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Airlines for Europe

A4E

Airlines for Europe represents major European airlines to improve competitiveness and promote aviation sustainability.

Lobbying Activity

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

Meeting with Elisabeth Kotthaus (Head of Unit Mobility and Transport)

21 Nov 2025 · Key concerns of A4E members during the trilogue discussions/ discussion of data that could have an impact on the decisions of the co-legislators.

Meeting with Giorgio Gori (Member of the European Parliament)

12 Nov 2025 · State of play and priorities of aviation sector

Meeting with Jan-Christoph Oetjen (Member of the European Parliament) and TUI AG

5 Nov 2025 · Air Passenger Rights

Meeting with Jan-Christoph Oetjen (Member of the European Parliament, Shadow rapporteur) and Lufthansa Group and

4 Nov 2025 · IATA working group visit - Air Passenger Rights

Airlines for Europe urges enforcement against misleading travel agents

23 Oct 2025
Topic — EU regulation on digital fairness, dark patterns, and consumer protection online.
Message — The organization requests the Commission focus enforcement on Online Travel Agents who mislead consumers through brand mimicry, hidden fees, and unclear pricing. They want differentiation between legitimate airline practices and exploitative intermediary behavior, warning against overly prescriptive rules that stifle innovation.1234
Why — This would shift regulatory scrutiny away from airlines toward intermediaries, protecting their direct sales advantage.567
Impact — Online travel agents face stricter disclosure requirements and potential restrictions on their business practices.8910
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Airlines for Europe opposes VAT on air transport services

16 Oct 2025
Topic — EU review of VAT rules for travel agents and passenger transport sectors.
Message — A4E urges the Commission to retain the current VAT exemption for air transport services. They argue that changes would increase costs, harm competitiveness against non-EU carriers, and add administrative burdens without environmental benefits.123
Why — This would protect them from additional costs and avoid regulatory compliance burdens already projected to reach €27.5 billion by 2030.45
Impact — EU Member States lose potential tax revenue from air transport services currently exempted from VAT.67
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Meeting with Ana Vasconcelos (Member of the European Parliament)

16 Oct 2025 · Regulation (EC) No 261/2004 (EU261)

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

7 Oct 2025 · Exchange of views on the drone sightings and their impact to manned flights

Airlines urge EU to protect competitiveness in tourism strategy

12 Sept 2025
Topic — The European Commission is designing a strategy to promote sustainable and competitive tourism.
Message — The sector requests that the EU avoids new taxes and prioritizes closing the price gap for sustainable fuels. They also call for raising delay compensation thresholds and avoiding mandatory data sharing with travel intermediaries.123
Why — This would protect airline profits and mitigate the high financial cost of environmental compliance.45
Impact — Passengers and travel intermediaries face reduced compensation rights and limited access to flight data.67
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Response to PNR Directive Evaluation

5 Sept 2025

Airlines for Europe is pleased to submit initial feedback to the call for evidence regarding the evaluation of Directive (EU) 2016/681 on Passenger Name Record (PNR) data, in attachment. This contribution was developed jointly with the International Air Transport Association.
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Airlines for Europe Urges EU to Bridge SAF Price Gap

3 Sept 2025
Topic — The European Commission is developing a strategic investment framework for renewable and low-carbon transport fuels.
Message — Airlines for Europe requests that the investment plan prioritizes the demand side by lowering the cost of sustainable aviation fuel. They advocate for recycling EU carbon market revenues back into the sector and extending fuel allowances beyond 2030.12
Why — These measures would reduce the immense financial burden of environmental compliance and protect airline competitiveness.34
Impact — Passengers and European destinations lose if costs are not mitigated, leading to higher fares and reduced connectivity.56
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Meeting with Eddy Liegeois (Head of Unit Mobility and Transport)

3 Sept 2025 · Possible measures to reduce disruptions from strikes by Air Traffic Controllers (ATC)

Meeting with Apostolos Tzitzikostas (Commissioner) and

17 Jul 2025 · Implementation Dialogue on ramping up renewable and low-carbon maritime and aviation fuels production in the EU

Meeting with Sophia Kircher (Member of the European Parliament, Rapporteur) and TUI AG

17 Jul 2025 · Air passenger rights

Airlines for Europe urges dedicated funding for sustainable aviation fuels

8 Jul 2025
Topic — The European Commission is evaluating the operation of the ETS Innovation Fund.
Message — The organization calls for a dedicated funding window for sustainable aviation fuels and e-fuels. They recommend adapting evaluation criteria to better reflect the needs of hard-to-abate sectors. They also request simpler application procedures to help smaller companies access funding.123
Why — The sector would secure more project funding and reach lower sustainable fuel costs.4
Impact — Established industrial sectors like steel and cement would lose their competitive funding advantage.5
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Airlines for Europe urges reinstatement of free ETS allowances

8 Jul 2025
Topic — Review of EU Emissions Trading System rules for aviation sector.
Message — The organization requests reinstating free ETS allowances for aviation, increasing SAF allowances to at least 2040, and supporting global CORSIA over extending EU ETS to extra-EEA flights. They argue unilateral EU measures risk carbon leakage and competitive disadvantage.123
Why — This would reduce their annual compliance costs from €5 billion by 2030.45
Impact — Climate ambitions lose as airlines avoid stronger carbon pricing by delaying decarbonization investments.67
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Meeting with Henrik Nielsen (Director Migration and Home Affairs) and

1 Jul 2025 · Entry/Exit System state of play and next steps

Meeting with Moumen Hamdouch (Head of Unit Mobility and Transport)

10 Jun 2025 · Discussion about STIP and follow up of CEOs Roundtable of 16 July

Airlines for Europe calls for targeted reforms to aviation rules

6 Jun 2025
Topic — The EU is reviewing regulations governing airline operations, passenger rights, and pricing freedom.
Message — A4E calls for a targeted revision focusing on airline competitiveness rather than adding new regulatory burdens. They request more flexibility for foreign investors and binding measures to minimize the impact of air traffic control strikes.123
Why — These changes would protect profit margins by blocking new costs and ensuring operational stability.45
Impact — Consumer groups and travelers may face fees for luggage and less protection during bankruptcies.67
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Meeting with Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič) and Air France-KLM and

20 May 2025 · Trade tensions’ impact on the aviation industry

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

5 May 2025 · Exchange of views on the decarbonisation agenda and sustainable aviation fuels

Airlines for Europe calls for streamlined EU SAF reporting rules

29 Apr 2025
Topic — EU regulation updating emissions monitoring rules for aviation's global carbon offsetting scheme.
Message — The association requests harmonised SAF reporting across EU ETS, ReFuel EU and CORSIA schemes to reduce administrative burden. They want the Union Database expanded to handle all SAF deliveries and airline claims automatically, with mutual recognition of certifications to avoid re-verification.1234
Why — This would significantly reduce their compliance costs by eliminating redundant reporting and verification requirements.567
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Meeting with Pierpaolo Settembri (Cabinet of Commissioner Apostolos Tzitzikostas)

