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ReFuelEU Aviation - Sustainable Aviation Fuels

Transport

This initiative aims to reduce the environmental footprint of the aviation sector and enable it to contribute to achieving the EU’s climate targets, by boosting the supply and demand for sustainable aviation fuels in the EU. Indeed, sustainable aviation fuels have the potential to make an important contribution to reducing emissions from aviation. However, to date this potential is largely untapped, as sustainable aviation fuels represent only 0.05% of total jet fuel consumption.

Links

Public consultation

ID: 12303

Lobbying Activity

111 responses

Transport & Environment urges higher e-kerosene targets for aviation

Transport and Environment (European Federation for Transport and Environment), 5 Nov 2021

T&E recommends a more ambitious e-kerosene sub-target while lowering targets for advanced biofuels. They call for capping limited feedstocks like used cooking oil to avoid resource diversion. Finally, they urge regulation of fuel aromatics to mitigate non-CO2 climate impacts.
Prioritizing e-kerosene ensures aviation decarbonizes using fuels that can be sustainably scaled.
Biofuel producers using food crops lose market access as T&E supports their exclusion.

Consultation response

Transport and Environment (European Federation for Transport and Environment), 19 Apr 2020

Overview T&E supports the introduction of a mandate for specific sustainable advanced fuels in the aviation sector, but only if certain conditions are met for such a mandate to provide both a clear environmental benefit and investor certainty. They include, but are not limited to, the exclusion of…

Consultation response

American Chamber of Commerce to the European Union, 18 Nov 2021

Sustainable aviation fuels (SAF) are one of the most direct ways to make substantial reductions in net carbon emissions for aviation across all market segments and aircraft sizes. AmCham EU members representing key players along the aviation value chain have been committed to the development and…

German industry group warns of carbon leakage in aviation

Bundesverband der Deutschen Industrie e.V., 17 Nov 2021

The BDI recommends applying fuel mandates only to intra-EU flights to protect the competitiveness of European airlines. They also propose a funding mechanism to offset high sustainable fuel costs.
Restricting the mandate's scope protects European airlines from losing passengers to non-European competitors.
Non-European airlines would lose their price advantage from using cheaper conventional jet fuels.

Consultation response

Bundesverband der Deutschen Industrie e.V., 21 Apr 2020

The “ReFuelEU Aviation” initiative by the EU Commission sends a positive signal for the sustained introduction and roll-out of sustainable aviation fuels (SAF) into the market in the pursuit of reducing CO2-emissions in aviation. In order to reach the ambitious CO2-emission reduction targets for…

Oleochemical Industry Opposes Diverting Animal Fats to Aviation Biofuels

European Chemical Industry Council, 18 Nov 2021

APAG urges legislators to prevent rendered animal fats category 3 from being added to biofuel feedstock lists. They want to protect access to these raw materials for existing oleochemical uses rather than diverting them to aviation fuel.
This would protect their access to limited raw materials and avoid competition from biofuel producers.
Aviation sector loses access to a proven sustainable fuel source needed to meet emissions targets.

Consultation response

European farmers, 18 Nov 2021

Moving the aviation sector in a more sustainable direction is a major undertaking. This is why Copa and Cogeca call upon the Commission to focus on synergies rather than selecting specific winners. While e-fuels will without a doubt be important in the future, they depend on carbon molecules,…

Consultation response

European farmers, 20 Apr 2020

The quote states that food and feed crops have a limited potential for decarbonisation, notably due to their indirect impacts on land use changes. Copa and Cogeca do not consider this statement by the Commission to be correct, since the EU has the strictest monitoring rules[2] in the world to…

TotalEnergies backs EU mandate for sustainable aviation fuel blending

TotalEnergies SE, 21 Apr 2020

TotalEnergies supports a blending mandate for sustainable aviation fuels, with SAF mandates separated from road transport mandates. They request technology-neutral requirements that recognize all sustainable feedstocks, not just those in Annex IX, and want harmonization with existing mechanisms like ETS and CORSIA.
This would allow Total to use their diverse feedstock portfolio competitively.

Consultation response

FuelsEurope, 20 Apr 2020

FuelsEurope supports the Green Deal’s ambition for climate neutrality in 2050 and will work with the EU institutions, Member States, and stakeholders, to help create the essential enabling policy framework. The Green Deal is clearly work in progress and will require careful societal consultation…

Shell urges EU aviation fuel mandate with CO2 targets

Shell Companies, 19 Apr 2020

Shell requests an EU-wide mandate for sustainable aviation fuels with fuel suppliers as obligated parties, set as a CO2 intensity target. The mandate should initially allow first-generation feedstocks and include trading of compliance certificates between countries.
This provides long-term investment certainty for Shell's sustainable aviation fuel production facilities.

