved  for  the  uptake  of  SAF  by  airlines  from  2024  to  203046.  The  aim  is  to 
incentivise  first  movers  by  fully  or  partially  covering  the  price  difference  between  SAF  and 
conventional  aviation  fuels.  This  reduces  RFEUA  impacts  on  competitiveness  of  European 
operators until SAF prices become more cost-competitive in relation to fossil fuels. For 2024, 
the support amounted to about 1.3 million allowances, worth approximately EUR 100 million, 
distributed to 53 operators. 

43 Horizon Europe Cluster 5 Call 02-2026 (WP 2025) (HORIZON-CL5-2026-02) 
44 This call has a specific objective on sustainable fuels and RFNBO technologies. 
45 “Breakthrough innovations for future mobility” challenge  
46 This support comes on top of the EU ETS incentive for using SAF as operators are not required to surrender allowances for 
the use of these fuels – an advantage worth around €25 million in 2024. 

10 

 
 
 
Given the potential of such a mechanism to bridge the price gap between fossil and renewable 
low carbon fuels, the Commission will assess the possibility of extending the ETS SAF support 
in terms of volume and duration for aviation and will explore an analogous mechanism for EU-
produced SMF without prejudice to the proposals on new own resources. 

Flagship actions 

The Commission will: 

•  Provide MEUR 446 under the 2024 Innovation Fund call for 4 eSAF projects and 5 maritime 

fuel projects. 

•  Launch  a  European  Hydrogen  Bank  auction  (Innovation  Fund),  with  a  EUR 300  million 

window for projects with aviation and maritime off-takers (Q4 2025). 

•  Mobilise  EUR 2  billion  from  InvestEU  for  the  sustainable  alternative  fuel  sector  (2026-

2027). 

•  Support  the  EIB  Group  to  mobilise  additional  investment,  including  through  the  TechEU 

programme (2026). 

•  Provide an indicative budget of EUR 133.5 million supporting R&I projects of renewable 
fuel technologies and industrial value through Horizon Europe call and SET Plan flagships 
(2026-2027). 

•  Consider  extending  SAF  support  under  the  EU  ETS  as  part  of  its  upcoming  review,  and 

explore analogous support or alternative measures for EU-produced SMF (2026) 

3.2 Developing new instruments to tackle market failures  

In  consultations  for  this  plan,  stakeholders  have  univocally  pointed  out  that  the  EU  needs  to 
consider  a  new  approach  to  derisking  market  investment  in  addition  to  existing  tools, 
namely  one  that  addresses  the  root  cause  of  price  and  revenue  risks.  Competitive  bidding 
mechanisms such as double-sided auctions are recognised as a key instrument in this regard47.  

To  accelerate  the  possible  establishment  of  a  double-sided  auction  and  field  test  possible 
solutions at EU level, the Commission will formally launch an “Early Movers Alliance” with 
interested Member States at high-political level by the end of the year, whilst also assessing the 
conditions  for  an  EU-wide  intermediary  mechanism  in  the  medium  term  that  should  support 
making full use of the power of the single market. 

Understanding double-sided auctions 

Member  States  have  put  in  place  mechanisms  such  as  contracts  for  difference,  carbon  contracts  for 
difference  (CfD  or  CCfD)48,  and  ’revenue  certainty  mechanisms’,  as  well  as  double-sided  auctions49. 
Double-sided auctions use a market intermediary to connect fuel producers and buyers, by offering 

47 Draghi report https://commission.europa.eu/topics/eu-competitiveness/draghi-report_en#paragraph_47059  
48 A  CfD  mitigates  the  market  risk  by  paying  the  supplier  the  difference  between  a  predetermined  reference  price  reflecting 
conventional fuel and a ‘strike price’ set at the value required for the new technology to be viable. CCfD schemes are suitable 
for sectors covered by the ETS. 
49These mechanisms are subject to State Aid approval by the Commission when they involve Member State resources. Germany 
and the Netherlands have provided EUR 600 million to the H2 Global Foundation, which is an intermediary, for a joint tender to 
import renewable hydrogen in 2027 through double auctions. 

