Policy Overview

The RefuelEU Aviation Initiative seeks to boost the supply and demand for sustainable aviation fuels (SAFs) by imposing mandates on fuel suppliers to include SAF in aviation fuel supplied at EU airports, to all international flights. The proposal will also review incrementally increasing sub-mandates of synthetic fuels, such as e-kerosene, to be blended with kerosene jet fuel. The policy will also consider the sustainability criteria for feedstock classification as SAF. The initiative was proposed in February 2020 by the EU Commission, and a public consultation was launched to gather stakeholder views in March 2020.

Policy Progressing

The EU Commission's ambitious proposal included a sub-target for e-kerosene and an increasing Sustainable Aviation Fuel (SAF) blending mandate, and, despite intense opposition from the aviation industry, it covers all flights departing the EU. The provisional agreement from the three EU bodies proposed targets compromising those suggested by the Commission and Parliament, while adopting the Council’s proposed 6% target for 2030.

InfluenceMap Query

Renewable Energy

Policy Status

Provisional agreement adopted by EU Parliament, Council and Commission.

  • European Parliament: TRAN Committee
  • Rapporteur: Søren Gade (Renew Europe)
  • European Council: Transport, Telecommunications and Energy Council

Evidence Profile



opposing not supporting mixed/unclear
supporting strongly supporting

European Commission

European Parliament

European Council

Policy Engagement Overview

The aggregated evidence of corporate and industry lobbying on the ReFuelEU initiative shows the aviation industry has expressed top-line support for the initiative combined with strongly emphasized concerns around its implementation.

Long-term Lobbying Trends

A significant majority of the aviation industry stressed concerns around SAF costs and availability in order to advocate for weaker mandates. Top-line support from associations and corporations such as Air-France KLM and International Airlines Group has often been strongly caveated on the condition that it should only apply to intra-EU flights. The International Air Transport Association (IATA) opposed an EU SAF mandate in 2020, yet its position in 2021 appeared to evolve to support an intra-EU SAF mandate only.

2021-22 saw wider support from the aviation industry generally, while general divisions remained between low-cost airlines supporting its application to all international flights, and legacy airline advocating for the policy to only apply to intra-EU flights.

Some aviation actors were less oppositional to a SAF mandate, EasyJet stating support for an EU SAF mandate applying to long-haul flights only in 2020.

The oil and gas industry generally supported a SAF mandate, including corporations Royal Dutch Shell and BP. FuelsEurope supported a mandate on the condition that it is “realistic” and “achievable.”

Lobbying on the EU Commission’s proposal since July 2021

Actors in the aviation industry continued opposition to a SAF mandate. IATA and IAG consistently advocated against the inclusion of international (EEA to non-EEA) flights in the EU SAF mandate, stressing concerns around carbon leakage. Both Air France-KLM and Lufthansa further stressed carbon leakage, cost and international competitiveness concerns resulting from an EU SAF mandate applied to intra-EU feeder flights.

Cross-sector associations raised numerous objections to the implementation of a SAF mandate, with the Federation of German Industries (BDI) specifically calling for the mandate to be limited to intra-EU flights, instead of the EU Commission’s proposal.

An ambitious SAF mandate continued to be pushed by some aviation companies, and the utilities and energy sectors. In 2022, easyJet and Ryanair consistently advocated for the EU SAF mandate to apply to departing international flights while easyJet, Lufthansa and Air France-KLM were supportive of the binding mandate on e-kerosene. Following support for the Commission’s proposal, and opposition to Parliament’s more ambitious targets, Airlines For Europe supported the provisional agreement on the SAF mandate. In 2023, it urged finalization of the policy, suggesting that delays to RED reform were jeopardizing the ReFuelEU policy.

Some actors in the aviation industry advocated for strong sustainability criteria. Airlines for Europe and easyJet opposed the weaker sustainability criteria proposed by EU Parliament, asserting that the Commission’s original definition of SAFs, which excludes animal fats and distillates, should be maintained.

Several entities outside the aviation sector including Engie and Sasol advocated for an e-kerosene mandate for 2027 and 2030. Iberdrola and Rolls-Royce supported strengthening the existing mandate through higher SAF and e-fuel targets. Hydrogen Europe supported the binding SAF mandates agreed in the provisional agreement.

Impacts on Policy Ambition

By considering the potential scenarios in the EU Commission's original Impact Assessment Report for ReFuelEU, and comparing this to the final proposal, a gauge of the impact of industry lobbying can be taken. In this case, intense engagement from the aviation sector does not appear to have weakened the ambition of the EU Commission or Parliamentary proposals.

EU Commission Proposal

  • SAF mandate: The proposed SAF mandate includes a ramping-up SAF blending mandate in of 2% by 2025, 5% by 2030 and 63% by 2050. It also includes sub-obligation of 0.7% e-kerosene from 2030, rising to 28% by 2050. This is in line with more ambitious policy options in the EU Commission’s Impact Assessment.

  • ReFuelEU Scope: The proposal is particularly notable for covering all flights departing from the EU, despite opposition from many key aviation industry lobbyists.

EU Parliament Proposal

The EU Parliament Transport Committee voted in June 2022 to increase some of the Commission’s ambition on long-term targets, while weakening its criteria for sustainable fuel. In July 2022, a plenary vote by Parliament finalised the Parliament’s positions, broadly keeping the same positions.

  • SAF Targets: The proposal increases RefuelEU’s mandated SAF targets to 37% by 2040 and 85% by 2050.