Consultation response

Hydrogen Europe, 8 Nov 2021

Hydrogen Europe recommends the following points regarding the recent proposal of the ReFuelEU Aviation Regulation: 1. Increase the level of ambition with a dedicated, realistic target for the adoption of RFNBO’s in the aviation sector by 2025 and, overall, higher targets and a more even growth…

Consultation response

Hydrogen Europe, 21 Apr 2020

Hydrogen Europe welcomes the ReFuelEU Aviation initiative designed to increase uptake of Sustainable Aviation Fuels (SAF) and thus reduce the carbon footprint of the aviation sector. The initiative is both timely and needed. It's also commendable that the Commission sees a place for both biofuels…

Consultation response

Wirtschaftskammer Österreich, 18 Nov 2021

WKÖ supports the European Green Deal and stands by the climate neutrality goal by 2050. Now a concrete set of measures for a sustainable, ecological change in the EU, in line with a new growth strategy, is necessary. WKÖ will contribute to a legislative package that meets the requirements of…

Neste urges broader feedstocks and higher SAF blending targets

Neste Oyj, 17 Nov 2021

Neste requests expanding eligible feedstocks beyond Annex IX materials, increasing blending targets above current levels, and allowing Member States to set higher national mandates. They argue current modest targets will make aviation climate goals difficult to achieve.
This would expand markets for their existing SAF production capacity reaching 1.5 million tonnes.

Neste urges EU to adopt binding aviation fuel mandates

Neste Oyj, 21 Apr 2020

Neste recommends a blending mandate of at least 8% to 10% by 2030 to provide investment certainty. They also urge that all sustainable waste and residue feedstocks be eligible for use under the new rules.
This policy would secure long-term demand and financial security for Neste's massive global production facilities.
Traditional fossil fuel suppliers would lose market share as mandatory blending requirements prioritize renewable alternatives.

Consultation response

IBERDROLA, 17 Nov 2021

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.…

Consultation response

Technology Industries of Finland (Teknologiateollisuus ry), 18 Nov 2021

Teknologiateolisus ry kannattaa EU-tason toimia uusiutuvien lentopolttoaineiden käytön lisäämiseksi. Valittavat toimet tulee toteuttaa tavalla, joka vähentää tehokkaasti lentoliikenteen päästöjä, ehkäisee hiilivuotoa ja huomioi lentoliikennealan toimintaedellytykset sekä jäsenvaltioiden…

Consultation response

General Electric Company, 18 Nov 2021

GE Aviation has been actively involved in assessing and qualifying SAF since 2007 and works closely with SAF producers, regulators, and operators to ensure that SAF can be widely adopted for use in aviation. Sustainable Aviation Fuel (SAF) are critical for the decarbonization of the aviation…

Consultation response

General Electric Company, 17 Apr 2020

GE Aviation fully supports the widespread adoption of Sustainable Aviation Fuels (SAF) and the objectives being pursued by the ReFuel EU Aviation initiative. While technological innovation and advancement will provide foundational carbon emission reduction opportunities for the mid-to-long term,…

Europe's largest airline urges EU subsidies to match US SAF support

Ryanair Holdings, 18 Nov 2021

Ryanair requests EU-level financial incentives to close the price gap between conventional jet fuel and SAF, matching US support measures. They also call for a flexible book-and-claim system for regional airports and warn against the proposed kerosene tax.
This would reduce their SAF costs and preserve capital for fleet investments.
Taxpayers fund airline subsidies while climate benefits depend on voluntary industry uptake.

Ryanair Urges Global Sustainable Fuel Rules Over Regional Mandates

Ryanair Holdings, 21 Apr 2020

Ryanair demands global rules rather than regional mandates to avoid distorting competition. Policies must create fuel supply before imposing usage mandates on airlines. Efficient carriers should not face the same fuel requirements as long-haul operators.
This would help the airline keep fares low for price-sensitive passengers.
Long-haul carriers and airlines with premium seating would face higher relative costs.

Consultation response

SUEZ Group, 21 Apr 2020

SUEZ welcomes and supports the initiative of the European Commission to boost the supply and demand for sustainable aviation fuels (SAF) which will contribute to achieving EU climate neutrality ambition by 2050. SUEZ as a leader in environmental services in Europe is already engaged in several…

Consultation response

International Air Transport Association, 21 Apr 2020

Please find our feedback in attached document.

