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Rules for calculating price difference to kerosene and for EU ETS allocation of allowances for the use of eligible fuels

Climate action

Article 3c(6) of Directive 2003/87/EC establishes a support mechanism for actual use of eligible aviation fuels. The same article requires the Commission to establish the detailed rules for calculating each year the difference between the cost of eligible aviation fuels and fossil kerosene, in order to allocate allowances for the use of these eligible fuels, and also to define the rules for this allocation.

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Public consultation

ID: 14020

Lobbying Activity

20 responses

T&E calls for dedicated e-kerosene support in fuel rules

Transport and Environment (European Federation for Transport and Environment), 6 Jan 2025

The group requests a dedicated 'basket' of allowances for e-kerosene to ensure it receives sufficient support. They also call for measures to foster long-term offtake agreements and de-risk production for investors.
This prioritization ensures the implementation of the long-term aviation decarbonization strategy they promote.
Biofuel producers lose subsidies as the group labels their products prone to fraud.

Airbus urges immediate extension and better rules for SAF allowances

Airbus, 5 Jan 2025

Airbus asks to include logistics costs like blending and storage in price calculations. They request extending the subsidy period to 2034 to ensure investment certainty. They also urge simplifying reporting to avoid extra administrative work.
This would lower financial barriers for aircraft operators and stabilize long-term green investments.
Governments lose auction revenue when more free allowances are granted to the aviation sector.

EDF Demands Equal Subsidies for Low-Carbon Aviation Fuels

ELECTRICITE DE FRANCE, 6 Jan 2025

EDF requests that support for non-fossil low-carbon fuels be set at 95%. They argue these fuels share identical emission reductions and similar cost structures.
Higher subsidies would help EDF bridge the production cost gap with conventional fuels.
Conventional kerosene producers lose their market advantage as sustainable alternatives become more competitive.

Fuel Industry Urges Extension of Aviation Fuel Support Mechanism

FuelsEurope, 31 Dec 2024

The organization requests extending the support mechanism beyond 2030 to enable long-term investment decisions. They argue the current 20 million allowance budget ending in 2030 cannot bridge the price gap between fossil kerosene and sustainable aviation fuels over the typical 10-15 year asset amortization period. They also seek safeguards against antitrust risks and inclusion of co-processed RFNBO fuels at 95% support levels.
This would provide revenue certainty for 10-15 year fuel supply contracts and production facility investments.
Taxpayers fund extended subsidies for an industry bridging to commercially viable sustainable fuel production.

Hydrogen Europe urges full price coverage for aviation e-fuels

Hydrogen Europe, 6 Jan 2025

The group proposes focusing support on fuels with the greatest environmental potential, specifically hydrogen and e-fuels. They request increasing price difference coverage to 100% to offset high production costs. They also suggest extending support until 2034 to provide long-term market predictability.
These measures would reduce financial risks and lower costs for hydrogen fuel producers.
Producers of less sustainable biofuels may lose market share to more subsidized hydrogen-based fuels.

DHL Group seeks clearer rules for aviation fuel allowances

DHL Group, 6 Jan 2025

DHL Group requests a streamlined reporting process via the Union Database and better interoperability. They seek clarity on the allocation timeline and suggest extending allowance volume and duration.
Greater planning security for e-fuels projects and a smoother reporting process for operators.

Airlines for Europe criticizes proposed EU sustainable aviation fuel allowance scheme

Airlines for Europe, 6 Jan 2025

A4E requests revisions to SAF price calculation methodology, including allowing airline-reported prices for all fuel types and increasing the 10% margin for minimum selling prices. They seek clearer confidentiality guarantees for price data and removal of requirements to communicate EU support on passenger tickets.
This would better reflect their actual SAF costs and reduce compliance burdens.
Transparency advocates lose as airlines seek confidentiality protections that could limit public oversight.

IATA urges higher profit margins for green aviation fuels

International Air Transport Association, 4 Jan 2025

IATA argues that the hurdle rate for price calculations should exceed 10%. They claim green fuel projects face higher technological risks than electricity generation. The group also requests clarity on market representativeness for fuel prices.
This would allow airlines to claim more free allowances for fuel costs.
The EU budget loses revenue when airlines are granted more free allowances.

