ReFuelEU Aviation

ReFuelEU Aviation is Regulation (EU) 2023/2405, an EU regulation that imposes an escalating sustainable aviation fuel (SAF) blending mandate at EU airports for fuel uplifted by aircraft operators. It entered into force on 5 December 2023 and the principal SAF mandate began applying on 1 January 2025. Unlike RED III, ReFuelEU Aviation is a regulation rather than a directive — it applies directly in all Member States without transposition into national law.

SAF blending trajectory

The regulation sets a minimum SAF share of total jet fuel uplifted at EU airports on a published trajectory:

• 2025: 2% SAF
• 2030: 6% SAF (with at least 1.2% from synthetic SAF / RFNBO routes)
• 2035: 20% SAF
• 2040: 34% SAF
• 2045: 42% SAF
• 2050: 70% SAF (with at least 35% from synthetic SAF)

The 2030 sub-target for synthetic SAF — derived from renewable hydrogen and captured CO2 — is one of the most analyzed elements of the regulation, given the limited current global RFNBO production capacity.

Eligible SAF feedstocks

The regulation defines SAF eligibility by reference to RED III's Annex IX feedstock list and adds explicit exclusions. Eligible feedstocks include:

• Annex IX Part A advanced biofuels (lignocellulosic, municipal solid waste fractions, etc.)
• Annex IX Part B used cooking oil and animal fats (with caps)
• Renewable fuels of non-biological origin (RFNBOs), primarily synthetic SAF made from renewable hydrogen and CO2
• Recycled carbon fuels under specific conditions

Food-and-feed crop SAF (e.g., palm oil, soybean oil, rapeseed oil) is excluded from counting toward the mandate.

Anti-tankering provisions

A distinctive feature of ReFuelEU Aviation is its anti-tankering provision: aircraft operators must uplift at least 90% of their fuel needs at the EU airport of departure. The provision prevents operators from circumventing the SAF mandate by carrying additional non-SAF fuel from non-EU airports for European legs. Compliance is monitored by the European Union Aviation Safety Agency (EASA).

Compliance and enforcement

Three compliance roles are set out in the regulation:

• Aviation fuel supplier — must supply at least the regulated SAF share at each EU airport
• Aircraft operator — must uplift at least 90% of fuel at the airport of departure
• EU airport managing body — must facilitate SAF availability and reporting

Enforcement is via Member-State competent authorities, with administrative fines and the public Union database for tracking SAF supplied at each airport.

Connection to U.S. SAF supply

The U.S. is one of the world's largest SAF producers, and ReFuelEU Aviation represents a significant demand pull for U.S. SAF exports into the EU jet fuel pool. Section 45Z's higher SAF credit value ($1.75 per gallon vs $1.00 for non-SAF) is an explicit U.S. domestic incentive aligned with the demand framework that ReFuelEU Aviation creates on the EU side.

Linkage to ETS

ReFuelEU Aviation operates alongside the EU Emissions Trading System (EU ETS). Aircraft operators on intra-EEA flights face EU ETS allowance obligations; SAF use lowers the carbon-emissions tally that determines allowance demand. The two systems together provide a price signal and a quantity mandate on the same physical fuel pool.

Historical context

ReFuelEU Aviation was proposed by the European Commission in July 2021 as part of the "Fit for 55" climate package. The regulation went through co-decision under the ordinary legislative procedure and was adopted by the European Parliament and Council in October 2023. Implementing acts under Article 13 are issued periodically as the regulation phases in.

Sources

Regulation (EU) 2023/2405 (ReFuelEU Aviation, OJ L 2023/2405, 31.10.2023). Directive (EU) 2023/2413 (RED III, Annex IX feedstock list). EU ETS: Directive 2003/87/EC as amended. Implementing acts published by the European Commission as they take effect.