Consultation response

AIR LIQUIDE, 18 Nov 2021

Air Liquide welcomes the Commission proposal to set a minimum share of sustainable aviation fuel, including a minimum share of synthetic aviation fuel. Key recommendations include: (i)Fully recognise Hydrogen (H2) as a potential sustainable aviation fuel (ii)Facilitate the uptake of sustainable…

Consultation response

Aerospace, Security and Defence Industries Association of Europe, 18 Nov 2021

Aerospace and Defence Industries Associations of Europe (ASD) thanks the European Commission for this opportunity to comment on the proposal. ASD welcomes the EU’s Refuel EU Aviation initiative; we support the intent of the initiative to boost the production and uptake of sustainable aviation fuels…

Consultation response

Aerospace, Security and Defence Industries Association of Europe, 21 Apr 2020

AeroSpace and Defence Industries Association of Europe (ASD) thanks the European Commission for the possibility to comment on their inception impact assessment on ReFuelEU Aviation - Sustainable Aviation Fuels. ASD fully supports the intent of the initiative to boost the production and uptake of…

Consultation response

Naturschutzbund Deutschland e.V., 21 Apr 2020

NABU supports the introduction of a mandate for specific sustainable advanced fuels in the aviation sector, but only if certain conditions are met for such a mandate to provide both a clear environmental benefit and investor certainty. They include, but are not limited to, the exclusion of food &…

Consultation response

Zero Waste Europe, 4 Apr 2020

The ReFuelEU Aviation initiative can only contribute to climate change mitigation in the aviation sector by aligning finances with actions that help move the EU towards the circular economy. I. Policy Coherence - Any potential support to waste-based fuels needs to be fully in line with other…

BP urges higher SAF targets and flexibility in aviation fuel mandate

BP p.l.c., 17 Nov 2021

BP requests raising the 2030 sustainable aviation fuel target from 5% to 10%. They want recycled carbon fuels included to support waste-to-fuel pathways. BP seeks flexibility to comply based on total EU supplies rather than individual airports, and wants SAF to count toward multiple regulations.
This would expand market opportunities for BP's existing refining capacity and SAF production capabilities.
Higher targets could increase fuel costs for airlines and passengers in short-term.

Repsol urges EU to expand renewable fuel pathways for aviation

Repsol, S.A., 17 Nov 2021

Repsol requests alignment between RED and ReFuel Aviation to allow renewable fuels of non-biological origin as intermediate products. They call for removing the 1.7% cap on Annex IX part B feedstocks and including renewable hydrogen from biological origin in compliance calculations.
This would expand the range of renewable fuels Repsol can supply for aviation compliance.

Consultation response

Green Power Denmark, 18 Nov 2021

This document comprises Danish Energy’s updated positions on: 1. ReFuelEU Aviation on ensuring a level playing field for sustainable air transport 2. FuelEU Maritime on the use of renewable and low-carbon fuels in maritime transport It is important to have ambitious European targets for…

Consultation response

Boeing Belgium SRL, 17 Nov 2021

Boeing welcomes the Proposal for a regulation of the European Parliament and of the Council on ensuring a level playing field for sustainable air transport. We appreciate the opportunity to comment on this legislative proposal that advances key sustainable aerospace objectives in Europe. Boeing has…

Consultation response

eFuel Alliance, 3 Nov 2021

The eFuel Alliance is a stakeholder initiative committed to promoting the political and social acceptance of eFuels and to securing their regulatory approval and represents more than 150 companies along the value chain of eFuel production. The ReFuelEU Aviation regulation poses a great opportunity…

Consultation response

Farm Europe, 17 Apr 2020

Farm Europe’s Green Energy Platform’s reply to the public consultation on ReFuelEU Aviation - Sustainable Aviation Fuels EUROPEAN BIOFUELS MAKE AN ESSENTIAL CONTRIBUTION TO THE GREEN DEAL The transport sector poses one of the greatest challenges to the Green Deal. GHG emissions have risen fast,…

Consultation response

European Biodiesel Board, 18 Nov 2021

- Biofuels comply today with strict single EU-wide sustainability criteria. This allows all sustainable biofuels to have a role in the decarbonization of European transport. The approach to feedstocks and GHG savings calculations in the Aviation and Maritime proposals unduly deviate from the RED II…

Consultation response

European Biodiesel Board, 21 Apr 2020

The EBB welcomes the opportunity to respond to the EC’s consultation, and to be part of the preparatory process of the ReFuelEU Aviation - Sustainable Aviation Fuels (SAF) initiative, as well as upcoming EC activities designed to gather further stakeholder input. The EBB recognizes the importance…