  • Sustainable fuels: The Parliament voted to expand the definition of sustainable fuels in the mandate to include recycled carbon fuels and some biofuels from animal fats or distillates until 2034.

EU Council Proposal

The EU Councils position retained the core aspects of the EU Commission’s proposal. It also however introduced national flexibilities allowing Member States to introduce increased sub-mandates for synthetic fuels.

  • SAF Targets: The proposal increases RefuelEU’s mandated SAF targets from 5% to 6% for 2030.

  • Sustainable fuels: The Council voted to extend the scope of eligible sustainable aviation fuels to include biofuels complying with the RED sustainability and emissions saving criteria, excluding food and feed crop biofuels.

Policy Progress

In April 2023, the European Commission, Parliament, and Council reached a provisional agreement on the ReFuel EU Aviation file. The agreement increased the ambition of the Commission’s mandated targets for SAF and e-kerosene, whilst not adopting the ambitious targets put forward by Parliament. The agreed SAF targets are 2% in 2025, 6% in 2030, 34% in 2040, and 70% in 2050, alongside sub-targets for e-kerosene of 1.2% in 2030, rising to 35% in 2050. Synthetic fuels, recycled jet fuels and biofuels produced from agricultural and forestry residues, algae and some animal fats have been included under the term ‘sustainable aviation fuels’ in the provisional agreement, despite the Commission excluding recycled fuels and fuels produced from animal fats from its proposal. In May 2023, votes on the provisional agreement were postponed due to an impasse between France and Germany on the role of nuclear energy in the Renewable Energy Directive.

InfluenceMap Query

Renewable Energy

Policy Status

Provisional agreement adopted by EU Parliament, Council and Commission.

  • European Parliament: TRAN Committee
  • Rapporteur: Søren Gade (Renew Europe)
  • European Council: Transport, Telecommunications and Energy Council

Evidence Profile



opposing not supporting mixed/unclear
supporting strongly supporting

European Commission

European Parliament

European Council

Live Lobbying Alerts

Lufthansa urge EU to set binding targets for e-kerosene

07 July 2021

Lufthansa have signed a joint letter coordinated by Transport & Enviornment urging the EU to adopt e-kerosene mandates of 0.5%-1% for 2027 and 2.5% for 2030. This suggests an evolving, more positive position for Lufthansa, who in 2021 previously emphasized competitiveness concerns in private emails with EU policymakers around a sustainable aviation fuels mandate.

BDI gives a mixed response to the ReFuelEU proposal

14 January 2022

In feedback to the EU Commission in November 2021, the Federation of German Industry adopted a mixed position on the ReFuelEU proposal, supporting a higher SAF mandate target by 2030 but advocating to limit scope of blending mandate in ReFuelEU proposal to intra-EU flights.

European budget airlines call for climate policies to apply to all flights

04 February 2022

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.

Aviation groups split on details of Sustainable Aviation Fuels target

23 June 2022

According to a June 9th media report, Airlines for Europe opposed a more ambitious Sustainable Aviation Fuels (SAFs) blending target of 6% by 2030, as proposed in the EU Council’s general approach, preferring the earlier mandate of 5%. Lufthansa appeared to stress competitiveness, carbon leakage and cost concerns with the Council’s position. In contrast, International Airlines Group welcomed the more ambitious target.

BusinessEurope supportive of EU Energy Taxation Directive and ReFuel EU with exceptions

03 December 2021

Confindustria appears to not support a SAF mandate

17 January 2022

In feedback to the EU Commission in November 2021, Confindustria appeared not to support an ambitious sustainable aviation fuel mandate within the RefuelEU Aviation proposal, supporting numerous exemptions.

BusinessEurope stress cost and competitiveness impacts of FF55 package mobility policies

24 February 2022

In a February newsletter, BusinessEurope suggested that mobility policies in the Fit for 55 package should take into account the costs for industry and impacts on competitiveness. The association supported the emission intensity standards but advocated for alternative production pathways for fuels in the FuelEU Maritime legislation, and suggested that there could be international retaliation.

BusinessEurope was supportive of slightly higher blending obligations in the short and medium term in the ReFuelEU Aviation legislation, but supported flexibilities for companies. The association advocated for increased ambition of the roll-out of charging and refuelling infrastructure in the Alternative Fuels Infrastructure Regulation.

Lufthansa unsupportive of EU SAF mandate and extension of the EU ETS to aviation

06 July 2022

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.

Entities Engaged on Policy

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 BandOrganizationEngagement Intensity
DInternational Airlines Group (IAG)40TransportationEurope
DAirlines For Europe (A4E)50TransportationEurope
DAir France-KLM49TransportationEurope
C-Airbus Group45IndustrialsEurope
C+Deutsche Post DHL Group41TransportationEurope
B-AeroSpace and Defence Industries Association of Europe (ASD)21TransportationEurope
C+Hydrogen Europe40EnergyEurope
C-Airports Council International Europe (ACI Europe)28TransportationEurope
D-BusinessEurope54All SectorsEurope
DConfederation of Italian Industry (Confindustria)56All SectorsEurope
DFederation of German Industries (BDI)61All SectorsEurope
C-Air Liquide39ChemicalsEurope
CSiemens Energy45EnergyEurope
ACorporate Leaders Group (CLG)53All SectorsEurope
C+European Round Table for Industry (ERT)22All SectorsEurope
D+European Regions Airline Association (ERA)22TransportationEurope
DSpanish Confederation of Business Organizations (CEOE)34All SectorsEurope