European Network Airlines' Association
ENAA
The European Network Airlines Association gathers the major EU network airlines that are calling for an EU regulatory framework that promotes and safeguards the competitiveness of the EU industry.
ID: 224920726807-48
Lobbying Activity
Meeting with Gzim Ocakoglu (Acting Head of Unit Mobility and Transport)
9 Sept 2025 · Exchange of views on the EU-Qatar Aviation Agreement and other EU aviation agreements
Response to Revision of EU rules on air services
11 Jun 2025
The European Network Airlines Association (ENAA) believes that the Air Services Regulation, Regulation (EC) 1008/2008, has served well to further the EU internal market for air services. Its provisions remain fit for purpose until today and a comprehensive review as concluded by the 2019 evaluation of the Regulation is unnecessary. In case the European Commission moves ahead with the revision, the Regulation should continue to ensure a level playing field for all market players, fair competition, and a competitive air services industry. Please see the attached document for our detailed input.
Read full responseMeeting with Pierpaolo Settembri (Cabinet of Commissioner Apostolos Tzitzikostas)
20 Mar 2025 · External aviation dimensions and the enforcement of the EU-Qatar agreement
Meeting with Nina Carberry (Member of the European Parliament)
18 Sept 2024 · Aviation Policy
26 Jul 2024
The European Network Airlines Association (ENAA) welcomes the European Commissions approach that requires airlines to monitor and report on the non-CO2 impacts of their intra-EEA flights for the years 2025 and 2026. This will allow a smoother ramp-up of the non-CO2 MRV implementation for aircraft operators and aligns with the current EU ETS scope. While ENAA acknowledges the overall warming effects of non-CO2 emissions, it also wishes to highlight the lack of substantial scientific evidence to show that non-CO2 emissions would be responsible for around half of aviations global climate impact, based on the GWP100 metric. It also shows that a small share of flights (~3%) would be responsible for the majority of non-CO2 effects. ENAA would like to underline that the scope of the monitoring, reporting and verification must be maintained for intra-EU flights only, until operators are ready to effectively and efficiently collect and transfer data from long-haul flights. Furthermore, the amended EU ETS Monitoring and Reporting Regulation also includes provisions related to the claiming of sustainable aviation fuel (SAF) allowances (article 54a), notably stating that where eligible aviation fuels cannot be physically attributed to a specific flight, the aircraft operator shall receive the so-called SAF allowances proportionally to its surrendered EU ETS certificates at this specific airport. ENAA is of the view that this proportionality principle should apply only to the ReFuelEU Aviation mandated SAF volumes that airlines procure. For volumes going beyond the ReFuelEU mandate, aircraft operators should not be bound to this proportionality principle provided they can prove additionality in their fuel accounting.
Read full responseMeeting with Rachel Smit (Cabinet of Commissioner Adina Vălean)
30 Mar 2023 · Meeting on social aspects of aviation
Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean), Rachel Smit (Cabinet of Commissioner Adina Vălean), Walter Goetz (Cabinet of Commissioner Adina Vălean)
25 Oct 2022 · The revision of Regulation (EC) 1008/2008.
Response to Strengthening social dialogue
19 Oct 2022
The European Network Airlines’ Association (ENAA) is in favor of strengthening social dialogue in the European Union and its Member States. ENAA believes a strong involvement of social partners is key to ensuring a fair transition to a climate-neutral, digital economy, for shaping the future of work and building stronger industries.
ENAA supports the promotion of dialogue between employers and employees and collective bargaining, which should ensure transparency, legal certainty, and ultimately better working conditions in all sectors, including the aviation sector. Furthermore, social dialogue between employers and employees may even increase the attractiveness of the workplace, the health of the employees and address issues such as the staff shortages that many sectors currently face.
Sectoral social dialogue (SSD) facilitates a mutual understanding between trade unions and employers, offers a possibility for a clear dialogue with the European Commission, and provides for possibilities to influence the legislative processes. Nevertheless, in the SSDG for civil aviation, there is quite a disparate structure with highly differentiated issues to deal with but also making it difficult to agree on certain issues and the powers of SSD have not been fully used. To ensure a greater impact of SSD on policymaking, which so far has seen limited results in terms of legislative effects, the outcome and impact must be strengthened.