Consultation response

European Cockpit Association, 18 Nov 2021

The European Cockpit Association (ECA) is the representative body of European pilots associations, striving for the highest levels of aviation safety and fostering social rights and quality employment for pilots in Europe. It represents 40.000 pilots from across Europe. More information at…

Consultation response

Bellona Europa, 18 Nov 2021

Bellona considers that the Refuel EU strategy fails to ensure that the aviation sector pull its weight when it comes to climate action. In fact, the proposed solutions for the sector to decarbonise are likely to increase emissions since there are no safeguards in place to prevent perverse outcomes.…

Consultation response

European Cockpit Association, 21 Apr 2020

ECA is the representative body of European pilot associations, representing 40.000 pilots from across Europe. More info about ECA at www.eurocockpit.be. ECA fully supports a common European policy to incentivise and use Sustainable Aviation Fuels (SAF) for the mid- to long-term. SAF will…

Consultation response

Bellona Europa, 21 Apr 2020

Reducing greenhouse gas emissions in a growing sector such as aviation is becoming increasingly important. While some advanced biofuels (renewable and waste derived) and electro-fuels can reduce emissions in the aviation sector, their use can also lead to an adverse effect. Bellona supports the…

Consultation response

Landwirtschaftskammer Österreich, 18 Nov 2021

Grundsätzlich werden die Überlegungen der Europäischen Kommission, den Flugverkehr nachhaltiger zu gestalten und in diesem Zusammenhang insbesondere ein Beimischungsgebot für nachhaltige Flugkraftstoffe, unterstützt. Allerdings empfehlen wir auf Kraftstoffe zu setzen, die auch in der benötigten…

Consultation response

MOL Hungarian Oil and Gas Company, 18 Nov 2021

MOL Group has a strong ambition to make improvements in its operations that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030. The…

Consultation response

Enagás S.A., 18 Nov 2021

Air transportation is an increasingly growing industry; it became a backbone of citizen’s mobility across borders and central asset for local businesses like tourism, from which several regions depend upon. With the coming of just-in-time logistics, aviation now also plays a key role on agile…

Consultation response

Airlines for America, 21 Apr 2020

Please see the attached document from Nancy Young, Vice President-Environmental Affairs, Airlines for America, that includes our feedback regarding the Sustainable Aviation Fuels Roadmap. Thank you for your attention to these comments.

Consultation response

General Aviation Manufacturers Association, 18 Nov 2021

Dear Madam or Sir Please find attached GAMA’s feedback on the Sustainable aviation fuels – ReFuelEU Aviation. Please feel free to contact me, should you require any additional information or have any questions. Best regards Raphaël Fabian Raphaël R. FABIAN Director, European Affairs

Consultation response

European Regions Airline Association Ltd., 21 Apr 2020

ERA (European Regions Airline Association) is the trade association representing more than 50 airlines and 150 associate members, including manufacturers, airports, suppliers and aviation service providers, across the entire spectrum of the aviation industry. The power of one collective voice,…

Consultation response

General Aviation Manufacturers Association, 17 Apr 2020

Dear Madam or Sir We hope this note finds you, your colleagues and families in good health in these peculiar times. Please find in the attached PDF file GAMA's feedback on the ReFuelEU Aviation Initiative Roadmap. Should you require additional information or discuss any of our comments, please…

Consultation response

Commissariat à l'Energie atomique et aux énergies alternatives, 19 Apr 2020

Le CEA est un organisme de recherche public spécialisé dans les énergies bas-carbone, le cycle du carbone et l’étude du climat. Il soutient sans réserve l’objectif de neutralité climatique pour 2050. Cela passera par une réduction drastique des émissions de gaz à effet de serre dans tous les…

Consultation response

Rolls-Royce plc, 17 Nov 2021

Rolls-Royce: Rolls-Royce pioneers the power that matters to connect, power and protect society. For nearly three decades, our family of turbofan aircraft engines have continued to push the boundaries of what is possible, as each new model sets new performance benchmarks for civil…

Consultation response

Global Business Travel Association, 15 Nov 2021

Business travel is fundamental to the world economy and brings many benefits in terms of international connections and wealth creation. However, climate change is a global threat and responsible governments, industries and corporations must continue to work together to reduce carbon emissions and…

Consultation response

Rolls-Royce plc, 21 Apr 2020

Use of sustainable aviation fuels is the quickest way to reduce the aviation industry’s carbon footprint today. Rapid scale-up in production of SAF, alongside other aviation developments, will be required if aviation is to meet its 2050 decarbonisation goals; at Rolls-Royce we believe SAF will be…

