The EU Emissions Trading System Directive 2003/87/EC (EU ETS) governs the world’s largest carbon market: a cap-and-trade system covering key energy intensive sectors, accountable for 41% of EU emissions. In light of the European Green Deal and the EU’s new 2030 GHG target, the EU Commission proposed extending the scope of the EU ETS to expand carbon pricing to cover more of the European economy in September 2020, and a public consultation was launched to gather stakeholder views in October 2020. The review will consider extending the EU ETS to new sectors, including the road transportation sector, the buildings sector and the maritime transportation sector, and to all international flights for aviation, as the scope is currently limited to intra-EU flights.
Following intense negative engagement from the aviation sector, the reform of the EU Emissions Trading System (ETS) for aviation did not extend the scheme to international flights, but the extension to the maritime sector was maintained despite strong opposition. A standalone ETS adopted for road transportation and buildings aligned with advocacy from heavy industry (steel, chemical and cement sectors).
The EU ETS Monitoring, Reporting and Verification (MRV) framework for non-CO2 effects requires airlines to collect and share data on their non-CO2 emissions, enabling policymakers to better understand their impact. Although the 2022 revision of the EU ETS covered all flights departing or arriving at an airport situated in a Member State, the public consultation launched by the EU Commission in July 2024 proposed an intra-EEA scope until 2027. In August 2024, the MRV rules under the EU ETS were agreed, applying the measure to intra-EEA flights until 2027. From 2027, the requirement will be mandatory for all inbound and outbound flights to the EEA.
In 2012, the EU ETS was introduced to the aviation sector. Originally designed to apply to all flights departing the European Economic Area (EEA), the scope of the EU ETS was temporarily limited to intra- EEA flights to support the development of the “Carbon Offsetting and Reduction Scheme for International Aviation” (CORSIA), a global measure designed by the International Civil Aviation Organization. Following the 2023 EU ETS aviation revision, the restricted scope of the EU ETS was extended until 2027. The European Commission will perform an assessment of the EU ETS for aviation considering the efficiency of CORSIA in July 2026. If CORSIA is proven not to be sufficient to deliver on the goals of the Paris Agreement, the Commission could present a legislative proposal to extend the geographical scope of the EU ETS to all flights departing from the EEA. Ahead of this review, the European Commission launched a public consultation on the EU Emissions Trading System (EU ETS) and the Market Stability Reserve in April 2025.
Emissions Trading
The file was approved in April 2023 and will apply from 1 January 2024. A review of the policy’s geographical scope for the aviation sector is scheduled to take place by July 2026.
Emissions Trading
The file was approved in April 2023 and will apply from 1 January 2024. A review of the policy’s geographical scope for the aviation sector is scheduled to take place by July 2026.
In a May 2025 policy paper, Airlines for Europe (A4E) emphasized cost, competitiveness and carbon leakage resulting from climate policies for aviation and advocated against the extension of the Carbon Border Adjustment Mechanism to the aviation sector. A4E also appeared to advocate for the EU Emissions Trading System (ETS) to be aligned on the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) which would significantly reduce the ambition of the policy. However, it did call for a more ambitious CORSIA scheme. Finally, A4E emphasized cost, competitiveness, and carbon leakage concerns resulting from the EU SAF mandate but appeared to support it on the condition that a SAF Border Adjustment Mechanism is adopted.
In a 13 June interview at the Paris Air Show, the CEO of Air France-KLM, Ben Smith, emphasized competitiveness concerns resulting from climate policies for aviation, advocating for a level playing field. He stressed competitiveness concerns over the EU SAF mandate and the EU ETS, appearing to oppose the extension of the latter. Ben Smith was also unsupportive of the cap at Schiphol airport.
In its 2024 Annual Report published on 15 May 2025, Ryanair advocated for the EU Emissions Trading System (ETS) for intra-EU flights to be aligned with international Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) standards. Ryanair argued this would ensure the 'fair treatment' of intra-EU passengers.
In a 16 May position paper, Airlines for Europe (A4E) supported the introduction of the Sustainable Transport Investment Plan. It supported an increased use of bio-based SAF in aviation in the short-term with clear support for a switch to synthetic fuels in the medium to long-term but advocated for a technology neutral approach.
