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General Aviation Manufacturers Association

GAMA

The General Aviation Manufacturers Association represents over 140 manufacturers of general aviation aircraft, engines, avionics, and related services, including emerging electric and autonomous flight technologies.

Lobbying Activity

General Aviation Manufacturers Association urges green taxonomy inclusion

5 Dec 2025
Topic — The Commission is updating technical criteria for the EU's green investment classification system.
Message — GAMA requests including small aircraft and business jets in the green investment rules. They argue these platforms are the cradle of innovation for clean aviation.12
Why — This would remove an innovation penalty and signal that Europe is open for business.34
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Meeting with Seán Kelly (Member of the European Parliament) and EUROPEAN BUSINESS AVIATION ASSOCIATION

11 Nov 2025 · State of the Irish aviation industry

GAMA urges relaxed state aid rules for aviation deep-tech

1 Oct 2025
Topic — The Commission is revising rules that exempt specific state aid from prior notification.
Message — GAMA requests revising 'Undertaking in Difficulty' criteria that currently impede capital-intensive deep-tech companies. They propose relaxing loss limits or removing employee caps for aid eligibility. The association also suggests technology-neutral programs offering high funding rates and grants.123
Why — Aviation manufacturers would gain easier access to national funding for innovative green technologies.45
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Response to European Innovation Act

29 Sept 2025

The General Aviation Manufacturers Association (GAMA) thanks the European Commission for the opportunity to submit comments in response to the Call for evidence for an impact assessment for a European Innovation Act. Please find GAMA's detailed comments in the attached document.
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Aviation Manufacturers Urge EU to Adopt Fuel Book and Claim

3 Sept 2025
Topic — The consultation seeks a strategic framework for the energy transition in EU transport.
Message — GAMA calls for a “virtual ticketing mechanism” to decouple physical fuel from environmental credits. This would allow operators at smaller airports to claim the benefits of sustainable fuel even without a local physical supply.12
Why — This mechanism would lower operational costs and simplify logistics for business aviation operators.34
Impact — Regional development goals could be undermined if fuel production concentrates only in industrial clusters.5
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GAMA urges EU to fund smaller clean aviation projects

7 Jul 2025
Topic — European Commission consultation evaluating the operational effectiveness of the EU Innovation Fund.
Message — GAMA suggests revising rules to include aircraft under 5700kg and simplifying the complex application process. They propose a tiered submission system and performance-based funding milestones to better support small innovators.123
Why — Member companies would access new funding opportunities while reducing the high costs of grant applications.45
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GAMA opposes expanding EU emissions trading for aviation

7 Jul 2025
Topic — Review of the EU emissions trading system for maritime and aviation sectors.
Message — The organization opposes expanding the emissions trading scheme to all departing flights. They advocate for a global approach to pricing emissions to avoid double taxation.12
Why — Limiting the tax scope prevents high costs that would weaken European industrial competitiveness.34
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Response to EU Emissions Trading System - update of Verification and Accreditation Regulation (AVR), Batch 2

17 Apr 2025

The General Aviation Manufacturers Association (GAMA) thanks the European Commission for the opportunity to comment on the proposed update of the AVR Regulation (Batch 2). Please see our detailed comments in the attached document.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

The General Aviation Manufacturers Association (GAMA) thanks the European Commission for the opportunity to comment on the Net Zero Industry Acts (NZIA) proposed Delegated Act on primarily uses components for the production of net-zero technologies. Our comments can be found in the attached paper.
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Meeting with Pierpaolo Settembri (Cabinet of Commissioner Apostolos Tzitzikostas)

4 Feb 2025 · exchanged views with GAMA

Meeting with Filip Cornelis (Director Mobility and Transport) and

23 Jan 2025 · Meeting with GAMA members at their Committee Meeting

Response to Restriction updating Annex XVII REACH regarding CMRs (2023)

2 Jan 2025

The General Aviation Manufacturers Association (GAMA) and the wider General Aviation sector in Europe fully support the European Commission's proposal to add a derogation for cumene for aviation fuel uses in Appendix 11 of Annex XVII of the REACH Regulation. This derogation will give much need legal certainty for the continued operation by 600,000 non-commercial / private / recreational pilots of approximately 80,000 aircraft using Aviation Gasoline (Avgas) or kerosene (Jet-A/Jet-A1), operating from around 4,000 EU airports and airfields. We therefore encourage the speedy adoption of this amendment to ensure the continued operation of this important sector of European aviation.
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Meeting with João Cotrim De Figueiredo (Member of the European Parliament)