11 

 
 
 
 
long-term contracts (e.g. 10-15 years) with producers of fuels on one side, and by concluding short-term 
contracts (e.g. 1-3 years) with buyers of SAF or SMF for the offtake of these fuels on the other side. They 
provide promoters with the revenue certainty needed to secure financing for the construction of new 
production facilities, while taking on the financial risks of refinancing through a series of shorter-term 
offtake contracts. 

Early Movers Alliance and pilot for a pooled double-sided auction  

The Commission will set up a task force with the Member States to establish a conceptual 
framework  for  the  pilot  auction  to  be  finalised  by  the  end  of  2025.  The  objective  will  be  to 
mobilise at  least  EUR 500 million in  2026 to  finance several  large-scale projects  through the 
organisation of the first pooled double-auction for eSAF. This could be implemented using 
existing mechanisms such as the H2 Global Foundation50. 

In  this  context,  the  Commission  will  offer  further  support  through  the  Competitiveness 
Coordination  Tool.  By  the  end  of  the  year,  the  Commission  will  establish  a  pilot  for 
renewable and low carbon fuel production for the maritime and aviation sectors, with the aim 
of  facilitating  the  joint  work  on  a  first  EU-pooled  double-sided  auction  pilot  and  joining  the 
necessary financial support.  

Working towards an EU-wide double-side auction 

Building on the pilot action, the Commission will launch preparations, in early 2026, for setting-
up  an  EU-wide  mechanism  for  an  EU-wide  double-sided  auction  for  SAF  and  SMF 
production, without prejudice to the proposals on the next MFF and new own resources. 

This will include identifying the best options for the design and governance of the EU market 
intermediary and methodologies for mobilising sufficient funding at EU and Member State level 
including possibly through the Innovation Fund and other instruments. The proposal for the new 
European Competitiveness Fund will allow support for renewable and low-carbon fuels over the 
2028-2034 period, including through award procedures in the form of competitive bidding. 

The Commission will further analyse suitable auction models51. To this end, a study is ongoing 
to assess appropriate governance frameworks and identify the legal requirements that would be 
necessary to launch such auctions. 

3.3 Improving the use of support measures at national level 

50 https://h2-global.org/ 
51  Study 
tenders/opportunities/portal/screen/opportunities/tender-details/5201c7be-3e33-43f6-b1e7-081412f75e34-CN 

financed  by  European  Parliament,  call 

tender  available  at  https://ec.europa.eu/info/funding-

for 

12 

 
 
 
Important support is already being provided through various Member States’ support schemes52. 
However, there could be additional efficiency gains from  better aligning  and leveraging  such 
support. 

The  Commission  calls  upon  Member  States  to  make  the  full  use  of  the  flexibility  and 
simplification introduced by the new State aid rules accompanying the Clean Industrial Deal 
State  Aid  Framework  (CISAF)53.  Simplified  compatibility  requirements  apply  to  State  aid 
schemes that incentivise investment projects adding production capacity for renewable and low-
carbon  fuels  as  well  as  manufacturing  capacity  for  the  plants  and  main  components  that  are 
needed to deploy the required related production technologies. 

The Commission also calls upon Member States to ensure that national measures on the use of 
methane and blends do not indirectly introduce barriers to transnational trade with bio-methane 
and limit cross-border availability within the single market54. The uptake of the Union Database 
will prevent claims from being counted twice and lay the groundwork for an integrated single 
market  for  biomethane.  The  Commission  will  work  with  Member  States  to  address 
inconsistencies  regarding  the  eligibility  of  subsidized  biomethane  across  Member  States  to 
facilitate an easier uptake of the SMF55. 

The Joint European Forum for Important Projects of Common European Interest will decide 
by the end of November 2025 whether to consider a potential IPCEI candidate in the area of 
renewable and low-carbon fuels for aviation and waterborne transport56. Once candidate status 
is  endorsed,  the  Commission,  through  the  new  Design  Support  Hub  stands  ready  to  assist 
Member States in the early design of such an IPCEI candidate. 

