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ReFuelEU Aviation

ReFuelEU Aviation

The European Union is working towards its emissions reduction target of 55% by 2030 through the Fit for 55 package which includes the Regulation (EU) 2023/2405, known as ReFuelEU Aviation. This regulation penalises economic tankering to avoid emissions related to extra weight, and mandates fuel suppliers to provide a minimum share of Sustainable Aviation Fuels (SAF) at Union Airports. Aircraft operators must understand and ensure their operations are compliant with these regulatory requirements. 

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Why choose Normec Verifavia?

  1. Choose unmatched expertise: Normec Verifavia’s verification process is carried out by a team of aviation experts, ensuring a comprenshive verification of aviation emissions data and related parameters. 
  2. Ensure compliance excellence: Normec Verifavia guarantees strict adherence to regulation compliance and reporting standards, backed by our accreditation under 17029 standards. 
  3. Rely on our proven experience: While ReFuel EU Aviation represents a new standard, our extensive experience with verifying reports under EU ETS, UK ETS, and CORSIA for more than 300 airlines, demonstrates our capability in handling complex regulatory frameworks. 

The ReFuelEU Aviation Regulation lays down rules aiming to create a level playing field for EU air transport while contributing to the EU climate targets. It applies to aircraft operators operating flights departing from Union airports; to Union airports and their respective managing bodies; and to aviation fuel suppliers. The ReFuelEU Aviation Regulation sets specific requirements for the different stakeholders: 

  • Aviation fuel suppliers, to increase the share of SAF in Union airports: 

Article 4 requires fuel suppliers to ensure that aviation fuel at each Union airport contains the minimum shares of SAF yearly; from 1 Jan 2025, a minimum share of 2 % of SAF, progressively changing to reach 70% share of SAF from 2050. 

  • Aircraft operators departing from Union airports, to uplift the necessary fuel for a flight avoiding economic tankering practices: 

Article 5 requires the yearly aviation fuel uplifted by an aircraft operator at a given Union airport to be at least 90 % of the yearly aviation fuel required. 

  • Union airports, to facilitate access and infrastructure for refuelling aircraft with SAF: 

Article 6 requires airports to take the measures to facilitate access to aircraft operators to the aviation fuels with the minimum shares of SAF specified in the ReFuelEU Regulation. 

Obligations of aircraft operators: 

  • Monitoring: Establish a robust monitoring system to track the completeness of flights, the required fuel, uplifted fuel, and other data required for reporting.  
  • Reporting: Compile the data for the reporting period (1 Jan – 31 Dec) in the reporting template. The first reporting period is 2024.  
  • The template for reporting is available here.  
  • The list of Union Airports provided by the Commission is available here.  
  • The list of aircraft operators (non-exhaustive) is available here. 
  • Verification: Engage with an independent verifier, the ReFuelEU Aviation and verification reports must be submitted to the Competent Authority by 31 March of the next year following the reporting period. The first report is due on 31 March 2025, for the 2024 reporting period.  
  • The list of Competent Authorities is available here. 

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Streamlined Compliance Process:

  1. Engagement and Scope Definition

    The process begins with the aircraft operator engaging with NORMEC VERIFAVIA’s commercial team. This stage involves a detailed definition of the operational scope, ensuring all parties have a clear understanding of the verification boundaries. The engagement is formalized through a contract, setting the stage for a structured and transparent verification process.

  2. Data and Documentation Submission

    A verification team will be assigned to an aircraft operator, the lead auditor will send an audit preparation letter which will include the list of documents and data to be submitted. Aircraft operators are required to submit all relevant data and documentation for verification. This includes the ReFuelEU Aviation report, and all the supporting data and documents, as specified by the verification team.

  3. Data Analysis and Verification

    The submitted data undergoes a comprehensive review to ensure accuracy and completeness, with operators promptly notified of any discrepancies or the need for additional clarification. This step is crucial for ensuring the reported data accurately reflects the real operations. The verification work ensures compliance with all applicable standards, and upon its completion, a verification report will be issued. The aircraft operator will then submit it along with the ReFuelEU Aviation report to its Competent Authority.