18 Dec 2024 · Industrial policy

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

17 Dec 2024 · general exchange on the current challenges for innovative aviation

Meeting with Kris Van Dijck (Member of the European Parliament)

17 Dec 2024 · European Business Aviation

Meeting with Jens Gieseke (Member of the European Parliament)

17 Dec 2024 · Austausch zu EU Politik

Meeting with Daniel Attard (Member of the European Parliament)

17 Dec 2024 · Electric Aviation

Meeting with Angelika Winzig (Member of the European Parliament)

18 Nov 2024 · Meeting with a representative of GAMA

Meeting with Daniel Attard (Member of the European Parliament)

6 Nov 2024 · Electric Aviation

GAMA urges scientific caution on EU non-CO2 aviation reporting

29 Jul 2024
Topic — The initiative updates rules for monitoring and reporting non-CO2 aviation emissions under the EU ETS.
Message — GAMA requests that the MRV focus purely on data reporting rather than converting impacts into CO2 equivalents. They propose a standard yearly review and formal roles for stakeholders in the process.12
Why — This approach prevents business aviation operators from facing burdensome requirements and inflated climate impact measurements.3
Impact — Environmental advocates lose a potential regulatory basis for pricing non-CO2 aviation climate impacts.4
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Meeting with Héloïse Auplat (Cabinet of Executive Vice-President Margrethe Vestager)

11 Jun 2024 · Presentation of GAMA’s White Paper on Electric Aviation with a focus on GAMA’s recommendations regarding State aid

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 Erik Bergkvist (Member of the European Parliament, Rapporteur)

21 Sept 2023 · Möte (APA level)

Aviation groups urge EU to include small aircraft in Taxonomy

3 May 2023
Topic — This consultation defines sustainable investment criteria for economic activities under the EU Taxonomy.
Message — The industry requests the inclusion of aircraft carrying 19 passengers or less within the Taxonomy. They advocate for aligning noise and emissions standards with international ICAO rules.12
Why — Inclusion would secure essential investments for small aircraft manufacturers and ensure a level playing field.34
Impact — Remote European regions and emergency services lose essential connectivity and vital innovation funding.56
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Aviation manufacturers urge inclusion of small aircraft in Taxonomy

2 May 2023
Topic — The initiative establishes a classification system for sustainable economic activities for investment purposes.
Message — GAMA requests that aircraft carrying 19 passengers or less be included in the EU Taxonomy. They also recommend aligning carbon and noise standards with international ICAO requirements.12
Why — This would help manufacturers avoid higher financing costs and maintain global market competitiveness.34
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Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

Dear Madam or Sir Please find attached GAMA’s feedback on low-emission vehicles – improving the EU’s refuelling/recharging infrastructure. Please feel free to contact me, should you require any additional information or have any questions. Best regards Raphaël Fabian Raphaël R. FABIAN Director, European Affairs
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Response to Revision of the Energy Tax Directive

18 Nov 2021

Dear Madam or Sir Please find attached GAMA’s feedback on the EU Green Deal – Revision of the Energy Taxation Directive. Please feel free to contact me, should you require any additional information or have any questions. Best regards Raphaël Fabian Raphaël R. FABIAN Director, European Affairs
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

18 Nov 2021

Dear Madam or Sir Please find attached GAMA’s feedback on the Sustainable aviation fuels – ReFuelEU Aviation. Please feel free to contact me, should you require any additional information or have any questions. Best regards Raphaël Fabian Raphaël R. FABIAN Director, European Affairs
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Response to Draft amendment of Annex XIV to the REACH Regulation

