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Europeans for Fair Competition

E4FC

Europeans for Fair Competition is a coalition of EU airlines and unions.

Lobbying Activity

Meeting with Marc Angel (Member of the European Parliament)

4 Nov 2025 · Social challenges and fair competition in European aviation

Aviation coalition E4FC demands priority in sustainable transport funding

2 Sept 2025
Topic — The initiative provides a strategic framework for funding the European transport energy transition.
Message — E4FC requests prioritising aviation and introducing corrective measures like a carbon border mechanism. They argue carbon trading revenues from aviation should be reinvested into sustainable fuel projects.12
Why — This financial support would reduce the high cost of climate compliance and maintain global competitiveness.34
Impact — Non-EU airlines would face new costs to mitigate the competitive advantage of lower regulatory standards.5
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E4FC urges stronger labor rules to protect airline competitiveness

11 Jun 2025
Topic — The European Commission is updating rules governing airline operations and worker protections.
Message — The coalition wants to tackle bogus self-employment and fictitious home bases. They advocate for a clear legal definition of an airline's operational base.123
Why — These measures would protect established European airlines from being undercut by rivals.4
Impact — Foreign airlines and investors would face stricter limits on European market access.5
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Meeting with Eva Schultz (Cabinet of Executive Vice-President Roxana Mînzatu), Francesco Corti (Cabinet of Executive Vice-President Roxana Mînzatu)

23 Apr 2025 · Meeting on intra-EU competition in the aviation sector

E4FC urges EU to end aviation's social law circumvention

30 Jan 2025
Topic — The Commission initiative aims to remove single market barriers and foster global competitiveness.
Message — E4FC calls for a harmonized EU framework to prevent the circumvention of labor laws. They demand better enforcement by national authorities to eliminate legislative fragmentation.12
Why — Harmonized standards would protect airlines following rules from unfair competition and market distortion.3
Impact — Carriers using complex business models to avoid social security and tax obligations would suffer.45
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E4FC urges social standards in new flight emission labels

22 Oct 2024
Topic — Consultation on creating a common methodology for voluntary flight environmental labelling.
Message — The group requests that the label includes social responsibility and fair labor standards. They also want a methodology that allows the flexible allocation of sustainable fuel to specific flights.12
Why — Network airlines would avoid ratings disadvantages stemming from their complex operations and higher labor costs.3
Impact — Low-cost carriers with minimal labor protections would lose the advantage of a purely environmental rating.4
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Meeting with Johan Danielsson (Member of the European Parliament)

17 Oct 2024 · Konkurrenskraft och arbetsvillkor i flygsektorn

Meeting with Jens Gieseke (Member of the European Parliament)

1 Oct 2024 · Austausch zur Europapolitk

Meeting with Daniel Attard (Member of the European Parliament) and Forward Global and ChargeUp Europe

18 Sept 2024 · Introductory Meeting

Europeans for Fair Competition urges retaining airport slot rules

6 Jun 2024
Topic — A review of EU airport laws regarding competition, capacity, and decarbonisation goals.
Message — E4FC believes that the current Slot Regulation continues to be fit-for-purpose. They argue the five-week minimum series length provides the right operational framework. Significant revisions are considered unnecessary, as guidelines would be sufficient.123
Why — Staying with current rules avoids extra operational constraints and maintains hub efficiency.45
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Meeting with Aleksandra Baranska (Cabinet of Vice-President Maroš Šefčovič), Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

23 Jan 2024 · Aviation

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

23 Jan 2024 · Aviation Industry

Response to 2024 Evaluation of the European Labour Authority

21 Dec 2023

Over recent years, the EU Single Aviation Market has experienced heightened competition due to the emergence of new airline business models and increased accessibility for non-EU carriers. These evolving business models frequently circumvent applicable labour and social laws, undermining social rights and creating distortions in fair competition, as opposed to legacy airlines who respect decent social standards which obviously comes at extra costs. Therefore, we cannot speak of a (social) level playing field on intra-EU operations. Examples of these unfair practices include the establishment of fake or fictitious home bases, fraudulent manipulation of social security certificates, exploitation through bogus self-employment, improper use of worker posting, and the lack of oversight in national and transnational operations, leading to a near absence of enforcement of social laws. The lack of a comprehensive EU-wide social legislation concerning air crew, coupled with significant variations in labour laws across Member States, resulted in a fragmented regulatory framework. Consequently, effective enforcement of rules governing cross-border mobility suffers. Therefore, Europeans for Fair Competition (E4FC) has welcomed the establishment of the European Labour Authority (ELA) and firmly believes that the ELA should assume a central role in addressing the challenges pertaining to cross-border mobility within the European aviation sector. ELA's proactive involvement in aviation is crucial to combat the circumvention of social laws and tackle the aforementioned issues.
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Meeting with Agnes Jongerius (Member of the European Parliament)

