ReFuelEU Aviation obligations unaffected by market lulls

ReFuelEU Aviation (Regulation (EU) 2023/2405) imposes volume-weighted blending obligations on aviation fuel suppliers at EU airports, with non-compliance penalties reaching €5,000 per tonne of shortfall. The regulation’s 2025 threshold of 2% SAF by energy content has already entered force, followed by a stepped trajectory: 6% in 2030 (including a 1.2% synthetic e-fuel sub-mandate), 20% in 2035, 34% in 2040, 42% in 2045, and 70% in 2050. A quiet month for project finance or capacity announcements does not alter these legal deadlines; fuel suppliers and airline procurement teams remain obliged to source certified volumes under Directive (EU) 2018/2001 (RED II, now RED III under revision).

Compliance directors searching “2030 SAF mandates” or “ReFuelEU reporting” will find that the regulatory framework distinguishes between Annex IX-A feedstocks (used cooking oil, animal fats) and power-to-liquid (PtL) synthetic kerosene. Only renewable fuels of non-biological origin (RFNBOs)—produced via electrolysis with renewable electricity and captured CO₂—count toward the e-fuel sub-quota, a rule designed to stimulate green hydrogen and direct-air-capture infrastructure even when biological SAF capacity dominates early volumes.

Certification and book-and-claim under RED III

RED III amendments, expected to transpose by mid-2025, tighten lifecycle greenhouse-gas thresholds for all renewable transport fuels, including SAF. Producers must demonstrate at least 70% GHG savings versus fossil jet-fuel comparators (83.8 gCO₂eq/MJ) through certified sustainability schemes recognised by the European Commission (e.g., ISCC EU, RSB EU RED). Under ReFuelEU, book-and-claim mechanisms allow airlines to purchase sustainability certificates from SAF producers even when physical molecules remain in third-country markets, provided the fuel meets RED III criteria and is uplifted at an EU airport within the same reporting year. This flexibility is critical during periods of limited European production capacity, yet it requires diligent documentation and third-party audit trails to satisfy national competent authorities.

Marketing and procurement imperatives for 2030–2032

For marketing directors at fuel suppliers and airline sustainability officers, the 2030 cliff—6% SAF, 1.2% e-fuel—represents the first material volume challenge. At current EU jet-fuel consumption (~60 million tonnes per annum), 6% translates to approximately 3.6 million tonnes of certified SAF, a six-fold increase over 2025. The lack of announcements this period underscores supply-chain risk: procurement pipelines must lock in long-term offtake agreements well before 2030 to avoid shortfall penalties. Directors should monitor upcoming calls under the Innovation Fund (co-financing PtL and HEFA plants) and align internal compliance calendars with annual ReFuelEU reporting to national aviation authorities, due each spring for the preceding calendar year.

Sources

• Solving the “Hybridization” Challenge of Pure EV Platforms, Horse Powertrain Provides Solution at Auto China 2026 | Gasg
• Horse Powertrain – Wikipedia
• Horse Powertrain unveils hybrid system for BEV platforms – electrive.com

Featured image via Unsplash.