29 Apr 2025 · Exchange of views on current aviation priorities

Meeting with Peter Liese (Member of the European Parliament) and Germanwatch and

27 Mar 2025 · Austausch

Airlines for Europe urges simpler aviation taxonomy reporting rules

25 Mar 2025
Topic — Amending EU Taxonomy rules to reduce reporting costs and administrative complexity for companies.
Message — A4E requests removing operating expenditure reporting and the Global Replacement Ratio for aviation. They also seek to decouple aircraft financing from sustainable aviation fuel mandates.123
Why — This would lower compliance costs and improve access to financing for fleet renewal.45
Impact — Environmental advocates lose because the proposals would weaken strict sustainability criteria for aircraft.6
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Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

21 Mar 2025 · Exchange on files concerning transport operators

Meeting with Miguel Gil Tertre (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Petra Nemeckova (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Sean Mernagh (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

19 Mar 2025 · Priorities of the European Commission on climate and fair enforcement of the DMA for aviation

Meeting with Eddy Liegeois (Head of Unit Mobility and Transport)

18 Mar 2025 · Exchange of views on the European Emissions Trading System (EU ETS) and on the Carbon Offsetting Reduction Scheme for International Aviation (CORSIA)

Meeting with Alice Teodorescu Måwe (Member of the European Parliament, Shadow rapporteur)

6 Mar 2025 · 2024/0315 (COD) - Temporary derogation from certain provisions of Regulation (EU) 2017/2226 and Regulation (EU) 2016/399 as regards a progressive start of operations of the Entry/Exit System

Meeting with Magda Kopczynska (Director-General Mobility and Transport) and European Regions Airline Association Ltd.

27 Feb 2025 · Exchange following the launch of the Destination 2050 Roadmap review

Meeting with Maria De Las Flores Diaz Pulido (Head of Unit Mobility and Transport)

25 Feb 2025 · Cooperation for better network performance, Modulation of charges, Flight plan adherence, Most efficient flight trajectory, Summer 2025 and the cooperation ongoing with ANSPs, The indicators in the Annex of RP4 regulation.

Meeting with Borja Giménez Larraz (Member of the European Parliament)

17 Feb 2025 · Priorities in air transport for the new mandate

Meeting with Filip Cornelis (Director Mobility and Transport) and

6 Feb 2025 · DESTINATION 2050 updated roadmap

Meeting with Gosia Pearson (Cabinet of Commissioner Magnus Brunner), Mari Hamalainen (Cabinet of Commissioner Magnus Brunner)

5 Feb 2025 · Exchange of views on the Entry-Exit System (EES), Passenger Name Records (PNR) and Advanced Passenger Information (API)

Meeting with Eddy Liegeois (Head of Unit Mobility and Transport)

21 Jan 2025 · Introductory meeting

Meeting with Filip Cornelis (Director Mobility and Transport) and

10 Jan 2025 · Exchange of views on efforts to agree minimum standards for hand luggage dimensions

Airlines for Europe criticizes proposed EU sustainable aviation fuel allowance scheme

6 Jan 2025
Topic — EU rules for calculating SAF-kerosene price differences and allocating emissions trading allowances.
Message — 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.1234
Why — This would better reflect their actual SAF costs and reduce compliance burdens.56
Impact — Transparency advocates lose as airlines seek confidentiality protections that could limit public oversight.78
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Meeting with Ana Vasconcelos (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

2 Dec 2024 · Accounting of greenhouse gas emissions of transport services 2023/0266(COD)

Meeting with Kosma Złotowski (Member of the European Parliament, Shadow rapporteur)

27 Nov 2024 · Discussion on passenger rights after public hearing in TRAN Committee

Meeting with Borja Giménez Larraz (Member of the European Parliament)

26 Nov 2024 · Priorities for the new EU mandate from Airlines for Europe

Meeting with Silvia Sardone (Member of the European Parliament, Committee chair)

25 Nov 2024 · ENVI COMMITTEE

Meeting with Johan Danielsson (Member of the European Parliament)

20 Nov 2024 · Passagerarrättigheter

Meeting with Tom Berendsen (Member of the European Parliament)

5 Nov 2024 · Aviation policy

Airlines for Europe seeks flexibility and less red tape

22 Oct 2024
Topic — This consultation concerns a common methodology for a voluntary flight emissions label.
Message — A4E demands reusing existing regulatory data to minimize administrative burdens and costs. They also urge more realistic timelines for developing complex IT systems.12
Why — Reducing redundant reporting would lower compliance costs and improve industry competitiveness.3
Impact — Third-party travel agencies may face new burdens to display environmental data.4
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Meeting with Nina Carberry (Member of the European Parliament)

15 Oct 2024 · Aviation Policy

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

15 Oct 2024 · General exchange on current aviation topics

Meeting with Nina Carberry (Member of the European Parliament)

10 Sept 2024 · Aviation Policy

Airlines for Europe demands realistic non-CO2 emission monitoring standards

27 Jul 2024
Topic — This consultation updates rules for monitoring and reporting greenhouse gas emissions in the aviation sector.
Message — A4E requests a monitoring framework based on robust scientific data and realistic default values. They suggest using existing EU databases to automate reporting and reduce the administrative burden. The group calls for a stakeholder consultation process to ensure the tracking software is practical.12
Why — Using existing data sources would simplify compliance and reduce operational costs for aircraft operators.3
Impact — Public transparency is reduced as the industry seeks to keep flight-level fuel data confidential.4
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Airlines for Europe urges reform to curb airport market power

6 Jun 2024
Topic — The Commission is evaluating if current EU airport legislation is still fit for purpose.
Message — A4E requests reforming the Airport Charges Directive into a Regulation to tackle monopoly power. They advocate for a single till principle where non-aeronautical profits offset airport charges. They also seek to remove artificial barriers in the ground handling market.123
Why — These reforms would reduce airline costs by preventing airports from abusing their monopoly positions.45
Impact — Larger airports would lose their ability to maintain high profits through market dominance.6
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Response to Union-wide performance targets for the fourth reference period (RP4)

19 Apr 2024

A4E finds that the level of ambition of the targets proposed leaves room for improvement. The suggested EU-wide targets stay behind the level of ambitions the previous initial target ranges. In past target setting processes we had to experience that during the examination procedure by member states targets have been weakened. In our view the performance and charging scheme should improve the status quo instead the current targets are more suited to manifest it. In general, we are not convinced that the targets set in the KPAs of capacity and environment will effectively support airspace user ambitions to contribute to the European Commission high-level objective of emissions reductions. Airspace users expectations remain high - and we still expect these exceptions to be met.
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Meeting with Wopke Hoekstra (Commissioner) and Ryanair Holdings and

20 Mar 2024 · Aviation Summit - EU 2040 targets implication for air transport : carbon market diplomacy, and how to ensure competitiveness and prevent carbon

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

19 Mar 2024 · - Decarbonisation of aviation - Aviation market developments

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

19 Mar 2024 · Evening Reception

Airlines for Europe urges broad reform and intermediary liability

14 Mar 2024
Topic — The Commission is reviewing passenger rights and proposing a framework for multimodal travel.
Message — A4E urges a broad reform of passenger rights to ensure legal certainty and simplicity. They request that ticket intermediaries share passenger contact details and be held liable for refunds. They advocate for a "less is more" approach to multimodal travel regulations.123
Why — This would reduce administrative costs and prevent airlines from paying double refunds.45
Impact — Ticket intermediaries would face stricter regulatory oversight and sanctions for repeated non-compliance.6
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Meeting with Jan-Christoph Oetjen (Member of the European Parliament, Shadow rapporteur) and Lufthansa Group and

22 Feb 2024 · Stakeholder Meetings on Passenger Mobility Package

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

8 Jan 2024 · Decarbonization of the aviation sector

Meeting with Jeroen Lenaers (Member of the European Parliament, Shadow rapporteur) and International Air Transport Association and KLM Royal Dutch Airlines

23 Nov 2023 · API

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

12 Oct 2023 · Introductory meeting and presentation of A4E’s priority areas, in particular decarbonisation and SAF, Single European Sky, regulatory environment (airports, connectivity, passenger rights).

