By Federico Ricci Buffetti

Refuel EU sets ambitious SAF mandate but opens Book & Claim dilemma for Business aviation

While the EU Parliament's approval of ReFuel EU Aviation marks a significant milestone in boosting Sustainable Aviation Fuels (SAF) availability in Europe, the absence of a Book & Claim system presents substantial challenges for the Business aviation sector.

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The European Parliament Plenary approved the Regulation “ReFuelEU aviation” on the 13th of September 2023. Members of the European Parliament (MEPs) laid out an ambitious timeline for the provision of jet fuel to operators, obliging EU fuel suppliers to ensure that, starting from 2025, at least 2% of aviation fuels delivered to Union Airports will be Sustainable Aviation Fuel (SAF), with this share increasing every five years: 6% in 2030, 20% in 2035, 34% in 2040, 42% in 2045 and 70% in 2050. Additionally, a share of the fuel mix (1.2% in 2030, 2% in 2032, 5% in 2035 and progressively reaching 35% in 2050) must comprise synthetic fuels like e-kerosene.

The text has now to be formally approved by Member States in the Council, before entering officially into force as an EU Regulation with immediate effect within Member States. This last step will likely be completed without significant hurdles, with the Council expected to approve the Parliament’s text of the legislation as the two institutions have already found a compromise during a long trialogue process that preceded the vote in Plenary.

The European Union’s policymaking effort to decarbonise the aviation sector began in July 2021, with the launch of the Fit for 55 package, setting the ambitious climate goal of reducing EU Greenhouse Gas emissions by at least 55% compared to 1990 levels, by 2030.

Proposals to decarbonise the transport sector, including aviation, played a central role that saw policymakers across the EU institutions engaged in protracted political negotiations. The recent conclusion of the legislative process for ReFuelEU and the entry into force of the updated EU ETS for aviation in June 2023 marked the realisation of the EU’s vision for a sustainable future in aviation.

EBAA welcomed the final vote on ReFuelEU in a press release, underscoring that this new legislation  marks the first-ever Sustainable Aviation Fuel (SAF) mandate in the EU. SAF is indeed one of the four pillars of the Business Aviation Commitment on Climate Change, with which the Business aviation sector is aiming to reach net-zero carbon emissions by 2050. EU legislation designed to support the production and uptake of SAF is an encouraging sign for Business aviation operators to see fuel suppliers starting to bolster SAF production, thus presenting them with a significant opportunity to decarbonise their operations.

Despite promising indications of increased production in 2022, including IATA’s report of a threefold increase in SAF production to approximately 300 million litres and multiple project announcements from potential SAF producers, SAF currently still represents a minuscule fraction of the global jet fuel market. This is primarily attributed to the absence, up until today, of clear legislative mandates capable of resolving the long-standing “chicken and egg” dilemma that has impeded the overdue expansion of SAF production.

Consequently, legislative measures like the EU’s ReFuelEU, which obliges fuel suppliers to ramp up production within a predefined timeline extending to 2050, have the potential to provide much-needed reassurance to the demand side of the jet fuel market and potentially lead to mid-term price reductions.

From the perspective of the business aviation sector, the increased availability of SAF at European airports marks a positive development enthusiastically embraced by operators, who are seeing a fast-growing demand of customers willing to fly sustainably, without sacrificing the advantages of using business jets, such as enhanced connectivity, flexibility, and confidentiality.

However, as noted in EBAA’s press release, the text of the legislation regrettably lacks the inclusion of a Book & Claim system within the scope of the legislation. The inclusion of a Book & Claim system, based on the SAF flexibility mechanism, has been advocated by EBAA throughout the negotiations.

As Business aviation operators face ongoing challenges in securing a steady supply of SAF, partly due to the competition with airlines which possess stronger bargaining power when dealing with fuel suppliers, a Book & Claim system would allow operators to purchase SAF even if it is not available in their re-fuel location. This, in turn, would contribute to a virtuous cycle by boosting both the supply and demand for SAF.

Moreover, the definition of ‘Union airport’ as an airport with passenger traffic higher than 800,000 a year poses additional challenges for Business aviation as SAF availability at smaller airports, to which business aircraft fly to, will be very limited if not inexistent.

EBAA expressed concern that due to these elements, Business aviation operators will face considerable challenges in meeting decarbonisation objectives.

However, there is still the possibility for the future adoption of a Book & Claim system. ReFuelEU’s Article 15 on “flexibility mechanisms” stipulates that “By 1 July 2024, the Commission shall… assess possible improvements or additional measures to the existing SAF flexibility mechanism, such as establishing or recognising a system of SAF tradability. This would enable fuel supply within the Union without requiring a physical connection to a supply site. The objective is to further streamline the supply and utilisation of Sustainable Aviation Fuel (SAF) for aviation during the flexibility period, incorporating elements of a Book & Claim system.”

This represents a window of opportunity for EBAA to continue its advocacy effort, by reiterating that such a system is vital for the Business aviation sector to decarbonise at pace, in accordance with its own Business aviation Commitment on Climate Change (BACCC), which sets up SAF as one of the main pillars in the trajectory for the industry to reach net-zero carbon emissions by 2050.

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