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ReFuelEU Aviation environmental labelling scheme

Transport

Regulation (EU) 2023/2405 (ReFuelEU Aviation) creates a voluntary labelling scheme for flights covered by the Regulation through a common, standardised and publicly accessible methodology for the emissions calculation of flights. The Commission is empowered to adopt implemening acts detailing this methodology by 1 January 2025, which will build on the previous work carried out by EASA in the Pilot Project of the European Parliament for the environmental labelling scheme.

Links

Public consultation

ID: 14142

Lobbying Activity

29 responses

Transport and Environment: Flight labels must include non-CO2 impacts

Transport and Environment (European Federation for Transport and Environment), 21 Oct 2024

T&E seeks greater transparency by including non-CO2 effects and train alternatives in flight labels. They also recommend using a correction factor for furnishings when apportioning emissions to cargo.
Accurate data would support the group's mission to shift demand toward cleaner transport.
Airlines currently benefiting from the omission of non-CO2 effects would face increased scrutiny.

BEUC Urges Strict Controls to Prevent Misleading Flight Emission Labels

Bureau Européen des Unions de Consommateurs, 22 Oct 2024

BEUC demands the Label serves consumer information purposes at the point of sale only. They request a disclaimer stating flying is polluting and suggest choosing sustainable alternatives. Airlines should be barred from using the Label for advertising purposes.
Consumers gain protection from deceptive marketing practices and labels that use misleading green colors.
Airlines lose the ability to use unregulated mimic labels or marketing to greenwash flights.

Airbus urges simplified reporting for new flight emissions labels

Airbus, 22 Oct 2024

Airbus requests simplified reporting to avoid duplication with other EU regulations and calls for the use of international standards. They suggest that fallback calculations should distinguish between specific aircraft models to highlight the efficiency of modern planes.
This would reduce administrative burdens and provide a competitive advantage for their newer aircraft.
Operators of older, less efficient aircraft would receive lower environmental ratings under this system.

Fuel Industry Seeks Limits on Aviation Label Requirements

FuelsEurope, 22 Oct 2024

FuelsEurope requests that the scheme not impose additional data requirements on fuel suppliers beyond existing ReFuelEU obligations. They seek alignment with other EU regulations and clarification on implementation details, particularly regarding the flexibility mechanism and batch allocation.
This would avoid increased administrative burden and compliance costs for fuel suppliers.
Consumers lose more detailed transparency on flight emissions from independent verification.

DHL Group urges flexible emission labels for cargo transport

DHL Group, 22 Oct 2024

The group expresses reservations about applying labels to individual cargo flights due to technical complexities. They advocate for using the ISO 14083 standard to report emission savings over time.
This approach allows them to report carbon savings without mapping fuel to specific flights.
Regulators and customers lose the ability to compare the environmental impact of individual flights.

European Rail Body Demands Better Aviation Labels for Mode Comparison

Community of European Railway and Infrastructure Companies, 22 Oct 2024

CER requests the label include non-CO2 climate impacts like nitrogen oxides and vapour trails. They demand consistency with broader EU methodology to allow direct comparisons with rail transport. The group also advocates for a classification-style logo rather than a simple certification seal.
Uniform comparison methods would help rail operators capture market share from high-emission flights.
Airlines may lose customers if the full scope of their climate impact becomes visible.

Airlines for Europe seeks flexibility and less red tape

Airlines for Europe, 22 Oct 2024

A4E demands reusing existing regulatory data to minimize administrative burdens and costs. They also urge more realistic timelines for developing complex IT systems.
Reducing redundant reporting would lower compliance costs and improve industry competitiveness.
Third-party travel agencies may face new burdens to display environmental data.

Ryanair urges accurate flight labels and longer compliance deadlines

Ryanair Holdings, 22 Oct 2024

Ryanair proposes using existing data to avoid red tape and extending label display deadlines. They also demand precise emissions allocation between cargo and passengers to prevent deceiving consumers.
These changes would lower administrative burdens and prevent competitors from accessing sensitive commercial information.
Unauthorized ticket resellers lose out as airlines refuse responsibility for their label compliance.

IATA urges flexibility in voluntary EU flight emission labeling

International Air Transport Association, 22 Oct 2024

IATA requests flexibility in fuel measurement methods and a phased approach for label implementation. They want to limit the label's geographical scope and exclude it from corporate reporting.
These changes would ensure efficient implementation with minimized costs and administrative burdens.
Companies seeking standardized data for corporate reporting lose a potential tool for transparency.

Air France-KLM urges harmonized standards for flight emission labels

Air France-KLM, 21 Oct 2024

The airline group requests harmonized calculation methodologies to avoid creating a confusing patchwork of reporting models. They also argue that airlines should be permitted to allocate sustainable fuel uptake manually.
Standardized rules would reduce reporting burdens while reinforcing passenger trust in environmental data.
Consumers face confusion if labels use methods that conflict with other EU rules.

CEOE Urges More Flexibility in EU Aviation Emissions Labelling

CEOE - Confederación Española de Organizaciones Empresariales, 22 Oct 2024

CEOE requests allowing airlines to voluntarily include their entire EU flight network to avoid discrimination. They argue for removing the unmanageable five-day IT update deadline and using default emission values when specific fuel data is unavailable.
Airlines would avoid unmanageable IT deadlines and reduce excessive administrative data reporting burdens.
Passengers might receive less precise information if default emission values are widely applied.

IAG urges broader scope for EU flight emissions labels

International Consolidated Airlines Group, 22 Oct 2024

IAG recommends allowing all airlines to use the labeling methodology for all flights to ensure information reliability. They also propose aligning definitions with existing rules and avoiding duplicate reporting of fuel and emissions data.
Using existing reporting schemes would reduce the administrative burden and costs of label implementation.
Consumers might be misled into believing flights without labels fail to meet safety standards.