A4E appeared to advocate for weaker policy measures to safeguard the impact of SAF production on carbon stocks, alongside pushing for crop-based SAFs. It also advocated for Recycled Carbon Fuels eligibility to be extended beyond 2041.
Additionally, A4E appeared to emphasize cost, competitiveness and regulatory burdens from both RefuelEU Aviation the Fit for 55 package, but advocated for additional aviation policies responding to climate change. Finally, A4E advocated for the reinvestment of the EU ETS revenues in SAF uptake.
At an Airlines for Aviation (A4E) summit held on 27 March, Benjamin Smith, Carsten Sphor, Luis Gallego, and Michael O'Leary, the CEOs of Air France-KLM, Lufthansa, the International Airlines Group, and Ryanair called for the EU sustainable aviation fuel (SAF) mandate to be delayed until the further maturity of the SAF market. Lufthansa's CEO, Carsten Sphor, appeared to advocate for a less ambitious response to climate change and advocated to weaken climate policy for aviation. Ryanair's CEO, Michael O'Leary, advocated for the EU Emissions Trading Scheme to be aligned with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), which would weaken the ambition level of the policy.
However, the CEO of Air France-KLM, Benjamin Smith, supported the introduction of a carbon border adjustment mechanism in the aviation sector. Additionally, A4E clarified that the aviation sector still supports net-zero by 2050 for the aviation sector, despite emphasizing concerns surrounding SAF supply and cost resulting from the EU SAF mandate.
On 04 February, Destination 2050, a coalition between different European industry associations including Airlines For Europe (A4E), AeroSpace and Defence Industries Association of Europe (ASD), Airports Council International Europe (ACI Europe) and European Regions Airline Association (ERA), put out their new decarbonization roadmap.
It supports a long-term aspirational goal through ICAO of net-zero CO2 emissions from international aviation by 2050, supports the Carbon Offsetting and Reduction Scheme for International Aviation, the Paris Agreement, supports the Carbon Border Adjustment Mechanism for sustainable aviation fuel and advocated for increased use of bio-based SAF in aviation in the short-term with clear support for a switch to zero-emissions technologies in the medium to long-term. The roadmap appears to generally support policies incentivizing the production and uptake of SAFs. Destination 2050's roadmap supports continued free emissions of SAF allowances after 2030 and the inclusion of carbon removals under the EU ETS by 2026 alongside the re-investment of EU ETS revenues in clean technologies research and upscaling. The roadmap opposes any increase to SAF and e-fuel targets under ReFuelEU, but advocated for a gradual SAF supply increases of the SAF target under ReFuelEU.
More negatively, Destination 2050's roadmap opposes the EU tax on jet fuel and advocated for the alignment of feedstocks sustainability criteria for SAFs while advocating for the removal of non-biogenic CO2 restrictions. It also supports the Clean Industrial Deal but emphasize carbon leakage and competitiveness concerns from the Fit for 55 package, advocating that EU regulations must align with global measures.
In the minutes of an 8 January meeting with DG CLIMA, Airbus advocated for the delay of the non-CO2 Monitoring Reporting and Verification (MRV) scheme, and appeared to oppose the extension of the EU-ETS to all or departing international flights, suggesting ICAO should regulate international flights emissions. The EU ETS Monitoring, Reporting and Verification (MRV) framework for non-CO2 requires airlines to collect and share data on their non-CO2 emissions, enabling policymakers to better understand their impact.
Airbus also advocated for the EU Clean Industrial Deal to contain incentives and take a global approach.
In a 4 October Euractiv article, the president of the Confederation of the Italian Industry (Confindustria), Emmanuel Orsini, voiced concerns about the upcoming phase out of free allowances in the EU Emissions Trading System (ETS), stating “we cannot afford to lose pivotal supply chains due to key policy choices that we now know were wrong”. In the same article, Euractiv also reported that Confindustria will push for scrapping the new ETS for buildings and road transport, which is due to come in force in 2027.
In a January 11th joint statement, easyJet, KLM, Airbus and the Dutch Employers’ Federation (VNO-NCW) urged the introduction of a global kerosene tax on all flights and increased investment in international EU trains as an alternative to short-haul flights. The statement also supported the EU sustainable aviation fuel mandate, the removal of free emissions allowances under the EU Emissions Trading Scheme, and the development of infrastructure and policies to enable electric and hydrogen aircraft. The statement did not appear to support an increase to national air passenger duty tax.
