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Aerospace, Security and Defence Industries Association of Europe

ASD

ASD represents the European aeronautics, space, defence, and security industries to promote their competitiveness.

Lobbying Activity

Aerospace group ASD demands funding for Advanced Materials Act

13 Jan 2026
Topic — A consultation regarding EU legislation to strengthen research and production of advanced materials.
Message — ASD requests dedicated funding for aerospace projects and streamlined "fast-track" certification for new materials. They also advocate for investments in European recycling infrastructure rather than scrap export bans.12
Why — These measures would reduce the high cost of innovative materials and accelerate technology deployment.3
Impact — International recycling markets lose access to valuable waste as Europe prioritizes domestic sovereign chains.4
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Aerospace industry demands exemptions for flame-retardant chemical use

19 Dec 2025
Topic — EU proposal to restrict medium-chain chlorinated paraffins under the Persistent Organic Pollutants Regulation.
Message — ASD requests aligning EU rules with international standards to exempt specific aerospace adhesives and sealants. They seek a pragmatic approach for newly identified supply chain uses and broader exemptions for spare parts.12
Why — This allows companies to ensure aircraft safety and avoid the high costs of retiring equipment prematurely.34
Impact — Environmental health is harmed by the continued use of persistent pollutants in large-scale industrial manufacturing.5
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Meeting with Paraskevi Papantoniou (Head of Unit Defence Industry and Space)

10 Dec 2025 · Exchange of views on the revision of the Defence Procurement Directive (Directive 2009/81/EC)

ASD Urges EU to Simplify Taxonomy Chemical Safety Rules

5 Dec 2025
Topic — The European Commission is reviewing technical criteria for the EU environmental taxonomy.
Message — ASD calls for aligning chemical safety criteria with existing EU regulations to ensure feasibility. They also want business aviation included and aircraft component replacement rules relaxed.12
Why — These changes would reduce reporting burdens and prevent inconsistent audits of sustainable activities.34
Impact — Financial markets lose visibility on hazardous substances that exceed standard EU regulatory requirements.5
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Meeting with Christophe Grudler (Member of the European Parliament)

2 Dec 2025 · Politique aéronautique européenne

Meeting with Filip Cornelis (Director Mobility and Transport) and

27 Nov 2025 · Structured Dialogue meeting, focusing on current policy developments in aviation, and suggested recommendations from airline industry

Aerospace Industry Demands Ring-Fenced Aviation Budget in EU Framework

12 Nov 2025
Topic — EU's post-2027 Multiannual Financial Framework and competitiveness funding architecture.
Message — The association requests dedicated sector-specific funding of €23.5 billion for civil aviation with ring-fenced budgets for Clean Aviation and SESAR partnerships. They demand clarity on governance structures, keeping aviation programmes separate, and opposing mandatory cash contributions over in-kind support.1234
Why — This would secure predictable long-term funding for their technology development programs and avoid cash requirements.56
Impact — Smaller research areas lose if aviation secures disproportionate ring-fenced allocations from flexible budgets.7
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Meeting with Manuel Mateo Goyet (Acting Head of Unit Communications Networks, Content and Technology)

10 Nov 2025 · Exchange of views on the Cloud and AI Development Act

Aerospace Industry Urges Exemption from Mandatory Recycling Content Targets

6 Nov 2025
Topic — EU Circular Economy Act aims to boost recycled materials and circular business models.
Message — The industry requests sector-specific exemptions from mandatory recycled content targets and recognition of repair-as-produced principles. They seek harmonised EU-wide End-of-Waste criteria for critical materials and robust exemptions protecting defence confidentiality from digital traceability requirements.1234
Why — This would allow continued use of novel lightweight materials without costly recertification processes.567
Impact — Environmental groups lose stronger circularity requirements that would increase recycled material use in aerospace.8
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Meeting with Anne Fort (Cabinet of Commissioner Andrius Kubilius)

1 Oct 2025 · Presentation of activities of ADS in 2026

Meeting with Nicolas Bessot (Head of Unit Migration and Home Affairs)

24 Sept 2025 · Exchange of views in the internal security funding structure under the new Commission MFF proposal

Meeting with Cathrin Bauer-Bulst (Cabinet of Commissioner Magnus Brunner)