Response to Evaluation of eu-LISA

15 Sept 2023

Airlines for Europe, on behalf of its members, welcomes this opportunity to provide its views on the performance of eu-LISA. The European airline industrys main experience with eu-LISA concerns the implementation of the EES and ETIAS systems. We would like to reiterate our support for the intended objectives of the EES and ETIAS systems. The successful implementation of these systems has the potential to reduce the number of INADs, prevent disruption and inconvenience, thus benefiting all stakeholders involved. We are highly concerned, however, that the lack of effective preparedness we have been observing throughout our interactions with eu-LISA threatens these goals. In the attached document, we detail the elements that we believe must be considered by the agency to ensure that the implementation of the EES and ETIAS systems does not pose a risk to EU connectivity, hamper the passenger experience, and hinder or disrupt industry operations. Overall, it is our view that the operational readiness of eu-LISAs systems must be ensured before pressing ahead with their implementation. Air carriers remain eager to work closely with eu-LISA in order to ensure a smooth implementation of its systems to the benefit of the industry, passengers, and EU connectivity.
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Response to Revision of the Visa Suspension Mechanism

30 Aug 2023

On behalf of its members, Airlines for Europe (A4E) welcomes the opportunity to provide feedback on the initiative EU visa policy revision of the visa suspension mechanism. The attached document provides a united aviation industry feedback for this initiative. In particular, we consider the priority objective of this revision should be to achieve a common and homogenous approach across Member States and the EU. In addition, this revision should ensure that: the suspension mechanism remains a mechanism of last resort; the travelling public and the industry are promptly and adequately informed in cases of visa suspension. This should avoid placing unnecessary pressure on air carriers and airports, leading to excessive waiting time at border control, jeopardizing connectivity, the impacts of any visa suspension on other EU border management tools, such as EES and ETIAS, shall be duly addressed for coordinated functioning. This should prevent travellers from showing up at the external borders without the required visa, impacting the passenger experience, airlines liability and the border crossing points at airports, the revised suspension mechanism avoids unilateral, non-coordinated, knee-jerk national restrictive measures (as seen during the COVID-19 pandemic). We believe that these elements are essential to ensure that the revised visa suspension mechanism is effective and efficient, while also protecting the interests of all stakeholders.
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Meeting with Adina-Ioana Vălean (Commissioner) and

23 May 2023 · EU-US transatlantic aviation cooperation, SAFs

Airlines for Europe urges swift inclusion in EU green taxonomy

2 May 2023
Topic — This consultation defines sustainable economic activities to guide environmental investments across the EU.
Message — A4E calls for aviation criteria to be included immediately to attract investment. They request clear operational guidance and definitions to ensure the system works.12
Why — The green label would help airlines secure billions for expensive fleet renewals.34
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Meeting with Rachel Smit (Cabinet of Commissioner Adina Vălean) and International Air Transport Association and European Regions Airline Association Ltd.

22 Mar 2023 · Meeting on MDMS

Response to Creation of the Common European Mobility Data Space

7 Dec 2022

A4E considers this initiative as part of the EU initiatives to share data in the area of transport. As such, airlines urge the EC to ensure that all these different activities are aligned. Furthermore, data shared by airlines, and the respective results of data processing, should still be owned by airlines. EC should take care that airlines are not mistakenly forced to share business sensitive information.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

29 Nov 2022 · 1) SES2+ reform 2) RefuelEU

Meeting with Ciarán Cuffe (Member of the European Parliament, Shadow rapporteur)

29 Nov 2022 · Fit for 55 package including Sustainable aviation fuels (ReFuelEU Aviation Initiative) 2021/020(COD)

Meeting with Jens Gieseke (Member of the European Parliament)

28 Nov 2022 · Austausch zur Europapolitik

Response to Review of EU rules on the allocation of slots at Union airports

21 Nov 2022

A4E believes the existing framework largely serves its purpose and does not see a pressing need to revise it. While congestion and unmet demand at EU airports are serious concerns, slot coordination can only help to mitigate the effects of scarce capacity, and make the best of use of available capacity, but it cannot tackle the need for additional capacity. Despite the significant market developments since the Regulation was introduced, the rules have been able to support route growth, increased connectivity, higher passenger volumes, and high levels of capacity utilisation at Level 3 coordinated airports. A4E sees primary value in consistent application and enforcement of the existing rules in a harmonised manner across the EU. A4E could consider some targeted improvements in certain areas, such as the capacity declaration process and aligning the framework with the updated Worldwide Airport Slot Guidelines (WASG), which have introduced important changes, including a higher threshold for new entrants. A4E will provide a more detailed response to the Commission separately.
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Meeting with José Ramón Bauzá Díaz (Member of the European Parliament, Rapporteur) and International Air Transport Association

16 Nov 2022 · ReFuelEU Aviation

Response to Type approval of motor vehicles regarding access to in-vehicle generated data

1 Aug 2022

Although this consultation concerns access to vehicle data and not aircraft data, reading the comments showed that in both modes of transport (road and air) the issues are the same. A4E fully supports the European Commission’s approach to the Data Act to allow for open access to data generated by the use of connected products by airlines, aircraft operators and Maintenance, Repair and Overhaul (MRO) organisations. This open access to data will lead to increased operational efficiency and flight safety, more efficient maintenance and repair processes as well as increased sustainability.
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Meeting with Adina-Ioana Vălean (Commissioner) and

13 Jul 2022 · Aviation Dialogue

Meeting with Søren Gade (Member of the European Parliament, Rapporteur) and Transport and Environment (European Federation for Transport and Environment)

5 Jul 2022 · Refuel EU Aviation

Meeting with Ciarán Cuffe (Member of the European Parliament)

6 Jun 2022 · Emissions Trading System for Aviation Event

Meeting with Jan-Christoph Oetjen (Member of the European Parliament, Rapporteur)

6 Jun 2022 · Dinner on EU ETS Aviation (2021/0204(COD))

Response to Update of common rules for the allocation of slots at European Union airports

24 May 2022

A4E welcomes the opportunity to comment on the Commission’s planned initiative to extend slot relief measures and address the impact of COVID-19 developments and the Russian invasion of Ukraine on the use of airport capacity in the EU. Please find our comments attached.
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Response to Evaluation of the European Union Aviation Safety Agency’s performance in relation to its objectives, mandate and tasks

