What are RefuelEU Aviation’s sub-mandates for SAF and e-SAF per year?

SAF includes biofuels, synthetic fuels, e-fuels, and recycled carbon fuels. The regulation sets progressive blending targets for SAF, rising from 2% in 2025 to 70% by 2050. A separate sub-mandate for e-fuels begins at 1.2% in 2030, reaching 35% by 2050.

EU SAF and e-fuel targets from 2025-2050

The regulation places obligations on aviation fuel suppliers, aircraft operators and EU airports. Fuel suppliers must ensure the correct share of SAF is blended into fuel at EU airports. Aircraft operators must refuel at EU airports with at least 90% of the fuel needed for their flight, a measure to prevent “fuel tankering”. EU airports are mandated to facilitate access to the necessary infrastructure to deliver, store, and refuel aircrafts with SAF. All three actors face fines for non-compliance with their respective obligations.

How does carbon dioxide removal fit into ReFuelEU?

RFEUA’s primary link to carbon removal is through e-fuels. Synthetic aviation fuels are produced by combining renewable hydrogen and captured carbon, which can be sourced directly from the atmosphere using Direct Air Capture (DAC) technologies. The regulations sub-mandate for e-fuels creates a market signal for DAC technology, helping to scale up the industry.

Furthermore, because RFEUA faces potential issues with SAF supply, a possible solution is to introduce CDR as a compliance option to reach SAF obligations. Such a measure would allow fuel suppliers to meet a portion of their SAF obligations with permanent CDR credits, while lowering overall compliance costs and preserving climate ambition.

Secondly, the production of SAF is significantly more expensive than conventional jet fuel, driven by high feedstock costs and the energy-intensive nature of certain production methods. Therefore, the industry faces challenges in the limited feedstock supply chains, and the high capital investment required for new facilities. The long lead times for these new projects, often taking six to eight years to become fully operational, make it difficult to expand capacity in line with rising regulatory demands.

Thirdly, the production of e-fuels is a particularly energy-intensive process that creates significant demand for renewable electricity. According to recent estimates, producing the required amount of SAF by 2050 would require 1.5 times the total renewable electricity production in the EU in 2021. This places it in direct competition with other sectors also transitioning to clean energy.

Opportunities and the path forward for the SAF industry

Despite the significant challenges facing the SAF industry, these same hurdles are creating opportunities for innovation, investment, and development within the sector.

Europe is currently undergoing a surge in investment in advanced technologies like Power-to-Liquid (PtL) projects, which show promise for greater scalability with fewer feedstock constraints. For example, the European Commission has approved significant state aid for PtL projects, such as a EUR 350 million measure within Germany to support Concrete Chemicals in producing synthetic aviation fuels. Such investment enables the development of innovative technologies that are crucial for the sustainable aviation sector.

Furthermore, airlines and fuel producers are increasingly entering into long-term, fixed-price contracts to reduce the financial risk for new production facilities. This is exemplified by the 15-year offtake agreement between Europe-based Haffner Energy and Luxaviation Group. Haffner Energy outlines that securing such long-term deals is one of the most crucial conditions for financing its SAF projects, as these contracts guarantee a stable purchase price and enable real-world investments in SAF infrastructure.

How CDR could fit in the scope of RFEUA

While ReFuelEU Aviation sets ambitious targets, it includes a formal 2027 review clause to assess the regulation’s feasibility. This presents an opportunity to introduce new mechanisms that could facilitate reaching its goals.

A possible policy option to facilitate the long-term decarbonisation of the aviation sector and address SAF supply challenges is to integrate carbon removals into the RFEUA framework. This approach could be evaluated as part of the European Commission’s 2027 review, providing a pathway for a CDR sub-mandate to fit within the regulation’s scope. Such a mechanism could serve as a cost-containment measure, allowing fuel suppliers to meet a small portion of their RFEUA obligation through the purchase of permanent CDR credits.

Examples from abroad

Examples from the UK and the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) mechanism highlight how carbon removal can coexist with and complement SAF policies.

The UK’s SAF mandate: Includes a direct incentive for Power to Liquid, which is fuel derived directly from carbon capture.

The CORSIA mechanism: Encourages carbon removal by requiring international airlines to offset their CO₂ emissions above a baseline level by purchasing carbon credits from the market. CORSIA allows airlines to meet their offsetting requirements by either purchasing CORSIA eligible fuels, which include SAF, or by acquiring CORSIA eligible emissions unit, which are ICAO-approved carbon credits from reduction or removal projects.

Glossary/Acronyms:

• Synthetic aviation fuel = e-fuel
• Sustainable aviation fuel = SAF