Airlines International Representation in Europe

AIRE

Airlines International Representation in Europe represents various sectors of the international air transport industry.

Lobbying Activity

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

9 Dec 2025 · Air passenger rights at a crossroads: Striking the right balance (event)

AIRE urges EU to keep airline VAT exemptions

14 Oct 2025
Message — AIRE demands preserving the VAT exemption for international air transport under existing law. They argue taxing international flights is technically impractical and causes administrative inefficiency.12
Why — Retaining exemptions helps avoid higher operating costs and maintains passenger demand levels.3
Impact — Consumers would face more expensive travel and reduced international flight connections.45

AIRE urges flexible ownership and leasing for EU airlines

11 Jun 2025
Message — The group wants more flexible airline ownership rules to attract international capital. They suggest simplifying plane rental rules and oppose any bans on short-haul flights. Additionally, they call for a harmonized EU approach to manage air traffic control strikes.123
Why — Easier access to foreign funding would help airlines finance their expensive transition to greener technologies.4
Impact — Aviation workers may lose job security if the industry continues using diverse, unregulated employment models.5

Meeting with Peter Agius (Member of the European Parliament)

13 Feb 2025 · Introduction with association

Meeting with Pierpaolo Settembri (Cabinet of Commissioner Apostolos Tzitzikostas)

5 Feb 2025 · exchange of views

Airlines Demand Realistic Timelines for Non-CO2 Emission Reporting

29 Jul 2024
Message — AIRE requests more time for monitoring plans and a simplified reporting template. They propose aligning the non-CO2 scope with existing EU ETS rules. This alignment aims to streamline management and reduce administrative burdens.123
Why — This would reduce administrative complexity and prevent inflated costs from overestimated emissions.45
Impact — Environmental groups lose data accuracy if conservative estimates are replaced by average values.6

AIRE Urges Greater Competition and Flexibility in EU Airport Rules

6 Jun 2024
Message — The group wants to keep existing slot usage rules and boost competition among ground handlers. They also seek more transparency regarding airport charges to prevent unfair price hikes.123
Why — Airlines would benefit from lower operational fees and greater flexibility during peak travel times.45
Impact — Large airport operators would lose their monopoly over service provision and fee-setting power.67

AIRE seeks to end animal transport exclusivity for IATA members

11 Apr 2024
Message — AIRE requests that the regulation include airlines that are not IATA members. They propose allowing carriers that are IOSA certified or follow IATA Live Animals Regulations.12
Why — This prevents the exclusion of over 100 airlines from the animal transport market.3
Impact — IATA members lose the exclusive market access suggested in the original commission proposal.4

AIRE Supports Passenger Rights Reform but Opposes Free Assistant Seats

13 Mar 2024
Message — AIRE requests raising the delay threshold for compensation to five hours. They propose a standard reimbursement form and a definition for alternative flights. They argue assistants for disabled passengers should pay for seats.1234
Why — Reducing compensation eligibility and litigation would lower overall compliance and operational costs.56
Impact — Disabled passengers would lose the right to free seating for their assistants.7

AIRE backs multimodal rights but warns of carrier burdens

13 Mar 2024
Message — AIRE requests a dedicated platform for multimodal delay tracking and opposes mandatory penalty frameworks. They further challenge liability requirements for service animal damage and equipment replacement.12
Why — Clear ticket classifications and caps on accommodation would reduce administrative and reimbursement costs.34
Impact — Disabled passengers lose protections if carriers are exempted from equipment and animal liability.56

Response to Revision of the Visa Suspension Mechanism

4 Dec 2023

Airlines International Representation in Europe (AIRE) welcomes the opportunity to provide feedback on the proposal for Regulation COM (2023) 642. Please find attached the aligned feedback provided by the industry, which could be summarized as follows: (i) the promotion of securely removing barriers to travel, (ii) the visa-free regime at Schengen, currently in place with 61 countries, and (iii) any EU effort to speed/ease visa procedures for travellers while efficiently fostering process automation for authorities, airports and airlines.
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Response to Revision of the Visa Suspension Mechanism

31 Aug 2023

Airlines International Representation in Europe (AIRE) welcomes the opportunity to provide feedback on the initiative EU visa policy revision of the visa suspension mechanism. The file attached includes the main outcome that the revision should guarantee: (i) the suspension mechanism remains a mechanism of last resort without any automaticity, (ii) the travelling public and the industry should be well in advance and clearly informed in case of visa suspension, (iii) the impacts of any visa suspension on other EU border management tools, such as EES and ETIAS, shall be duly addressed for coordinated functioning, and (iv) the revised suspension mechanism avoids unilateral, non- coordinated, knee-jerk national restrictive measures (as seen during the COVID-19 pandemic). Thus, the Commission should issue guidelines on the basis of which states will act at least within the internal borders of the EU. A common and homogenous approach across Member States and the EU should be a must.
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Response to Update of common rules for the allocation of slots at European Union airports

24 May 2022

Please find attached the join position of the members of Airlines International representation in Europe (AIRE). We do hope that a common understanding between the Commission and the industry can be found for the sake of the recovering European aviation and its customers. Do let us know if you have any further questions.
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Response to REGULATION on measures against transport operators in relation to illegal entry into the territory of the European Union