22 Sept 2025 · Security industry policy

Meeting with Christine Berg (Head of Unit Mobility and Transport) and Airbus

15 Sept 2025 · Halon replacement for cargo compartments (safety of civil aviation point of view)

Response to EU industrial maritime strategy

28 Jul 2025

The EU needs the ability to produce naval and dual-use assets that Member States may require during a conflict. To achieve its strategic autonomy, it is crucial to enhance the competitiveness, innovation and transformation of the European naval shipbuilding industry, so that it is able to compete globally. The link between the naval and civilian maritime industries makes exploiting the duality of the ecosystem the only realistic and economically viable way to ensure that the EU defence needs in the naval domain are met. As part of this approach, Europe must focus on investing where it is indispensable, supporting the development of critical technologies and focusing EU funding on a selected pool of capabilities and infrastructures. ASD suggests tackling in the strategy the following points of interest: -The synergies and challenges in civil and military shipbuilding: when it comes to innovation, coherence across military and civilian R&D funding programs would optimise investment, avoid duplication of efforts, and maximise the transfer of technology. Most civilian vessels can be considered as strategic sealift and support assets that can be used for military purposes if needed. -The supply chain interdependence between civil and naval production lines: Europe needs the capacity to autonomously manufacture critical defence products, with its own technology and without dependences on third countries. To achieve this, a strong maritime industrial sector that supports defence shipbuilding activity is indispensable. Without civilian ship production generating a minimum demand, European maritime equipment manufacturers will disappear and military ship production will be forced to install equipment made outside of Europe. Addressing the relocation of equipment manufacturing requires an ambitious, forward-looking industrial strategy, following a dual track approach and partnering with countries based on shared standards and aligned strategic interests. -The specific requirements in the naval defence industrys energy and ecological transitions: differing and uncoordinated national approaches on how to progress with the green transition of fleets could become a risk for the interoperability of European navies. The defence sector faces more challenges than the civilian one, as not all the technological solutions currently considered to reach net-zero emissions can be applied to naval vessels. To ensure the operational capability of the fleet, the vessels must remain able to operate broadly available fuels. Similarly, the pursue of a circular economy and eco-design of naval products should consider the difficulty of achieving goals if there is only small-scale production. -Innovation in production processes and industrialization of technological developments: there needs to support for both R&D and product industrialization. Without the latter, there is a risk that technological development will be not translated into useful European capabilities or will be lost to foreign competition. The EU Industrial Maritime Strategy should define dedicated actions to support the profound change in materials and production processes associated with this evolution. -The production capacity of defence shipbuilding in response to ramp-up demands: responding to immediate demands to adapt production in situations of conflict or threat will imply expanding, upgrading, and re-purposing production plants; establishing emergency stocks of critical materials or components; and addressing how to handle a great increase in demand for workforce. -The training plan: there is a mutual dependence in terms of skills, training, and labour mobility. The industry's transformation requires adequate training process, both for attracting new personnel and for reskilling the current workforce, guaranteeing the quantity and quality of the staff. We kindly request that you refer to the attachment for the full list of research, arguments, and recommendations.
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Meeting with José Cepeda (Member of the European Parliament)

16 Jul 2025 · Priorities current term

ASD Urges Dedicated EU Funding Stream for Aviation Decarbonisation

8 Jul 2025
Topic — Evaluation of the EU Innovation Fund operations regarding climate action and industrial decarbonisation.
Message — ASD calls for a dedicated aviation funding window and bonus points for sectoral projects. They propose adapting eligibility rules to account for long-term aircraft development and fleet-level emissions.12
Why — Tailored criteria would help the sector overcome high investment hurdles for new technologies.3
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ASD urges global aviation rules and earmarked ETS funding

8 Jul 2025
Topic — The European Commission is reviewing rules for emissions trading across multiple industrial sectors.
Message — ASD recommends a global approach via ICAO-CORSIA to avoid international trade conflicts. They request that ETS revenues be earmarked for aviation and the Innovation Fund be adapted.12
Why — This strategy avoids international retaliation while securing massive subsidies for the sector's green transition.34
Impact — Other industrial sectors may face reduced funding if ETS revenues are ring-fenced for aviation.5
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Meeting with Herald Ruijters (Deputy Director-General Defence Industry and Space)

2 Jul 2025 · SAFE

ASD calls for 'High+' cloud security standards in EU law

19 Jun 2025
Topic — Revision of the EU Cybersecurity Act focusing on ENISA's mandate and certification schemes.
Message — ASD calls for clearly defined responsibilities between EU agencies to prevent overlapping functions. They advocate for 'High+' cloud criteria to protect sensitive data from non-EU legal access.12
Why — Members benefit from a unified standard that protects industrial data and reduces fragmentation.3
Impact — Non-EU cloud providers lose market access for sensitive high-security government and industrial contracts.4
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Meeting with Simonas Satunas (Cabinet of Commissioner Andrius Kubilius)

18 Jun 2025 · Defence and space industry and policy developments

Meeting with Pierpaolo Settembri (Cabinet of Commissioner Apostolos Tzitzikostas)

2 Jun 2025 · Overview of a topical aviation issues ahead of the Paris Air Show

Meeting with Andrey Novakov (Member of the European Parliament)

14 May 2025 · Security and Defence

Meeting with Cathrin Bauer-Bulst (Cabinet of Commissioner Magnus Brunner)

8 Apr 2025 · Outreach to industry on the ProtectEU strategy

Meeting with Jan Hendrik Dopheide (Cabinet of Commissioner Maroš Šefčovič)

3 Apr 2025 · Introductory meeting / EU-UK relations in the field of security and defence

Meeting with Lucilla Sioli (Director Communications Networks, Content and Technology) and

2 Apr 2025 · Discussion on the AI Continent Action Plan and the Apply AI Strategy

ASD warns EU chemical rules are impossible to implement

26 Mar 2025
Topic — The European Commission is seeking to simplify reporting requirements for the EU sustainability taxonomy.
Message — ASD proposes replacing specific chemical bans with a general requirement to follow existing environmental laws. They claim current criteria are unrealistic and virtually impossible to implement for manufacturers.12
Why — This amendment would lower compliance barriers, helping companies finally demonstrate their activities are sustainable.3
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Meeting with Andrey Novakov (Member of the European Parliament)

13 Mar 2025 · Security and Defence

Meeting with Anne Fort (Cabinet of Commissioner Andrius Kubilius), Ramunas Stanionis (Cabinet of Commissioner Andrius Kubilius)

5 Mar 2025 · European defence industry action plan and flagships to face upcoming naval warfare challenges

Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

Please find attached the Aerospace, Security and Defence Industries Association of Europe (ASD) contribution to the consultation on the draft delegated act under Article 46(7) of the Net-Zero Industry Act (NZIA). ASD welcomes this opportunity to provide feedback and ensure the act effectively supports aviation decarbonisation. We appreciate the Commissions efforts in shaping a strong regulatory framework for net-zero technologies and remain committed to supporting policies that drive innovation and competitiveness in Europe. For further details, please refer to the attached document.
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Meeting with Andrius Kubilius (Commissioner)

16 Jan 2025 · White Paper on the Future of European Defence

Meeting with Valdis Dombrovskis (Executive Vice-President) and BUSINESSEUROPE and