21 Jul 2021

Our constituency would be directly impacted by the inclusion of Tetraethyllead (TEL) in Annex XIV as this substance is a key component in 100LL aviation gasoline which is the only fuel that is currently certified and approved for use in over 16,000 General Aviation aircraft registered in the EU. This represents around one third the EU´s aviation fleet. We fully support the efforts of the EU and ECHA in support of the European Environmental objectives in general, and also more specifically in the case of TEL. Obviously, it needs to be ensured that hazardous substances are carefully controlled, and that citizens are always protected. Our industry, on a global level is already fully working towards finding a replacement high octane aviation gasoline without the additive TEL. However, such a replacement fuel without TEL has not been approved and we would therefore request the European Commission to postpone the inclusion of TEL in Annex XIV until such times as a replacement fuel has been successfully made available on the European market. It should be worth noting that over time TEL-consumption is already in a strong and continuing decline: understanding that only a few decades ago, Avgas 100LL containing TEL was the only aviation fuel available. This situation has clearly improved, and the trend is still continuing: Lower power piston-engines up to approx. 180 hp mainly run on lead-free aviation or automotive fuels, while larger piston engines over 400hp are gradually being replaced by turbine-engines consuming Jet A1. The first electric aircraft was already certified by EASA and entered the market with high success, with many more are expected to come soon. The agreed objective of our industry is to significantly further reduce the TEL consumption until it is no longer used for aviation fuel at all, and our efforts show positive results. We also fully support the PAFI programme in the United States with the objective to find a lead-free replacement for TEL. The PAFI-project has made good progress to date, but has not yet come to the desired result of phasing out TEL. In this context we would strongly suggest proper funding for a European research activity on a TEL-replacement. Over time such an activity could be complemented by research for a carbon-free piston-engine fuel. We are aware that this recommendation is clearly supported by the EASA. A promising interim solution worth consideration would be the use of Avgas 100VLL, “Very Low Lead”, with a substantially reduced maximum allowed TEL content by 20%, which is covered by the pertinent fuel-specifications. As a penultimate point we would strongly like to suggest revisiting the REACH risk assessment. After Brexit the relevant TEL-quantity should be around 90% below the magnitude of the 2018 figures in the current risk assessment. The reason is that the only remaining TEL-producer worldwide, “Innospec”, is based in the UK, and consequently the TEL-risk assessment of 2018 was still based on the figures of the UK company Innospec producing TEL for the world-market. The EU´s TEL-market only has a share in the order of 10% of the world-market. Finally, we would like to draw your attention to the need to avoid a foreseeable economic reaction, in which an authorisation for TEL is either not requested or granted: all Avgas 100LL supplied to aircraft in the EU would have to be made by shipping TEL from the UK to the USA, blending it, then importing it back from the USA into the EU, damaging the business of the current EU blending facilities and leading to significant environmental costs as well as additional shipping costs that would have to be borne by EU citizens. In conclusion, we see the risk that by the inclusion of TEL into the Annex XIV, the EU´s citizens would not benefit and the EU´s General Aviation industry, in most cases SMEs and private individuals would suffer from uncertainties and increased cost. Even the ecological cost for longer distribution channels would increase.
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Response to A Drone Strategy 2.0 for Europe

2 Jul 2021

Dear Madam or Sir Please find attached GAMA's feedback on the Drone Strategy 2.0 for Europe roadmap. Please feel free to contact us, should you have any questions or require additional information. Best regards Raphaël Fabian Raphaël R. FABIAN Director, European Affairs M: +32 (0)492 56 10 51 E: rfabian@gama.aero General Aviation Manufacturers Association (GAMA) Rue de la Loi 67 (box 3), 1040 Brussels, Belgium T: +32 (0)2 210 52 90 | www.gama.aero | Twitter: @GAMA_EUR Company no: BE 0817.026.347 | EU Transparency Register: 49221685491-82 “General Aviation is the cradle of innovation for aviation.” The General Aviation Manufacturers Association (GAMA) represents more than 130 of the world’s leading manufacturers of Business and General Aviation aeroplanes, rotorcraft, engines, avionics, components, and related services and technologies. GAMA members are also providers of maintenance and repair services, fixed-based operations, pilot and maintenance training, and aircraft management. Additionally, GAMA represents companies in the emerging sector of new air mobility, which includes the development of vertical take-off and landing (VTOL) aircraft as well as electric, hybrid and hydrogen propulsion and autonomous systems for civil purposes. GAMA member companies have facilities in over 30 countries.
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Meeting with Gaëlle Michelier (Cabinet of Commissioner Adina Vălean)

18 Mar 2021 · Call to prepare the participation of the Commissioner to the GAMA SAF Conference.

Response to Climate change mitigation and adaptation taxonomy

15 Dec 2020

Dear Madam or Sir Please find GAMA's feedback on Sustainable finance – EU classification system for green investments in the attached document. Best regards Raphaël Fabian Raphaël R. FABIAN Director, European Affairs General Aviation Manufacturers Association (GAMA) Rue de la Loi 67 (box 3), 1040 Brussels, Belgium T: +32 (0)2 210 52 90 | www.gama.aero | Twitter: @GAMA_EUR Company no: BE 0817.026.347 | EU Transparency Register: 49221685491-82
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Meeting with Adina-Ioana Vălean (Commissioner) and

25 Nov 2020 · Introductory meeting to discuss aviation policy.

Meeting with Walter Goetz (Cabinet of Commissioner Adina Vălean)