On June 5th, Reuters reported that International Air Transport Association (IATA) CEO, Willie Walsh, had criticized EU climate policies as “anti-aviation” at its AGM, appearing to oppose the EU sustainable aviation fuels mandate, alongside opposing the introduction of jet fuel taxes in Europe and extending the EU ETS to international flights
In a May 10th position paper, Airlines For Europe (A4E) opposed an EU jet fuel tax, emphasizing costs, competitiveness and carbon leakage concerns. A4E also argued the tax would impede tourism and decarbonization efforts by diverting funds from decarbonization solutions. In the position paper, A4E further appeared to leverage its support for the EU Emissions Trading Scheme, EU sustainable aviation fuels mandate, and global Carbon Offsetting and Reduction Scheme to oppose the kerosene tax.
The Danish news agency DR reported in an April 2023 article that Maersk initially directly lobbied the Danish government to limit the expansion of the European Union (EU) Emissions Trading System to intra-EU shipping voyages. Maersk changed its position following the publication of the Commission’s proposal, supporting the inclusion of all shipping voyages, but called for the measure to apply from 2028, rather than 2024.
In a 16th February ‘The Points Guy’ article, easyJet stated it was “very disappointed” with the EU’s decision not to include all departing flights in the EU Emissions Trading Scheme (EU ETS), leaving them to be regulated by the Carbon Offsetting and Reductions Scheme for International Aviation. The spokesperson for easyJet further described CORSIA as “demonstrably ineffective” and urged for policies to make CORSIA more effective, or to expand the EU ETS to all departing flights in 2026.
In a press release on 15 December, BusinessEurope Director General Markus J. Beyrer stressed the impacts of the Carbon Border Adjustment Mechanism and EU Emissions Trading System Reform on the competitiveness of EU industry before the policy trilogues. He also supported export rebates in the CBAM and a gradual application until the mid-2030s, and supported a slower rebasing of the EU ETS emissions cap, and advocated for the EU ETS for road transport and buildings to include private households.
In a December 5th Trade Winds article, International Chamber of Shipping (ICS) Secretary General, Guy Platten, reportedly described the EU’s inclusion of maritime in the EU Emissions Trading Scheme (EU ETS) as “interesting” and stated that “to solve the global climate crisis, global solutions are needed”. However, according to Trade Winds, Platen also hoped that the EU’s momentum on climate policy would be adopted at the International Maritime Organization (IMO), which will hold its 79th Marine Environment Protection Committee (MEPC) this December.
In a November 30th press release, the World Shipping Council (WSC) appeared supportive of the EU’s inclusion of maritime in the EU Emissions Trading Scheme (EU ETS), advocated for a global carbon price to be established at the IMO’s 79th MEPC and urged the EU to “ensure that the EU ETS is a green pathway towards global decarbonization, and to work for effective global regulation at the IMO in December”.
In a letter to Members of European Parliament on 2nd December, BusinessEurope did not seem to support higher national targets in the ReFuelEU Aviation Plan, and advocated for a transitional period for the phase in of sustainable aviation fuels. It also supported a weaker reform of the EU Emissions Trading System for aviation.
Following trilogue negotiations on the EU Emissions Trading Scheme (EU ETS) for aviation, Ryanair released a press release which “condemned” the outcome of the vote. CEO, Michael O’Leary, appeared to argue that the decision to limit the scope of the EU ETS to intra-EU flights, rather than extending the scope to all flights departing the EU, has “abandoned the environment and ordinary families” and exempts the most polluting flights from paying taxes.
On November 30th, Airlines For Europe (A4E) Managing Director, Thomas Reynaert, released a letter providing policy recommendations ahead of an EU Transport Minister’s meeting occurring on December 5th. The letter appeared to support the Alternative Fuels Infrastructure Regulation while proposing exemptions for small airports and cautioned against targets for hydrogen and electric re-charging infrastructure for aircraft. It also supported an EU sustainable aviation fuel mandate while appearing to oppose the provision enabling member states to increase national mandates, suggest that fuel cost implications from the invasion of Ukraine be considered for interim targets, and emphasize carbon leakage concerns.
On December 5th, A4E released a YouTube video opposing an EU jet fuel tax, while supporting the EU Emissions Trading System (EU ETS). The video stated a jet fuel tax would undermine the EU ETS, distort competition and could lead to an increase in CO2 emissions.
