Three key takeaways from the paper:
1) Anti-tankering rule
- Issue: Operational realities create a heavy administrative workload under the current rules and sometimes even additional fuel burn.
- Proposed solution: Introduce more proportionate thresholds and a harmonised EU exemption framework.
2) SAF documentation & ETS alignment
- Issue: Late and inconsistent sustainability documentation, combined with misalignment between ReFuelEU and EU ETS, creates audit risk and can prevent airlines from claiming emissions benefits for SAF they have paid for.
- Proposed solution: Introduce harmonised EU documentation templates, earlier delivery timelines, and stronger alignment between ReFuelEU and EU ETS reporting frameworks.
3) Supplier market behaviour & pricing transparency
- Issue: SAF surcharges are often opaque and not clearly linked to verifiable SAF volumes, while limited supplier competition at some airports weakens airlines’ negotiating leverage.
- Proposed solution: Improve transparency of SAF surcharge methodologies and implement Book & Claim to strengthen market transparency and competition.
A targeted fast-track revision in 2026 could strengthen legal certainty, reduce unnecessary administrative burden, and ensure that every euro spent on SAF translates into real decarbonisation.
