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Bundesverband der Deutschen Luftverkehrswirtschaft e. V.

BDL

The BDL is the central association representing the interests of the German aviation industry including airlines and airports.

Lobbying Activity

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

15 Oct 2025 · Air Passenger Rights

Meeting with Valdis Dombrovskis (Commissioner) and

22 Sept 2025 · SIMPLIFICATION

German aviation body demands level playing field for sustainable fuels

4 Sept 2025
Topic — Strategic framework to boost investment in renewable and low-carbon transport fuels.
Message — The BDL wants to close the cost gap between sustainable fuels and kerosene. They advocate for a level playing field between EU and non-EU airlines. They also support a flexible system allowing for easier fuel purchasing and consumption.123
Why — These measures would protect European airlines from disproportionate costs and international competitive disadvantages.45
Impact — Fuel suppliers could lose specific benefits if regulations are adjusted to favor airline interests.6
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German aviation association warns of ETS competitive disadvantages

8 Jul 2025
Topic — This consultation reviews the EU Emissions Trading System for maritime, aviation, and stationary sectors.
Message — BDL wants to keep the carbon market's scope limited to flights within Europe. They also advocate for lifting the cap on sustainable fuel subsidies to reduce investment risks.12
Why — Limiting the scope prevents European airlines from losing more market share to foreign competitors.3
Impact — European holiday destinations face higher costs compared to non-EU rivals like Turkey or Morocco.4
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German aviation group urges EU to prioritize airline market competitiveness

11 Jun 2025
Topic — The European Commission is reviewing rules for air services to ensure affordable and sustainable aviation.
Message — The association urges the EU to prioritize competitiveness and avoid new regulatory burdens. They call for a minimum price on flights to stop tickets being sold below cost. They also reject mandatory financial protection for passengers if an airline goes bankrupt.123
Why — Airlines would maintain financial planning security and avoid the costs of mandatory insurance schemes.4
Impact — Budget travelers lose access to the cheapest fares if minimum price rules are enforced.5
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Response to Revision of EU rules on air services

6 Jun 2025

BDL believes that Regulation 1008/2008 has worked well and sees no urgent need for a revision of the Regulation. Instead, the European Commission should prioritize promoting the competitiveness of EU aviation. In case the European Commission moves ahead with a revision a few elements should be considered: 1. If the revision considers the contents of the "Fit for 55" package, it must include a framework for effective climate protection that eliminates carbon leakage and distortions of competition, esp. towards non-EU airlines and airports. The actual status already leads to carbon leakage, loss of EU connectivity and jobs as well as distortion of competition in favor of non-EU airlines/airports 2. Together with the social partners, our government and the manufacturing industry, we have stated that compliance with collective bargaining agreements, applicable labor and social conditions by all companies based in Germany and for all employees of foreign companies stationed in Germany should be on the same high level. Avoiding social and price dumping is also essential to reach the climate targets. 3. Aviation must have a minimum price to avoid dumping. Also, for the sake of price transparency, it must be made legally binding that tickets may not be sold at a price below applicable taxes, surcharges and passenger-related charges/fees. 4. Our members apply full price transparency and display the air fare in full accordance. 5. An insolvency protection scheme is superfluous. The insolvency risk in aviation is much lower than in other sectors: only 0.04% of all passengers in the EU were affected between 2011 and 2019 (2018-Steer study). The average default was ca. 350, far lower than e.g., in the construction industry, where much more substantial prepayments are common: - Germany: 5 insolvencies of commercial airlines in the last 10 years. - Germany: construction business insolvencies in 2024 ca. 3.500, 2023 ca. 2.900 - Germany: all sectors (companies) 21.812 and respectively 17.814 insolvencies 6. Pricing is a key control element for an airline, incl. the right to set different prices for flights in different markets. Customers choose connecting flights only if they are less expensive than direct flights. At the same time, connecting passengers are important to operate a route profitably. The practice of prepayment allows passengers early booking discounts and gives airlines financial planning security for stable schedules and ensures high load factors. Customers could book a ticket close to their departure date at a more expensive price reflective of demand and supply at the time. Contrariwise goods, a seat on a flight cannot be resold if a customer does not decide to fly. Abolishing prepayment only in the EU distorts competition solely to the expense of EU carriers and creates difficulties for EU airlines to participate in the international aviation payment and interlining systems. 7. Wet leasing is very important for our members. Any revision must be carefully considered so that the rules stay fit for purpose. 8. Traffic Distribution Rules should be abolished. They have almost always proven to be discriminatory in the past. Moreover, it should be left to the market to decide whether other airports in the same area are suitable to be served. However, the current provisions in the Regulation at least ensure that TDRs cannot so easily be abused as EU COM approval is needed and certain principles must be observed. 9. Environmental flight bans have proven to be useless. Any ban would just lead to traffic and carbon relocation, limit the freedom of movement of citizens and distort competition.
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Meeting with Filip Cornelis (Director Mobility and Transport)

5 Feb 2025 · Overview of aviation and situation of the German aviation market

German aviation body seeks fairer sustainable fuel pricing rules

18 Dec 2024
Topic — EU regulations for calculating price gaps between sustainable fuel and kerosene.
Message — The association seeks a full-service price definition and a lower deviation threshold for reporting. They also request clarification on currency exchange rates and the official start date.123
Why — This would ensure that subsidies cover the actual costs of purchasing sustainable fuels.45
Impact — The EU's climate budget would decrease as more free allowances are granted to airlines.67
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Meeting with Jens Gieseke (Member of the European Parliament)

