Destination 2050 said elements of the current proposal could affect European competitiveness and emissions reduction efforts. It called on EU legislators to provide investment certainty, support innovation and base new measures on validated science and operational feasibility.
SAF allowances and ETS revenues
Destination 2050 welcomed recognition that greater support is needed to accelerate sustainable aviation fuel uptake. However, it raised concerns about reduced support levels for each SAF category and the planned phase-out of support for waste-based bio-SAF after 2029.
The organisation also opposed a “Made in Europe” criterion for SAF. It called for a framework reflecting market conditions and operating consistently with ReFuelEU Aviation and RED III.
Destination 2050 said additional allowances should be available from the outset, independently of any geographical expansion. It also called for support without distinctions based on the nature or business model of aviation activity. “We call for stronger and longer-term SAF allowance support.”
On ETS revenues, Destination 2050 welcomed the proposal to secure a share of revenues for sectors covered by the mechanism. The organisation said aviation ETS revenues should support decarbonisation, technological modernisation and competitiveness. “We urge the co-legislators to ensure that 100% of the revenues from the auctioning of allowances associated with emissions from our sector are reinvested in the sector to support its decarbonisation, technological modernisation and competitiveness.”
CORSIA, innovation and carbon removal priorities
Destination 2050 said CORSIA is the appropriate global carbon pricing framework for international aviation emissions. It opposed extending the EU ETS to routes outside the European Economic Area, citing potential competition distortions and regulatory fragmentation. “We strongly oppose expanding the geographical scope of the EU ETS and urge to prioritise global mechanisms by strengthening CORSIA, assisting Member States with ICAO’s Long-Term Aspirational Goal.”
The organisation also called for a book-and-claim mechanism under the EU ETS. It said the mechanism could address uneven SAF availability across Europe by allowing verified purchases to receive support regardless of physical fuel supply location. “We call for the introduction of purchase-based attribution to fuel users under the EU ETS to enable an effective European book-and-claim system.”
Destination 2050 also called for aviation projects to be included in the Industrial Decarbonisation Bank. It urged changes to the EU Innovation Fund to support technology maturation across aviation. The organisation identified more efficient propulsion systems, aerodynamic improvements, advanced materials, hybrid aircraft and electric aircraft among relevant technologies. “We urge policymakers to include aviation projects in the Industrial Decarbonisation Bank and to adapt the EU Innovation Fund by supporting the technology maturation in the aviation sector, ranging from emissions reductions from more efficient propulsion systems and aerodynamic improvements, over advanced materials to ‘breakthrough innovative technologies’.”
Ιnclusion of carbon removals in the EU ETS proposal welcomed
Destination 2050 also welcomed the inclusion of carbon removals in the EU ETS proposal. It called for a regulatory and financial framework supporting carbon capture and utilisation research and technology. The organisation identified the EU ETS Innovation Fund, Horizon Europe and the Connecting Europe Facility as potential funding streams. “We call on policymakers to incentivise CCU and carbon removals through R&D, Technology Investment and EU ETS Integration to create a clear market framework and drive widespread adoption across the sector, and by de-risking capital investment in carbon removals with Contracts for Difference (CfD) mechanism.”
Finally, Destination 2050 raised concerns about the scientific and operational basis for proposed incentives linked to aviation non-CO₂ effects. It said forecasting contrail formation at the flight-planning stage remains subject to significant scientific uncertainty. The organisation noted that forecasts do not determine whether a particular flight trajectory is operationally available. It also said weather conditions can change rapidly and flight paths depend on real-time operational constraints. “The understanding of aviation non-CO₂ effects is still very much evolving and contrail avoidance strategies should be regulated and incentivised when there is mature scientific understanding and demonstrated operational feasibility across the whole aviation system.”
Tags: Destination 2050 European Commission