Downloads

Regulation (EU) 2023/2405 of the European Parliament and of the Council of 18 October 2023 on ensuring a level playing field for sustainable air transport (ReFuelEU Aviation) ReFuelEU Aviation Template for Aircraft Operators List of Union airports established for the purpose of ReFuelEU Aviation List of aircraft operators established for the purpose of ReFuelEU Aviation List of competent authorities of the Member States responsible for enforcing the application of ReFuelEU Aviation
FAQ

Find answers to the most commonly asked questions

Who has obligations under the ReFuelEU Aviation?

The ReFuelEU Aviation is applicable to aircraft operators that operate flights from Union airports. The applicability threshold is based on the number of flights operated in the previous reporting period (1st January until 31st December). Obligations apply to operators that during the reporting period, have operated at least: 

  • 500 commercial passenger air transport flights departing from Union airports or 
  • 52 commercial all cargo air transport flights departing from Union airports. 

What are the obligations for aircraft operators under the ReFuelEU Aviation Regulation?

Aircraft operators must ensure that the flights departing from Union airports are refuelled with the necessary fuel for the flight. Article 5 of the ReFuelEU Regulation requires that the yearly quantity of aviation fuel uplifted by a given aircraft operator at a given Union airport shall be at least 90% of the yearly aviation fuel required. 

What information has to be reported?

As stipulated in Article 8 of the ReFuelEU Aviation Regulation, each year and for the first time in 2025, aircraft operators must submit a verified report to the respective Competent Authority by 31st March Year N+1 annually. The report includes the following: 

Fuel reporting: 

  • Total flight operated departing from a Union airport (in number of flights) 
  • Total flight hours operated departing from a Union airport (in number of hours) 
  • Yearly aviation fuel required (trip fuel and taxi fuel) at each Union airport (in tonnes) 
  • Total actual aviation fuel uplifted at each Union airport (in tonnes). 
  • Yearly non-tanked fuel quantity at each Union airport (reported as 0 if it’s negative or ≤ 10% of fuel requirements) 
  • Yearly tanked fuel quantity for fuel safety rules at each Union airport (in tonnes). 

SAF purchase reporting: 

  • Total Sustainable Aviation Fuel (SAF) purchased from suppliers for regulated flights (in tonnes) 
  • Details for each SAF purchase, including supplier name, batch number, quantity (tonnes), fuel category, feedstock, and lifecycle emissions. 
  • Eligible SAF claimed under EU ETS, CH ETS, CORSIA and other Market Based Measures (in tonnes) 
  • Eligible SAF not claimed. 

Declaration: 

A declaration that the aircraft operator has not claimed under more than one greenhouse gas scheme identical batches of SAF. 

What penalties apply for non-compliance?

There are no penalties for the 2024 reporting period, however, from 2025, if an aircraft operator does not meet the requirements set up in article 5 of the ReFuelEU Aviation Regulation (minimum uplift of 90% of the required fuel), penalties will apply. Member States will establish the penalties, these will be at least double the product of the yearly average aviation fuel price and total yearly non-tanked quantity. 

What happens if an aircraft operator cannot comply with the minimum of 90% due to fuel safety rules?

Fuel tankering might occur to comply with fuel safety rules (in line with Commission Regulation (EU) No 965/2012). In such cases tankering is justified by safety reasons; however there are specific circumstances, for example: 

  1. cases of fuel shortage 
  2. fuel contamination at the destination airport confirmed by a Notice to Airmen or Notice to Air Missions (NOTAM) 
  3. specific operational difficulties for some aircraft operators at some airports: in terms of disproportionate longer turnaround times for aircraft or reduced airport capacity at peak times. 

If the aircraft operator faces such cases, the aircraft operator should give an indication of the Union airports and flights impacted in the report to be submitted to the competent authority.  

Do aircraft operators need to meet minimum SAF uplift requirements?

No, the RefuelEU Aviation Regulation requires fuel suppliers to ensure that the aviation fuel available at Union aiports has a minimum SAF share. Aircraft operators’ obligations are related to avoiding economic fuel tankering practices. However, as SAF will become more accessible, thanks to the mandate to suppliers, aircraft operators will eventually uplift aviation fuel which includes the minimum shares of SAF. 

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