Europe Forging ahead on Sustainability through Mandates

As the worldwide aviation industry looks to accelerate its adoption of decarbonization strategies, Europe continues to leverage its experience and appetite for sustainable advancement.

These pair continent-wide regulatory requirements, such as European Union sustainable aviation fuel (SAF) mandates, with regional refining abilities, aiming to strengthen the SAF supply chain. However, further legislative clarity is needed to incentivize the timely construction of new fuel production facilities, with additional punitive taxes also hindering European competitiveness.

“Business aviation manufacturers, and the wider industry, remain fully committed to our sustainability goal of achieving net zero carbon emissions by 2050,” stated Kyle Martin, v-p of European affairs at the General Aviation Manufacturers Association (GAMA). This commitment remains despite a change of U.S. administration that may favor other priorities.

At the same time, Martin has not observed any change in European motivation to achieve its sustainability goals, even as they broaden. “Even before this, the new European Commission, which took office in late 2024, started with a very noticeable shift in focus towards competitiveness and innovation rather than a purely sustainability-driven agenda,” he explained. “We welcome this changed direction, as we can be both sustainable and competitive.”

However, an open letter from Airports Council International (ACI) Europe to European Commission President Ursula von der Leyen in February 2025 took a cautionary tone. Written on behalf of the “Destination 2050” industry alliance, it warned that “further EU public support” was needed to meet 2050’s target and called for a SAF industrial policy, supportive financing, and a simplification of regulatory burden.

Regulatory Landscape

Notably, 2025 is the year the EU’s ReFuelEU Aviation Regulation (first drafted in 2021 and formally adopted in 2023) has taken effect in Europe. From January 1, this minimum supply mandate has required aircraft departing from EU airports to use a minimum 2% blended SAF. This percentage will increase to 6% in 2030 and 70% by 2050, with aircraft required to uplift at least 90% of their total fuel from within the EU.

While ACI Europe’s director of sustainability, Alexandre de Joybert, believes these mandates “provide essential legal certainty, financial incentives and flexibility mechanisms to scale production at competitive prices are lacking.”

With the European Parliament due to issue a Sustainable Transport Investment Plan in the third quarter of 2025, the EU must complement this plan’s objectives with stronger policy support, said de Joybert. Such measures should include risk-sharing tools, innovation funding, revenue-certainty mechanisms, flexible supply and claims systems, and financing tailored to SAF needs. Beyond immediate financial support, he reiterated that “Europe must adopt a clear SAF industrial policy.”

However, further overarching regulatory review is also vital to fostering European decarbonization efforts, argued GAMA’s Martin. “Some policy measures are actually making it harder for industry to meet its sustainability goals,” he noted, citing the sharp increase in France’s so-called “solidarity tax” imposed in March 2025. This aggressive and punitive policy, he continued, “significantly added to the cost burden for commercial business aviation flights departing from French airports, yet offers no reductions or incentives for SAF use.”

This penalizing approach appears at odds with EASA figures explaining that within the EU, “every 10% increase in air connectivity yields 0.5% in GDP per capita along with 1.6% in employment.”

The UK has also turned up the fiscal dial on private aviation with its air passenger duty in 2025, with none of the anticipated £520 million ($700 million) expected income in the first year set to be allocated to sustainability incentives.

SAF Production

The ReFuelEU Aviation mandate successfully boosted bio-SAF production in Europe from almost zero to around 1.2 million tonnes in 2024, something de Joybert said sends “a positive and necessary signal to the market.” However, despite progression, the burgeoning European SAF industry continues to be dogged by a demand that far outpaces supply.

This is by no means a problem unique to Europe. However, while the U.S. Inflation Reduction Act provided some tax incentives to help scale up SAF production, European approaches differ. “In contrast, Europe’s current approach relies predominantly on mandates like ReFuelEU Aviation and limited ETS [Emissions Trading Scheme] allowances, which provide regulatory certainty but fall short of addressing the high upfront investment risks and cost challenges faced by SAF producers,” said GAMA’s Martin.

De Joybert concurred, believing that while European policies and mandates “provide positive momentum, more coordinated financial support and national backing are needed to ensure access to reliable, affordable SAF across the continent.” Crucially, although “mandates set the direction, only a mix of regulatory and robust financial incentives can mobilize private capital to scale up SAF production rapidly and cost-effectively,” he concluded.

Although ACI Europe recognized earlier this year that the EU does face disadvantages regarding SAF production—including the “cost of electricity [and] natural gas”—it does also possess “considerable refining infrastructure and the associated workforce.”

Of the 11 approved production pathways (set by the international industry standard-setting organization ASTM), current production is almost exclusively dominated by the hydroprocessed esters and fatty acids (HEFA) pathway. Although existing refineries can be more readily adapted to its production, HEFA’s requisite raw materials (including used cooking oil, vegetable oil, or animal fats) face significant scalability challenges.