25 Oct 2023 · Staff level: Resolution on the mandate of ELA

Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion)

10 Jul 2023 · Competitiveness of EU network airlines social standards in aviation

Europeans for Fair Competition urges 2040 targets to protect aviation competitiveness

23 Jun 2023
Topic — The EU is establishing a 2040 climate target to achieve neutrality by 2050.
Message — The coalition demands a thorough impact assessment of climate policies on airline competitiveness. They advocate for a level playing field through global standards and carbon border taxes.12
Why — These measures would protect European carriers from cost disadvantages against non-EU competitors.3
Impact — Non-EU airlines would lose their price advantages gained from lower costs and state support.4
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Response to Updating the reporting on fluorinated greenhouse gases

3 Mar 2022

Europeans for Fair Competition (E4FC) welcomes 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. E4FC is of the view that the Joint Communication should address air transport and particularly the challenges in this field. The EU and the Gulf Cooperation Council were working intensively on issues related to regulatory convergence and level playing field as a result of which the European Commission requested mandates from the EU Member States to negotiate comprehensive air transport agreements with the State of Qatar, the United Arab Emirates (UAE) and the Sultanate of Oman. While the UAE rejected to negotiate such an agreement with the EU, the EU signed a comprehensive air transport agreement with the State of Qatar (October 2021) and initialled one with the Sultanate of Oman (December 2021). The scope of these agreements go much further than just market access as they aim to provide provisions on regulatory convergence and fair competition as well as social and environmental standards. The above mentioned two agreements and their diligent enforcement could provide first steps in creating a balanced aviation relationship with countries from the Gulf region. To do this, they should be amended to create concrete and binding steps regarding decarbonisation and social rights. The COVID-19 pandemic has led to the deepest crisis in the history of air travel with global passenger traffic currently expected to return to pre-pandemic levels in 2024 at the earliest. This has a significant impact on the aviation in the EU and the GCC given that these sectors are major employers and sources of economic income in both regions. The very recent developments in Ukraine and the subsequent sanctions against Russia – including the closure of EU airspace from Russian carriers – will also impact relations between the two regions. With regard to the decarbonisation ambition of the EU, it will need to be addressed how the Gulf can support the EU’s effort to be climate neutral by 2050, including in the field of aviation. New EU priorities in the context of globalisation, such as the green economy and digital transformation, and the focus on inclusive sustainable growth, offer new innovative avenues for cooperation. While the air transport agreements with Gulf states include some language on social provisions, the Joint Communication should address social standards as well as labour rights issues according to the principles laid down in the European Pillar of Social Rights and thereby safeguarding competition on equal terms. Lastly, E4FC would also like to stress the importance of addressing the economic, social and environmental sustainability challenges comprehensively. E4FC believes that the importance of creating partnerships and agreements that incorporate fair competition within all three areas should be strongly underlined. If partnerships and agreements are weak in one area, it will likely cause adverse effects for the EU aviation industry and labour market, consequently distorting the market conditions in the EU. Such distortion would greatly counteract the EU’s current efforts in addressing the challenges of creating long-term economic, social and environmental sustainability.
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Meeting with Rachel Smit (Cabinet of Commissioner Adina Vălean)

3 Feb 2022 · Meeting to discuss the latest developments regarding aviation

Response to Revision of the Energy Tax Directive

17 Nov 2021

EU airlines and their employees have already and will continue to substantially invest in decarbonisation. E4FC members, therefore, welcome the proposed measures to significantly reduce CO2 emissions and to achieve CO2-neutrality in aviation by 2050. However, the Fit for 55 proposals contain certain elements that will increase the risk of carbon leakage due to substantial cost increases for European companies and competitive distortions vis-a-vis third country carriers, if no adjustments are made. The introduction of fuel taxes would merely have a marginal positive impact on the environment by reducing demand, therefore the members of E4FC strongly oppose the Commission’s proposal as the foreseen taxation system does not contribute to the objective of effectively reducing greenhouse gas emissions. Such a tax does not make the (future) flights more sustainable. EU airlines are committed to effective, sustainable solutions and are ready to directly invest in sustainable fuels and new, environmentally friendly aircraft that are at the heart of decarbonising the industry. But the design of this tax leads governments to take away financial resources from the airlines that could otherwise be allocated to this cause, but instead it will be detrimental to the global competitiveness of the EU aviation industry, including its jobs. A tax may result in unintended negative consequences such as detours and consequently higher CO2 emissions. For more information, please see the attached E4FC position paper.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