10 Sept 2024 · Preventing the circumvention of EU sanctions on sensitive goods

Meeting with Mairead McGuinness (Commissioner) and

10 Sept 2024 · High-level executive roundtable: preventing the circumvention of EU sanctions on sensitive goods.

EU aerospace industry urges phased approach to non-CO2 reporting

29 Jul 2024
Topic — Update of EU rules for monitoring and reporting non-CO2 aviation emissions under the ETS.
Message — ASD recommends a phased implementation where reporting focuses on emissions data before calculating climate impacts in CO2 equivalents. They request that the NEATS tool be publicly available and developed through regular, transparent peer reviews involving industry and academia.12
Why — This prevents premature regulation based on uncertain models and secures funding for industry research.34
Impact — Climate advocates lose immediate transparency on the full global warming impact of flights.5
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Meeting with Aleksandra Baranska (Cabinet of Vice-President Maroš Šefčovič), Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

29 May 2024 · Net zero aviation

Meeting with Aleksandra Baranska (Cabinet of Vice-President Maroš Šefčovič), Dino Toljan (Cabinet of Vice-President Maroš Šefčovič) and

24 May 2024 · Book and claim system for Sustainable Aviation Fuels

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

5 Apr 2024 · Discussions on the implementation of the REACH regulation

Meeting with Adina-Ioana Vălean (Commissioner) and

30 Nov 2023 · Board meeting of ASD (Challenges and requirements for the upscale of SAF - International vs regional standards for the green transition (SAFs, carbon pricing, aircraft) - Accelerating the rollout of new technologies (green transition certification)

Response to Count your transport emissions: CountEmissions EU

15 Nov 2023

Comments are provided in document "CountEmissions EU_ASD Position Paper Final" (attached).
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Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

27 Sept 2023

ASD is the voice of European Aerospace, Security and Defence Industries, actively supporting the competitive development of the sector. It has direct members, active in 18 countries, including 22 major European companies and 23 National Associations representing over 4000 companies employing 879,000 people in Europe. As such, we are uniquely qualified to act as a single voice for the European AS&D sector, including on topics related to standardisation. As such we stand ready to provide our views and to support the European Commission in its review and potential evolution of Regulation (EU) 1025/2012.
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Meeting with Magda Kopczynska (Director-General Mobility and Transport)

18 Sept 2023 · State of play of the aeronautical industry; decarbonisation; R&I

EU Aerospace Industry Demands Strategic Status for Aviation Fuels

26 Jun 2023
Topic — Consultation on manufacturing capacity for technologies necessary to achieve EU decarbonisation.
Message — ASD requests including sustainable aviation fuels and carbon capture technologies in the list of strategic net-zero technologies. They also call for liquid hydrogen technologies to be recognized to ensure the sector's long-term decarbonization.123
Why — This status would provide faster permitting and better access to public and private investment.4
Impact — Global fossil fuel producers may lose market share as Europe prioritizes domestic fuel production.5
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Response to European Critical Raw Materials Act

13 Jun 2023

ASD welcomes the European Commissions legislative proposal for a Regulation aimed at securing the supply of critical and strategic raw materials. Given the EUs aerospace and defence sectors almost exclusive reliance on raw materials imports, we strongly support attempts by EU decision-makers to build more resilience in the supply of CRMs. It is crucial for the proposed measures to be successful to ensure coherence with other EU policies affecting the materials sector, in particular with the chemicals regulation. Overall, ASD supports the Commissions ambitious proposal, but the latter is only a partial response to the CRM needs of the aerospace and defence industry. See ASD Position Paper attached for complete feedback.
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ASD Urges Broader Inclusion of Aviation in Green Taxonomy

2 May 2023
Topic — The initiative defines sustainable activities to guide investment toward European environmental objectives.
Message — ASD requests the inclusion of all areas of the aviation sector, including business aviation. They also seek to ensure maintenance and overhaul services remain eligible for the full operating lifetime of the aircraft.12
Why — Expanding the taxonomy's scope would help the industry secure hundreds of billions in transition financing.3
Impact — Noise-sensitive communities could lose tighter protections if specific EU aircraft noise thresholds are deleted.4
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ASD Urges Military Munitions Exemptions in Chemical Labeling Rules

30 Mar 2023
Topic — The European Commission is revising rules for classifying, labelling, and packaging hazardous chemicals.
Message — ASD requests a generic exemption from Poison Centre notifications for military ammunition mixtures. Exemptions for combat ammunition should include training scenarios and the supply chain. Labels should be placed on packaging boxes instead of on individual ammunition rounds.123
Why — This would protect sensitive military data from cyberattacks and reduce industrial compliance costs.45
Impact — Consumers lose access to chemical safety data that would normally be provided to Poison Centres.6
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Meeting with Timo Pesonen (Director-General Defence Industry and Space)

29 Mar 2023 · Meeting to follow up on access to finance for the defence industry.

Meeting with Zdzisław Krasnodębski (Member of the European Parliament, Rapporteur)

10 Nov 2022 · EDIRPA Regulation

Meeting with Erik Bergkvist (Member of the European Parliament)

11 Oct 2022 · Möte Urban Air Mobility

European aerospace industry demands alignment between chemicals and safety rules

10 Oct 2022
Topic — The EU is updating the governance and funding of the European Chemicals Agency.
Message — ASD requests a tighter partnership between ECHA and industry-specific bodies like EASA and ESA. They want a more coordinated approach to chemical regulations to prevent conflicting safety requirements.12
Why — This would prevent conflicting regulations from creating industrial deadlocks for aerospace companies.3
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Response to European chips act package – Regulation