15 Nov 2024 · Telefonat

German Aviation Association Urges Realistic Flight Emissions Labelling

22 Oct 2024
Topic — Developing a standardized methodology for the voluntary environmental labelling of aviation emissions.
Message — BDL proposes using a fleet-based approach to account for operational realities. They want labels to include forward-looking certified offers instead of historical data. Additionally, they call for liability limits regarding third-party display requirements.123
Why — Avoiding individual flight benchmarking prevents consumers from shunning specific aircraft types.4
Impact — Eco-conscious travelers lose the transparency needed to select the cleanest individual flights.5
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German aviation industry warns against overestimating non-CO2 flight impacts

29 Jul 2024
Topic — Updating EU rules for monitoring and reporting non-CO2 aviation emissions within ETS.
Message — The association demands more transparent modeling and opposes using uncertain data for pricing. They argue against public data disclosure due to current scientific inaccuracies.123
Why — Preventing data publication and pricing avoids financial penalties based on overestimated emission reports.45
Impact — Environmental groups lose access to public data needed to monitor airline climate impacts.6
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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 Janusz Wojciechowski (Commissioner) and Confederazione Nazionale Coldiretti and

26 Feb 2024 · To present their situation and requests to the representatives of the European Institutions

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

26 Jan 2024 · 'Fit for 55' implementation.

German Aviation Association Urges Inclusion of Major Nations in CORSIA

15 Jan 2024
Topic — This consultation defines which non-European countries are applying the international aviation carbon offsetting scheme.
Message — The German Aviation Association wants countries like China and India included in the scheme. They argue that excluding major nations undermines global climate protection efforts.12
Why — A broader global scheme prevents foreign competitors from avoiding carbon offsetting costs.3
Impact — Airlines from excluded countries like China would lose their current competitive cost advantage.4
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Response to Count your transport emissions: CountEmissions EU

15 Nov 2023

Der BDL unterstütz das Ziel Transportdienstleistungen transparent und vergleichbar darzustellen und dafür die Methodik und die Nutzung allgemeinverbindlicher Emissionsfaktoren zur Emissionsberechnung von Transportdienstleistungen zu vereinheitlichen. Insbesondere sind folgende Elemente im Entwurf zu begrüßen: (1) Die Anwendung der international anerkannten Norm (EN ISO 14083:2023) als Grundlage der Verordnung. (2)Der freiwillige Charakter der Methodik und damit die Begrenzung zusätzlicher Berichterstattungspflichten. (3) Die Nutzung des "Well-to-Wheel"(WTW)-Ansatz. Viele Fluggesellschaften berechnen den CO-Fußabdruck des von ihnen genutzten Kraftstoffs des bereits auf der Grundlage der WTW-Emissionen, basierend auf den Bestimmungen des Greenhouse Gas Protocol. Die WTW-Emissionen von Flugzeugtreibstoff bilden auch die Grundlage für verifizierte SBTi-Ziele, die immer mehr europäische Fluggesellschaften einführen. (4) Die Möglichkeit, dass die entwickelte Methodik für die EU-Richtlinie zur Unternehmens-Nachhaltigkeitsberichterstattung (Corporate Sustainability Reporting Directive, CSRD) verwendet werden kann.
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Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur) and ZF Friedrichshafen AG

10 Oct 2023 · Verkehrs- und Umweltpolitik

Meeting with Thomas Rudner (Member of the European Parliament)

18 Sept 2023 · Parlamentarischer Abend: Ausblick auf die Europawahlen 2024, Ideen zur Dekarbonisierung der europäischen Industrie- und Verkehrspolitik bis 2030, Fit for 55-Verordnung und ihre Umsetzung

German aviation industry urges strategic status for green fuels

27 Jun 2023
Topic — This consultation focuses on the European Union's proposed Net Zero Industry Act.
Message — The association requests that green fuels and carbon recycling be classified as strategic. They call for a financial incentive system similar to United States policies. Current blending mandates alone cannot stimulate the required market growth.123
Why — These subsidies would prevent capital and innovative power from leaving the European Union.4
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German aviation industry urges removal of fleet growth restrictions

3 May 2023
Topic — An EU initiative to define sustainable economic activities for investment purposes in aviation.
Message — The BDL requests removing the 'one in one out' rule to allow European airlines to grow sustainably. They argue sustainable aviation fuel use should not be linked to specific aircraft technologies. Additionally, they want more ground handling services included in the taxonomy.123
Why — Airlines would benefit from easier financing for fleet expansion and reduced technical compliance costs.4
Impact — Non-European carriers would lose the competitive advantage they currently hold over regulated EU airlines.5
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean), Walter Goetz (Cabinet of Commissioner Adina Vălean)

28 Mar 2023 · German aviation industry, Fit for 55, slots

Response to Evaluation of the European Union Aviation Safety Agency’s performance in relation to its objectives, mandate and tasks