To facilitate such social dialogue and its legislative impact, the EU would have to ensure the dialogue is transparent and continues, but also provide financial support to enable large groups to come together and participate in the dialogue. Despite the Commission’s facilitation of the SSDs, creating a forum to discuss social matters with the Member State experts and the funding of special projects, ENAA believes more can be done. The Commission needs to (i) show greater respect for the social partners and take into account their views and agreements developed through social dialogue; (ii) facilitate greater trust within the institutions in the potential of social dialogue; (iii) provide more technical and legal support to the bipartite social dialogue and support capacity-building among national social partners; (iv) coordinate for social dialogue in all of the Commission’s Directorates-General (DG) and appointing a coordinator for social dialogue in the DGs; (v) allow for better involvement of the social partners in policies; (vi) create clear and transparent rules of procedure on how to handle European social partner agreements, for instance on requests for Council of the EU resolutions based on joint agreements made by the social partners. Finally, the social partners can also strengthen their autonomy, through proactive participation and joint actions, such as through the organization of special projects under EU Commission funding.
Read full responseMeeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean), Rachel Smit (Cabinet of Commissioner Adina Vălean), Walter Goetz (Cabinet of Commissioner Adina Vălean)
12 Oct 2022 · Revision of Regulation (EC) 1008/2008.
Response to A partnership with the Gulf
1 Mar 2022
The European Network Airlines’ Association (ENAA) – formerly known as the Airline Coordination Platform - supports the efforts of the EU to develop a comprehensive framework for policy and political dialogue with the Gulf and to enhance cooperation between the two regions. ENAA believes that this policy initiative should include air transport and address the particular challenges in this field, enhancing regulatory cooperation and convergence and establishing a level playing field.
You can find our input to the call for evidence consultation in the attachment.
Read full responseResponse to Revision of the Energy Tax Directive
18 Nov 2021
Aligning air traffic and climate protection is a common goal of society, politics and the aviation industry. The regulatory framework should pursue ambitious and binding targets for CO2 reduction and at the same time ensure that European aviation, including value creation and employment, is not discriminated in international competition. The Airline Coordination Platform welcomes the European Commission’s proposal for a regulatory framework to reduce carbon emissions.
Aviation is a global industry and therefore also requires global climate solutions. Nevertheless, regional regulatory pressure may sometimes be needed to make progress on achieving environmental objectives. To the extent that European legislation aims to lead regulatory changes reducing carbon emissions, it is necessary to keep in mind that such efforts could be counteracted by traffic and emissions being shifted to hubs outside Europe ("carbon leakage"), where EU regulation and CO2 emission rules do not apply. Higher costs for flying with European carriers will inevitably be the consequence of the proposed legislation leading to passengers choosing cheaper options by flying to and via non-EU hubs. The current proposals therefore pose a serious threat to EU network airlines and EU hub airports, which are the backbone of European connectivity, employment and economy.
As a result of increasing asymmetrical regulatory costs for EU-based airlines, European airlines will no longer be able to compete with third country carriers. Moreover, flying to and via non-EU hubs becomes more and more attractive for an intercontinental journey for passengers. However, such a detour through non-EU hubs often only increases CO2 emissions: the opposite effect of what the Fit for 55 proposals aim to achieve.
With the European Green Deal, an aviation fuel or kerosene tax has become part of the political discussion. Currently, countries around the globe do not tax aviation fuel for international flights and have included provisions in their bilateral air service agreements to this effect. EU comprehensive air transport agreements include the same exemptions. The rationale of this long-standing notion is simple: States know that levying a tax on international flights unilaterally will likely trigger reciprocal measures from other countries, without ensuring that such taxes are financing aviation infrastructure. Instead, it is a global practice that airlines and passengers are charged for the use of aviation infrastructure on a “user-pays principle”: Airport charges and air traffic control charges; in some cases such charges include financing noise mitigation measures levies around airports.