Air France-KLM demands clarity on aviation fuel subsidy rules

Air France-KLM, 6 Jan 2025

Air France-KLM requests clarification on fuel price reporting and stricter confidentiality for data. They propose that Member States complete fuel subsidy allocations within two weeks.
These changes would protect commercial secrets and speed up the distribution of subsidies.
National regulators may struggle to meet the proposed two-week deadline for administrative actions.

BP Urges EU to Drop Co-Processed Fuel Categories

BP p.l.c., 6 Jan 2025

BP requests removal of separate subcategories for co-processed fuels. They argue co-processed biofuels should be included in existing categories based on feedstock type, not production pathway. The company emphasizes there is no technical or market basis for this distinction.
This would reduce bureaucratic burden and align treatment with their existing co-processing operations.

eFuel Alliance urges long-term support for synthetic aviation fuels

eFuel Alliance, 6 Jan 2025

The Alliance demands the rules be finalized swiftly to provide necessary regulatory clarity. They call for the mechanism to be developed into a more long-term, reliable instrument.
Extended support would ensure the long-term economic feasibility of expensive synthetic fuel production.
Global competitors lose their price advantage over European airlines burdened by climate legislation.

German aviation body seeks fairer sustainable fuel pricing rules

Bundesverband der Deutschen Luftverkehrswirtschaft e. V., 18 Dec 2024

The association seeks a full-service price definition and a lower deviation threshold for reporting. They also request clarification on currency exchange rates and the official start date.
This would ensure that subsidies cover the actual costs of purchasing sustainable fuels.
The EU's climate budget would decrease as more free allowances are granted to airlines.

CO2 Value Europe urges faster support for synthetic aviation fuels

CO2 Value Europe AISBL, 6 Jan 2025

The association requests swift implementation of the support system to boost e-kerosene investments. They demand that recycled carbon fuels be included to align with existing aviation mandates.
This support would help developers secure long-term contracts and scale up e-kerosene production.
Producers of recycled carbon fuels face exclusion from financial support compared to competitors.

Consultation response

SkyNRG B.V., 6 Jan 2025

SkyNRG welcomes the draft proposal on the delegated act to supplement the Directive 2003/87/EC (EU ETS), laying down detailed rules for the yearly calculation of price differences between eligible aviation fuels and fossil kerosene, and for the EU ETS allocation of allowances for the use of…

EdEn demands transparent pricing and equal subsidies for aviation fuels

Equilibre des Energies, 6 Jan 2025

The organization recommends that the methodology used to define the price of sustainable fuels be made public. They also call for ensuring a level-playing field between synthetic aviation fuels and low-carbon variants regarding allowance allocations.
This would allow their members to secure higher subsidies by accounting for actual logistics and certification costs.
The environment and air transport decarbonisation suffer if low-carbon fuel production becomes uncompetitive.

Consultation response

Polskie Linie Lotnicze "LOT" S.A., 19 Dec 2024

LOT Polish Airlines appreciates the opportunity to provide feedback to the public consultation. Please see our comments in the attachment.

Consultation response

Verso Energy, 6 Jan 2025

Please find bellow, Verso Energy's contribution.

Consultation response

, 3 Jan 2025

In allegato il contributo Unem - Unione Energie per la Mobilità che contiene raccomandazioni che riteniamo importanti per creare un ecosistema favorevole alla crescita dei carburanti sostenibili per laviazione. Con un meccanismo esteso, criteri di prezzo trasparenti, supporto mirato ai carburanti…

Consultation response

Opportunity Green, 2 Jan 2025

We welcome the planned introduction of 20 million allowances to be allocated to support the uptake of alternative fuels to drive aviation decarbonisation. The ReFuelEU Aviation regulation puts in place a clear framework that supports the vital role that alternative fuels will play in reaching EU…

Consultation response

bse Methanol GmbH, 27 Dec 2024

The bse Methanol supports the initiative of the European Commission on Aviation fuels & emissions trading calculating the price difference between eligible fuels and kerosene (detailed rules). See enclosed detailed Support Letter.