9 May 2022

ASD welcomes the proposed European Chips Act, which has the potential to strengthen Europe’s position in the global semiconductor value chain and its security of supply. This can enhance the EU’s resilience, strategic autonomy, technological sovereignty, and industrial competitiveness. To achieve its objectives, the European Chips Act must ensure efficiency in resource allocation, coherence among all relevant initiatives, and close involvement of industry in its governance. A truly strategic approach to chips must support especially the strategically important defence, aeronautics, and space industries, with specific measures across all pillars of the initiative. Please see attachment for more detailed comments.
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Response to Count your transport emissions: CountEmissions EU

16 Dec 2021

Aerospace and Defence Industries Associations of Europe (ASD) thanks the European Commission for this opportunity to provide comments to their call for evidence document on ‘CountEmissions EU’. These comments are detailed in the paper attached.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

Aerospace and Defence Industries Associations of Europe (ASD) thanks the European Commission for this opportunity to comment on the proposal. ASD is committed to the ultimate objective to reach a net-zero emissions aviation ecosystem in Europe by 2050, and to strongly contribute to the EU’s 2030 ambition. Notably, ASD together with the main players of the European aviation sector, has highlighted a roadmap to reach net zero CO2 emissions by 2050 and to reduce CO2 emission for intra EU, EEA and UK flights by 55% by 2030 (Destination 2050 – A Route to net zero European aviation report). The roadmap clearly shows that the industry can achieve these ambitious objectives without any further taxation of the sector. Instead, significant efforts and investments from the industry, together with the necessary support by governments, will be paramount. Smart economic instruments such as carbon trading and offsetting schemes already impose a high carbon price on aviation. Notably, today the EU ETS represents a carbon price of more than 60€ per tonne of CO2. This is expected to double by 2030 to reach between 100€ or even 150€. This ensures that aviation is included and contributes towards the global objective of reducing CO2 emissions in Europe by 55% in 2030. Through instruments like the Innovation Fund, revenues from the EU ETS are expected to be reused within the sector, to promote innovation. This is not the case for taxation which on the contrary hampers the industry’s ability to invest and innovate. Tax incentives or credits will have a more stimulating effect on the industry’s decarbonisation efforts and its uptake of sustainable aviation fuels than taxing airlines and manufacturers, especially in these critical times of recovery.
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Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

Aerospace and Defence Industries Associations of Europe (ASD) thanks the European Commission for this opportunity to comment on the proposal. ASD is committed to the ultimate objective to reach a net-zero emissions aviation ecosystem in Europe by 2050, and to strongly contribute to the EU’s 2030 ambition. Notably, ASD together with the main players of the European aviation sector, has highlighted a roadmap to reach net zero CO2 emissions by 2050 and to reduce CO2 emission of intra-EU, EEA and UK flights by 55% compared to 1990 (Destination 2050 – A Route to net zero European aviation report). Together with technology, Sustainable Aviation Fuels (SAF) are expected to be the levers with the highest emission reduction potentials. Whilst drop-in sustainable aviation fuels will require limited adaptations to the fuel distribution and supply systems, aviation will also be an end user of non-drop in SAF, such as hydrogen and other energy sources based on electricity. Deployment of infrastructure adapted to the aviation transition to such non-drop in SAF is of utmost importance. Therefore, ASD welcomes the Commission proposal as a good step in the right direction. The proposal does consider air transport and introduces target dates for electrification at gates, which ASD views as positive. However, we do not think a simple replacement of APU with electrification at the gate is the right approach. Increase of electricity usage at the airports must be aligned with an increase of renewable sources in the airports’ energy mix. Additionally, the Commission should consider the impact of other Fit for 55 proposals, like Refuel EU Aviation. The increase of SAF usage mandated under Refuel EU Aviation can be applied also to APUs; utilising SAF in APUs reduces the carbon emissions output by 60-80%. Separately, ASD calls for a stronger push on infrastructure deployment for hydrogen at airports. We recommend a new article be introduced to set binding measures for the deployment of hydrogen infrastructure at TENT-T airports and set targets to equip airports with liquid and/or gaseous hydrogen refueling stations. Those targets should ensure: - connection between trucks and freight air transport for goods. Notably, targets on the TEN-T road network to refuel heavy-duty vehicles are already proposed. - connection with public transport (e.g. hydrogen powered buses).
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Aerospace and Defence Industries Associations of Europe (ASD) thanks the European Commission for this opportunity to comment on the proposal. ASD is committed to the ultimate objective to reach a net-zero emissions aviation ecosystem in Europe by 2050, and to strongly contribute to the EU’s 2030 ambition. Notably, ASD together with the main players of the European aviation sector, has highlighted a roadmap to reach net zero CO2 emissions by 2050 and to reduce CO2 emission of intra EU, EEA and UK flights by 55% by 2030 compared to 1990 (Destination 2050 – A Route to net zero European aviation report). We welcome the Commission proposal amending the Renewable Energy Directive and we support the overall increased renewable energy target for 2030. We are also supportive of the proposed target of at least 2,6 % of renewable fuels of non-biological origin for transport by 2030. On a general note, ASD reiterates its support for the principles underlying EU legislation on renewable energy; robust sustainability criteria for raw materials used for SAFs are a prerequisite in order to avoid any direct or indirect impact on deforestation for example. Advanced biofuels should be used without competition with food production and with a low environmental footprint.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