Fossil fuel subsidies and taxation regimes have an impact on the price gap between fossil fuels 
and  renewable  and  low-carbon  fuels.  Member  States  are  encouraged  to  review  subsidies  and 
taxation regimes and to urgently conclude negotiations on the Energy Taxation Directive. 

Recovery and resilience plans (RRPs) under the Recovery and Resilience Facility (RRF) play 
a major role in the green transition in all Member States. Implementation is ongoing but delays 
still exist. As recently announced57, different options are available to Member States to ensure 
that their RRPs are implemented completely. There is still a small window of opportunity to take 
measures  to  allow  more  investment  in  the  production  of  renewable  and  low-carbon  fuels, 

52 For example, a Danish scheme of EUR 36 million (DKK 268 million) for use of SAF on domestic flights, a French call of 
EUR 100 million for domestic SAF production,  a German aid scheme of EUR 300 million for domestic eSAF production,  a 
Portuguese support scheme of up to EUR 40 million for SAF production, a Dutch scheme of EUR 150 million for development 
of SAF technologies or a Greek scheme of EUR 300 million for sustainable fuels in transport, including SAF. 
53 https://eur-lex.europa.eu/eli/C/2025/3602/oj  
54  Use  of  methane  and  blends  one  possible  short  to  medium  term  solution  to  reduce  emissions  of  EU  energy  and  transport 
systems, provided methane emissions into the atmosphere can be contained. 
55 Member States use different types of subsidies for biomethane. Some schemes allow producers to benefit from more than one 
subsidy, potentially from different member states that can distort competition. These differences lead to inconsistent eligibility 
rules and certification / guarantees of origin (GOs) and unequal risk profiles for investors influencing biomethane deployment. 
56 The decision to start the identification phase of an IPCEI must stem from Member States and approved by the Commission 
under State aid rules. 
57 COM (2025) 310 final  

13 

 
 
 
provided that they can be finalised by 31 August 2026 and Member States include them urgently 
in their revised plans. 

Member  States  are  legally  required  to  use  revenues  from  the  EU  ETS  to  invest  in  climate 
measures, which can include actions to decarbonise the aviation and maritime sectors, inter alia 
via production and uptake of sustainable fuels, improvement of the energy efficiency of ships 
and aircraft, investments in innovative technologies and sustainable infrastructure such as green 
airports  and  ports.  Some  Member  States  are  allocating  such  revenues  to  the  aviation  and 
waterborne sector supporting and providing better predictability for their investments. Member 
States are encouraged to use part of the revenues they are getting from the EU ETS to invest in 
decarbonising the maritime and aviation sectors, including via renewable and low-carbon fuels.  

Flagship actions 

The Commission will: 
•  Work together with Member States to set up a pooled joint pilot double-sided auction for 

eSAF production in the EU worth EUR 500 million (2025-26). 

•  Start, under the Competitiveness Coordination Tool, a pilot project on renewable and low-

carbon fuel production for the maritime and aviation sectors (2026). 
•  Work towards identifying a potential IPCEI on SAF and SMF (2026). 
•  Assess  the  feasibility  of  establishing  an  EU-wide  approach  to  double-sided  auctions  for 

SAF/SMF production (2025-27). 

•  Encourage  Member  States  to  allocate  adequate  ETS  revenues  for  maritime  and  aviation 

sectors, including sustainable and low-carbon fuel production.  

3.4 Ensuring good enabling conditions for market investments  

For the single market to work properly, all regulatory provisions need to be implemented and 
transposed  swiftly,  correctly  and  consistently.  This  concerns  in  particular  the  relationship 
between the RED and the RFEUA and FEUM Regulations.  

The Commission recalls that RFEUA sets harmonised SAF and eSAF supply mandates for the 
single market in the EU to preserve the level-playing field for the air transport single market. 
However, the situation is different  for maritime transport, not yet subject to dedicated supply 
targets in the EU, given the different operating profile of the sector. Yet under the RED, Member 
States are already required to include maritime fuel suppliers in the mechanisms to promote the 
use of renewable energy in transport. The Commission will further work with Member States to 
incentivise the supply of SMF to help meet the RED and FEUM targets while avoiding market 
distortions. Promoting availability of SMF in EU ports will receive particular attention in the 
preparation of the upcoming Energy Union package or the renewable energy framework to be 

14 

 
 
 
presented in 202658 and will be considered in the tripartite contract for biomethane as announced 
in the Commission roadmap to phase out remaining Russian energy imports. 