18 May 2022

Die EASA muss die Instrumente haben, die allen aktuellen Problemen und potenziellen Herausforderungen gerecht werden. Diesen Ansatz unterstützen wir ausdrücklich für die Bereiche Flugsicherheit und Flugbetrieb. Das S in EASA steht für SAFETY. Eine Ausweitung der EASA-Zuständigkeiten auf Umwelt, Bodenverkehrsdienste und Sicherheit/Security ist weiterhin kontraproduktiv. - Wir haben funktionierende Regelungen und Zuständigkeiten in diesen Bereichen, teils auf internationaler, europäischer oder nationaler Ebene. - Es besteht kein Bedarf an neuen EU Standards für Bodenabfertigung, dies schafft keine zusätzliche Sicherheit. Es schafft nur mehr Bürokratie/Kosten. - Die ebenfalls diskutierte Einführung von Sozialstandards/"soziale Dimension" ist richtig, aber nicht Aufgabe der EASA. 1. Das ist kein Problem des gesamten Luftfahrtsektors, es betrifft einzelne Akteure, einzelne Mitgliedsstaaten, einzelne Aufsichtsbehörden und einzelne Geschäftsmodelle. Schlupflöcher schließt man mit der Durchsetzung des EU-Rechts und nicht mit umfassender Regulierung für die, die Standards übererfüllen 2. Mit geltendem Recht (VO 1008/2008 oder Entsende-Rl.) ist es möglich ist, all dies zu lösen. - Zum Bereich Security ist anzumerken, dass die EASA zwar Informationen zu Conflict Zones veröffentlicht, eine eigene Sachverhaltsaufklärung/Konkretisierung erfolgt aufgrund fehlender eigener Expertise nicht. Auch wenn CZIBs rechtlich nicht bindend sind, führen sie zu einer erheblichen Verunsicherung, insb. bei Flugbetrieben und Crews. CZIBs enthalten keine Hintergrundinformationen, jedoch eine Handlungsvorgabe trotz „non mandatory recommendation“. Das eigentliche Ziel bzw. Mandat der EASA, Mitgliedstaaten und Fluggesellschaften bei der Information über potenzielle Gefährdungen zu unterstützen, wird somit nicht erfüllt. Rulemaking - Beteiligung Industrie: Die EASA ist für Erstellung von neuen Standards und Regulierung zuständig. Grundsätzlich sollen sich alle Rulemaking-Projekte an dem „European Plan for Aviation Safety“ (EPAS) orientieren und in Abstimmung mit Advisory Bodies erfolgen. Die Einbindung von Industrievertretern über die Advisory Bodies ist jedoch bisher nur teilweise erfolgt. Als ein positives Beispiel kann die umfassende und tiefgreifende Einbindung der Industrie und der Mitgliedstaaten bei der Erarbeitung des Manuals „Drone Incident Management at Aerodromes“ genannt werden. Bei den folgenden Rulemaking-Tasks wurde die (deutsche) Industrie beispielsweise nicht involviert: - Low-visibility operations (LVOs) im Rahmen von All-weather operations (RMT.0379) - Fuel/energy planning and management (RMT.0573) Das Management Board der EASA arbeitete im Herbst 2021 an einer Novellierung des Rulemaking-Prozesses. Auch hier erfolgte anfänglich keine Einbindung der Stakeholder, erst zu einem späten Zeitpunkt erfolgte es. Grundsätzlich sollte vor einer Entscheidung des Management Boards der angepasste Rulemaking-Prozess von den Stakeholder-Gremien, insbesondere dem Stakeholder Advisory Board (SAB), eingesehen und kommentiert werden können. Der Prozess sollte vor allem eine grundsätzliche und umfassende Beteiligung der Flughafenbetreiber und der Fluggesellschaften für alle „Rulemakings“, auch bei sog. Fast Track-Verfahren, vorsehen. Die Industrie muss die Regeln umsetzen, sodass diese von Beginn an – bei der Definition des Rulemaking-Prozesses bis zum Drafting einzelner Regelwerke –integriert werden sollten. So können die Kompetenzen entsprechend genutzt und die Akzeptanz der Industrie erhöht werden. Anhaltende finanzielle und personelle Engpässe in der Industrie aufgrund der COVID-19 Pandemie und des Kriegs in der Ukraine erschweren die Umsetzung neuer Regulierungen, sodass ein zurückhaltendes Vorgehen der EASA für die Erarbeitung neuer Regelwerke notwendig ist. Dies gilt insbesondere, da sich der Kompetenzbereich der EASA seit der neuen Grundverordnung nun auch auf die Themen Cyber-Security, Ground-Handling, Drohnen und Umwelt erweitert hat.
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Response to Count your transport emissions: CountEmissions EU

17 Dec 2021

In order to achieve the ambitious goal of CO2-neutral aviation by 2050, the companies of the German aviation industry presented a joint "Master Plan Climate Protection in Aviation" in 2020. The German airlines, airports and air traffic control have committed themselves to seven fields of action, which are being actively pursued: • Renew fleets by deploying lower-emission aircraft • Replace fossil kerosene with sustainable aviation fuels • Implement carbon neutral airport operations • More efficient air traffic management in European airspace • Shift traffic to rail by enhancing intermodal transportation • Reduce emissions with a competitively neutral carbon pricing system • Reduce non-CO2 effects In this context, the BDL welcomes the initiative of the COM to create a uniform framework for the quantification of GHG emissions in the transport sector. Such an initiative can clearly demonstrate the sector's efforts and successes in terms of environmental sustainability, contributing to a more positive image of aviation. To better evaluate and compare climate protection measures in the transport sector, methods are required that quantify GHG emissions (according to Kyoto Protocol) in a verifiable, transparent and comparable way. Besides, methods should be defined internationally - especially regarding aviation and shipping. An effective certification system for CO2-reducing fuels must also be included in the framework from the outset, so that the potential of sustainable technologies can be evaluated accordingly. We have several issues, which remain unclear in the “CountEmissions EU” proposal and need to be clarified to evaluate the proposal: • Why is EN 16258 considered as “insufficiently precise” and why could the ISO 14083 not be used as a suitable calculation method in this context? In the aviation industry, EN16258 is often used to calculate the carbon footprint and considered as sufficient. ISO 14083, which is expected to enter a consultation phase in February 2022 before its publication in October 2022, will be a globally valid calculation standard for transport-related emissions based on EN16258 and the GLEC Framework. Against this background, only after ISO 14083 has been published and analysed, potential next steps of the EU initiative should be considered. Ideally, the upcoming ISO 14083 will become the methodological basis for any calculation. • What will be the considered scope of emissions: lifecycle emissions vs. cradle to grave emissions incl. infrastructure, modal shift considerations etc.? Clarification is needed. The assessment for the industry must be considered from two points of view: A holistic approach in emissions accounting would show the true climate impact of the various transportation modes. This could relativise the sustainability issue of aviation (cf. recent study commissioned by the Naumann Foundation on holistic life cycle assessment of transport systems). The negative aspect in this approach is the enormous administrative effort in collecting data associated with financial burden. • The specific reporting requirements remain unclear to enable users to choose the most sustainable option: What form of report is planned and how will users be given access to the data? Will other reporting requirements and calculation standards be eliminated or harmonized? Private users already have broad information options via online platforms, emissions calculators and increasingly corporate sustainability related information disclosed according to recognised reporting standards (such as GHG Protocol). In some cases, calculation methods are not aligned. Therefore, we would generally appreciate to harmonize the reporting in contrast to extend through another report with another standard. In a B2B environment, there is a higher demand for the disclosure of customer-specific information in the form of dedicated carbon reports, which should be based on the same universal accounting standards.
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Response to Revision of the provision of air services