Used cooking oil is the most prevalent European feedstock, with around 80% of Europe’s imported from China, Indonesia, and Malaysia. Geopolitical uncertainty, combined with concern about the sustainability of supply chains, therefore has the potential to impact the European aviation sector’s resilience.

Next-generation Fuels

So-called “next-generation” SAF pathways aim to mitigate these concerns, with Europe already exploring the development of alternative synthetically produced liquid hydrocarbons. These are also known as power-to-liquid (PtL) or e-fuels. Carbon feedstocks (including from direct air capture) are synthesised with green hydrogen, with the resulting product also able to be blended with conventional kerosene.

Recognizing PtL’s potential, a ReFuelEU submandate for these fuels will start at 0.7% in 2030 and increase to 35% in 2050. The UK is a notable exception to the trend of HEFA dominance in 2030 announced capacity, “largely due to the HEFA cap within the UK SAF mandate, which sets a limit of 71% of SAF permitted to be HEFA by 2030 and 35% by 2040,” noted a recent ACI Europe report. De Joybert described the UK’s direction as “a balanced policy” and an approach that “mitigates risks associated with feedstock scarcity and geopolitical dependencies.”

Although de Joybert acknowledged that “Europe benefits from a robust pipeline of over 40 large e-SAF projects, representing more than half of the global capacity, none have yet reached the crucial final investment decision.” High start-up costs, along with the relative nascency of green hydrogen production and direct air capture methods, are impacting the speed at which European PtL plants can evolve beyond a pilot stage.

“Challenges like high investment risks…and strong competition from markets with better incentives hinder scale-up, particularly for next-generation SAF technologies struggling to reach final investment decisions,” he continued.

EASA estimates that of the almost 70 EU and European Free Trade Association (EFTA) facilities projected to be up and running by 2030, only five are likely to be operating. A further eight are “realistic,” with the remainder deemed “optimistic.”

Despite the UK’s Jet Zero Strategy (published in 2022) pledging a “commitment to have at least five [SAF] plants under construction by 2025,” only one project has commenced construction. Netherlands-headquartered SAF supplier SkyNRG flagged up a similar reality in its 2025 market outlook. With mandated European SAF demand expected to reach approximately 4 million tonnes by 2030, only 30% of the plants needed to meet a feasible annual production of around 3.8 tonnes are operational or under construction.

Regardless of its method of production, the availability of SAF is nevertheless steadily increasing across European FBOs. Aviation sustainability advocate 4AIR said that as of May 2025, SAF is available at 114 locations worldwide, 43 of which are in Europe.

Signature Aviation, operator of the world’s largest network of private aviation terminals, also claims it has “become the first FBO worldwide to offer permanent supplies of SAF and is aggressively expanding availability.”

With projected demand rising, in 2024, the European Business Aviation Association highlighted Paris Le Bourget, London Luton, and London Farnborough as representing the three biggest European FBO demands for SAF. Indeed, in March 2025, a new supplier deal saw Farnborough gain what the airport called “the potential to be the only airport in the world to be offering fuel with a 20% [SAF] blend across its entire supply by 2028.”

What’s Next?

With SAF as an intrinsic decarbonization strategy, GAMA is continuing to advocate for additional European initiatives to support its ramp-up, including the recognition of a book-and-claim SAF system. (Under this structure, the environmental attributes of SAF can be claimed by a company that does not receive the physical product.) Notably, the ReFuelEU mandate was initiated without any recognition of book-and-claim. Furthermore, the EU’s Emission Trading Scheme (EU ETS) for carbon pricing also doesn’t accept this decoupled scheme for SAF credits.

However, GAMA has recognized a “notable shift in the EU’s attitude towards recognizing a book-and-claim system for SAF over the past six months,” something bolstered by the EU’s public call for tender for a book-and-claim system in October 2025.

This, explained the EU, would identify the “viable options for the legally sound set up” of mechanisms that could subsequently be extended worldwide. An upcoming study will prioritize analysis of areas of the world “that have the largest trade volumes with the EU, such as the U.S., North Africa, and Singapore.”

GAMA, together with other aviation stakeholders, “are continuing to push for the recognition of a book-and-claim system under both EU ETS and RefuelEU Aviation as an essential measure to accelerate investment and growth in Europe’s SAF market,” concluded Martin.

In 2026, the European Commission is also set to assess ICAO’s Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). At this point, the arguably more ambitious EU ETS could potentially expand its scope to flights departing Europe. “Alternatively, the proposal could be to maintain the intra-European scope if CORSIA is strengthened and has a high level of global participation and implementation,” clarified the EU.