Consultation response

International Council on Clean Transportation, 18 Nov 2021

The International Council on Clean Transportation (ICCT) welcomes the opportunity to provide comments on the Commission’s proposed ReFuel EU Aviation regulation. We commend the Commission for its continuing efforts to promote a cleaner, lower-carbon transportation sector that uses less…

Consultation response

International Council on Clean Transportation, 21 Apr 2020

The International Council on Clean Transportation (ICCT) welcomes the opportunity to provide comments on the inception impact assessment for the ReFuelEU Aviation Initiative. The Commission’s suggestion in the roadmap that food and feed-based fuels have limited potential for decarbonization is…

Consultation response

European Producers Union of Renewable Ethanol, 30 Sept 2021

The European Commission’s Fit for 55 package sets important new goals for emissions reduction in transport. Giving a prominent role to renewable liquid fuels would create a solid foundation for reaching them. To that end, the EU should fully maximise the tools it has on hand for decarbonisation and…

Consultation response

European Producers Union of Renewable Ethanol, 16 Apr 2020

ePURE, representing the European producers of renewable ethanol from crops, waste and residues, welcomes the publication of the Inception Impact Assessment (IIA) on the ReFuelEU Aviation initiative and the opportunity to provide feedback. ePURE supports the Commission’s intention to consider…

Consultation response

Deutsches Verkehrsforum, 18 Nov 2021

Die Rückmeldung des Deutschen Verkehrsforums (DVF) ist als Anlage beigefügt.

Consultation response

Advanced Biofuels Coalition, 21 Apr 2020

The Advanced Biofuels Coalition (LSB) welcomes the opportunity to provide comments to the inception impact assessment on ReFuelEU Aviation and the promotion of sustainable aviation fuels (SAF) in the EU. LSB recognizes the need to reduce CO2 emissions in all transport modes and therefore supports…

Consultation response

Związek Pracodawców Business & Science Poland, 18 Nov 2021

Business and Science Poland welcomes the possibility to comment on the proposed Regulation on ensuring a level playing field for sustainable air transport (RefuelEU Aviation). Please find attached our feedback for your consideration.

Consultation response

Arbeitsgemeinschaft Deutscher Verkehrsflughäfen, 21 Apr 2020

The German Airports Association ADV welcomes the opportunity to comment on the European Commission’s initiative “ReFuelEU Aviation – Sustainable Aviation Fuels”. Please find enclosed our submission. ADV

Consultation response

Novozymes, 18 Nov 2021

Novozymes welcomes the Commission’s proposal to implement dedicated legislations for the decarbonization of aviation through sustainable renewable fuels but strongly objects to the decision to exclude or penalize biofuels produced from food and feed crops. The ReFuelEU Aviation regulation proposal…

Consultation response

Verband der Deutschen Biokraftstoffindustrie, 8 Nov 2021

Please find attached our comments on the initiative.

Consultation response

Verband der Deutschen Biokraftstoffindustrie, 21 Apr 2020

Addressing climate protection in the field of aviation is an excellent initiative of the European Commission. So far, this mode of transport has contributed virtually nothing to decarbonising Europe. This is mainly due to a lack of regulation. In order to reduce GHG emissions in aviation…

Consultation response

Bundesverband der Deutschen Luft- und Raumfahrtindustrie e. V., 20 Apr 2020

Comment of BDLI German Aerospace Industries Association 1/ The global market launch of SAF is essential for the sustainable development of aviation in accordance with internationally agreed CO2 reduction targets. The connection between global air traffic growth and a positively developing global…

Consultation response

Bundesverband der Deutschen Luftverkehrswirtschaft e. V., 1 Nov 2021

Replacing fossil kerosene with SAF is the decisive lever to achieve the goal of CO2-neutral flying. A binding blending quota can help accelerate the market ramp-up of SAF/PtL, therefore the aviation industry welcomes the Commission’s approach as a boost for the SAF market. The ecologically best…

Consultation response

Bundesverband der Deutschen Luftverkehrswirtschaft e. V., 21 Apr 2020

Position of the German Aviation Association (Bundesverband der Deutschen Luftverkehrswirtschaft | BDL) The German Aviation Association very much welcomes the initiative “ReFuelEU Aviation – Sustainable Aviation Fuels” of the European Commission. In addition to the UN aviation organization ICAO,…

Consultation response

CO2 Value Europe AISBL, 18 Nov 2021

CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (‘CCU’) and represents over 70 members along the CCU value chain, primarily industrial actors from different sectors. CCU is a broad term that covers all established and innovative industrial processes that…