An EU-level or national aviation kerosene tax has no direct CO2 reduction effect and would probably even have contrary consequences, as various examples in individual states and studies have shown. Few of the reasons:
1.) The funds would flow into the general national budget and would not be earmarked for climate/sustainability projects. Worse, the tax would withdraw funds from EU airlines that they need to invest in climate-friendly new aircraft and (energy) technology;
2.) It would create a competitive disadvantage for EU airlines compared to airlines with their main business in countries without such a tax. Long-haul transfer traffic could be diverted to hubs outside the EU to avoid the tax, often accepting longer and thus environmentally less advantageous routings.
3.) As evidence shows, it would not reduce the number of passengers or flights as the fierce competition in the aviation market - including from airlines with hubs outside the EU - would allow only a part of the cost to be passed through to ticket prices. Demand for air travel is mostly driven by GDP and – as the pandemic has shown - travel opportunities. This would have a negative impact on the profitability of certain routes, leading to a reduction of connectivity if such routes could no longer be served profitably.
Read full responseResponse to ReFuelEU Aviation - Sustainable Aviation Fuels
18 Nov 2021
As the association of the network carriers of the European Union, ACP firmly supports the ambitions laid down in the Fit for 55 package and its objective to become CO2 neutral by 2050. ACP is committed to sensible environmental legislation, a better integration into a European transport network, but most importantly technological investments in solutions that will shape the future of aviation. However, considering the particular international nature of the aviation industry, it is essential that all measures are seen in a global context, and unilateral policy initiatives are avoided. Policies and measures implementing the Green Deal for aviation should either be applied and enforced for all airlines serving the European market, or distortion of competition resulting from costs for EU airlines neutralised by designing policies in such a way that distortive effects are eliminated. Connecting Europe with the world requires strong European network carriers with sustainable hubs in Europe offering high quality jobs for thousands of EU citizens. Such a comprehensive policy approach will be even more urgent in view of the unprecedented crisis the aviation industry is currently undergoing.
The use of sustainable aviation fuels is considered as one of the most realistic and effective means to reduce aviation CO2 emissions in the next decades. However, the problem lies in the fact that the current cost to produce SAFs is three to ten times that of conventional jet fuel, depending on the feedstock used. As a result of these higher production costs and the currently limited supply, SAFs are currently - in the absence of an orchestrated support strategy - not an economically attractive substitute to conventional jet fuel.
The ReFuelEU Aviation initiative proposes the introduction of a so-called blending mandate as a means to boost production of SAFs. The proposed blending mandate is the obligation on fuel suppliers to blend a certain amount of SAF with all aviation fuel uplifted at all EU airports. Given that the price of SAFs is and will remain higher than conventional fuel, the proposed blending mandates for SAFs and for SAFs of non-biological origin would in their current form, as introduced in the proposal, adversely impact the competitiveness of EU airlines.
A mandate that would only apply to flights within the EEA would put European airlines at a disadvantage, because feeder flights to European hubs would be included, whilst feeder flights of non-EU carriers to hubs outside the EU would not – a situation similar to the one described above regarding the EU ETS. Also, traffic connecting through an airport in the EU risks being diverted to hubs outside the EU (e.g. flying from the USA via Istanbul to India rather than via Paris or Munich).
From an ecological point of view, a mandate without regulatory safeguards could have unintended consequences such as lowering sustainability standards, because some airlines may seek to fulfil their obligations with the cheapest option available, e.g. by using HEFA (hydrotreated esters and fatty acids) or feedstock-based (e.g. palm oil) fuels instead of future-proof technologies such as lingo-cellulose feedstock fuels or synthetic fuels (e-fuels) produced from sustainable power sources and CO2. Consequently, this leads to unnecessary extra CO2 emissions. These potential negative effects on the environment should be avoided.
Read full responseResponse to Updating the EU Emissions Trading System
8 Nov 2021
In order to achieve the CO2 reduction target of the sectors covered by the EU ETS, the Commission intends to address both the reduction of the total number of allowances (cap) and an increase of the auctioning share of allowances (reduced free allocation). It is worth recalling that the intention of the free allowances in aviation was to address competitive disadvantages in relation to third countries.
