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Towards Net-Zero Aviation: Understanding the ReFuelEU Aviation Initiative

Introduction to ReFuelEU Aviation

ReFuelEU Aviation (RFEUA) is an important element of the European Union’s (EU) ambitious climate policy, designed to significantly reduce carbon emissions in the aviation sector. Launched as part of the “Fit for 55” package, presented by the European Commission in July 2021 and adopted in October 2023, the package aims to enable the EU to reduce net greenhouse gas emissions by at least 55% by 2030 compared to 1990 levels and to achieve climate neutrality in 2050.

ReFuelEU Aviation seeks to decarbonize the aviation sector by requiring a minimum supply of Sustainable Aviation Fuels (SAF) across union airports. The initiative focuses on non-uniform tankering practices and progressive targets for aviation fuel suppliers, mandating an increasing proportion of SAF to be blended with conventional fuels, including synthetic options, at Union airports.

Traditional aviation fuels (Jet A/Jet A1) significantly contribute to carbon emissions, and with the increasing demand for air travel, there is an increasing urgency to shift to sustainable alternatives. Current tankering practices intensify the problem. Tankering involves an aircraft carrying more fuel than necessary to avoid refueling at destinations where fuel might be more expensive. While economically beneficial, this practice increases the overall weight of aircraft, leading to higher fuel consumption and, consequently, more emissions.

ReFuelEU Aviation addresses these issues by setting clear requirements for aircraft operators to uplift at least 90% of the required fuel for a trip at a union airport. The operators need to calculate the required fuel using two main components, the trip fuel and the taxi fuel from their flight plans. In addition, to simplify the reporting, the tool by EASA is now available on EASA’s website via invitations from competent authorities. As of September 2024, the Competent Authorities can review the exemption requests submitted by the aircraft operators through the ReFuelEU Aviation Sustainability Portal. The voluntary Labelling Scheme data reporting for aircraft operators will also be possible through future updates on the Sustainability Portal.

Stakeholders involved in ReFuelEU Aviation

  1. Aircraft Operators: These are the operators that have operated at least 500 commercial passenger air transport flights or 52 commercial all-cargo air transport flights departing from union airports, regardless of their destination. For ex. EDDH, Hamburg to LFPG, Paris Charles de Gaulle and EDDH Hamburg to OOMS, Muscat.
  2. Union Airports and their Managing Bodies: These are the airports where in the previous reporting period passenger traffic was higher than 800,000 passengers or freight traffic was higher than 100,000 tonnes. Managing bodies are responsible for providing the necessary infrastructure for SAF implementation. Click here for the list of Union Airports.
  3. Verification Bodies: These organizations are tasked with verifying the reports submitted by aircraft operators by the annual deadline set on the 31st of March Year N+1.
  4. Aviation Fuel Suppliers: Operating within the EU, the suppliers must ensure adequate SAF supply and comply with reporting obligations. Aviation fuel suppliers must provide relevant and accurate information for the reporting period, free of charge and not later than the 14th of February of each reporting year.
  5. Competent Authorities: They are responsible for overseeing aircraft operators, Union airport managing bodies, and aviation fuel suppliers to ensure they adhere to the sustainable aviation fuel (SAF) mandates and compliance obligations outlined in the regulation.

Obligations under ReFuelEU Aviation Regulation 2023/2405

  1. The obligation for aircraft operators to ensure that theΒ yearly quantityΒ of aviation fuel uplifted at a given EU airport is at least 90% of the yearly aviation fuel required (Trip Fuel + Taxi Fuel) from flight plans, to avoid tankering practices which would induce additional emissions from extra weight.
  2. ReFuelEU Aviation mandates a progressive increase in the use of SAF, starting with a 2% blend by 2025, escalating to 6% by 2030, and reaching 70% by 2050. Additionally, specific targets for synthetic fuels, such as e-kerosene, are set to ensure a significant shift towards sustainable energy sources.​
  3. The operators subjected to ReFuelEU Aviation are required to report on the 2024 monitoring period in 2025. This report must be verified by a third-party verifier and must be submitted to the respective authorities by March 31, 2025. The involvement of an independent verifier underscores the importance of accuracy and transparency. The reporting template is available on the European Commission’s website, and details about the key fields in the template will be included in EASA’s upcoming Guidance document which is expected to be released soon.