Consultation response

EUROPEAN BUSINESS AVIATION ASSOCIATION, 18 Nov 2021

Building a fair and inclusive SAF framework ensuring a level playing field for business aviation (more details in the attached position paper) The business aviation community understands that a serious and credible legislative proposal aiming at increasing the uptake of SAF in Europe has to be…

Consultation response

CO2 Value Europe AISBL, 21 Apr 2020

CO2 Value Europe (CVE) is the European association dedicated to Carbon Capture and Utilisation (CCU) and is representing over 65 members from different sectors along the CCU value chain. CVE welcomes the European Commission ReFuelEU initiative to curb CO2 emissions in aviation by promoting the…

Consultation response

St1 Nordic Oy, 21 Apr 2020

St1 welcomes the EU’s Green Deal and supports the target to achieve climate neutrality in the EU by 2050. Even though the length, depth and the recovery profile of COVID19 caused reduction in the aviation activity level is not known yet, it is fair to assume that it will reach and surpass the…

Consultation response

ZERO - ASSOCIAÇÃO SISTEMA TERRESTRE SUSTENTÁVEL, 21 Apr 2020

ZERO supports the introduction of a mandatory incorporation of advanced fuels into the aviation sector, however this should only be advanced if it brings a clear environmental benefit. It´s important the exclusion of food & feed crops and waste-based fossil fuels, key safeguards to ensure that the…

Consultation response

EWABA, 18 Nov 2021

Many thanks for this opportunity to comment on the ReFuelEU Aviation proposal. Please find EWABA remarks in the attached document.

Consultation response

Europeans for Fair Competition, 17 Nov 2021

The proposed ReFuelEU Aviation Regulation aims to increase the production and uptake of SAFs in Europe in the coming years. For the foreseeable future, however, SAF will be more expensive than fossil fuels. Therefore, an unbalanced SAF mandate would distort competition with the rest of the world…

Consultation response

EWABA, 7 Apr 2020

Many thanks for the opportunity to comment on this policy initiative. EWABA represents 28 corporate members including 21 waste-based biodiesel producing companies with 30 operative production facilities in Europe transforming used cooking oil (UCO) and animal fats into waste-based biodiesel. In…

Airline group AIRE demands delay to sustainable fuel mandates

Airlines International Representation in Europe, 17 Nov 2021

AIRE calls for delaying the 2% sustainable fuel target until 2030. They want synthetic fuel requirements to be optional for member states. The organization also rejects proposed taxes on aviation fuel and tickets.
Lowering these targets would protect airlines from surging operating costs and competitive disadvantages.
European travelers and the tourism industry face higher costs and reduced mobility.

Consultation response

Equilibre des Energies, 4 Nov 2021

Substituting fossil kerosene for Sustainable Aviation Fuels (SAF) can lead to significant GHG emission reductions in the relatively short term but the development of SAF is hampered by several obstacles: • Insufficient maturity in terms of industrial development, lack of investment in production…

Consultation response

Confédération Européenne de la Production de Maïs, 18 Nov 2021

CEPM wishes to transmit its comments on various texts proposed in the “fit for 55” package. In general, CEPM regrets that the contribution of crop based biofuels, including corn bioethanol, is not better supported. CEPM requests that the role of these biofuels be improved, and that it is reflected…

Consultation response

European Network Airlines' Association, 18 Nov 2021

As the association of the network carriers of the European Union, ACP firmly supports the ambitions laid down in the Fit for 55 package and its objective to become CO2 neutral by 2050. ACP is committed to sensible environmental legislation, a better integration into a European transport network,…

Consultation response

LanzaTech EU B.V, 17 Nov 2021

LanzaTech commends the European Commission for its consideration of policies in support of aviation greenhouse gas reductions and increased supply and offtake of sustainable aviation fuels in the EU. We welcome the opportunity to respond to the EU Commission’s proposal, and we look forward to…

Consultation response

Vereniging Milieudefensie, 20 Apr 2020

Milieudefensie - Friends of the Earth Netherlands welcomes the opportunity to give feedback on the inception impact assessment of the ReFuelEU Aviation initiative. Milieudefensie supports the objective to reduce the environmental footprint of the aviation sector. To bring the sector in line with…

Consultation response

LanzaTech EU B.V, 20 Apr 2020

We support the EU-SAF Blending Mandate with recommendations: a) Should come into force after min. of 3 years to enable implementation of commercial SAF projects and to allow airlines, airports, and other stakeholders time to prepare. b) To be effective, the cost of non-compliance should exceed…

Consultation response

France Hydrogène, 4 Nov 2021

France Hydrogène welcomes the initiative Refuel Aviation whose goal is to support the uptake of renewable fuels in the air transport. Either with fuel cells or H2 turbines, hydrogen-powered aircraft are not directly targeted by the Regulation as they are considered insufficiently mature…