6 Dec 2021

Generally, we welcome the revision of Regulatiob 1008/2008. 1. If the revision should consider the objectives of the "Fit for 55" package, it must include a framework for effective climate protection that eliminates carbon leakage and distortions of competition, esp. towards non-EU airlines and airports. The Commission current proposals will lead to - carbon leakage - loss of EU connectivity and jobs - distortion of competition in favor of non-European airlines/airports 2. Together with the social partners, our government and the manufacturing industry, we have stated that compliance with collective bargaining agreements, applicable labor and social conditions by all companies based in Germany and for all employees of foreign companies stationed in Germany should be on the same high level. Avoiding social and price dumping is also essential to reach the climate targets. 3. Aviation must have a minimum price to avoid dumping. Also, for the sake of price transparency, it must be made legally binding that tickets may not be sold at a price below applicable taxes, surcharges and passenger-related charges/fees. 4. Our members apply full price transparency and display the air fare in full accordance. 5. An insolvency protection scheme is superfluous. The insolvency risk in aviation is much lower than in other sectors: only 0.04% of all passengers in the EU were affected between 2011 and 2019 (2018-Steer study). The average default was ca. €350, far lower than e.g., in the construction industry, where much more substantial prepayments are common: - Germany: 5 insolvencies of commercial airlines in the last 6 years - Germany: construction business 2018 3.334 and 2019 3.044 - Germany: all sectors 19.302 and respectively 18.749 insolvencies 6. The 2013 Commission proposal on Air Passenger Rights still represents a fair balance between consumer protection and the requirements for economic competitiveness of airlines and should be adopted as soon as possible by the EU legislators. - Create legal certainty for consumers and companies: clarify "extraordinary circumstances" - Maintain incentive for airlines to use replacement aircraft in the event of severe delays to transport passengers: maintain thresholds of 5, 9 and 12h Our Airlines have responded to the pandemic by providing flexible rebooking options to regain confidence. 7. Pricing is a key control element for an airline, incl. the right to set different prices for flights in different markets. Customers choose connecting flights only if they are less expensive than direct flights. At the same time, connecting passengers are important to operate a route profitably. The practice of prepayment allows passengers early booking discounts and gives airlines financial planning security for stable schedules and ensures high load factors. Customers could book a ticket close to their departure date at a more expensive price reflective of demand and supply at the time. Contrariwise goods, a seat on a flight cannot be resold if a customer does not to fly. Abolishing prepayment only in the EU distorts competition solely to the expense of EU carriers and creates difficulties for EU airlines to participate in the international aviation payment and interlining systems. 8. Wet leasing is very important for our members. Any revision must be carefully considered so that the rules stay fit for purpose. 9. A revision of the regulation should clarify that still existing bilateral air service agreements between EU countries shall brought in line with the concept of the European Common Aviation Area, esp. for flights of EU air carriers to/from 3rd countries via other EU member states. 10. Traffic Distribution Rules should be abolished. They have almost always proven to be discriminatory in the past. Moreover, it should be left to the market to decide whether other airports in the same area are suitable to be served. 11. Inclusion of commercial drone operators is welcomed.
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Meeting with Markus Pieper (Member of the European Parliament, Rapporteur) and Climate Action Network Europe and