Following trilogue negotiations on the EU ETS for aviation, A4E released a position paper on December 7th. The paper appeared supportive of the EU’s decision to maintain the scope of the EU ETS to intra-EU flights and create sustainable aviation fuel-based allowances, while opposing the proposed 2026 phase-out date for free emissions allowance.
Following EU trilogue negotiations on the EU Emissions Trading Scheme (EU ETS) for maritime, the European Community Shipowners Association (ECSA) and World Shipping Council released statements on November 30th, which appear to support the resulting proposal. The compromise applies the EU ETS to all emissions from ships travelling between, or berthed in, EU ports, and 50% of emissions travelling between an EU and non-EU port. ECSA specifically supported the vote to earmark revenues from the EU ETS for maritime’s energy transition and the allocation of EU ETS allowances to the shipping sector.
In a 21st November open letter, the World Shipping Council (WSC) appeared to support the inclusion of maritime under the EU Emissions Trading Scheme (EU ETS) and advocated for a life-cycle approach for fuels. This approach would incorporate the emissions released during fuel production and incentivize the use of Renewable Fuels of Non-Biological Origin.
The Federation of German Industries (BDI) published a position paper on the EU’s Fit for 55 package on 20th September, in which the association laid out its opposition to the 2035 zero emissions vehicle standard proposed by the EU Commission. In addition, the association supported quotas for low-CO2 and climate neutral aviation fuels as part of ReFuelEU Aviation, while emphasizing the risk of carbon leakage and the need for flexibility to compensate for additional costs, and called for "ambitious but realistic" quotas for biofuels in the Renewable Energy Directive (RED).
In the same position paper, BDI advocated for a Carbon Border Adjustment Mechanism (CBAM) test phase which only includes industries that support it, and the maintenance of free emissions allowances in the EU Emissions Trading System (ETS). Furthermore, the entity supported the extension of the EU ETS for road transport and buildings, but not for aviation, and it did not support “inappropriate” Minimum-Energy-Performance-Standards (MEPS) in the Energy Performance Buildings Directive (EPBD), as well as not supporting an energy consumption cap in the Energy Efficiency Directive (EED).
In an August 29th policy brief, Lufthansa appeared unsupportive of the Fit for 55 package, emphasizing cost and competitiveness concerns. In particular, it appeared to support the exemption of EU feeder flights from the EU Emissions Trading System (ETS), and oppose an extension to include all flights departing the EU. Lufthansa also called for ReFuelEU Aviation to be “designed in such a way that it does not affect EU airlines unilaterally” and a sustainable aviation fuels compensation mechanism after the quota increases in 2030.
In its weekly newsletter, published on 14th July, BusinessEurope stated positions on several of the EU’s Fit for 55 package policies, which have had positions agreed by all EU institutions. It supported increasing the ambition of the Alternative Fuels Infrastructure Regulation and was in favor of speeding up the EU Emissions Trading System (EU ETS) for road transport and buildings. However, it supported the EU Parliament’s proposal to stagger the rebasing of the EU ETS emissions cap. It also did not support proposals for an EU Carbon Border Adjustment Mechanism (CBAM), advocating for export rebates.
In a 27th June policy brief, Lufthansa appeared unsupportive of an extension of the EU emissions trading scheme (ETS) to flights departing the EEA and the inclusion of non-CO2 impacts, as proposed by EU Parliament. It further appeared to emphasize cost, competition and carbon leakage concerns with the EU sustainable aviation fuels (SAF) mandate and advocated for a “competition-neutral” design, without specifying any specific amendments.
In a 27th June press release, Hydrogen Europe welcomed the European Parliament position on the EU Emission Trading Scheme (ETS). The association supported the EU ETS extension into the maritime and aviation sectors, and a new scheme for the buildings and transport sectors. It also advocated for coverage of the hydrogen sector in the system. Hydrogen Europe also appeared to support the EU Carbon Border Adjustment Mechanism (CBAM) proposal from the EU Parliament. The group supported the gradual phase out of free allowances from the EU ETS, without specifying a timeline. However, it also called for rebates for exporters by emphasizing risk of carbon leakage. Finally, CEO Jorgo Chatzimarkakis advocated for higher sectoral sub-targets and targets for renewable fuels of non-biological origin (RFNBOs) in the EU Renewable Energy Directive revision, following the EU Council’s position on the policy.