19 May 2022

With the adoption of the EASA Basic Regulation, EASA’s responsibilities have been expanded in areas such as drones and urban air mobility, environmental protection, research and innovation, implementation of the Single European Sky, international cooperation, and interdependencies between civil aviation safety and security, including cyber-security. Airlines for Europe (A4E) appreciates the possibility to add airline views to the call for evidence following Article 124 of the EASA Basic Regulation.
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Airlines for Europe urges open access to aircraft operational data

13 May 2022
Topic — A legislative initiative aimed at facilitating data access and use across the data economy.
Message — A4E requests that airlines own and control all data generated during aircraft operations. They advocate for open access to sensor data to improve fuel efficiency and maintenance. The group also calls for legal clarity to avoid conflicts with data protection laws.123
Why — Airlines would reduce operational costs and improve sustainability by breaking manufacturer data monopolies.45
Impact — Aircraft manufacturers lose their exclusive control over data and the technical maintenance market.67
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Meeting with Ciarán Cuffe (Member of the European Parliament, Shadow rapporteur)

10 May 2022 · Sustainable aviation fuels (ReFuelEU Aviation Initiative) 2021/020(COD)

Meeting with Cyrus Engerer (Member of the European Parliament)

3 May 2022 · Emissions Trading System

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

29 Apr 2022 · Exchange on the aviation proposals of the FF55 package. In particular, SAF double-zero rating under the ETS / SAF allowances, non-CO2 emissions and RED vs CORSIA SAF compliance

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

29 Apr 2022 · Sustainable aviation fuels

Meeting with Milan Brglez (Member of the European Parliament, Shadow rapporteur)

20 Apr 2022 · EU ETS Aviation

Meeting with Jens Gieseke (Member of the European Parliament)

30 Mar 2022 · Austausch zur Europapolitik

Meeting with Ondřej Kovařík (Member of the European Parliament, Shadow rapporteur)

9 Mar 2022 · aviation decarbonisation and consequences of the Energy Taxation Directive on airlines

Meeting with Jakop G. Dalunde (Member of the European Parliament, Shadow rapporteur for opinion)

15 Feb 2022 · EU ETS

Meeting with Clare Daly (Member of the European Parliament, Shadow rapporteur)

20 Jan 2022 · Refuel EU Aviation

Airlines for Europe Urges Compensation Reform and Opposes Insolvency Fund

17 Jan 2022
Topic — The Commission is reviewing EU rules on passenger rights and financial protection.
Message — A4E demands a five-hour delay threshold for compensation and stricter rules for claim agencies. They also reject proposed mandatory insolvency insurance for airlines.123
Why — This would lower compensation costs and prevent expensive new regulatory levies.45
Impact — Third-party claim agencies and passengers seeking compensation for shorter delays would lose.67
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

14 Jan 2022 · COVID recovery; sustainability; passenger rights & international aviation

A4E urges holistic measurement of multi-modal transport emissions

17 Dec 2021
Topic — Proposal for a common EU framework for calculating and reporting transport sector greenhouse gas emissions.
Message — A4E advocates for a well-to-wheel methodology that considers infrastructure impacts and environmental externalities beyond emissions. They emphasize the need for multiple performance indicators rather than a single metric. The organization also suggests aligning the framework with existing aviation-specific labeling initiatives.123
Why — A multi-metric approach avoids misleading rankings and prevents discrimination against specific airline business models.45
Impact — Rival transport modes may lose their competitive advantage if infrastructure-related environmental externalities are measured.67
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Response to Revision of the provision of air services

6 Dec 2021

Dear All, The Air Services Regulation (EU 1008/2008) has been under analysis for review for some years. We recognise that the Regulation has been of benefit to both the aviation industry and European consumers. Nevertheless, the evaluation carried out in 2019 identified several areas for improvement to adapt to the changes in the functioning of the internal market for air services. Further areas of possible improvement became clear during the COVID-19 pandemic concerning the ability of the European Commission and/or Member States to react appropriately and swiftly. In addition, it was suggested that the developments linked to the EU Green Deal might have an impact on the existing regulatory framework for aviation. On this aspect, it needs to be ensured that it supports industry decarbonisation efforts and that there is no overlap or contradiction between the different pertinent regulations. Best Regards
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Meeting with Didier Reynders (Commissioner) and

22 Nov 2021 · EU Digital COVID Certificate, travel restrictions

Response to Contingency plan for transport

28 Sept 2021

Airlines for Europe (A4E) welcomes the opportunity to comment on the European Commission’s roadmap towards a “Contingency plan for transport”. European airlines strongly support the goal of establishing a “crisis manual” to ensure crisis preparedness and business continuity in the transport sector. Based on our experience of the COVID crisis, we would like to flag a series of important elements that could help industry, as well as national and European institutions to work better together when facing a crisis. 1. General considerations • Coordination between Member States and agreement on a common EU approach to any given crisis is essential. The next step is to ensure that Member States do follow the coordinated approach as agreed in the Council when implementing national solutions (as a counter example, the Council Recommendations on travel restrictions have not been consistently implemented throughout the Union, creating a strenuous challenge for passengers and airlines alike in navigating the patchwork of measures). • Evidence-based policy-making should be the guiding principle of an EU contingency plan for transport, thanks to institutionalised consultation with stakeholders before, throughout and after the crisis. • Emergency measures adopted to face a specific crisis should be limited in time, to enable an evidence-based revision of their effectiveness and proportionality following regular intervals. Similarly, emergency measures should always include conditions and/or criteria on how they should be lifted. • An EU contingency plan for transport should focus on intra-EU movement (passengers and goods), without forgetting the important international dimension of our sector. In this context, the EU should also aim at better harmonising its responses with other key markets, as well as with international institutions (ICAO, WHO, etc). • Communication is fundamental for a good crisis plan: the European Commission and its agencies must have a consistent approach across the Union, and work towards key messages to be relayed at national level by Member States’ governments and authorities. In turn, this would simplify the communications requirements towards stakeholders and citizens. We detail in the attached document further considerations on: 2. Health crisis, data collection and the role of airlines, and 3. Specific airline challenges.
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen) and Airports Council International - European Region and

1 Jul 2021 · EU COVID Certificate

Meeting with Chris Uregian (Cabinet of Vice-President Margaritis Schinas), Despina Spanou (Cabinet of Vice-President Margaritis Schinas), Maria-Myrto Kanellopoulou (Cabinet of Vice-President Margaritis Schinas) and

1 Jul 2021 · Implementation Covid Certificate

Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen)