The market-based approach to the reduction of CO2 emissions is principally correct and efficient. However, the same conditions must apply to all global competitors. Only then will the EU ETS have its desired steering effect. At present, the EU ETS distorts competition in global aviation, because its scope is limited to the European Economic Area (EEA). Airlines will have to buy CO2 allowances for flights departing from and arriving at destinations in the EEA. This also affects intra-European feeder flights to European hubs. At these hubs, EU network airlines efficiently bundle their passengers feeding long-haul flights. The EU ETS thus creates a level playing field among hubs within the EEA.
On the other hand, flights which start in the EEA and make an intermediate stop or end outside the EEA are excluded from the EU ETS. Accordingly, feeder flights to hubs outside the EEA enjoy a financial advantage. Due to their geographical proximity to the EEA, airlines and hubs in Turkey as well as the Near and Middle East in particular benefit from this unequal treatment. The EU ETS, therefore, tends to favour companies from those regions, which already have a cost advantage over their European competitors due to lower environmental, social and consumer protection standards.
However, the effects of the EU ETS are not limited to direct competition - the absolute cost burden is also affected. EU network airlines compete globally with network airlines from other continents, which are not subject to similar systems. The regionally limited EU ETS reduces the investment power of airlines needed to compete with intercontinental competitors.
Possible solutions
1. Establish a Carbon Border Adjustment Mechanism (CBAM) for aviation
A Carbon Border Adjustment Mechanism is a method to reduce or eliminate the distortion of competition. It has already been proposed for other sectors. As aviation has been identified as the fourth most exposed sector to carbon leakage , we feel a similar instrument is warranted for aviation.
2. Alleviate financial burden on EU feeder flights within the EU
The risk of carbon leakage could be addressed by introducing a compensation targeting only the fraction of traffic actually exposed to this risk. These modifications could be achieved without reducing the overall CO2 emission reduction ambitions, or limiting the effectiveness of the EU ETS.
A formula to calculate the compensation for airlines is relatively simple. In a first step, all airlines report annually the total amount of passengers, who transfer via an EEA-hub to an extra-EU destination. Via such a formula, fuel consumption is allocated to individual passengers, and the outcome of such a formula shows the compensation that an airline should receive on the basis of traffic that is actually exposed to the risk of carbon leakage.
The payment of this compensation could be done in the form of “fair compensation allowances”.
3. Integrate environmental compliance in the EU comprehensive air transport agreements
In principle, air transport agreements should allow for the integration of third country hubs into the EU ETS. EU comprehensive air transport agreements that have not yet been signed or pending bilateral agreements could be therefore amended accordingly. By doing so, flights by third country airlines feeding into their non-EEA hubs would be integrated into the EU ETS on a mandatory basis. For existing agreements, the Joint Committees could also work towards their subsequent inclusion in the EU ETS, although this could be an extremely difficult process.
Read full responseResponse to Addressing distortions caused by foreign subsidies
20 Jul 2021
The Airline Coordination Platform welcomes the proposed new regulation to address distortions caused by foreign subsidies and emphasizes the timeliness of such a regulation, particularly in the wake of the COVID-19 pandemic that hit the EU aviation industry hard and as a result put EU airlines in a vulnerable situation, more exposed to foreign investments.
European airlines and its employees have been affected by unfair competition from state-subsidised third country airlines for years. The EU ownership and control rules laid down in Regulation (EC) 1008/2008 are currently the backbone for the independence of European aviation, as they prohibit majority stake - and shareholdings by foreign entities. There is however a lack of enforcement of this Regulation that should be done by individual Member States. Though not yet applied, Regulation (EU) 2019/712 addresses the problem of competitive distortions caused by subsidies to third-country airlines resulting in unfair practices (e.g. capacity/price dumping/discrimination). There is, however, no applicable legislation that deals with subsidies granted by third countries to EU airlines or other relevant EU entities, including in the framework of acquisitions. Therefore, as long as there is no breach of the ownership and control rules, there is no mechanism in EU law to deal with such practices. Nonetheless, even below this threshold, financial contributions from third countries (often via third country airlines) can have a clearly distortive effect in the EU aviation market.