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 (SAF) to ensure their large-scale availability at low costs in the medium and long term. We consider it as a very good first step which, as detailed further down in our comments, can be further enhanced. The recently announced 4,3 B$ USA action plan on SAF and the “Sustainable Aviation Fuel Grand Challenge” to increase SAF production to at least 3 billion gallons per year by 2030 (estimated to be equivalent to 10% usage in the US by that date), should call for at least a similar level of ambition from the EU, as it marks the launch of a race for the SAF market. The EU should keep in this matter the leadership triggered by the Green Deal. ASD is committed to the ultimate objective to reach a net-zero emissions aviation ecosystem in Europe by 2050, and to strongly contribute to the EU’s 2030 ambition. Notably, ASD together with the main players of the European aviation sector, has highlighted a roadmap to reach net zero CO2 emissions by 2050 and to reduce CO2 emission for intra EU, EEA and UK flights by 55% compared to 1990 by 2030 (Destination 2050 – A Route to net zero European aviation report ). Destination 2050 clearly shows that the use of SAF on one hand, and the development of low-carbon aircraft technologies on the other hand, are the levers that will bring the most effective CO2 emissions reduction. The aviation industry will continue to research and invest in both. Of note, today SAF are certified to be used in existing aircraft, provided they are mixed with conventional jet fuel up to a 50% blend ratio; the manufacturers’ ambition is to remove all the technical barriers in order to allow a 100% SAF compatibility by 2030. This will require adapting the aircrafts systems as well as the fuel formulation. ASD wishes to make some suggestions on the current proposal as detailed below:  A 2030 target of at least to 10 % SAF incorporation, instead of the proposed 5%, should be set.  Deployment of SAF and eFuel should be promoted at all European airports, including those served by Corporate Aviation.  Until this happens, a temporary SAF accounting framework could be put in place.  The establishment of European Industrial Alliance on SAF is paramount.  Incentives and supporting programmes to stimulate and accelerate SAF scale up are urgently needed.  Maintaining strong international links is supported.
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Meeting with Thierry Breton (Commissioner) and

10 Nov 2021 · ASD Board/General Assembly Meeting

Response to Revision of the EU Emission Trading System Directive concerning aviation

8 Nov 2021

AeroSpace and Defence Industries Association of Europe (ASD) thanks the European Commission for this opportunity to comment on their proposals to amend the EU ETS with regards to aviation and the overall system. ASD is committed to the ultimate objective to reach a net-zero emissions aviation ecosystem in Europe by 2050, and to strongly contribute to the EU’s 2030 ambition. Alongside CORSIA, we view the EU ETS as the most appropriate economic measure to limit and reduce CO2 emissions and price CO2 in the interim, until new disruptive technologies and SAF will become available and will be deployed. Already today, the EU ETS represents a high carbon price for aviation, at more than 60€ per tonne of CO2. This price is expected to double by 2030 and reach between 100€ or even 150€. Further, as of today, CORSIA remains the only worldwide market-based measure that can limit the CO2 emissions of aviation. As such, we have always supported an as smooth as possible integration of the ICAO CORSIA scheme with the EU Emissions Trading System for aviation with focus on minimising the burden to European operators. The Commission proposal to apply CORSIA to international flights is essential to maintain level playing field and to avoid double charging on EU operators. The clean cut between the EU ETS and CORSIA proposed by the Commission avoids this double charging, but other hybrid solutions could be considered to be fully compliant with ICAO principles and facilitate the relations with third countries. We recommend dialogue with ICAO be pursued as the EU participation to CORSIA is pivotal. Regarding the intention to apply the EU ETS to flights from and to third countries not adhering to CORSIA after 2026, we understand the intention is to encourage those countries to partake to the global scheme. However, we believe that other avenues, such as strengthened dialogue and climate diplomacy should be explored to avoid negative third countries’ reactions. Separately, we would like to highlight two points relevant to the overall EU ETS revision: •The Innovation Fund under the EU ETS should support break-through technologies and innovative infrastructure to decarbonise the aviation sector and the production of SAFs. •Carbon Capture and Utilisation and Storage removal is regarded as a key pillar for the decarbonisation of our sector. The Commission initiative to establish a harmonised framework to certify removals is a welcome step; we recommend including a link within the EU ETS revision to such an initiative to facilitate deployment of removals.
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Meeting with Alejandro Cainzos (Cabinet of Executive Vice-President Margrethe Vestager), Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager)

19 Oct 2021 · Aviation - climate goals

Response to A Drone Strategy 2.0 for Europe

28 Jun 2021

1. DRONES ARE A PART OF THE AVIATION CULTURE BUT ARE MORE THAN AVIATION: The Strategy should have a broad scope, looking at citizens, safety, noise, visual pollution, inclusion, affordability, lifecycle assessment and privacy. It should treat drones as part of mobility, linking to other transport modes like trains, cars and eVTOL passenger taxis. Further, related technologies must also be considered as they can bring benefits for UAS activities (eg AI, batteries, new materials). 2. WIDE STAKEHOLDER INVOLVEMENT: Many stakeholders must work together, from all numerous domains, and the EU must be at the centre of this dialogue. This includes both civil and defence stakeholders to ensure operational interoperability, including ATM and UTM management. 3. SOCIAL ENGAGEMENT: UAS activities must be understood, embraced and even demanded by citizens; citizens must be included. It is only with this approach that a genuine ‘market pull’ approach can be put in place, through which services can be introduced and scaled – truly unlocking the possibilities of the third dimension of mobility in cities and regions. 4. EU SYNERGIES: The Strategy should be developed within the context of other EU Activities (eg Green Deal, Sustainable and Smart Mobility Strategy, and Synergies Action Plan). As some are still being formed, they should be developed in coordination and the EU must ensure that synergies are identified. 5. REMOVING SILOS: Silos should be removed. For example, civil technologies can also be introduced for defence (e.g., last-mile troop deployment and 4D activities) and security (e.g., police and border forces) applications; and defence funds, research and lessons learned can accelerate technology advancements within which can then be fed into the civil sector. 6. BUILD ON PAST WORK: Lots of work has already been done on drones. For example, the UAS drone Regulations and the UTM Regulations, and any future work must build upon this. However, it should also be clear that these regulations are just the initial steps and will need to be improved as lessons are learned, as needs change and as technology advances. Finally, the Strategy must recognise that regulations are not the only method of supporting the drone ecosystem. ASD welcomes the creation of the Strategy as it helps stakeholders understand the different mobility needs, safety and security concerns, regulatory aspects, planning regimes, decision-making process, etc., that all vary from city to city and region to region. Further, ASD is the primary industry association in Europe that represents key UAM stakeholders and is, therefore, well-positioned to support the EU.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