11 Sept 2020 · Meeting to discuss latest development in the aviation sector.

Meeting with Daniel Calleja Crespo (Director-General Environment)

6 Jul 2020 · European Green Deal

Meeting with Anouk Faber (Cabinet of Commissioner Nicolas Schmit), Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit)

3 Jun 2020 · Videoconference on skills

Response to ReFuelEU Aviation - Sustainable Aviation Fuels

17 Apr 2020

Dear Madam or Sir We hope this note finds you, your colleagues and families in good health in these peculiar times. Please find in the attached PDF file GAMA's feedback on the ReFuelEU Aviation Initiative Roadmap. Should you require additional information or discuss any of our comments, please feel free to contact me (rfabian@gama.aero). Stay safe and healthy. Best regards Raphaël Fabian Director, European Affairs General Aviation Manufacturers Association (GAMA)
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Meeting with Gaëlle Michelier (Cabinet of Commissioner Adina Vălean)

6 Mar 2020 · Aviation

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

10 Feb 2020

The European Commission (EC) on 13 December 2019 published a draft implementing regulation, amending Regulation (EU) No 1206/2011 and 1207/2011 (i.e., the SPI regulation for aircraft identification, transponders, and ADS-B equipage). The EC is seeking input about the exemption framework through its better regulation website. The proposal made by the EC makes certain accommodations to manage the 7 June 2020 compliance date. The proposed changes are generally welcomed by GAMA members, including specifically the draft amendment providing exemptions for aircraft with an original certificate of airworthiness issued prior to 7 June 1995 and the operational exemptions for maintenance flights, aircraft exported from Europe, and aircraft that will cease operation by 7 June 2023. The proposal also makes several needed changes to the technical requirements of the regulation that are essential for the successful implementation of the surveillance mandate. GAMA requests consideration of the comments attached to this message (see, GAMA20-08 Comments to EC Better Regulation... - Final 10-02-2020.pdf
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

18 Dec 2019 · aviation issues

Meeting with Daniel Calleja Crespo (Director-General Environment)

2 Apr 2019 · Sustainable alternative jet fuels

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

13 Mar 2019 · bilateral safety agreements

Response to Clarifying the provisions for the data communication between aircraft and traffic controllers.

7 Mar 2019

Ms. Christine Berg Head of Unit – Single European Sky Directorate-General for Mobility and Transport European Commission Building DM24 1049 Brussels Dear Ms. Berg, The General Aviation Manufacturers Association (GAMA) appreciates the opportunity to provide comments to the European Commission (EC) proposal entitled updating the rules on equipping aircraft with data link services that was published on 7 February 2019. GAMA represents over 110 aircraft, engine, and avionics manufacturers from Europe and around the world. We have been involved in the development of Data Link Services (DLS) since its inception, including various workshops and the on-going European Aviation Safety Agency (EASA) review of DLS in Rulemaking Task (RMT) 0524. GAMA members—including aircraft Original Equipment Manufacturers (OEM), avionics manufacturers, and operators—have expended significant money over the past decade developing solutions to support the mandate—in response to communications from the EC to support the deployment and essential equipage of the European fleet with DLS-compliant avionics solutions. As the EC moves forward with finalizing the exemption framework, GAMA offers comments about three areas of the proposal in an attachment to this letter: - The status of DLS deployment; - the new proposed exemption framework; and - the need to publish a final list of aircraft models exempted from the DLS requirements. Publishing a comprehensive list of aircraft models exempted is especially important to provide much needed clarity about who needs to take the necessary steps to invest in an DLS avionics upgrade. GAMA appreciates the continued engagement by the EC in establishing the requirements for the Single European Sky. We will continue to work with you and other stakeholders with the goal of achieving the successful deployment of data link services. Please let me know if you have any questions. Sincerely, Jens C. Hennig Vice President, Operations
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Meeting with Daniel Calleja Crespo (Director-General Environment)

13 Mar 2018 · Environmental sustainability of the airline industry

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

15 Nov 2017 · Aviation issues

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

15 Mar 2016 · General Aviation Road Map, BASA

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

15 Mar 2016 · Aviation

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

10 Jun 2015 · General Aviation, Revision of EASA Basic Regulation

Meeting with Marjeta Jager (Cabinet of Commissioner Violeta Bulc)

17 Mar 2015 · Aviation issues

Meeting with Marjeta Jager (Cabinet of Commissioner Violeta Bulc)

17 Mar 2015 · General Aviation Manufacturers Association (GAMA)