28 Jun 2021 · Destination 2050 – A route to net zero European aviation

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

8 Jun 2021 · Fit for 55

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

8 Jun 2021 · Videoconference - Discussion on energy taxation and the taxation of the aviation sector

Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

To whom it may concern Protecting human health and the environment while making use of hazardous chemicals is of utmost importance to A4E members. That is why we support the objectives of the REACh Regulation, and welcome its revision to ensure an even better protection of human health and the environment. We appreciate the opportunity to participate in this revision process. In general, we concur with the conclusion that the impact lies mainly with producers and REACH/ECHA internally for now. Nevertheless, we do have concerns on the availability of products. The aerospace sector is a relatively small market and of lesser importance for chemical suppliers e.g. chromium trioxide. As the outcome is uncertain and to ensure availability of product, no extra costs for industry is a precondition. In order to ensure reliability and safety of complex aerospace products throughout their entire lifecycle the Maintenance, Repair and Overhaul (MRO) business is dependent on certain hazardous chemicals. The use of these materials is specified by Original Equipment Manufacturers (OEM) in order to meet key functional requirements. Comments on key messages from the Inception Impact Assessment: 1) The communication in the supply chains is inefficient We share the Commission's assessment that timely, complete and efficient transmission of information along the supply chain through MSDS is a key condition for achieving a high level of protection for humans and the environment. This assessment should also include the Extended Safety Data Sheets that are required for substances listed on the Authorisation List. Due to the current lack of standardisation and the lack of digitalization, information along the supply chain is largely exchanged in paper or paper-like electronic documents instead by a standardized electronic exchange format. This creates considerable efforts and risk (outdated MSDS e.g. missing information about Exposure Scenarios & Risk Management Measures (RMM) for products containing substances subject to Authorization (Extended Safety Data sheets)). A binding standard, possibly a legal obligation, to provide the relevant data electronically and in a standardized format is urgently needed. We would also suggest a central deposit of digital safety data sheets at ECHA. This would facilitate easy access to current data, whilst ensuring that registration and risk evaluation have performed as required. 2) The authorization procedure is too heavy and inflexible We share the Commission's assessment that the current authorization process is too cumbersome and inflexible. As companies in the aerospace industry are experiencing dramatically opposed demands from two European specialist authorities: (a) the regulation of air law requires strict compliance with relevant manufacturing and maintenance specifications (b) the demands of REACh partly force the renunciation of such procedures. This could be solved by a regular involvement of EASA – legally institutionalizing the existing cooperation in the authorization procedure. Comment concerning MRO business model and production processes: 1) Facilitation for Legacy Spare Parts that are still produced We recognize the intention of the European Commission’s draft “COMMISSION IMPLEMENTING REGULATION (EU) …/... of XXX laying down rules for the application of Regulation (EC) No 1907/2006 as regards applications for authorisation and review reports for the uses of substances in the production of legacy spare parts and in the repair of articles and complex products no longer produced and amending Regulation (EC) No 340/2008” This scope is to limited as already stated in a submission to the European Commission in 2015 of an Aviation Industry Associations (AEA/ASD) paper on this issue – highlighting that for Airline operators any simplified authorization should not be limited to repair of Articles no longer in production. This limitation should be reviewed to ensure applicability.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

29 Apr 2021 · Update on aviation recovery

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

15 Apr 2021 · European airlines and CO2 emissions

Meeting with Adina-Ioana Vălean (Commissioner) and

25 Mar 2021 · Conversation with A4E steering board

Meeting with Adina-Ioana Vălean (Commissioner)

25 Mar 2021 ·  Covid-19 travel restrictions, testing protocols and vaccination certificates.  Aviation decarbonisation  Air traffic management

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

23 Mar 2021 · aviation recovery

Response to Union-wide performance targets for the air traffic management network for the third reference period

15 Mar 2021

A4E was founded in 2016 and we represent the united voice of Europe’s leading airlines in Brussels. Our 16 airline group members represent over 70% of European air traffic and carry over 700 million passengers per year – pre crisis. Leading global aircraft manufacturer are also members of A4E. Airlines with cargo and mail activities transport more than 5 million tons of goods to more than 360 destinations annually. Our goal is to ensure the sustainable growth of aviation and contribute positively to the socioeconomic development of European nations. As such we appreciate to be given the possibility to provide further comments on the Commission Implementing Decision setting revised Union-wide performance targets for the air traffic management network for the third reference period (2020-2024). This is being done on the backdrop of: • A volatile traffic situation, which will not recover to pre-crisis level before 2024; • Airlines fighting for survival and not being able to offset any cost increases with revenues; • Mitigation measures of the last year have been falling short of the needs of the industry. We conclude that suggested draft provides a first step but only limited relief to airlines and other airspace users. Consequently, possible financing alternatives for the ANSP revenue gap, need to be re-assessed by Members States and the European Commission, including the most effective use of available recovery funds or ANSP profits from previous reference periods. Ambitious targets need to be set (i.e. KPA of Cost Efficiency). Therefore, we ask the European Commission to review the targets and update them to be more ambitious and supporting for the recovery of the industry. We would like to thank the European Commission for taking our remarks and suggestions into consideration. We remain open to for further discussion. If you have any questions and remarks about this statement, please do not hesitate to contact us at any time.
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Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

8 Mar 2021 · Presentation of the report Destination 2050, a roadmap to net-zero CO2 emissions from aviation by 2050, by the authors

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

3 Mar 2021 · SES2+

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

3 Mar 2021 · Future of aviation

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean), Gaëlle Michelier (Cabinet of Commissioner Adina Vălean)

11 Feb 2021 · Meeting to prepare the Commissioner's participation to the A4E event.

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

9 Feb 2021 · Climate plans for aviation

Airlines for Europe Urges Aviation Inclusion in EU Green Taxonomy

18 Dec 2020
Topic — This consultation establishes a classification system for sustainable economic activities to guide investments.
Message — A4E wants aviation to be classified as a transitional activity while zero-emission technology is unavailable. They request that technical criteria support current fleet renewal and sustainable aviation fuels.12
Why — This would allow the struggling aviation sector to access green financing for modernization.3
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Response to Proposal for a Regulation - Mobility and Transport

17 Dec 2020

Please find attached the comments of A4E on the EC proposal.
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Meeting with Frans Timmermans (Executive Vice-President)

27 Nov 2020 · Green recovery in aviation

Meeting with Henrik Hololei (Director-General Mobility and Transport) and European Transport Workers' Federation and

26 Nov 2020 · Aviation Roundtable Report

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean), Gaëlle Michelier (Cabinet of Commissioner Adina Vălean)

19 Nov 2020 · SAF Alliance discussions

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

29 Oct 2020 · Aviation in the European Green Deal

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

14 Sept 2020

The Airline community appreciates the opportunity to comment on the draft implementing regulation on the establishment of the Common Project One (CP1) supporting the implementation of the European Air Traffic Management Master Plan provided for in Regulation (EC) No 550/2004 of the European Parliament and of the Council, amending Commission Implementing Regulation (EU) No 409/2013 and repealing Commission Implementing Regulation (EU) No 716/2014. Introduction Aviation as a whole and Airspace Users, in particular, are among the hardest hit industries by the COVID-19 pandemic. Consequently, decisive measures by the industry and by lawmakers are required to get aviation back on a robust and financially sustainable track. This is the best way support industry and wider economic recovery. We have provided comments on the regulatory body appreciating that CP1 is developed. Nevertheless, it should not constitute just a minor update but set the baseline and starting point for a transition from the system, which resulted in the delays during 2018 and 2019, onwards to a seamless and digital European Sky. Consequently, timelines and systems need to be ambitious and mechanisms need to clearly support the deployment of technologies in line with airline needs, the ATM Masterplan as well as the Airspace Architecture Study. We remain open to any discussion with you at any time, either on bilateral or multilateral exchange. If you have any questions and remarks about this statement, please do not hesitate to contact us at any time.
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Response to External dimension of the EU policy on Passenger Name Records