The Commission will also assess how to address the challenges regarding difficulties for aircraft 
operators  in  obtaining  information  and  documents  on  prices,  volumes  and  locations  of  SAF 
supplied, and in gaining access to the fuel distribution infrastructure at airports for self-supply. 
Airlines are encouraged to join the Flight Emissions Label, which informs passengers on airlines’ 
carbon footprint, reflecting SAF uptake and fleet modernisation. 

Building  on  experience  with  mitigating  the  financial  risks  of  wind  and  solar  projects59,  the 
Commission  will  examine  how  power  purchase  agreements  (PPAs),  could  be  extended  to 
renewable and low-carbon fuel production when these markets are more developed. And drawing 
on experience in offshore wind and grids, the Commission will also facilitate the setting up of a 
tripartite contract for SAF and SMF for storage and for biomethane through the RLCF Alliance. 

Given the variety of SMF and different energy transition strategies of operators, it will be not 
economically feasible to ensure the availability of all fuels at all ports. Similarly, given the small 
amounts  of  eSAF  and  advanced  biofuels  to  be  produced  over  the  coming  years,  it  could  be 
challenging to secure supply to all airports across the EU in short-term. The Commission will 
assess the feasibility and design options for possible mechanisms using tradable SAF and SMF 
certificates, as well as evaluating time-framed book and claim options. Such a system should 
take into account the existing sustainability certification systems60. 

Finally, the Commission will also launch a study in 2026 to assess the issue of decarbonisation 
in the inland waterways sector and identify possible regulatory changes which could contribute 
to the uptake of alternative fuels. 

3.5 Measures to simplify the implementation of the existing regulatory framework  

Experience from the early stages of RFEUA implementation has shown that investments in new 
SAF  capacity  could  be  further  facilitated  by  strengthening  market  transparency  and  reducing 
administrative burden. To this end, the Commission will assess ways to clarify the obligations 
on incumbent upon aviation fuel suppliers, including promptly providing aircraft operators 
with SAF documents, ensuring the traceability of SAF volumes and sustainability certificates 
until final consumption by aircraft operators and connecting the Union Data Base (UDB) with 
the EASA Sustainability Portal to allow the use of the UDB data.  

The Commission will also consider options for the simplification and further digitalisation of 
the reporting requirements61, including those stemming from the anti-tankering obligations. 
The Commission also plans to further strengthen the sustainability certification rules as well as 
to enforce the mandatory use of the UDB to cover raw materials. Extending and upscaling the 

58 This framework will include legislative proposals in 2026 setting-up of the energy efficiency framework and of the renewable 
energy framework.  
59 e.g. cooperation of Commission and the EIB in a pilot project with an indicative volume of EUR 500 million.  
60 Certification under the RED and the fuel traceability needs until final consumption via the Union Database.  
61 With an aim to have single data entry point for all the reporting obligations. 

15 

 
 
 
UDB is necessary to enable full traceability of renewable and low-carbon fuels right up until the 
end use, through the EASA Sustainability Portal62.  

For  maritime,  and  building  on  lessons  from  the  first  reporting  periods,  the  Commission  will 
assess the ability to simplify the monitoring and verification of maritime fuels use. It will 
examine the possibility of developing a single monitoring, reporting and verification framework 
(MRV) for maritime decarbonisation, serving both ETS Maritime and FuelEU, with an important 
potential  to  reduce  administrative  burdens  for  shipping  companies,  verifiers,  and  Member 
States63. This will be considered in the upcoming review of the EU ETS, MRV and FEUM. The 
future EU Ports Strategy, to be adopted in Q2 2026, will support ports in fulfilling their roles in 
the energy transition and energy hubs. The EU Industrial Maritime Strategy, to be adopted jointly 
with  the  Ports  Strategy,  will  strengthen  Europe’s  maritime  manufacturing  and  technological 
base, especially in new technologies, driven by increased use of sustainable fuels. In line with 
the  existing  legal  commitments,  EU  ETS  and  FEUM  will  also  be  reviewed.  The  adoption  of 
global measures at IMO will be taken into consideration. 