Dear Madam, Sir, Thank you for this opportunity to comment. Please find attached AeroSpace and Defence Industries Association of Europe's (ASD) views. Kind regards
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Response to New EU urban mobility framework

21 May 2021

1. Urban Mobility’s (UM) Air Segment Having an Air segment to current & future UM systems will provide an additional degree of freedom and resilience in terms of efficiency and effectiveness. Those airborne mobility solutions will also contribute, enhance and complement the existing public services network by leveraging its point-to-point, time-critical missions through an urban planned and integrated vertiport network. As an example, in this context, vertiports will become a pivot point for future Emergency Medical Services allowing medical, staff or patient transportation. 2. What is UAM The term UAM refers to the new potential that can be brought to UM by airborne vehicles. However, the term UAM is not defined and can mean different things by different stakeholders. • The term Urban can be understood to include different types of airborne operations. No matter the type, the key characteristic is that the airborne segment will involve at least a portion of a flight above populated areas. • The term Air often focuses on the aircraft component and its transition through the airspace. Both in the EU and outside, discussions often treat UAM as being synonymous with passenger eVTOL aircraft operating from vertiports with ATM/U-space services (ie air taxi services). However, UAM also includes traditional aviation and drones. • The term Mobility includes the intermodal movement of people and freight by air, and its inherent link to other mobility services, such as bikes, scooters, trams, trains, cars, often considered in their electric-powered version. It is the case that UAM is already a part of UM, for example, ground public transport connects to airports and drones are delivering cargo and conducting emergency medical services. However, UAM is expected to grow alongside growing mobility demands, including the introduction of new services like flying air taxis. UAM will also contribute to higher levels of safety, reduced emissions, noise reduction in the urban environment through advanced technologies regulated by stringent rules. 3. Air Segment’s Socio-Economic Benefits The fact that these vehicles can provide a lot of benefits does not mean that they will be intrinsically embraced by society. Many stakeholders must work together to engage with the public, to ensure that these services are understood, embraced and even demanded by citizens. It is only with this approach that a genuine Market Pull approach can be put in place, through which services can be introduced and scaled – truly unlocking the possibilities from the third dimension of mobility in cities and regions. Many factors will have to be taken into account from a societal perspective (safety, noise, visual, pollution, inclusion, affordability, lifecycle assessment and privacy). The service developers are aware of these factors and are designing mitigations into their solutions. However, it is important that the social dialogue around these vehicles and their services starts as early as possible, involving all stakeholders. Such collaboration will allow for a constructive dialogue leading to societal embracement, and a clear understanding by all on the specific mobility challenges being tackled by these air vehicles, and the benefits they bring to sustainable UM. This kind of collaboration will also help these service developers understand the different mobility needs, safety & security concerns, regulatory aspects, planning regimes, decision-making process, that all vary from case-by-case. 4. Conclusion To ensure full societal benefit, optimise mobility solutions and create an EU competitive UM market, ASD believes UAM is a fundamental element not only in the wider EU UM ecosystem but also as a strategic edge for EU’s leadership and sovereignty. Thus, UAM’s presence should be ensured. Further, ASD, representing the European aviation manufactures, is able and willing to support you and provide valuable contributions to the UM discussions.
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Meeting with Despina Spanou (Cabinet of Vice-President Margaritis Schinas)

18 May 2021 · Security union

Meeting with Anouk Faber (Cabinet of Commissioner Nicolas Schmit), Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit) and

15 Jan 2021 · Meeting on the Pact for Skills.

Meeting with Thierry Breton (Commissioner) and

27 Oct 2020 · Aerospace, Defence, Security & Space

Meeting with Thierry Breton (Commissioner) and

16 Oct 2020 · Roundtable on Aerospace & Defence Pact for Skills

Meeting with Nicolas Schmit (Commissioner) and

16 Oct 2020 · Pact for Skills Roundtable on Aerospace & Defence.

Response to SESAR Common Project 1: Concluding the pilot phase of the SESAR deployment framework