4 Sept 2020

Airlines for Europe (A4E) fully supports the Commission’s initiative and would welcome the publication of a new Communication on the topic, in order to establish a new strategic framework for the transfer of PNR data to third countries. As outlined in the roadmap, European air carriers can only share PNR data with third countries when a bilateral agreement on such transfers has been reached. At the moment, such agreements only exist with the US and Australia, and the agreement with Canada is pending validation. Bilateral agreements are necessary to transfer PNR data, in particular in light of the EU General Data Protection Regulation (GDPR) adopted back in 2016. We have voiced our concerns at the growing gap between the rising number of demands from third countries requesting PNR data and the limited number of EU bilateral agreements. In addition, the ICAO task force on PNR standards is setting new obligations (under amendment 28 to Annex 9 of the Chicago Convention) that could enter into force in early 2021. A4E fully agrees with the Commission’s assessment that this is creating a “conflict of laws for EU air carriers”. This might also distort competition with third-country carriers, which are not covered by the EU GDPR. In its roadmap, the Commission outlines the key objectives of its upcoming Communication, which A4E fully subscribes to, in particular pertaining to the legal certainty for air carriers. It is important that the conflict of laws is solved as soon as possible, in order to provide clarity to air carriers and their passengers, but also a robust legal framework establishing conditions under which transfer of PNR elements could take place. The Commission’s roadmap also lists possible follow-up policy options, including the development of a model agreement on data exchange with third countries or leaner bilateral agreements. European air carriers have a strong preference for the legal path chosen by the European Commission: the possibility of a Regulation – which would set out the clear conditions and precise criteria to transfer the data, “including how the Union would remain at all times compliant with the ICAO binding standards, and by the required monitoring arrangement” would be the most efficient way forward. Air carriers and their passengers would benefit from a Regulation that is applied harmoniously throughout the EU Member States, therefore strengthening the EU aviation single market. A4E, together with its members, stands ready to continue participating in the Commission’s work on the external dimension of the EU PNR policy.
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Airlines for Europe urges EU to avoid double carbon pricing

28 Aug 2020
Topic — Updating EU carbon market rules to align aviation with global standards.
Message — A4E urges the EU to align its carbon market with the global CORSIA scheme to prevent double counting. They propose that the EU system only applies to emissions not already obligated by the global program.12
Why — This would protect the international competitiveness of European airlines and lower their financial burden.34
Impact — The environment loses if the weaker global scheme replaces the more rigorous European market.5
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Response to Definition of the Common European Risk Classification Scheme for civil aviation occurrences

11 Aug 2020

Launched in 2016, Airlines for Europe (A4E) is Europe’s largest airline association, based in Brussels. With more than 720 million passengers carried each year, A4E members accounted for more than 70 per cent of the continent’s journeys and operating more than 3,000 aircraft. The COVID-19 pandemic has put all of this in question due to the grounding of air traffic at the beginning of the year -- and is only now slowly beginning its recovery. The aviation sector was dealt a crippling operational and economic blow by the pandemic. The result is that many airlines remain under severe cash flow pressure which unfortunately, will not be alleviated as the industry had hoped for this summer – thanks to uncoordinated travel restrictions throughout Europe. Differing national approaches have emerged and are further complicating the situation, undermining consumer confidence and pushing airlines closer to the brink of insolvency. Decisively addressing the consequences of the COVID-19 pandemic is of utmost importance to speed up economic recovery and re-establish European citizens’ freedom of movement. Consequently, we support and complement the efforts of the European Commission, the European Aviation Safety Agency and national governments to ensure a swift return to normal operations for the benefit of passengers and European economies. In this role we have taken the opportunity offered by the European Commission to provide our comments to: a) COMMISSION IMPLEMENTING REGULATION laying down the arrangements for the implementation of Regulation (EU) No 376/2014 of the European Parliament and of the Council as regards the common European risk classification scheme b) COMMISSION DELEGATED REGULATION (EU) supplementing Regulation (EU) No 376/2014 of the European Parliament and of the Council as regards the common European risk classification scheme in the attached file.
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Response to Implementation of the common European Risk Classification Scheme

11 Aug 2020

Launched in 2016, Airlines for Europe (A4E) is Europe’s largest airline association, based in Brussels. With more than 720 million passengers carried each year, A4E members accounted for more than 70 per cent of the continent’s journeys and operating more than 3,000 aircraft. The COVID-19 pandemic has put all of this in question due to the grounding of air traffic at the beginning of the year -- and is only now slowly beginning its recovery. The aviation sector was dealt a crippling operational and economic blow by the pandemic. The result is that many airlines remain under severe cash flow pressure which unfortunately, will not be alleviated as the industry had hoped for this summer – thanks to uncoordinated travel restrictions throughout Europe. Differing national approaches have emerged and are further complicating the situation, undermining consumer confidence and pushing airlines closer to the brink of insolvency. Decisively addressing the consequences of the COVID-19 pandemic is of utmost importance to speed up economic recovery and re-establish European citizens’ freedom of movement. Consequently, we support and complement the efforts of the European Commission, the European Aviation Safety Agency and national governments to ensure a swift return to normal operations for the benefit of passengers and European economies. In this role we have taken the opportunity offered by the European Commission to provide our comments to: a) COMMISSION IMPLEMENTING REGULATION laying down the arrangements for the implementation of Regulation (EU) No 376/2014 of the European Parliament and of the Council as regards the common European risk classification scheme b) COMMISSION DELEGATED REGULATION (EU) supplementing Regulation (EU) No 376/2014 of the European Parliament and of the Council as regards the common European risk classification scheme in the attached file.
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Response to Exceptional measures RP3

6 Aug 2020

Launched in 2016, Airlines for Europe (A4E) is Europe’s largest airline association, based in Brussels. With more than 720 million passengers carried each year, A4E members accounted for more than 70 per cent of the continent’s journeys and operating more than 3,000 aircraft. The COVID-19 pandemic has put all of this in question due to the grounding of air traffic at the beginning of the year -- and is only now slowly beginning its recovery. The aviation sector was dealt a crippling operational and economic blow by the pandemic. The result is that many airlines remain under severe cash flow pressure which unfortunately, will not be alleviated as the industry had hoped for this summer – thanks to uncoordinated travel restrictions throughout Europe. Differing national approaches have emerged and are further complicating the situation, undermining consumer confidence and pushing airlines closer to the brink of insolvency. Decisively addressing the consequences of the COVID-19 pandemic is of utmost importance to speed up economic recovery and re-establish European citizens’ freedom of movement. Hence, we appreciate the efforts of the European Commission in presenting the draft for the “Commission Implementing Regulation (EU) on exceptional measures for the third reference period (2020-2024) of the single European sky performance and charging scheme due to the COVID-19 pandemic”. We support and complement the efforts of the European Commission, the European Aviation Safety Agency and national governments to ensure a swift return to normal operations for the benefit of passengers and European economies. In this role we have taken the opportunity offered by the European Commission to provide our comments to the “Commission Implementing Regulation (EU) on exceptional measures for the third reference period (2020-2024) of the single European sky performance and charging scheme due to the COVID-19 pandemic”.
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Meeting with Adina-Ioana Vălean (Commissioner) and