The Commission will shortly propose an Industrial Accelerator Act with measures supporting 
the  decarbonisation  of  energy  intensive  industries  including  refineries  for  renewable  and  low 
carbon fuel production. Hydrogen supplied to zero emission aircraft can count to eSAF targets. 
The Commission will support operationalising the EU SAF Clearing House bringing new SAF 
pathways  to  the  market  and  will  establish  a  collaborative  network  of  regional  centres  of 
excellence64, complementing the Alliance for Zero Emission Aviation.  

Ensuring  additional  renewable  electricity  production  capacity  dedicated  to  hydrogen  and 
reducing its cost is critical to making e-fuels more cost-competitive. The Commission will further 
assess how to facilitate access to feedstock, in the context of the effectiveness of the hydrogen 
framework. It is also important to provide certainty to producers of e-fuels that the renewable 
fuel of non-biological origin they use is future-proof in terms of counting towards the targets. 
The Commission will consider criteria to safeguard existing investments in case future reviews 
of the regulatory framework led to change in the relevant provisions for production inputs. 

Flagship actions 

The Commission will: 

•  Work on extending PPAs to renewable and low-carbon fuels (2026).  
• 

Assess ways to increase availability of SMF in ports in the context of in the context of the 
Energy Union package for the decade ahead (2026).   
Assess possible mechanisms using tradable SAF and SMF and evaluate book and claim 
options. 

• 

62 Challenges are also raised by project promoters as regards the interpretation of the eligibility of certain advanced bio-feedstock. 
To  this  end,  the  Commission  will  provide  further  guidance  in  the  context  of  the  revision  of  the  Implementing  Regulation 
996/2022. 
63 Including aligning definitions and design elements, such as responsible entity. 
64 The centres will support coordinated deployment of infrastructure and services and promote the regulatory environment that 
facilitates effective operations for zero emission aircraft. 

16 

 
 
 
• 

• 
• 

• 

Consider the needs of maritime sector in the tripartite contract for biomethane and work 
to develop a tripartite contract for SAF and SMF through the RCLF Alliance (2026). 
Improve alignment and simplify reporting for aviation and maritime sectors.  
Explore measures to protect early movers' investments in the context of the Energy Union 
package for the decade ahead (2026). 
Review the EU ETS and FEUM when IMO Net Zero Framework will be adopted. 

4.  STRATEGIC PARTNERSHIPS AND GLOBAL COLLABORATION TO BOOST 

SUSTAINABLE FUEL SUPPLY  

The  EU  has  been  instrumental  in  achieving  considerable  progress  on  global  commitments  to 
action  in  the  International  Civil  Aviation  Organization  (ICAO)  and  the  measures  being 
considered  by  International  Maritime  Organization  (IMO).  International  cooperation  will 
continue to be key for creating a global lead market for renewable and low carbon fuels. In turn, 
a global market will generate opportunities for European industry and benefit local economies, 
while  also  strengthening  our  ties  with  international  partners  and  avoid  carbon  leakage. 
Renewable and low-carbon fuels from partner countries, conditioned on the requirement to meet 
EU  or  EU-equivalent  environmental  standards  and  regulations,  including  CORSIA,  will  be 
needed to complement domestic fuels production, particularly in the initial ramp-up phase. At 
the same time, to prevent fraud and ensure a competitive level playing field65, action needs to be 
taken  to  safeguard  investments  in  the  EU.  Support  of  partner  countries  in  ambitious  binding 
international agreements is fundamental for implementation of these partnerships. 

