As the European Union stands at the precipice of its first major compliance milestone under the ReFuelEU Aviation regulation, the association representing producers of bio-based aviation fuel (HEFA) in the EU looks forward. By 2030, the mandate for Sustainable Aviation Fuel (SAF) will jump to 6% and 20% by 2035. These targets sound modest until you consider the sheer industrial scale required to replace millions of tonnes of fossil kerosene. With currently 1-2% of the aviation fuel coming from non-fossil origin, the European Biodiesel Board (EBB) stresses that maintaining the overall ambition of EU aviation decarbonisation policies is essential to ensure investment certainty and deliver emissions reductions. However, improvements can be made – particularly to the ReFuelEU Aviation Regulation. To decarbonise our skies, we must scale European SAF volumes. Every drop of fossil kerosene we displace is a win for the climate and a step toward energy independence.

In a recently released position paper, the EBB advocates for a framework that provides regulatory certainty for the years to come. SAF production requires substantial upfront capital, long lead times and a stable framework to reach final investment decisions. SAF projects are highly capital-intensive industrial undertakings.

SAF mandates trajectory

Large jumps in the SAF mandate trajectory (such as from 6% in 2030-2034 to 20% in 2035) do not reflect the industrial reality of how SAF capacity is planned and developed. Therefore, the current five-year steps risk creating periods of temporary misaligning between capacity and mandated demand, followed by abrupt compliance pressure. This severely complicates offtake planning. For this reason, the EBB proposes to complement the existing milestone 5-year targets with a predictable and incremental annual trajectory. This would not alter the overall ambition of the Regulation, but would create a smoother and more investable curve for both producers and airlines.

Beyond the minimum

To grant greater flexibility, the EBB proposes to introduce a ‘SAF surplus and pre-fulfilment’ mechanism within ReFuelEU in addition to an annual incremental increase of SAF targets. Furthermore, the proposal touches on the EU ETS for Aviation and how it can support EU-produced SAF uptake, on the need to address the risk of carbon leakage, and on the recognition of co-production of eSAF with bioSAF. It also stresses that the ambition and scope of the ETS aviation should be maintained, and provides ideas on how collected ETS revenues should be reinvested in the EU aviation sector.

Feedstocks paradox

In many applications of biofuels, including aviation, we observe a feedstock paradox: while the targets keep increasing (and rightly so), the EU’s feedstock eligibility rules have become a patchwork. Instead, the Renewable Energy Directive (including its sustainability and GHG emission saving criteria) should be the only regulatory reference for feedstock eligibility.

Domenico Mininni is Policy Director at the European Biodiesel Board (EBB)