Consultation response

Enerkem Incorporated, 21 Apr 2020

Enerkem welcomes the opportunity to provide the following comments regarding the Objectives and Policy Options put forward in the Inception Impact Assessment (IIA) of the European Commission to enable a supportive policy environment for an increase in the production and offtake of Sustainable…

Consultation response

Groupe Avril, 21 Apr 2020

Avril fully supports the Sustainable aviation fuel initiative. As CO2 emissions by commercial flights rose by 32% from 2013 to 2018 and in line with Green Deal objectives of reducing transport emissions by 90%, sustainable biofuels should be used for the decarbonisation of the aviation sector.…

Consultation response

Bioenergia ry - Bioenergy Association of Finland, 20 Apr 2020

We appreciate this important initiative on sustainable aviation fuels (SAF) and the opportunity to comment. This initiative will help to achieve reductions in GHG emissions from aviation. The use of SAFs present an immediate solution with significant reduction potential. The wide-spread use of…

Consultation response

Carbon Engineering ULC, 18 Nov 2021

Carbon Engineering's response is attached.

Consultation response

Gevo, Inc., 20 Apr 2020

Gevo welcomes the ReFuelEU Aviation initiative. Gevo is one of the few companies in the world that has worked towards producing a renewable feedstock called isobutanol for the production of sustainable low-emission fuels like gasoline, kerosene (SAF), diesel or chemicals for building a bio-based…

Consultation response

Preem AB, 21 Apr 2020

The European Commission's presentation of the European Green Deal has raised the need for new policies within the EU, in order to realize the joint climate goals and ambitions. Within the framework of the upcoming Strategy for Sustainable and Smart Mobility, the Commission has stressed the…

Consultation response

FincoEnergies B.V., 18 Nov 2021

FinCo Fuel Group position on ReFuelEU Aviation We appreciate the EU’s efforts in leading the energy transition and, besides road transport, now also tackling GHG emissions in both the maritime and aviation sector. Given the cross-border nature of those sectors, it is the right approach to address…

Consultation response

Iogen Corporation, 8 Nov 2021

Iogen Corporation supports “Fit for 55”, the transformational changes that are required to achieve the EU’s 2030 decarbonisation goals and climate-neutrality by 2050. Indeed, we as a company are fully dedicated to using our world-leading advanced biofuels technologies to develop deep…

Consultation response

Environmental Defense Fund, Incorporated, 21 Apr 2020

Environmental Defense Fund (EDF) welcomes the opportunity to comment on the EC’s plans to incentivize sustainable aviation fuels (SAF). The European Commission should only propose a quantitative SAF mandate if it incorporates a robust sustainability and accounting framework that addresses flaws in…

Consultation response

Münzer Bioindustrie GmbH, 21 Apr 2020

Muenzer Bioindustrie GmbH produces UCO-based biodiesel in Austria. We employ 250 and in 2019 we produced about 210.000 t of UCO-based biodiesel with GHG reductions higher than 90 %. We are proud to make an important contribution to reducing GHG emissions of EU road transport. The Commission’s…

Consultation response

FUNDACIÓN ECOLOGÍA Y DESARROLLO, 18 Nov 2021

ECODES (Fundación Ecología y Desarrollo), agradece a la Comisión Europea la oportunidad de comentar la propuesta de modificaciones del reglamento para combustibles sostenibles para la aviación ReFuelEU. ECODES es una organización independiente sin ánimo de lucro que busca acelerar la transición a…

Consultation response

Mittelstandsverband abfallbasierter Kraftstoffe e.V. (Waste-based Fuels Association), 18 Nov 2021

The MVaK represents 21 members which pretreat suitable vegetable waste and residues, mainly used cooking oil and waste fatty acids, process them into waste-based biodiesel or trade feedstocks and finished products. Biodiesel cannot be used in aviation due to its cold flow properties but it is a…

Consultation response

Advisory Council for Aviation Research and Innovation in Europe, 18 Nov 2021

This feedback is sent in on behalf of the Advisory Council for Aviation Research and innovation in Europe (ACARE). ACARE provides a network for strategic research in aeronautics and air transport so that aviation satisfies the needs of society and secures global leadership for Europe in this…

Consultation response

2030 sekretariatet, 15 Nov 2021

The sustainability debate for aviation is quite recent, and it is welcome to see a stronger sustainability focus on aviation. The RefuelAviation Directive is an important step. The RefuelAviation Directive is one of two new directives with a focus on strategic parts of the transport sector and are…

Consultation response

Brazilian Sugarcane and Bioenergy Industry Association, 21 Apr 2020

The Brazilian Sugarcane Industry Association, UNICA, welcomes the publication of the Inception Impact Assessment on ReFuel EU Aviation and the opportunity to comment on decarbonisation pathways for the aviation sector.