4.1 Promote international partnerships for diversification, market access and global 
ambition 

Free  trade  agreements  and  mutually  beneficial  international  partnerships  remain  critical  to 
enhance  diversification,  access  to  markets,  helping  to  secure  imports  of  renewable  and  low-
carbon fuels and feedstock materials, and facilitating the import/export of clean tech in line with 
the recently adopted ‘Global Europe’ regulation proposal. For this purpose, the Commission will 
make the best use of free trade agreement and clean trade and investment partnerships (CTIPs) 
to  facilitate  the  financing  of  SAF/SMF  production,  storage  or  refuelling  (bunkering) 
infrastructure in partner countries, when it does not pose a competitive threat for the EU ports. 
These  sub-sectors  have  been  designated  as  flagship  projects  under  the  Global  Gateway.  As 
outlined in the Joint Communication for an EU global climate and energy vision66, the EU will 
support the executing of large flagship projects in partner countries through the Global Gateway 
Strategy.  The  Free  Trade  Agreement  with  Chile  already  contains  dedicated  provisions  to 
facilitate trade and investments in RFNBOs, including SAF and SMF, and to remove distortions. 
The EU has proposed such disciplines also in ongoing negotiations with Thailand, Australia, the 
Philippines, and the United Arab Emirates67. 

The first CTIP with South Africa aims to deepen cooperation on clean trade, create sustainable 
investment opportunities and promote EU and South African clean technologies in line with the 

65 ISCC, ISCC Response to Recent Suspected Cases of Mislabelling of Advanced Biodiesel, 2023. 
66 JOIN(2025) 25 final 
67 For example, export monopolies, dual pricing or non-tariff barriers for trade and investments. 

17 

 
 
 
Clean  Industrial  Deal.  The  CTIP  will  support  cooperation  in  strategic  clean  supply  chains 
including  sustainable  transport  fuels  in  the  aviation  and  maritime  sectors  and  related 
infrastructure. 

On  aviation,  the  EU  is  implementing  the  Assistance,  Capacity-Building  and  Training  for 
Sustainable Aviation Fuels (ACT-SAF) project with ICAO and EASA, in line with the ICAO’s 
‘No Country Left Behind Strategic Goal’. The Commission will continue to work with partner 
countries  in  Africa,  Latin  America  and  the  Caribbean  and  the  Asia-Pacific  as  well  as  with 
relevant UN organisations to support the development, production and use of SAF. In the short 
term, the Commission will launch a new Aviation Partnership Project in Latin America in Latin 
America  and  the  Caribbean  which  includes  support  for  SAF  production.  The  EU  will  also 
collaborate to exchange knowledge and experience gained through the RLCF Alliance with the 
ICAO Finvest Hub initiative to support the emergence of similar platforms at regional and global 
level.  The EU will look  to  further increase cooperation on sustainable fuels  with  the African 
Union,  including  by  supporting  efforts  to  replicate  the  RLCF  Alliance’s  good  practices  in 
Africa68. 

As regards maritime transport, the Commission has identified strategic ports worldwide (i.e. in 
Latin America, Sub-Saharan Africa and Asia) that have strong SMF production and bunkering 
potential. The Commission will accelerate the deployment of such fuels through contributing to 
the  establishment  of  green  shipping  corridors/hubs.  The  Global  Gateway  Green  Shipping 
Corridors (GGGSC) initiative is in its early stages of implementation, with the EU prioritising 
partnerships to decarbonise maritime transport. Finally, the Commission is proposing to allow 
for the possibility of awarding direct grants to private entities in support of projects that are in 
the strategic interest of the EU69. This would benefit both the aviation and maritime sectors. 

The Commission will also facilitate the development of renewable and low-carbon fuels value 
chains as part of a broader effort to support sustainable mobility and transport solutions in the 
Western Balkans, Ukraine and Moldova, as well as the whole Black Sea 70, which is integral to 
the Union’s connectivity, energy security and regional stability.  

The Commission proposed to establish renewable and low-carbon fuels as a key priority under 
the new Pact for the Mediterranean71 with the aim of strengthening a shared commitment to their 
production and use, promoting knowledge exchange, and stimulating private sector engagement. 