20 Jul 2020 · Meeting to discuss aviation and COVID

Airlines for Europe urges dedicated strategy for aviation fuels

8 Jun 2020
Topic — The EU is exploring clean hydrogen's potential to help decarbonize the economy by 2050.
Message — A4E requests a dedicated EU industrial policy providing financing and legislation for innovative aviation fuels. They want synthetic fuels to become an economically attractive substitute for conventional kerosene.12
Why — Financial support would help airlines offset the high cost of sustainable fuels.3
Impact — Road transport would lose its current advantage in meeting renewable energy targets.4
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Response to 2030 Climate Target Plan

15 Apr 2020

European airlines are closely exploring potential pathways towards a net-zero, or low-carbon European air transport through reduction of CO2 emissions in absolute terms and CO2 mitigation (offsets or market-based measures). It is crucial to recognise the magnitude and the urgency of the commitment expected. Airlines know the importance of not failing in turning this pledge into a future reality. Carrying more than 720 million passengers each year and operating around 3000 aircraft, A4E airlines are ready and willing to contribute to making the European Green Deal a success. Before the COVID-19 crisis, European airlines had planned to invest in the next decade €169 billion in greener aircraft technologies which are on average 25% cleaner and less noisy than their predecessors. The breadth of knowledge, best practices, track record in efficiency and especially the competencies that Europe’s aviation sector holds are valuable tools in reaching these ambitious goals. Air transport is a prerequisite for achieving many UN Sustainable Development Goals. It represents the right to access essential human needs: jobs, markets and goods, social interaction, education and other services. Improved access helps address general concerns such as socio-economic cohesion throughout the EU or the depopulation of rural areas. European airlines are closely exploring potential pathways towards a decarbonised air transport at the horizons 2030 and 2050, at European and global scale. The challenge is daunting, and the effort will be enormous. How airlines respond will be closely linked to the reform of the continent’s airspace, the availability of innovative solutions (Sustainable Aviation Fuels -SAFs, future aircrafts and engines) and future economic policies: -Due to the international nature of air traffic, only globally coordinated measures are effective. The EU must step up its climate diplomacy efforts to ensure a full implementation of CORSIA and work to ensure more reluctant countries such as China, Russia, India and Brazil join the CORSIA system by 2021. -Europe’s single aviation market remains incomplete and in need of reform. A digital and seamless European Sky and a fully implemented Single European Sky regulatory framework are key to reducing aviation’s carbon footprint, both for passenger transport and air cargo alike. In particular, improving Europe’s airspace architecture, adapting airspace design to traffic flows and implementing new forms of operations based on digital and smart technologies could lead to an up to 10% reduction in CO2 emissions. This initiative would reduce CO2 emissions in Europe by 18 million tonnes per year. -In 2012, the EU defined a target of two million tons of SAFs produced in Europe by 2020. Yet, eight years later, production is significantly behind schedule. Well-designed measures to support the development of SAFs are crucially missing and were not sufficiently considered in the 2018 Review of the Renewable Energy Directive (REDII). A dedicated EU industrial policy for the deployment of innovative aviation fuels through financing and legislation is urgently needed -More EU support is needed for research, development and innovation plans including electric and hybrid engine technologies, which would reduce airlines’ dependency on fossil fuels and be essential in developing a green aviation industry of the future. Structural funds, the new Multiannual Financial Framework (MFF) and programmes such as the Emissions Trading System (ETS) Innovation Fund, but also the future research and innovation “Partnerships” with industry and Member States, should be aligned to boost the sector’s decarbonisation transformation. -The EU ETS is the most appropriate solution to limit and reduce CO2 emissions and price CO2. Aviation is part of it since 2012 and over that period, the net reduction in aviation-related emissions reached 193.4 Mt of CO2 emissions.
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Response to Revision of the Energy Tax Directive

1 Apr 2020

Air transport is a major contributor to the socioeconomic development of European nations. A coherent regulatory and fiscal framework at EU level should support the industry’s energy transition away from fossil fuels. The aviation industry will rely on fuel-based propulsion for the foreseeable future. Sustainable aviation fuels (SAFs) are therefore one of the most effective means to reduce aviation CO2 emissions in the coming decades. These drop-in fuels are compatible with existing engine technologies and can reduce lifecycle CO2 emissions by up to 85%. In 2012, the EU set a target of two million tons of SAFs to be produced in Europe by 2020. Eight years later, the supply remains low and the price high relative to conventional jet fuel. Regulatory and fiscal measures to support the development of SAFs have proven inadequate and were not sufficiently considered in the 2018 review of the Renewable Energy Directive (REDII) nor does it guarantee truly sustainable fuels. Climate policy regulation in the form of sector-specific taxes, levies or bans are ecologically and economically counterproductive. They reduce the aviation industry’s capacity to invest and innovate whilst potentially shifting CO2 emissions to other regions. Carbon pricing is already applied to aviation through the EU Emissions Trading System (ETS). Crucially, the industry needs an alternative to kerosene to be available on a commercial scale. The review of the Energy Taxation Directive should therefore consider tax incentives for the production and deployment of innovative sustainable fuels instead of new forms of taxation. If the core issue is to cut carbon emissions from all sectors of the economy, the long-term policy response must be to develop – and most importantly deploy – the alternatives that will make aviation cleaner in the first place, and then, in the second place, to consider the use of carbon pricing to incentivise a shift to more sustainable energy sources. Anything else risks putting the cart before the horse. Carbon pricing is already applied to aviation through the EU ETS. In short – if the ultimate policy objective is to induce a change in behaviour in favour of more sustainable energy use, then there needs to be an alternative to switch to. Fiscal measures, which reduce the investment capacity of the aviation industry, and which do not reduce emissions per se, will not help to achieve the Commission’s Green Deal, as things stand. The review of the Energy Taxation Directive is an important opportunity to kickstart a European market for SAFs. These fuels – which can be derived from a variety of feedstocks including cooking oil, plant oils, municipal solid waste, waste gases, sugars and biomass, subject to appropriate sustainability criteria or electrofuels developed thanks to hydrogen, carbon capture and storage as well as renewable electricity for– have been developed and tested for the past decade and can now be commercialised. As the Commission assesses how the ETD’s provisions on taxation of renewable fuels can be amended to align with the EU’s energy, climate change and environment policies, and to promote the use of such fuels, it should consider the introduction of a tax incentive scheme for SAFs, which could be modelled on the United States’ Blender’s Tax Credit scheme. Tax incentives or credits will have a more stimulating effect on the industry’s uptake of SAFs than taxing airlines or end users. In the absence of low- or zero-carbon alternatives on any significant scale, and at commercially viable prices, it is hard to see the purpose of a tax on kerosene. Subjecting jet fuel to excise duty – possibly through a removal of the exemption in the Energy Taxation Directive – will not reduce carbon emissions from flying in the long term, whilst also risking to lead to distortive effects such as tankering – transporting with extra fuel on board to avoid uptake of fuel in the EU.
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Meeting with Adina-Ioana Vălean (Commissioner)

