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
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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.
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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.
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SAF Targets: The proposal increases RefuelEU’s mandated SAF targets to 37% by 2040 and 85% by 2050.
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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.
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SAF Targets: The proposal increases RefuelEU’s mandated SAF targets from 5% to 6% for 2030.
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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.