CANSO urges removing air traffic management from aviation labelling scheme

CANSO - Civil Air Navigation Services Organisation, 22 Oct 2024

The organization calls for the reference to air traffic management to be removed from the regulation. They highlight that fuel-saving measures often depend on decisions taken by the pilot or airline.
This would shield air navigation service providers from accountability for emissions factors outside their control.
Travelers would lose visibility into how air traffic management efficiency affects the environmental impact of flights.

easyJet calls for ETS recognition on flight labels

easyJet, 22 Oct 2024

easyJet requests labels indicate if flights are covered by the EU Emissions Trading Scheme. They propose a 150kg passenger weight adjustment to account for aircraft infrastructure.
This would acknowledge their high carbon costs and reduce administrative reporting burdens.
Airlines operating outside the EU carbon framework may face reduced consumer trust.

Global Business Travel Association urges transparent flight emission labels

Global Business Travel Association, 22 Oct 2024

The group demands that travel managers and booking platforms access official emissions data. They also advocate for flexibility to align EU labels with global standards.
Standardized data reduces reporting burdens and builds trust in sustainable bookings.

Austrian Chamber of Labour warns against misleading flight labels

Bundesarbeitskammer Österreich, 22 Oct 2024

The labeling should be mandatory for all flights and include non-CO2 climate impacts. The organization also demands avoiding green colors and misleading terms that suggest flying is eco-friendly.
Austrian consumers gain a reliable basis for choosing the most climate-friendly travel options.
High-polluting airlines lose the ability to hide their impact through voluntary non-participation.

Consultation response

Finnair, 18 Oct 2024

Finnair agrees with the comments by Airlines for Europe (A4E). In addition, Finnair would wish submit the additional comments in the attachment.

German Aviation Association Urges Realistic Flight Emissions Labelling

Bundesverband der Deutschen Luftverkehrswirtschaft e. V., 22 Oct 2024

BDL proposes using a fleet-based approach to account for operational realities. They want labels to include forward-looking certified offers instead of historical data. Additionally, they call for liability limits regarding third-party display requirements.
Avoiding individual flight benchmarking prevents consumers from shunning specific aircraft types.
Eco-conscious travelers lose the transparency needed to select the cleanest individual flights.

E4FC urges social standards in new flight emission labels

Europeans for Fair Competition, 22 Oct 2024

The group requests that the label includes social responsibility and fair labor standards. They also want a methodology that allows the flexible allocation of sustainable fuel to specific flights.
Network airlines would avoid ratings disadvantages stemming from their complex operations and higher labor costs.
Low-cost carriers with minimal labor protections would lose the advantage of a purely environmental rating.

Consultation response

Polskie Linie Lotnicze "LOT" S.A., 21 Oct 2024

LOT Polish Airlines welcome European Commissions ambitious climate goals. We believe that every passenger should have access to transparent and clear data regarding the environmental impact of their air travel. However, we have a few comments on the European Commission's proposal regarding the…

Consultation response

Airport Regions Council, 5 Oct 2024

Regarding the Flight Emissions Label proposal, Airport Regions Council: . welcomes the initiative of the European Commission . congratulates the efforts of the Commission to engage the aviation and airport stakeholders in the process to prepare the proposal . considers that there are elements of…

Consultation response

Koninklijke Nederlandse Toeristenbond ANWB, 22 Oct 2024

ANWB welcomes a system to enable and improve informed choices by passengers regarding sustainable transport. At this stage of your consultation we only want to make two short remarks: 1. Every airliner should participate. Comparisons of results based on a selection of airlines are incomplete and…

Consultation response

Topsector Logistiek, 14 Oct 2024

The initiative to incorporate aviation in emission registration is to be recommended: clear unambigous data on the energy- and emission effectiveness on both passenger and freight aviation is the basis for GHG emission reduction. An emission label is a normative translation of primairy data:…

Consultation response

European Network of Business Travel Associations, 22 Oct 2024

The Flight Emissions Label aims to provide a clear view of CO emissions per flight, allowing for informed decision-making when choosing travel options. For a company or organisation concerned with reducing the environmental impact of travel, this would be a significant advantage, as it could use…

Consultation response

Svenska Flygbranschen, 22 Oct 2024

The Swedish Aviation Industry Group (SAIG) supports the establishment of a voluntary and harmonized labelling system aimed at enhancing the environmental performance of aviation. As passenger awareness of flight emissions grows, a transparent labelling system can help travelers make informed…

Consultation response

Opportunity Green, 22 Oct 2024

The SASHA Coalition - facilitated by Opportunity Green - welcomes the publication of, and opportunity to respond to, the draft Implementing Act for the Flight Emission Label. Providing a framework for the consistent labelling of flight emissions is important for consumers to make well-informed…

Consultation response

Aviation Environment Federation, 22 Oct 2024

There is demand for the provision of environmental information to consumers and the public regarding the impact of flying. This is a timely opportunity to consider how a Flight Emissions Label can contribute to the publics understanding, and in doing so, raise awareness of the sectors greenhouse…

Consultation response

UNION EUROPEENNE CONTRE LES NUISANCES AERIENNES, 18 Oct 2024

From UECNA We appreciate this initiative. Anyway, it should be mandatory.We see some problems if labels are issued to the aircraft operators. In some cases airlines orderflights by other operators (Wet-lease, charter). In many cases customers buy package tours withoften unknown airline. We suggest…

Consultation response

Authentic Energy Management Services, 29 Sept 2024

Overall this label will work well and I support it. It brings the tools we professionals use to wider public use. However it should be planned / extended at a future date e.g. when CountEmissionsEU regulation has been widely adopted to show alternative modes of transport alongside. I see Lufthansa…