17 Nov 2021

The proposed ReFuelEU Aviation Regulation aims to increase the production and uptake of SAFs in Europe in the coming years. For the foreseeable future, however, SAF will be more expensive than fossil fuels. Therefore, an unbalanced SAF mandate would distort competition with the rest of the world and shift traffic outside of the EU. E4FC advocates for financial support for the development and deployment of SAFs bridging the price gap between fossil fuels and SAFs, which are currently three to six times more expensive. Synthetic fuels are even eight to ten times more expensive than regular kerosene. While the current proposal ensures a level playing field only for intra-EU traffic, it has significant distortive effects regarding intercontinental journeys, including feeder flights. These effects will not be solved by the proposed prevention of tankering practices, as it is neither feasible, nor does it address long-haul flights from non-European hubs. Taking, for instance, a flight from Madrid via Frankfurt to Beijing and back, EU airlines are subject to the elevated fuel price for three out of four flights. In contrast, the SAF-blending target affects non-EU airlines only for the first flight to its non-EU hub. The second, longer flight is not covered by the regulation, nor is the return journey from a non-EU hub to Europe. The SAF mandate must, therefore, be designed in such a way that it ensures an ambitious growth market for SAF and at the same time a level international playing field.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

The members of E4FC are fully committed to reducing their carbon footprint and support the ambition set out in the European Commission’s Fit for 55 package. The proposed initiatives will however require substantial investments and will add to the costs of European airlines, thereby impacting the global competitiveness of European network airlines and their employees. Therefore, airlines and employees together with the other stakeholders in the value chain will have to work together with policymakers to agree on adaptations of parts of the proposals with a dual objective: define new, smart legislation that helps the realisation of the ambitious plans and does not lead to carbon leakage. Aviation is a global industry, therefore, unilateral measures could be counter-productive and could result in distortion of competition within the EU as well as globally. While the European Commission’s proposal for the Carbon Border Adjustment Mechanism is not applicable to aviation, the principle of carbon leakage for the aviation sector should be recognised by the regulators and remedies should be construed, e.g. in the revision of EU ETS. The revision of the EU ETS must address the risk of carbon leakage and thereby ensure a level playing field between EU and non-EU carriers. In the current EU ETS, airlines receive free allowances non-specifically and without direct connection to the degree of potential competitive disadvantage. To address the problem of carbon leakage adequately and to allow for a smart, balanced and more efficient regulation, a new and different system could be introduced that specifically targets the fraction of air traffic actually exposed to the risk of carbon leakage. For more information, please see attached position paper.
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Response to Addressing distortions caused by foreign subsidies

16 Jul 2021

E4FC welcomes the proposed new regulation to address distortions caused by foreign subsidies and emphasizes the timeliness of such a regulation, in view of the current weakened state of the European airline industry that exposes the sector to direct or indirect takeovers. 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 (e.g. Qatar Airways’ investment in Air Italy or Etihad’s investment in Air Berlin), 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. E4FC 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 (e.g. Qatar Airways shares/capital raise in IAG). 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 (e.g. Qatar Airways investment/loans to Air Italy, Etihad investment/loans to airberlin). We would 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), E4FC would like to understand why there is a need to regulate their relation to each other when there is none. 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 examples of ownership and control in EU airlines.
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Meeting with Pablo Fabregas Martinez (Cabinet of Commissioner Adina Vălean)