9 Nov 2021 · RED III

Response to ReFuelEU Aviation - Sustainable Aviation Fuels

1 Nov 2021

Replacing fossil kerosene with SAF is the decisive lever to achieve the goal of CO2-neutral flying. A binding blending quota can help accelerate the market ramp-up of SAF/PtL, therefore the aviation industry welcomes the Commission’s approach as a boost for the SAF market. The ecologically best solution are fuels that are produced from atmospheric CO2, which is why the sub-quota for PtL is rated positively. The German aviation industry supports this goal and, together with the German federal government and other NGOs, has adopted a joint PtL roadmap at the beginning of 2021 (https://www.bdl.aero/de/publikation/ptl-roadmap/). Our concerns with the draft and the suggested solutions (see also attachment) are: A book&claim - approach is missing and must be enabled in the regulation to keep SAF supply chains as efficient and ecological as possible. It must be possible for individual operators to buy and use more SAF than what is required through the blending mandate. We are welcoming that bypassing tankering (Art. 5) is generally addressed in the draft. It would however be necessary to find individual agreements between Member States/EU and the relevant third country (the respective air transport agreements). If a third country would not give its binding consent under international law, supervisory authorities from EU Member States may not be in the position to oblige foreign carriers to refuel at EU airports. This would result in competitive advantages for non-EU carriers, relocation of traffic to third countries or tankering outside the EU. To the extent that Art. 5 violates (international) law, the approach on tankering regarding international flights should be adjusted. Right now, SAF prices are 3-6 times higher than conventional kerosene. The cost of kerosene makes up around 1/3 of the operating cost for airlines. This leads to the result that EU-carriers will be facing much higher costs than non-EU carriers, that will result in a massive distortion of competition and possible relocation of traffic from the EU and an incentive for intercontinental passengers to avoid transferring in Europe. The result is not climate protection, but loss of jobs in the EU and carbon leakage. To enable the market ramp-up of SAF and at the same time prevent the consequences of distortion of competition and carbon leakage, we consider the following to be necessary and possible: - For intra-European traffic (approx. 75 % passengers, 50 % traffic), the quotas are set as provided for in the draft regulation. However, to prevent carbon leakage, the costs attributable to feeder/transferring passengers must be excluded. - For ex-EU traffic (approx. 25% passengers, 50% traffic), a separate regulation for binding quotas must be made: Ideally, a binding quota for the use of SAF should be agreed upon and implemented as quickly as possible at the international level (ICAO) for all international long-haul traffic (i.e., also ex-EU traffic). If a blending quota is imposed on international traffic in the foreseeable future, the costs attributable to feeder passengers must no longer be excluded. If the introduction of an internationally coordinated SAF quota fails in the foreseeable future (e.g., at ICAO level or in international air transport agreements) and the EU wishes to adhere to its plan to also impose a blending quota on international traffic until such a quota has been agreed internationally, it would be essential to take precautions to avoid carbon leakage. Additional costs in ex-EU-pax traffic must be compensated in a competition-neutral manner with suitable measures. One possible option could be: The EU states use the revenue from passenger- and destination-related national aviation/passenger taxes to offset the additional costs of SAF.
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German Aviation Association urges exemptions for connecting flights

8 Oct 2021
Topic — The consultation reviews the EU Emissions Trading System for the aviation sector.
Message — The BDL recommends exempting transfer passengers on connecting flights to EU hubs. They also propose a fixed CORSIA baseline based on 2019 emission levels.12
Why — This measure would prevent competitive distortion and maintain the economic equality of EU airlines.3
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Response to Carbon Border Adjustment Mechanism

8 Oct 2021

The revised EU-CO2 pricing will lead to carbon leakage to third countries: production could be located outside the EU and replaced by imports with a higher CO2 footprint. CBAM could turn the table: Instead of reducing emissions inside the EU by ETS, CBAM proposes to impose certificates on the price level of the EU-ETS for imports from third countries with a CO2 emission imbalance. But implementation of this proposal creates strong challenges: - Imposing additional costs on imports might conflict with WTO and existing trading agreements and may inflict counter measures by the third countries. - CBAM creates additional administrative and border processes to goods, thereby hampering trade. - Defining emissions for a product produced outside the EU might be difficult, nearly impossible and could risk leading to fraud. In the proposed regulation carbon leakage is only considered regarding goods. However, carbon leakage can also occur in services like global air transport and is not only related to the EU-ETS, but also to the future SAF-quotas and a planned energy tax on fuels. The EU is home of global airlines e.g., Lufthansa Group, Air France–KLM, Finnair, and others and global hubs as Frankfurt, Paris, Amsterdam, Munich, and others. The aviation industry is facing a global, not only intra-EU competition and competes with international competitors, e.g., from the US, UK, UAE or Turkey. EU carriers safeguard EU’s connectivity to the world. In this international market a traveller from Stockholm to Singapore has several options to use flights with EU Carriers and hubs or non-EU Carriers and hubs (i.e., Turkish Airlines via Istanbul). For transfer flights within the EU (i.e., Stockholm – Munich) EU-airlines must contribute to the ETS, they have to bear in future higher cost for alternative fuels (SAF), and furthermore the EU plans to introduce energy taxes on intra-European passenger flights. As result the cost for transferring-flights of European airlines to European hubs would be substantially increase, leading to higher consumer prices for the EU-airlines compared to the non-EU airlines. Additionally, the SAF-quota would increase the fuel cost for the long-haul flight from the EU to Singapore. These higher prices might direct customers to airlines and hubs outside the EU and would transfer (not reduce) traffic to non-EU carriers damaging the EU aviation industry. The current CBAM proposal does not address the risks of carbon leakage in services like aviation as it focuses only on goods. In any case, applying CBAM on international air transport would oblige all third-party carriers, to report emissions for all flights involved, also flights from/to destinations outside the EU (e.g., Istanbul-Singapore) based on an internationally accepted method which minimizes the risk of fraud, and then to pay respective EU emission duties. This would be legally impossible to implement unilaterally by the EU. The German aviation industry strongly supports the EU-ETS and the introducing of SAF-quotas, but the effects of carbon leakage in aviation must be addressed. We suggest that this must be realised within the planned instruments (EU-ETS, SAF-Quotas, and if implemented energy taxes): - Applying all instruments (also SAF-quotas) strictly for flights within the EU only, as CORSIA applies to non-EU flights. - Emissions and fuel consumptions of transfer passengers on intra-European flights as part of an EU-Non-EU journey can be identified by the transporting airlines. For these passengers specific (not flight specific) consumptions and emissions, the respective instrument should foresee free certificates or reimbursing of taxes and higher fuel cost. - If this is not feasible, alternative methods within the instruments must be developed. Charging third party carriers for non-EU flight emissions is unrealistic if it is not regulated at the level of ICAO.
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Response to Revision of the Energy Tax Directive