14 Sept 2020

AF5 It is noted that the sub-ATM Functionality “Flight Object Information Exchange (Blue Profile)” has been removed from the proposed draft CP1. This sub-ATM Functionality was initially part of PCP. It has been subject to a number of questions and analyses, mainly with regards to its maturity and readiness for deployment in PCP/CP1 timeframe. Recent status highlighted the significant progress achieved during the last two years, with: • a clear IOP roadmap definition, • successful SESAR validation exercise in Q2 2019, • a formal GO decision taken after maturity assessment in June 2019 by SESAR JU, • successful SESAR validation exercise in Q2 2020, it was the completion of the SESAR related development activities, • an efficiency re-launch of related standardisation activities in EUROCAE, resulting in the delivery of a version of ED-133 revA in February 2020, so that it enables a deployable IOP within the CP1 timeframe. Consistently, the sub-ATM was part of the first CP1 draft circulated end 2019 and presented as such during the CP1 Seminar held on April 2020. With the regulatory mandate now removed, there is a high risk that the existing (and difficult to reach) momentum is lost for any further deployment activity, and that later re-activation will be extremely difficult. ASD strongly recommend that sub-ATM Functionality “Flight Object Information Exchange (Blue Profile)” is re-introduced in CP1, with appropriate progress monitoring and decision gates. AF6 ASD fully supports the last revision of the CP1 AF-6 that replaces former objective given to the SDM by a clear mandate on both the air and ground operators to synchronise their deployment of the ATS B2 services in order to leverage the a/c transmission of the ADS-C EPP from early 2028 EU wide. It is ASD’s understanding that besides the ADS-C EPP forward fit mandate in the CP1, additional initiatives will take place under the “Integrated ATM” lead (e.g. 20% market uptake,…) to incentivise air and ground early movers, so that a critical mass of capable aircraft will already be flying by 2028. ASD would like however to suggest additional changes to the CP1 AF-6: • The forward fit mandate by Dec 2027 should be complemented by a retrofit date (e.g. 2035) with possibly some exemptions (for close to retirement a/c, etc …) in order to provide investors with confidence in the business case, with the achievement of full benefits happening sooner than a forward fit program that could spread over more than 20 years. • The mandate should be less prescriptive on the supporting standards and the sole reference to the “ED-228 A” should be changed to “ED-228 A or further revisions”. • The extension of the mandate to the “FMS autoload” of the CPDLC clearances should be investigated taking account of aircraft manufacturers industrial plans for ATN B2 datacom implementation. The “FMS autoload” would benefit to the timely update of the ADS-C EPP download and enable the use of complex clearances with enhanced benefits for ATM. • Saturation of the VDL Mode 2 network load by 2028 should be anticipated, and complementary SATCOM communication (e.g. IRIS) should be mandated on the ground combined with incentives for aircraft equipage in the CP1. It should be noted that other communication technologies could be deployed once maturity is reached.
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Response to Revision of the EU Emission Trading System Directive concerning aviation

28 Aug 2020

AeroSpace and Defence Industries Association of Europe (ASD) thanks the European Commission for this opportunity to comment on its plans for the revision of the EU Emission Trading System Directive 2003/87/EC concerning aviation. We consider it essential that a full basket of measures be applied to mitigating aviation emissions including Technology, Sustainable Aviation Fuels, infrastructure/operational improvements, renewal of the fleet and the use of market based measures. Our industries support the Green Deal and the EU climate objectives; ASD is committed to the ultimate goal to reach a net-zero emissions aviation ecosystem in Europe by 2050, as well as strongly contributing to the EU’s 2030 ambition. ASD welcomes the clear indication in the inception impact assessment that the EU and its Member States “strongly” support international action on climate change, including CORSIA. The EU participation to CORSIA is pivotal for the success of the scheme, which is gaining momentum ahead of its pilot phase, with more countries joining it. For our sector, it is of utmost importance to maintain close links with ICAO and to ensure a strong worldwide framework and level playing field be in place. ASD recommends a smooth integration of the ICAO CORSIA scheme with the EU Emissions Trading System for aviation with focus on minimising the burden to European operators. Therefore, we welcome the Commission’s intention to closely consider minimisation of the administrative burden and to ensure a harmonious interaction between the EU ETS and CORSIA. The EU ETS revision should also take into consideration the unprecedented crisis it is experiencing as a result of the COVID-19 pandemic and the broadening of the scope of the ETS to other transport modes could also allow a more ambitious reduction of European transport’s carbon footprint over time. Finally, we are keen that revenues generated from the EU ETS implementation are reinvested in the aviation sector, to support advanced and breakthrough technologies development and deployment, the production and uptake of SAF and, ultimately, its efforts towards the 2030 and 2050 goals.
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Response to Update of concentration limit values of persistent organic pollutants in waste

4 Aug 2020

Dear Madam/Sir, Thank you for this opportunity to comment on the initiative. Please find attached comments on behalf of AeroSpace and Defence Industries Association of Europe (ASD).
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Meeting with Monique Pariat (Director-General Migration and Home Affairs)

17 Jul 2020 · Discussion on the ASD proposals for EU Relief Measures for Aerospace, Defence and Security Industries.

Meeting with Vangelis Demiris (Cabinet of Vice-President Margaritis Schinas)

7 Jul 2020 · Security Union

Meeting with Michel Barnier (Head of Task Force Task Force for Relations with the United Kingdom)

24 Jun 2020 · Videoconference with the Task Force for Relations with the United Kingdom

Meeting with Despina Spanou (Cabinet of Vice-President Margaritis Schinas), Vangelis Demiris (Cabinet of Vice-President Margaritis Schinas)

11 Jun 2020 · Exchange of views on the new Security Union Strategy

Meeting with Michel Barnier (Head of Task Force Task Force for Relations with the United Kingdom)

14 May 2020 · Videoconference with the Task Force for Relations with the United Kingdom

Meeting with Monika Maglione (Cabinet of Commissioner Ylva Johansson)

12 May 2020 · The role of technologies in the internal security and the related upcoming EU initiatives.

Meeting with Gaëlle Michelier (Cabinet of Commissioner Adina Vălean), Walter Goetz (Cabinet of Commissioner Adina Vălean)