16 Jun 2021 · Key policy priorities for the future of the EU aviation industry

Response to Updating the EU Emissions Trading System

25 Nov 2020

E4FC supports the ambition of the EU to reduce carbon emissions. European airlines have long been working to reduce their CO2 output with investments in new aircraft and technologies, the development and use of sustainable aviation fuels, operational improvements and the participation of aviation in the EU Emissions Trading System (ETS) as well as the global carbon offsetting program, CORSIA. The European Green Deal is a comprehensive policy approach, encompassing several elements applicable to aviation, most markedly the revision of the EU ETS and the “ReFuel Aviation” initiative promoting sustainable fuels. It is clear that the increased efforts under the European Green Deal will require investments and significantly add to the costs of European airlines, thereby negatively impacting the global competitiveness of European network carriers. At the same time, the very mechanisms that put EU airlines at a competitive disadvantage also create the potential for something akin to “carbon leakage”, thereby counteracting the desired environmental effect. An example is the current EU ETS: The current scope covers only flights to, from and within the European Economic Area (EEA) but does not include flights between the EEA and third countries. This means on a trip from the EEA with a transfer at a European hub, the feeder flight is subject to the ETS. On a trip with a transfer outside the EEA (such as Istanbul, Dubai or, in the future, London), the ETS does not apply. This does not only put EU airlines and EU hubs at a competitive disadvantage, but it also encourages price-sensitive passengers to fly detours via hubs outside the EU, potentially increasing fuel consumption and emissions. A similar effect would occur if the proposed “Refuel Aviation” legislation obliges airlines to use expensive sustainable fuels in Europe, but not elsewhere. There are solutions to avoid such distortions und unintended environmental consequences. The introduction of a carbon border adjustment mechanism for example can ensure the level playing field between EU airlines and third country carriers. However, if the EU cannot succeed in this effort, feeder flights to EEA hubs could be exempted from the ETS, thereby levelling the playing field. Alternatively, comprehensive air transport agreements (CATAs) could make it a condition that third country airlines are bound by EU environmental legislations, also ensuring a level playing field. E4FC therefore calls upon policy makers to ensure that sustainability standards or any other mechanisms under the European Green Deal are crafted in such a way that competitive disadvantages and unintended environmental consequences are avoided. This is particularly important at a time where the COVID-19 pandemic has hit European aviation hard and airlines will struggle for years to regain footing. The pandemic has already led to an unprecedented loss of jobs in the aviation sector: In Europe alone, six million jobs are at risk. The European Green Deal should not be responsible for increasing this tally – and it is our view that it does not need to - if legislations are smart and directed to ensure a level playing field.
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Response to Addressing distortions caused by foreign subsidies

29 Oct 2020

Europeans For Fair Competition (E4FC) welcomes the European Commission’s plans to propose a regulation that addresses distortions caused by foreign subsidies in the internal market. E4FC agrees that the granting of (direct and indirect) subsidies can lead to unfair competition and undermine the level playing field, thereby distorting the EU internal as well as the international market. E4FC has been advocating for the enforcement of international and EU-level aviation and trade rules, maintaining high social standards and ensuring fair and equitable competition and a satisfactory level playing field. Hence, E4FC has been stressing the crucial importance of an EU-based airline industry, which best serves Europe’s strategic, economic and social interests in securing jobs, enabling continued investments and ensuring competitiveness and connectivity. European network airlines operate in a highly competitive international environment. They are subject to European and national environmental standards that are more stringent than most of their global competitors. A number of non-EU airlines – with often lower social protection for employees resulting in lower operational costs – have received significant subsidies on a regular basis even before the COVID-19 pandemic. Some of these subsidised airlines have invested in or are financing European carriers primarily for strategic reasons, causing serious market distortion by expanding their network in the EU market (e.g. Qatar Airways investments into IAG and Air Italy, Etihad investment into airberlin, etc.). Regulation (EC) 1008/2008 limits foreign investment in EU carriers up to 49% and requires control by EU-based entities. In the past, EU carriers have argued that certain financing of their competitors by subsidised third-country airlines amounted to third-country control. However, control in these carriers is ambiguous and difficult to assess and consequently complaints were unsuccessful. The yet untried Regulation (EU) 2019/712 addresses the competitive distortion caused by subsidies to third-country carriers, not to EU carriers and is therefore also not applicable to the cases contemplated by the consultation. The new legislative proposal on foreign subsides should fill that gap and it is needed to address such situations in the air transport sector. It will be important to ensure that the new tool takes into account the different forms in, which subsidies can be provided in the aviation industry such as loans and equity. Furthermore, it is critical that both direct and indirect subsidies are addressed as in the aviation industry it is often a state-subsidised airline subsidising an EU-entity rather than the third country directly (e.g. Qatar Airways shares in IAG). E4FC therefore advocates for a legislative action at EU level (Policy option 2) that complements existing EU acquis (e.g. aforementioned Regulation (EC) 1008/2008 and Regulation (EU) 2019/712.
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