8 Oct 2021

The German aviation industry supports the EU-goal of climate neutrality by 2050. CO2 emission pricing plays a pivotal role along with other measures such as increasing the fuel efficiency by exchanging old aircraft with new aircraft. Alone fleet renewal reduced the emissions per passenger by 44% since 1990. Improvements in the context of the Single European Sky and transferring demand to railways on short distances deliver further CO2 emission reductions. The airports contribute by enhancing terminal infrastructure and apron mobility. The Fit for 55 Program proposes to remove the current energy tax exemption for passenger air traffic over a ten-year period starting in 2023. We strongly reject this proposal based on seven reasons. 1. Double taxation: Like other member countries, Germany applies already taxes on departing passengers. This tax reflects distance and thus emissions and it is neutral within the inner-European and global competition as it refers to the final destinations regardless of the used flights. 2. Distortion of global competition: The EU is home to global airlines, e.g., Lufthansa Group, Air France–KLM, IAG, SAS, and Finnair as well as to global hubs such as Frankfurt, Paris, Amsterdam, Munich, Madrid, Helsinki, or Vienna. The EU aviation industry faces global competition, not only Intra-EU. EU airlines and hubs safeguard the EU’s excellent connection with the world for the benefit of export, industry, services, tourism, and social contacts. In this competition a traveller from Stockholm to Singapore can use flights with EU Carriers and their hubs or non-EU Carriers and non-EU hubs (e.g., Turkish Airlines via Istanbul). For transfer flights within the EU (i.e., Stockholm–Munich) EU airlines must contribute to the ETS, and they must bear in future additional cost for alternative fuels regulated by ReFuelEU Aviation. Additional fuel taxes would increase unilaterally the cost of EU airlines even more, directing customers to cheaper airlines and hubs. Thus, this would transfer (not reduce) traffic to non-EU companies and damage the EU aviation industry one-sided. 3. No climate protection: As the revenues of a fuel tax move into the general budget of each member state there is no direct climate protection function of a fuel tax (unlike ETS or SAF blending quota). A tax just increases the cost of companies and consumers without providing cleaner mobility. 4. Depriving the industry of necessary funds for renewing the fleet: An Airbus 350 uses 30% less fuel per 100 passenger kilometres than an Airbus A340-300. Investments in the fleet are the highest and most long-term investments of an airline and is of self-interest of an airline. Any funds, additional taken away from the companies, reduce the abilities of the companies to undertake this important fleet rollover. 5. Tankering: European airlines would cater for more fuel outside EU to use it for intra-European flights. Aircraft would be heavier and thus would have higher emissions. The amount of fuel taken on board a given flight is – alone for safety reasons – in the clear authority of pilot and the airline. 6. National differences in EU energy taxation: Today Germany applies almost twice of the minimum EU tax rate on gasoline. If this continuous, there would be a significant imbalance in the intra-EU aviation market. 7. Shift in tourism to countries outside the EU: More distant tourist destinations like Turkey or North Africa would become more attractive (lower airfares) compared with Spain, Greece, Croatia, or Italy. This would result in additional CO2 emission and would damage the tourism sector in the EU. More efficient aircraft, new technologies, CO2 pricing in a competition-neutral design, alternative fuels, and an improved organisation of mobility within Europe could lead to sustainabalaviation. In light of the existing and proposed instruments (blending mandates, EU-ETS, CORSIA), a fuel tax is superfluous and counterproductive for climate protection.
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German aviation lobby urges EU-UK carbon market linkage

17 May 2021
Topic — Regulation excluding incoming UK flights from the EU carbon trading system.
Message — The BDL calls for linking the EU and UK trading systems. They suggest mutual recognition of auditors and free certificates for transfer flights.123
Why — Linking the systems would reduce administrative costs and manual data errors.45
Impact — Non-European hubs would lose their price advantage over EU-based flights.67
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German aviation group demands protection for European flight hubs

26 Nov 2020
Topic — The European Commission is updating rules for the European Emissions Trading System.
Message — BDL demands measures to prevent carbon leakage and protect European flight hubs. They suggest free emission allowances or cost reimbursements for intra-European feeder flights.12
Why — The group would secure billions in revenue and prevent passengers from switching to international competitors.3
Impact — Non-European aviation hubs would lose the competitive advantage they currently enjoy over European rivals.4
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