23 Apr 2020 · Current situation of the civil aeronautics sector

Response to ReFuelEU Aviation - Sustainable Aviation Fuels

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 sustainable aviation fuels (SAF) to ensure their large-scale availability at low costs in the medium and long term. The aviation manufacturing industry is committed to implement CO2 emissions reductions through technology, policies and innovation and is currently working with the European airlines, airports and air navigation service providers on a roadmap for the sector to strongly contribute towards the EU’s Green Deal goals. The use of SAF on one hand, and the development of low-carbon aircraft technologies on the other hand, are the levers that are expected to bring the most effective CO2 emissions reduction. The aviation industry will continue to research and invest in both. Today existing aircraft already allow for a 50% blend ratio and the manufacturers’ ambition is to move forward to 100% SAF blending. Manufacturers are also keen to further the understanding of the non-carbon benefits of SAF beyond CO2 reductions, which are an important element to consider. We are supportive of the idea suggested in the inception impact assessment to establish an “EU coordination platform” to harmonise the approach towards SAF. This is currently lacking at EU level and would certainly support dialogue amongst regulators and all stakeholders. In addition to the policy measures listed in the inception impact assessment, which we view as a good starting point for the analysis, it would be relevant to also consider how the certification process of SAF in ASTM could be enhanced to reduce its cost and remove current blending barriers. Manufacturers are fully involved in such certification process and ASD is ready to provide insights from the OEM point of views and to share lessons learnt. We also suggest taking a broad view and seeking synergies rather than competition with other sectors. In conclusion, ASD looks forward to the next steps on this strategic subject and is keen to provide input to support the development of this initiative.
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Meeting with Timo Pesonen (Director-General Defence Industry and Space)

17 Apr 2020 · Call to discuss aeronautics, space and defence topics.

Meeting with Gaëlle Michelier (Cabinet of Commissioner Adina Vălean), Walter Goetz (Cabinet of Commissioner Adina Vălean)

10 Jan 2020 · Aviation

Meeting with Mariya Gabriel (Commissioner)

11 Dec 2019 · Research and Innovation in Aeronautics, Space and Defence sector

Meeting with Jolana Mungengova (Cabinet of Vice-President Cecilia Malmström), Pedro Velasco Martins (Cabinet of Vice-President Cecilia Malmström)

12 Nov 2019 · Discussion on WTO reform and some aspects of the EU-US and EU-China relationships

Meeting with Jolana Mungengova (Cabinet of Vice-President Cecilia Malmström)

9 Sept 2019 · EU trade policy deliverables 2014-2019, ongoing priorities

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

10 May 2019 · Reach regulation, supply chain communication, Waster Framework Directive Database

Meeting with David Knight (Cabinet of Commissioner Julian King), Julian Siegl (Cabinet of Commissioner Julian King)

25 May 2018 · Security Research

Response to Recast of Persistent Organic Pollutants (POPs) Regulation

17 May 2018

ASD would like to thank the European Commission for giving the opportunity to stakeholders to provide feedback on this proposal, as part of implementing the Commission's Better Regulation Agenda. ASD would like to outline the key specificities of the aerospace and defence sectors and propose improvement areas in order to enhance the functioning of the POP regulation within the various EU chemicals legislation. These elements are detailed in the document attached.
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Meeting with Kilian Gross (Cabinet of Vice-President Günther Oettinger)

17 Apr 2018 · FP9

Meeting with Antoine Kasel (Cabinet of President Jean-Claude Juncker)

7 Mar 2018 · Research and Innovation policies, MFF

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

2 Mar 2018 · Aviation issues

Meeting with Filomena Chirico (Cabinet of Vice-President Jyrki Katainen)

22 Nov 2017 · Research and competitiveness in aerospace industry

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

20 Apr 2017 · Invitation to attend the meeting of the External Affairs Committee of ASD

Meeting with Manuel Nobre Goncalves (Cabinet of Commissioner Carlos Moedas)

6 Dec 2016 · Introductory meeting

Meeting with Filomena Chirico (Cabinet of Vice-President Jyrki Katainen)

22 Nov 2016 · Research in the aeronautics sector under H2020

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

19 Oct 2016 · Aviation

Meeting with Henrik Hololei (Director-General Mobility and Transport)

27 May 2016 · GMBM, EASA

Meeting with Andreas Schwarz (Cabinet of Vice-President Kristalina Georgieva)

19 May 2016 · CSDP related research and Preparatory Action

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

18 May 2016 · Preparatory action

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

10 Mar 2016 · Aviation

Meeting with Eric Mamer (Digital Economy)

11 Dec 2015 · Aviation package

Meeting with Lowri Evans (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

11 Dec 2015 · Presentation of the sector, defence preparatory action, civil aeronautics, research.

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

17 Nov 2015 · Aviation

Meeting with Matthias Ruete (Director-General Migration and Home Affairs)

5 Nov 2015 · EU Industry's Role in the Migration Crisis

Meeting with Julie Fionda (Cabinet of Commissioner Marianne Thyssen)

23 Oct 2015 · EU Aviation package

Meeting with Henrik Hololei (Director-General Mobility and Transport)

14 Oct 2015 · Air transport issues

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

5 Oct 2015 · Aviation

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

30 Sept 2015 · Aviation

Meeting with Tânia Frazão Nunes (Cabinet of Commissioner Carlos Moedas)

30 Sept 2015 · EU Aviation package

Meeting with Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

6 Jul 2015 · Energy Union

Meeting with Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

22 Jun 2015 · Meeting with ASD

Meeting with Keith Sequeira (Cabinet of Commissioner Carlos Moedas)

22 May 2015 · Horizon 2020

Meeting with Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

6 May 2015 · Aviation issues

Meeting with Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

6 Apr 2015 · Meeting on Aviation issues

Meeting with Elżbieta Bieńkowska (Commissioner)

31 Mar 2015 · Participation in board meeting

Meeting with Marjeta Jager (Cabinet of Commissioner Violeta Bulc)

16 Mar 2015 · MR De Vroey AeroSpace and Defence Industries Association of Europe

Meeting with Matthias Ruete (Director-General Migration and Home Affairs)

23 Jan 2015 · Exchange of views on Security Industrial issues, The European Agenda on Security and Proposals for flagship programmes in Cybersecurity and Border Management

Meeting with Daniel Calleja Crespo (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

22 Jan 2015 · Problématique secteur aéronautique en Europe

Meeting with Fabrice Comptour (Cabinet of Commissioner Elżbieta Bieńkowska)

6 Jan 2015 · Introductory meeting with Eurospace