In a June 17th press release, the World Shipping Council appeared to oppose an extension of the EU Emissions Trading System to extra-EEA voyages, instead advocating for a global market-based mechanism.
In a June 14th press release, Ryanair supported the expansion of the EU Emissions Trading System (EU ETS) to include flights departing the EEA, as proposed by EU Parliament. Ryanair’s CEO, Michael O’Leary, further described the current intra-EEA scope “absurd, unfair and inexplicable” and called on EU member states and Frans Timmermans to support the Parliamentary vote. However, in a June 9th press release, International Air Transport Association's (IATA) CEO, Willie Walsh, opposed the application of the EU ETS to flights departing the EEA, appearing to argue it may derail decarbonization efforts in faster growing markets outside of Europe. Instead, Walsh supported regulation through CORSIA. Likewise, in a June 8th statement on the EU Parliamentary vote, Airlines for Europe (A4E) appeared to also oppose an extension of the EU ETS to flights departing the EEA, the phase-out of free emissions allowances by 2025, and the inclusion of non-CO2 emissions within the EU ETS. In the statement, A4E welcomed the adoption of Sustainable Aviation Fuel allowances by Parliament.
On June 8th, Politico reported on a study commissioned by easyJet and Ryanair, which appears supportive of the inclusion of international flights in the EU Emissions Trading System (EU ETS). The report concluded that EU measures applying only to intra-EEA flights jeopardize 73% of emissions savings and encourage passengers to switch to non-EU destinations, while applying regulations to all flights doesn't lead to destination swapping.
According to a May 11th 2022 Politico report, a proposal by Airlines for Europe (A4E) advocated for continued free emissions allowances for aviation under the EU Emissions Trading System, allocated based on Sustainable Aviation Fuel (SAF) usage. The proposal argues the mechanisms would incentivize the deployment of SAFs more than a mandate.
easyJet, Ryanair and Wizz Air signed a joint letter advocating for the EU’s aviation climate policies to apply to all flights departing from European airports, not just intra-EU flights, and opposing new EU mechanisms to address carbon leakage. This includes expanding the scope of the EU ETS for aviation to include all international flights, and supporting the inclusion of all departing international flights in the EU’s sustainable aviation fuels mandate.
In feedback to the EU Commission in November 2021, the Federation of German Industry appeared to support a separate EU ETS for buildings and road transport, but welcomed the lack of EU ETS expansion to aviation.
Eurelectric, a European power sector trade group, stated support for reforms made to the EU’s Emissions Trading Scheme within the EU’s Fit for 55 climate package, including higher ambition and an increase in the linear reduction factor (LRF), in a reaction paper on the policy. However, the association appeared to have a mixed position on the EU’s Carbon Border Adjustment Mechanism in its reaction paper on the policy. Despite, advocating for the removal of free allocations and the inclusion of the hydrogen sector's emissions in the scope of the policy, the groups appeared to state support for exceptions for exporters.
The World Shipping Council published a position paper on its website, stating that the EU ETS and EU policy in general should ‘'complement' global GHG emissions reduction policy, instead of impeding it. It also recommended that only emissions from intra-EU shipping journeys are included in the EU ETS, arguing that including non-EU journeys will ‘incentivize market behaviour that weakens climate action through carbon leakage and market distortion’.
BDI published new position papers targeting the new German administration, strongly supporting increased ambition on national energy efficiency deployment, but opposing the proposed EU kerosene tax for aviation and advocating for increased free emissions permits for intra-EU feeder flights within the EU ETS.
An easyJet press release this week announced support for EU policies to decarbonize aviation, including tax breaks and reductions in airport charges for zero-emissions aircraft. Additionally, the press release reiterates their support for the expansion of key EU aviation climate policies, including a proposed kerosene fuel tax, the EU ETS, and a SAF mandate, to cover all international flights within the EU.
The table below lists the entities found to be most engaged with the policy. The entities are ranked by performance band. InfluenceMap tracks over 500 companies and 250 industry associations globally. Each entity name links to its full InfluenceMap profile, where the evidence of its engagement can be found.
| Influencemap Performance Band | Organization | Policy Position | Policy Engagement Intensity |
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