However, the current proposal does not make it sufficiently clear whether the new regulation will apply alongside Regulations (EC) 1008/2008 and (EU) 2019/712. ACP considers it important that the new regulation is complementary to existing ones and it addresses subsidies from third countries to EU airlines. Furthermore, it is critical that both direct and indirect subsidies are addressed as in the aviation world it is often a third-country national or state-subsidised airline subsidising an EU-entity rather than the third country directly.
Already, EU carriers are subject to more stringent European and national environmental and consumer protection standards than most of their non-EU competitors. A number of their main non-EU competitors – with often lower social protection for employees leading to lower operational costs - received (unconditional) subsidies, which further distort the EU airlines’ competitiveness (EU airlines are heavily scrutinized and often face remedies when receiving state support). Many of these subsidised airlines invested in European carriers, tapping into the market, causing serious distortion.
We would particularly appreciate the Commission’s clarification regarding the interpretation of Chapter 6, Art. 40, paragraph 6:
“This Regulation is without prejudice to the application of Regulation (EU) 2019/712 of the European Parliament and of the Council. Notifiable concentrations, as defined in Article 18 of this Regulation, involving air carriers shall be subject to the provisions of Chapter 3. Public procurement procedures, as defined in Article 27 of this Regulation, involving air carriers shall be subject to the provisions of Chapter 4.”
As the two regulations cover two different scenarios and there is no overlap (in fact, the purpose of the regulation is to close a gap in legislation), we would like to understand why there is a need to regulate their relation to each other when there is none.
In addition, the new proposed regulation covers three “components”: a) concentrations, b) procurement and c) all other market situations. The paragraph above covers the first two and clarifies that they are subject to certain chapters of the new regulation. There is however no mention of component c), which is the one that applies to subsidies of third countries and/or their airlines in EU airlines that have been most prevalent – and unenforceable - in the past.
Read full responseMeeting with Pablo Fabregas Martinez (Cabinet of Commissioner Adina Vălean)
21 Jun 2021 · Call to discuss the social aspects of aviation.
Response to Addressing distortions caused by foreign subsidies
29 Oct 2020
The Airline Coordination Platform (ACP) welcomes the European Commission’s initiative addressing possi-ble distortions caused by foreign subsidies. When drafting a legislative proposal, the European Commission should ensure that the aviation industry is included in the scope of a future legislative framework on foreign subsidies. European airlines in particular have for years been affected not only by unfair competition from third country airlines but also by foreign subsidies to their European competitors. In the post-COVID recov-ery phase, foreign subsidies are prone to have an even greater distortive impact on an industry which has been especially hard hit by the pandemic.
In the past, such subsidies were granted in the form of generous (and existential) loans or equity injections, where no financially reasonable investor or lender would have granted such support. In some cases it reached an extent where it led to the foreign entity having factual, if not legal control over the receiving EU airline. In such cases, complaints to the Commission for breach of the EU ownership and control regime laid down in Regulation (EC) 1008/2008 was the only venue open to ward off distorting practices. The test for foreign control, however, is strict and the requirement of EU control does not capture practices below the level of a foreign entity actually gaining control. Regulation (EC) 1008/2008 is, therefore, not applicable to many of the cases described in the impact assessment.
The recently adopted Regulation (EU) 2019/712 addresses distortions caused by subsidies to third-country airlines, but neither addresses the problem described in the inception impact assessment, as it does not deal with subsidies granted by non-EU authorities or entities to EU airlines or other EU companies in the aviation industry (such as manufacturers, maintenance organisations, distribution systems, catering, ground handling companies, etc.). As in other sectors, such uncontrolled foreign subsidies can have a substantial distortive effect on the EU aviation market.
The members of the ACP therefore consider that there is a need for the new instrument including the Euro-pean aviation industry, complementary to existing regulations. The new tool should take into account the different forms in which subsidies can occur, be it direct financial support from a third-country government or through foreign state-owned companies, which grant financial advantages to or invest in European avia-tion companies.
Given the above, ACP supports legislative action(s) at EU level (Policy option 2) that complement(s) exist-ing EU regulations (e.g. Regulation (EC) 1008/2008 and Regulation (EU) 2019/712).
Read full response