The German aviation industry as one of the hard-to-decarbonise-sectors is committed to the EU climate goal of greenhouse gas neutrality by 2050. The German Aviation Association very much welcomes the initiative to revise the RED II earlier. In order to be able to fly carbon-neutral, fossil fuels must be replaced by Sustainable Aviation Fuels (SAF). Until now, SAF in particular electro-fuels (RFNBO) have not been available in sufficient quantities and are still too expensive. With current oil prices at historic lows, the price of SAF is still 5 times higher than fossil fuel. Should the after-corona-recession persist, this price differences could prevail. The Technology for production and usage of SAF is proven and feasible. The most important starting point is to demonstrate and scale-up the production of SAF, in particular electro-fuels, in order to produce sufficient quantities and to leverage scaling and learning effects. As there is a broad range of conceivable processes, demonstration of different technologies is required. The German aviation industry is prepared to participate in pilot projects. Because the question of whether and when such fuels can be used is for sure not a matter of technical feasibility but of an empowering energy policy framework, the revision of RED II is of utmost importance. A binding SAF mandate for blending synthetic fuels with fossil kerosene would be a preferable option at a global level as it would affect all airlines in the same way. Thus, any attempt to set such a mandate in regional exclusive agreements such as EU could affect competition in air transport – like the ETS presently. Fuel costs already account for around a quarter of an airline’s operating costs. Corresponding to an increase of these costs would be an increase of distortion of competition in favour of non-European airlines, because such unequal costs could not be passed on to customers by the European airlines in the form of higher prices. Therefore financial support is necessary and should aim for reduction of SAF costs by evaluation of the best production concept prior scale-up. In the long run, large-scale production outside of the EU should be anticipated due to feedstock and energy potentials as well as lower production costs. It is essential, that any blending mandate reflects the SAF production capacity and is technologically agnostic. However, it must be ensured that promising concepts – that might show there benefits far from now – are not neglected. Without such a special support (e.g. sub mandate, different multiplier), electro-fuels might be excluded in the near term aviation fuels supply in spite of their pivotal importance regarding the ultimately limited potential of biomass. In any case, an internationally coordinated roadmap is needed to ensure that production plants are built and that fuel is sold at marketable prices. Any quota regulations should ideally be defined globally analogous to the internationally agreed CO2 pricing instrument CORSIA. The EU should therefore also take the issues forward at global level within ICAO. Any mandate should focus on reliable sustainability criteria and allow sufficient lead time for the respective production facilities to be set-up. The multiplier for aviation with 1.2 is not a real incentive for fuel suppliers. It must therefore be increased in order to accelerate SAF production scale-up. The impact assessment should examine which factor is sufficient to create a real incentive and if there is a necessity to implement a different multiplier for electro-fuels and advanced biofuels. In order to maintain the competitiveness of European airlines and not to withdraw their financial resources for more climate protection, the Impact Assessment must include an evaluation of the various projects that exist for aviation within the framework of the Green Deal, each of which can lead to a competition-distorting price increase of aviation (RED II, ETD, ReFuelAviation, ETS).
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German aviation industry warns against double regulation and cost hikes

28 Aug 2020
Topic — Revising the EU Emissions Trading System to integrate the CORSIA international carbon offsetting scheme.
Message — BDL urges the EU to avoid "double regulation of emissions" and rejects the "swift phase-out" of free allowances. They also request that "revenues from the auctioning of certificates should be earmarked for aviation`s climate protection."123
Why — This would preserve financial resources and "maintain the competitiveness of European airlines" during the pandemic recovery.45
Impact — Environmental groups lose as the industry resists cost increases intended to drive faster emission reductions.6
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Response to Sustainable and Smart Mobility Strategy

23 Jul 2020

Air transport shall be greener, more digital and resilient: This is possible if companies remain economically healthy and competitive in the worldwide – not only EU - market. The air transport sector is far more affected by the COVID19 crisis than most other sectors. The latest generation of aircraft burns up to 25% less fuel and emits less CO2. With new energy-efficient aircraft and operational procedures, German airlines have been able to reduce CO2 emissions per passenger/km by 43% since 1990. The acquisition of new aircraft is an important lever for climate protection in aviation. In order to achieve the goal of CO2-neutral flying, replacement of fossil fuels with sustainable aviation fuels is essential. Besides advanced biomass-based fuels, the production of synthetic fuel from atmospheric CO2 using renewable electricity is very promising from an environmental perspective. It is important that the EU supports the development of sustainable aviation fuels in order to offer them at marketable prices. Experience shows that if rail services are good (high frequency, travel time ca 3h or less), the demand moves automatically to rail. Short travel times are more attractive than low prices. In France, Austria, Switzerland and Germany several schemes to connect rail to intercont flights exist. This requires complex procedures concerning luggage, customs, and irregularity management. Thus, we seek to intensify inter-modal collaboration. Furthermore the hub needs to be connected to the high-speed train network (not present in Munich or Milan). The demand volumes/emission-savings shifting air traffic to rail are small. Germany has ca. 15 mio local domestic air passengers, mainly on long routes with train travel times over 4h. Further 8 mio domestic passengers fly to transfer hubs. A full exploitation of the potential to shift domestic passenger to trains would decrease the emission share of the German domestic air travel from 0,3% to 0,2%. The potential amount of shifted air passengers is irrelevant compared to 150 mio long-haul rail passengers in total. Therefore the following measures have the main potential for climate protection: - Support fleet renewal through environmental funds - Foster sustainable aviation fuels, especially Power-to-Liquid-Fuels - Realize Single European Sky - International Carbon Pricing (CORSIA, ETS) Keeping in mind that aviation is an international market, it is mandatory that carbon pricing in aviation requires a global level playing field. Global distortion of competition must be avoided; also for intra-EU flights as part of global travel plans. Example: If a transfer traveler from Germany to Bangkok has to pay for a CO2-price for the feeder flight to Frankfurt or Paris these routings would be more expensive than via London or Dubai. Without reducing emission, this distortion would shift flights, jobs and companies to areas outside the EU. Carbon pricing models should refer to the traveler and his journey/final destination, regardless of airline or hub. The carbon-price should relate to the total distance and not to the fuel burned on parts of the journey. In order to promote climate protection in aviation all funds gained by new and existing carbon pricing should be used to enable innovation and the introduction of sustainable aviation fuels. As to airports we see climate protection measures on the following areas: - Supply and generation of sustainable and renewable energies - Optimization of the air-conditioning of terminals, construction of sustainable buildings (terminals and offices) - Sustainable mobility on the apron - Conversion of runway lighting to LED technology, optimization of passenger boarding bridges and baggage handling systems A strong aviation sector (airports / airlines) is a key driver to leave the Corona crises behind, as it enables trade, tourism, knowledge-transfer and international collaboration. See attachment: Open Letter to EU Ministers and European Commissioners.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