 The global aviation industry has set a goal of carbon-neutral growth and aims…

Consultation response

Mittelstandsverband abfallbasierter Kraftstoffe e.V. (Waste-based Fuels Association), 20 Apr 2020

The Mittelstandsverband abfallbasierter Kraftstoffe e.V. (MVaK) is a Berlin based association representing 22 medium-sized members along the value chain of waste-based biodiesel production in Germany, Austria and The Netherlands. The Commission’s Inception Impact Assessment (IIA) “ReFuelEU…

Consultation response

Association of Industry, Agriculture and Services, 20 Apr 2020

Dear all, Thank you very much for the opportunity to comment on this policy initiative. I`m writing you on behalf of Envien Group, the biggest Central and Eastern European biofuels holding with production facilities in Slovakia, Czech Republic, Hungary and Croatia. Our group currently employs…

Consultation response

GoodFuels, 18 Nov 2021

GoodFuels position on ReFuelEU Aviation. We appreciate the EU’s efforts in leading the energy transition and, besides road transport, now also tackling GHG emissions in both the maritime and aviation sector. Given the cross-border nature of those sectors, it is the right approach to address its…

Consultation response

, 18 Nov 2021

The Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. VDMA represents around 3300 German and European companies in the mechanical engineering industry. The industry represents innovation, export orientation, medium-sized companies and employs around…

Consultation response

Condor Flugdienst, 18 Nov 2021

Replacing fossil kerosene with SAF is the decisive lever to achieve the goal of CO2-neutral flying. A binding blending quota can help accelerate the market ramp-up of SAF/PtL, therefore Condor Flugdienst welcomes the Commission’s approach as a boost for the SAF market. The ecologically best…

Consultation response

Svenska Flygbranschen, 18 Nov 2021

Please find enclosed the comments by Svenska Flygbranschen (Swedish Aviation Industry Group (SAIG)) to the consultation ReFuelEU Aviation. Best regards, Fredrik Kämpfe, Director Industry Affairs Svenska Flygbranschen

Consultation response

Aviation Initiative for Renewable Energy in Germany e.V., 16 Nov 2021

Wir halten die Beimischungsquote für ein wirksames Instrument zur Förderung nachhaltiger Flugkraftstoffe. Um die Klimawirkung des Luftverkehrs weiter zu verringern und den Markthochlauf von SAF zu begünstigen, setzen wir uns für eine Erhöhung der Quote auf 10% in 2030 und der PtL-Subquote auf 2% in…

Consultation response

, 21 Apr 2020

The German Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. VDMA represents more than 3.300 member companies in the SME-dominated mechanical engineering industry in Germany and Europe. The major players in a Power-to-X (P2X) value chain are…

Consultation response

Bundesvereinigung gegen Fluglärm, 21 Apr 2020

Aviation is an industry with high greenhouse gas emissions (CO2, NOx and other harmful substances) . The share of air traffic of the CO2-emissions is about 2.4% [1]. But the total greenhouse impact is about 3-times higher. It is forecasted that air traffic will grow further with an annual rate of…

Consultation response

Svenska Flygbranschen, 21 Apr 2020

Yttrande över konsultation om ReFuelEU Svenska Flygbranschen (SFB) är ett bransch- och arbetsgivarförbund inom Transportföretagen. Vi har cirka 90 medlemsföretag med omkring 9400 anställda. Våra medlemsföretag representerar flygbolag, flygtrafikledning, flygplatser, flygskolor, service och…

Consultation response

Greenergy International Limited, 21 Apr 2020

Attached is our response on behalf of the Greenergy Group

Consultation response

Fulcrum BioEnergy Limited, 21 Apr 2020

Please find our Feedback in the attached document

Consultation response

Velocys Limited, 20 Apr 2020

Velocys, the sustainable fuels technology company, enables the production of sustainable aviation fuels (SAF) from municipal solid waste and waste woody biomass using the Fischer-Tropsch (FT) route. Our planned Altalto project in the UK is expected to be the first commercial solid-waste-to-fuels…

Consultation response

Cerulogy, 6 Apr 2020

The ReFuelEU inception impact assessment is a solid starting point to raise EU ambition on alternative aviation fuel. The document correctly states the nature of the challenge, and that the priority at the moment is to support the early stage roll out of advanced SAF production. The easiest…