17 Mar 2020 · Transport

Meeting with Adina-Ioana Vălean (Commissioner) and

10 Dec 2019 · Climate Action, Consumer Protection, Slots, Cooperation with US Airlines

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

16 Oct 2019 · Tour d'horizon of aviation files

Response to European Partnership for Integrated Air Traffic Management

27 Aug 2019

The European Partnership for Integrated Air Traffic Management as described by the Inception Impact Assessment provided by the Commission clearly outlines the need for such an initiative. A4E agrees in principle with the preliminary assessment of expected impacts. Aviation needs an efficient and easy way to fund and stimulate investments, supporting the development of an European airspace in line with the related recommendations in the EC Airspace Architecture Study or from the Wise Persons Group. In this sense, investments should target to increase airspace capacity and efficiency in line with the increasing demand, promote digitalisation and as a result improve the environmental footprint and benefit the passenger. We do not believe that the baseline scenario (Option 0) is an alternative to increase efficiency and speed up development or implementation of the Single European Sky. We would not support the choice of Option 0. We also perceive that option 1 and 2 as outlined, leave room for improvement. It is not clear, how positive experiences made so far are taken further nor how the governance structure will address one of the weaknesses of today and will ensure a stronger role of airspace users in the decision making process. A third option might be required in which airlines have the leadership role for future developments. In this sense, the future European Partnership for Integrated Air Traffic Management should ensure that: • The EU economy and travelling public are the beneficiaries. Speed to implement the Single European Sky (SES) is of the essence to reduce and finally avoid the additional costs of €5bn per year. • Airlines are allowed to step up and take the lead to guide developments directly impacting their services towards the customer. • Coordination and supporting activities for technology development and deployment resulting in a synchronised approach to ATM operational improvements are be improved. • The manufacturing industry and service provider is neither deciding on operational/development priorities nor on actual implementation to avoid a conflict of interest and promote competition and innovation. • The priority and focus of R&D and deployment is achieving actual operational performance benefits. • EC prioritises support developments that promote sustainability and/or projects with a demonstrated added value for the network. • There is a proper legal framework that supports and ensure that all corresponding investments are delivered on time to allow airspace users to deliver a good service to the passenger without undue burden on the environment. European airlines are working in an extremely competitive environment. Cost savings (operational, technical or financial) are transferred into stabilising operation to improve passenger experience, invested in modern more environmentally friendly and comfortable aircraft as well as in better airborne/ground technologies. Therefore, it is mandatory for airlines to identify the most efficient and effective way forward and to fulfil their leadership role. A4E and its members are open and ready to start discussions on how to allow airlines to step up and fulfil their leadership role in the context of a European Partnership for Integrated Air Traffic Management to efficiently and most effectively boost EU economy and support the travelling public. We also would like to stress that this needs to be a common target of all operational stakeholders, hence we are looking forward to a constructive cooperation with ANSPs and Airports on this matter of utmost importance.
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Response to Decision setting the Union-wide performance targets for the third reference period 2020-2024

25 Mar 2019

Airlines for Europe (A4E) appreciates the effort and process of the EC and the PRB in setting EU-wide targets for the third reference period (RP3). Nevertheless, airspace users conclude that the results of the process are leaving room for improvement. Best Regards Achim Baumann, Policy Director
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Response to Evaluation - Groundhandling services at airports

12 Mar 2019

A4E welcomes the European Commission's publication of an evaluation roadmap and looks forward to contributing to the evaluation of the Ground handling Directive. Please find our position attached.
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Response to Summertime consultation

12 Nov 2018

Airlines for Europe (A4E), Airlines International Representation in Europe (AIRE), the European Regions Airline Association (ERA) and the International Air Transport Association (IATA), and their respective members, are concerned about the proposal to abolish current DST changes switching from wintertime to summertime, and the timeline of the proposal, because it will have a significant impact on the aviation industry and consumers at both European and global level. We therefore urge the member states and European Parliament to consider the significant repercussions and disruption to passenger and freight connections when adopting their position. A4E, AIRE, ERA, IATA and their members would prefer to remain with the current situation. Should the decision be to abolish time changes, the airline community’s assessment and the required safeguards are as stated in the attached document.
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Airlines for Europe urges exclusion from new collective redress rules

21 Jun 2018
Topic — This consultation covers a proposed directive on representative actions protecting collective consumer interests.
Message — A4E demands the complete exclusion of air transport from the proposed directive. They argue existing aviation regulations already provide sufficient tools for passenger compensation.12
Why — Avoiding these rules would prevent mass litigation and protect airlines from profit-driven companies.34
Impact — Third-party claims firms lose the opportunity to profit from mass consumer compensation.56
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Meeting with Violeta Bulc (Commissioner) and

20 Jun 2018 · Meeitng with A4E CEOs

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová)

7 Mar 2018 · New deal for consumers

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc), Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

1 Feb 2018 · Meeting with Thomas Reynaert

Meeting with Violeta Bulc (Commissioner) and

17 Oct 2017 · A4E CEO Event

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

18 Sept 2017 · Coordinating the agenda for upcoming CEO lunch

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)

10 Jul 2017 · Transport

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

30 May 2017 · Air traffic control strikes, airport charges

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

12 May 2017 · Florence Symposium on aviation

Meeting with Jakub Cebula (Cabinet of Commissioner Elżbieta Bieńkowska)

6 Apr 2017 · EU Airport Charges Directive

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc), Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

1 Mar 2017 · Aviation issues

Meeting with Silvio Mascagna (Cabinet of Commissioner Julian King)

25 Jan 2017 · Upcoming conference

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

13 Jan 2017 · update on aviation related issues

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

9 Jan 2017 · State of play Aviation Strategy

Meeting with Miguel Arias Cañete (Commissioner)

20 Dec 2016 · ETS Aviation

Meeting with Violeta Bulc (Commissioner) and

20 Dec 2016 · A4E CEO Lunch

Meeting with Jyrki Katainen (Vice-President) and

20 Dec 2016 · Aviation sector economic challenges

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

20 Dec 2016 · Aviation

Meeting with Jyrki Katainen (Vice-President) and

20 Dec 2016 · Aviation sector economic challenges

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

8 Dec 2016 · situation of aviation industry

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

17 Oct 2016 · Regulation

Meeting with Maroš Šefčovič (Vice-President)

28 Jun 2016 · Aviation Package

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

28 Jun 2016 · Air mobility and prosperity

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Ryanair Holdings and FINNAIR OYJ

28 Jun 2016 · economic impact of ATC strikes on EU growth and jobs

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

28 Jun 2016 · CEO Summit

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

13 Apr 2016 · Aviation