21 Apr 2020

Position of the German Aviation Association (Bundesverband der Deutschen Luftverkehrswirtschaft | BDL) The German Aviation Association very much welcomes the initiative “ReFuelEU Aviation – Sustainable Aviation Fuels” of the European Commission. In addition to the UN aviation organization ICAO, which should set the global framework to push the market launch of Sustainable Aviation Fuel (SAF), it is the European Union, which should set the EU-framework to avoid national patchwork regulations for an industry which works in a strong global competition. Therefore the main challenge for ReFuelEU Aviation will be to push SAF into the market without market distortions between European and non-European Airlines. German federal ministries and states are working together with plant manufacturers, fuel producers and aviation industry on the development of a joint roadmap for electro-fuels. Until now, synthetic fuels from renewable energy sources have not been available in sufficient quanti-ties but are mainly produced in very small amounts as part of research projects and are still too ex-pensive. With current oil prices at historic lows, the price of SAF is still 5 to 6 times higher than fossil kerosene. Should the after-corona-recession persist, this price differences could prevail. Nevertheless, the technology for production and usage of synthetic fuels is proven and feasible. The most important starting point is therefore to set up industrial plants for the production of SAF, in particular electro-fuels, in order to produce sufficient quantities and to leverage scaling and learning effects. The German aviation industry is prepared to participate in pilot projects. Expecting that cost efficient electro-fuels will not be produced in Europe because of missing renewable energy, we support and participate in the Global Alliance Power Fuel, an association of the energy industry, fuel producers, plant manu-factures, aviation, and the automotive industry. Because the question of whether and when such fuels can be used is for sure not a matter of technical feasibility but of an empowering energy policy framework, ReFuelEU Aviation is of utmost importance. Read our detailed position in the document enclosed.
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Meeting with Walter Goetz (Cabinet of Commissioner Adina Vălean)

3 Mar 2020 · Aviation

Response to Evaluation of the 2011 White Paper on Transport

26 Feb 2019

In Europe we look back on very dynamic and successful development of the single market for aviation over the past 20 years. It makes an indispensable contribution to economic development and integration. We believe it is important that it continues to be one of the pillars of EUs prosperity. The EU aviation sector directly employs 1.4 to 2.2 mil. people and supports a total of 6.2 to 7.5 million jobs, according to EC figures. The direct contribution of air traffic to the EU GDP amounts to €110 billion, while the overall impact, including tourism, is €620 billion due to multiplier effects. To remain a strong business location, the EU and its member states must have efficient own international mobility connections, esp. air transport. The prerequisite for these are competitive EU airlines and airports. Due to regulation at EU and national levels European companies have higher fixed costs than those from 3rd countries. The resulting competitive disadvantages lead to a loss in market share. E.g. market share of non-German airlines at German airports rose from 34% in 2014 to 43% by 2018. So what could EU do? Start within its own competences to remove EU and national burdens to strengthen competitiveness of EU aviation. “Internal” Unilateral regulations/regulations that exclusively apply to the EU aviation sector lead automatically to unilateral burdens on EU airports and airlines. The (correct!) approach in the Commission's aviation strategy must now followed by action. EU policy and the policy of the member states should be critically assessed with a view to strengthening the competitiveness of the European air transport industry: 1. Tax and regulatory costs that disproportionately affect EU carriers compared to non-EU carriers should be addressed by the EC, at least in the form of recommendations to assess actual effectiveness and adverse effects of specific national measures. 2. National air passenger or kerosene taxes weaken the competitiveness of EU aviation, put national airlines and airports at a disadvantage in international competition, deprive companies of the financial means to invest more in climate protection/noise control and put at stake the credibility of the agreed multilateral approach CORSIA. 3. There should be no further unilateral additional burdens for air traffic, esp. in the areas of passenger rights, internalization of external costs, etc. 4. Initiatives to reduce competitive disadvantages and to cut special EU/national charges for air traffic is ecologically/economically worthwhile. Air traffic bears most of its external costs itself. 5. The continued growth is increasingly coming up against structural capacity bottlenecks in the air and on the ground. European ATM should be able to retain appropriate personnel resources and deploy controllers more flexibly. ATC should be further automated with the aim of increasing efficiency and safety. Additionally bottlenecks of the infrastructure of airports and at aviation security/border control systems must solved. “External” Aviation agreements should strengthen the global competitiveness of EU hubs and EU airlines, safeguarding fair competition, opening up market/business opportunities to export-oriented EU companies by boosting connectivity, both for airlines from EU and 3rd countries. International environmental cooperation is critical for a sector like aviation. Therefore, we support the global solution CORSIA for international aviation. The German Aviation Association BDL was founded in 2010 as a joint representation of the interests of the German air-transport industry. Members of the association are airlines, airports, German air traffic control and other aviation service providers. These companies employ more than 180,000 employees. Air transport in Germany enables mobility for more than 200 million passengers a year and contributes to the transport of goods worth more than €200 bill. to strengthen Germany as a business location.
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German aviation lobby demands 1:1 adoption of global carbon rules

21 Dec 2018
Topic — EU consultation on reporting requirements for a global aviation emissions scheme.
Message — The association requests that international standards be implemented verbatim into EU law. They demand removing international flights from the European carbon market.12
Why — This would prevent double regulation and reduce compliance costs for European airlines.3
Impact — Environmental integrity is harmed as the proposal creates reporting loopholes for international flights.4
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Meeting with Matthias Ruete (Director-General Migration and Home Affairs)

16 Jun 2016 · Discussion on Security and Migration

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

30 Nov 2015 · aviation strategy for Europe

Meeting with Marjeta Jager (Cabinet of Commissioner Violeta Bulc)

18 Mar 2015 · BDL German Aviation Association