31 Jan 2022

Please find attached the feedback by Airlines International Representation in Europe (AIRE). Do not hesitate to contact us in case you have questions. +32 470 544 542 aeropolitical.aire@aire.aero
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Airline group AIRE demands delay to sustainable fuel mandates

17 Nov 2021
Message — AIRE calls for delaying the 2% sustainable fuel target until 2030. They want synthetic fuel requirements to be optional for member states. The organization also rejects proposed taxes on aviation fuel and tickets.123
Why — Lowering these targets would protect airlines from surging operating costs and competitive disadvantages.4
Impact — European travelers and the tourism industry face higher costs and reduced mobility.5

Aviation group AIRE rejects fuel taxes and seeks mandate delays

17 Nov 2021
Message — AIRE rejects the proposed aviation fuel and ticket taxes in their entirety. They advocate delaying the 2% sustainable fuel mandate until 2030 to reflect market conditions. They also suggest making synthetic fuel production targets optional.123
Why — This prevents an increase in operating costs and maintains global competitiveness.45
Impact — Environmental groups lose as slower fuel transitions delay aviation decarbonization efforts.6

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

3 Mar 2021 · SES2+

Response to Revision of Regulation on performance and interoperability of surveillance for the single European sky

4 Feb 2020

Transition period AIRE welcomes and supports the introduction of a Transition Period; the date of June 2023 seems feasible for many airlines. Cease of operations However, despite the sound retrofit programmes of the individual airlines that have been shared with the SESAR Deployment Manager building the European ADS-B Implementation Plan, the manufacturing industry is not able to deliver ADS-B kits to the airlines per the agreed planning on which the airlines have based their retrofit programmes. The delayed delivery of kits has forced some airlines to postpone their ADS-B retrofits to the next maintenance checks. In addition, the continued grounding of the Boeing 737 MAX forced the airlines to re-evaluate their fleet planning and postponing the retrofit dates and cease of operations of their current aircraft. Temporarily inoperative In the context of the Minimum Equipment List (MEL), AIRE welcomes the provisions entitling aircraft with temporarily inoperative ADS-B equipment to operate in the SES airspace of a maximum of 3 consecutive days. AIRE has three requests: 1. For the above reasons, it is necessary to maintain the originally proposed date of 2025 for Cease of Operations. Considering the preparation of the ANSPs, such would not have a significantly impact on the operational readiness of ADS-B in Europe. 2. AIRE is seeking confirmation that for temporarily inoperative ADS-B equipment, the under Article 2 (8) new proposed Article 14a regarding Flight Plans also applies? 3. Referring to the Airline ADS-B retrofit programme, AIRE is seeking clarification that this document will not be formally requested but that the airline shall ensure that the appropriate documentation accurately reflects the airline’s operation and is available for the Competent Authorities upon their request?
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Meeting with Adina-Ioana Vălean (Commissioner) and

4 Feb 2020 · Environment, SES/SES2+, Airmorts, Slots, Passenger rights, safety, International liberalisation of Air Services Agreements

Response to List of aircraft types and models exempted from meeting the requirements on data link services

1 Aug 2019

AIRE thanks the European Commission for the opportunity to comment on the proposed exemptions. These are in line with what we requested on behalf of our member airlines over the past years. Therefore AIRE supports the proposed list of exempted aircraft. AIRE expects to see in the very near future a similar pragmatic proposal on ADS-B exemptions (Regulation (EU) 1207/2011) based on the conclusions and recommendations stemming from the Consolidated Implementation Plan that involved all stakeholders.
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Response to Decision setting the Union-wide performance targets for the third reference period 2020-2024

25 Mar 2019

In attachment you will find AIRE's comments. Kind regards Sylviane Lust Director General AIRE
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AIRE urges EU alignment with global aviation emission standards

30 Nov 2018
Message — AIRE strongly encourages the EU to bring its regulatory framework into alignment with international standards. They argue the current proposal creates technical differences that threaten the integrity of the global scheme.12
Why — Alignment would prevent market distortions and ensure airlines are not penalized by underestimating emissions.34
Impact — Global climate goals lose if other countries follow Europe’s lead and weaken emission standards.5

AIRE and airlines urge EU to maintain seasonal time changes

12 Nov 2018
Message — The airline associations strongly prefer to maintain the current system of seasonal time changes. If the policy changes, they demand a synchronized implementation across all member states delayed until 2021.123
Why — Keeping the status quo prevents massive logistical complexity and protects valuable global airport slots.45
Impact — Travelers and freight companies will experience reduced connectivity and higher costs from scheduling disruption.67

AIRE opposes including air passenger rights in collective lawsuits

21 Jun 2018
Message — AIRE urges excluding air passenger rights regulation from the scope of this directive. They request clear definitions for mass harm to avoid confusing and clashing procedures.12
Why — This exclusion avoids unfounded liabilities that could lead to higher air fares.3
Impact — Consumers lose a path to collective compensation for flight cancellations or delays.4

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

9 Mar 2018 · Aviation issues

Meeting with Violeta Bulc (Commissioner) and

23 Nov 2017 · Meeting with the delegation of AIRE CEOs on Aviation package

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

8 Jun 2017 · Presentation of IACA event

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

27 Jun 2016 · NM Audit, aviation strategy

Meeting with Joao Aguiar Machado (Director-General Mobility and Transport)

15 Jun 2015 · Aviation strategy, Eurocontrol governance, SESAR deployment