RefuelEU Aviation

ReFuelEU Aviation Regulation

The ReFuelEU Aviation Regulation (RFEUA) is the European legislative instrument to stimulate the production and adoption of Sustainable Aviation Fuel (SAF) within European skies. It mandates that fuel suppliers at Union airports gradually increase the share of SAF blended with conventional aviation fuel, starting with a 2% share in 2025, rising to 6% in 2030, and reaching 70% by 2050. Additionally, RFEUA mandates a share of synthetic aviation fuels in all EU airports from 2030.  

EBAA supports ReFuelEU Aviation and its SAF mandate, as the business aviation sector has been an early adopter of SAF, recognising it as one of the most effective tools to reduce aviation emissions. However, the current framework is not fully fit for the operational realities of business aviation. The Association therefore calls on European policymakers to refine the anti-tankering rules so they better reflect the unscheduled nature of business aviation operations, and to introduce a book-and-claim system to facilitate operators’ access to SAF. 

Antitankering rule 

Article 5 of Aircraft of RFEUA states that operators departing from EU airports must refuel with the aviation fuel necessary to operate the flight. This avoids the excessive emissions related to extra weight and minimises the risks of carbon leakage caused by so-called ‘tankering’ practices (Article 5). While the intention behind Article 5 is commendable, there are several unintended consequences from a safety, operational and business perspective. 

Requiring operators to uplift fuel at airports where they are often lower on fuelling priority can lead to delays, particularly at busy airports during the summer. This risks undermining the reliability of the air traffic management network and disrupting business aviation’s operating model, which relies on efficiency and time-critical reliability. In addition, the administrative burden created by complex reporting obligations, combined with the uneven implementation across Member States, further exacerbates the challenges faced by business aviation operators. 

This burden is associated with limited environmental gains, as the additional emissions avoided by preventing operators from uplifting fuel beyond what is strictly necessary for a flight are often negligible, particularly for smaller aircraft. 

EBAA advocates for a tankering rule that fully recognises the operational realities of our sector

Book and claim system 

Access to Sustainable Aviation Fuel (SAF) for business aviation remains difficult. The relatively small fuel volumes required by business aviation operators place them at a disadvantage compared to airlines when securing SAF supply. Moreover, many business aviation flights operate to and from smaller or non-EU airports where SAF is either extremely scarce or not available at all. 

This is why a book-and-claim system is so important: it would allow operators to purchase SAF even when it cannot be physically uplifted at their point of departure. In this way, business aviation could not only decarbonise at pace, but also actively support the scaling-up of SAF production by sending stronger, aggregated demand signals to producers. 

At present, however, business aviation operators face an additional challenge under the EU Emissions Trading System (ETS): SAF use booked and claimed cannot be recognised against ETS obligations. This creates a structural disadvantage, penalising operators who are willing to invest in SAF and undermining the effectiveness of voluntary decarbonisation efforts. 

EBAA advocates for a book-and-claim system that ensures business aviation can access SAF fairly, contribute to the growth of SAF production, accelerate emissions reductions, and be recognised under ETS in line with its operational realities. 

EBAA members can access the RefuelEU Working group through the EBAA Extranet Platform.