4.2 Work in international organisations towards global fuel market  

The IMO Net Zero Framework for shipping, the first global framework, was proposed to reduce 
GHG and aiming for net-zero emissions from international shipping by or around 2050. Even 

68 The EU-financed Assistance, Capacity-Building and Training for  SAF (ACT-SAF) project  implemented by the ICAO and 
EASA,  supporting  India  and  14 African  states:  Cameroun,  Côte  d´Ivoire,  Egypt,  Eq.  Guinea,  Ethiopia,  Kenya,  Madagascar, 
Mauritania, Morocco, Mozambique, Nigeria, Rwanda, Senegal, and South Africa with a budget of EUR 4 million. 
69 COM (2025) 551 final, Recital (70), Art 20 §10 and 11. 
70 JOIN (2025) 135 final 
71 JOIN (2025) 26 final 

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though  the  adoption  of  the  global  framework  has  been  adjourned  for  a  year,  the  Union  will 
continue working within IMO and international partners on a global framework.  

Thanks to the strong leadership of the EU and its Member States, progress has also recently been 
made  at  the  ICAO.  In  2022,  ICAO  member  states  adopted  the  long-term  aspirational  goal 
(LTAG) for international aviation of net-zero carbon emissions by 2050, which recognised SAF 
as the main enabler to achieve emission reductions. In 2023, agreed to the global aspirational 
vision to reduce international aviation emissions by 5% by 2030 through the use of SAF and 
other cleaner aviation energies (compared to zero cleaner energy use). 

In September 2025, ICAO member states called for widespread implementation of CORSIA as 
the global market-based scheme for international aviation.  

4.3 Working towards common standards at global level  

The Commission underlines the importance of international cooperation on robust sustainability 
criteria, transparent and comparable lifecycle emissions calculations for sustainable fuels as well 
as on improving compatibility, robustness and reliability of certification. Such cooperation on 
robust sustainability and emission calculation frameworks allow to improve level playing field 
across markets, reduces the risk of carbon leakage and administrative burden. In this context we 
will  continue  to  work  towards  dual  conformance  of  SAF  under  the  RED  and  CORSIA  and 
strengthening CORSIA. In the maritime sector, certification under the RED is being advanced 
both  in  the  EU  and  in  non-EU  countries,  while  at  the  global  level,  the  IMO  is  developing 
certification rules.  

4.4 Market monitoring and trade defence instruments  

Imports to the EU market should be subject to fair conditions to ensure a level playing field for 
EU operators. EU trade defence instruments provide an effective means to deter unfair practices 
and to take remedial measures against potential injurious imports. The Commission stands ready 
to use the trade defence instruments at its disposal, should this prove necessary. The Commission 
is currently stepping up its monitoring of imports of products from non-EU countries to detect 
potentially harmful import increases, including for biofuels.  

Uneven global rules in the aviation and maritime sectors, might result in traffic and emissions 
being  shifted  beyond  EU  borders.  The  Commission  will  assess  the  risk72,  and  if  appropriate, 
consider measures necessary to uphold a level playing field.  

5.  CONCLUSION 

The transition to a new powerbase in transport offers substantial opportunities for industrial 
growth and job creation in the EU, while helping the EU to increase its strategic autonomy, 

72  Commission’s  Economic  study  for  an  assessment  of  potential  carbon  leakage  in  the  aviation  and  maritime  sectors  and 
mitigating measures, other possible studies in the future possible as well. 

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diversify  energy  supplies  and  make  a  significant  contribution  to  decarbonising  the 
transport sector.  

While the road transport is advancing in its transition to zero-emission mobility and the rail sector 
has electrified a substantive share of its operations, decarbonising aviation and waterborne is still 
at an early stage. We must quickly build up renewable and low-carbon fuels capacity in the EU 
and  beyond.  The  challenge  is  pressing,  but  not  unsurmountable.  The  long-term  regulatory 
framework to  ramp-up demand for  such fuels  in the EU  is  in place  and is  here to stay. 
Ramping up domestic production and use is critical, but so is international cooperation to 
push  for  global  production  and  use,  not  only  to  meet  global  climate  goals  and  decarbonise 
transport, but also to provide also development opportunities for partner countries while ensuring 
a level playing field for our industry. 

For this transition to be successful, supporting and de-risking investments into the market ramp-
up of suitable technologies must be considerably stepped up placing renewable and low-carbon 
fuels and their sustainably sourced feedstocks firmly in the spotlight. 

20