Overall Impacts of ReFuelEU on the Aviation Sector

  • Promoting Market Adoption of Sustainable Aviation Fuel (SAF): The EU anticipates that its regulations will encourage increased investment in Sustainable Aviation Fuel (SAF), a prospect welcomed by fuel producers.
  • Penalties and Incentives: To support the transition to SAF and to avoid tankering practices, the regulation imposes fines on non-compliant aircraft operators and fuel suppliers.
  • Penalties for aircraft operators:If an aircraft operator fails to comply with the obligations, verifiers will issue non-compliance. The authorities will then impose fines on the operators (starting from the 2025 monitoring period).
𝐹𝑖𝑛𝑒 = 2 Γ— (π‘ƒπ‘Ÿπ‘–π‘π‘’ π‘œπ‘“ π‘π‘œπ‘›π‘£π‘’π‘›π‘‘π‘–π‘œπ‘›π‘Žπ‘™ 𝑓𝑒𝑒𝑙 π‘π‘’π‘Ÿ π‘‘π‘œπ‘›π‘›π‘’ βˆ’ π‘ƒπ‘Ÿπ‘–π‘π‘’ π‘œπ‘“ 𝑆𝐴𝐹 π‘π‘’π‘Ÿ π‘‘π‘œπ‘›π‘›π‘’) Γ— π‘π‘œπ‘›βˆ’Tanked π‘žπ‘’π‘Žπ‘›π‘‘π‘–π‘‘π‘¦ (π‘‘π‘œπ‘›π‘›π‘’π‘ )

Where:

Non-Tanked Quantity is Difference between the yearly aviation fuel required and the actual fuel uplifted by an aircraft operator for the flights departing from union airport.

  • Penalties for fuel suppliers: On the other hand, if an aviation fuel supplier fails to comply with the obligations, then the fine imposed shall not be less than twice as high as the amount resulting from the multiplication of the price difference between conventional fuel and SAF, and the amount of non-compliant fuel supplied.
𝐹𝑖𝑛𝑒 = 2 Γ— (π‘ƒπ‘Ÿπ‘–π‘π‘’ π‘œπ‘“ π‘π‘œπ‘›π‘£π‘’π‘›π‘‘π‘–π‘œπ‘›π‘Žπ‘™ 𝑓𝑒𝑒𝑙 π‘π‘’π‘Ÿ π‘‘π‘œπ‘›π‘›π‘’ βˆ’ π‘ƒπ‘Ÿπ‘–π‘π‘’ π‘œπ‘“ 𝑆𝐴𝐹 π‘π‘’π‘Ÿ π‘‘π‘œπ‘›π‘›π‘’) Γ— π‘π‘œπ‘›βˆ’π‘π‘œπ‘šπ‘π‘™π‘–π‘Žπ‘›π‘‘ π‘žπ‘’π‘Žπ‘›π‘‘π‘–π‘‘π‘¦ (π‘‘π‘œπ‘›π‘›π‘’π‘ )
𝐹𝑖𝑛𝑒 = 2 Γ— (π‘ƒπ‘Ÿπ‘–π‘π‘’ π‘œπ‘“ π‘π‘œπ‘›π‘£π‘’π‘›π‘‘π‘–π‘œπ‘›π‘Žπ‘™ 𝑓𝑒𝑒𝑙 π‘π‘’π‘Ÿ π‘‘π‘œπ‘›π‘›π‘’ βˆ’ π‘ƒπ‘Ÿπ‘–π‘π‘’ π‘œπ‘“ π‘ π‘¦π‘›π‘‘β„Žπ‘’π‘‘π‘–π‘ 𝑓𝑒𝑒𝑙 π‘π‘’π‘Ÿ π‘‘π‘œπ‘›π‘›π‘’) Γ— π‘π‘œπ‘›βˆ’π‘π‘œπ‘šπ‘π‘™π‘–π‘Žπ‘›π‘‘ π‘žπ‘’π‘Žπ‘›π‘‘π‘–π‘‘π‘¦ (π‘‘π‘œπ‘›π‘›π‘’π‘ )

Where:

Non-complaint quantity of fuel is simply the unjustified tankered fuel quantity other than safety and required (trip + taxi) fuel.

Key deadlines

  1. Monitoring fuel information as required by ReFuelEU Aviation obligations – Between 1st January and 31st December in year N.
  2. Fuel suppliers must provide the necessary SAF purchase documents to aircraft operators – Before 14th February in year N+1
  3. Fuel suppliers to complete reporting obligations on the union database – Before 14th February in year N+1
  4. The deadline to submit the verified report to the competent authority – By 31st March of year N+1

Immediate actions required for aircraft operators.

  1. Check your obligations under ReFuelEU Aviation requirements.
  2. Determine your competent authority and seek access to the EASA’s sustainability portal.
  3. Implement a robust system with clear procedures to track flights subject to reporting requirements.
  4. Gather and prepare fuel data for ReFuelEU Aviation reporting and verification.
  5. If required, apply for route exemptions from the competent authority and get approval. The European Commission will soon release imperative guidelines on exemptions.
  6. If you fail to uplift 90% of the required fuel at a particular union airport, investigate and provide reasons for the shortfall.
  7. Reach out to Normec Verifavia for ReFuelEU verification and finalize contracts as soon as possible to avoid last-minute hassle.

Conclusion

In conclusion, ReFuelEU Aviation is a key initiative that harmonizes market competition with sustainable development goals by requiring the use of Sustainable Aviation Fuels (SAF). The regulation guarantees fair competition among airlines across the EU while promoting the adoption of SAF. By encouraging the use of SAF and addressing tankering practices, ReFuelEU Aviation advances the EU’s broader climate targets and establishes a global standard for the aviation industry’s shift toward more sustainable practices.

References