Are You Ready for ReFuelEU?

Feb 2

Looking for clarity on the upcoming European Sustainable Aviation Fuel (SAF) mandates? The ReFuelEU regulation may be familiar, but its impact on your operation may not be clear. Learn more about the key details of the regulation, including its implementation timeline, how it affects operators, and what needs to be done to stay compliant below.

What is ReFuelEU, and where did it come from?

ReFuelEU is a key component of the European Union’s Fit for 55 package, designed to reduce the EU’s greenhouse gas emissions by 55% by 2030. The regulation requires fuel suppliers to blend increasing shares of SAF at designated EU airports, known as Union airports. These are airports with either more than 800,000 annual passengers or over 100,000 tons of cargo traffic per year. Additionally, other EU airports that do not meet these thresholds may opt into the scheme voluntarily.

In 2024, the European Commission identified the 143 Union airports subject to the regulation and released a detailed manual to assist aircraft operators and verification bodies in complying with the new rules. For the 2025 compliance period, 12 additional airports have been included, bringing the total to 155 Union airports.

How does ReFuelEU impact aircraft operators?

Under ReFuelEU, operators are not required to physically uplift SAF. However, operators can claim carbon reductions against voluntary reporting or emission trading schemes from mandated fuel.

Fuel suppliers must average the mandated quantity (2% in 2025) across all deliveries, meaning SAF may not be physically delivered to each Union Airport or varying blends of physical SAF being uplifted into your aircraft. The fuel will always meet the blending requirements to maintain JetA certification, but this may change the amount of SAF claimable by an end operator. More information is still needed to understand what may be claimable and may vary by fuel supplier. Fuel suppliers may even add compliance fees to pass along their costs of compliance, but this may not entitle an operator to any SAF claims.

To ensure SAF is uplifted at Union airports, the regulation addresses fuel tankering—the practice of carrying extra fuel to avoid higher uplift costs—by imposing penalties for unjustified fuel deficits. Operators must source at least 90% of their required fuel from Union airports, with penalties set at a minimum of twice the average price of Jet A fuel per ton for the deficit.

Only aircraft operators conducting over 500 flights annually from Union airports are subject to the regulation. They must report specific flight and fuel data by March 31 each year, starting in 2025 for the 2024 reporting year. Operators can justify certain tankering deficits for safety reasons and may also apply for time-limited exemptions on specific routes due to operational or other valid reasons.

Operators should check the European Commission's list of program participants to confirm their inclusion. Those not currently included but operating flights within the EU should monitor their flight activities, as exceeding 500 flights out of Union airports triggers the threshold for ReFuelEU reporting and tankering obligations.

To minimize costs, operators are encouraged to adjust fuel uplift policies and explore exemptions permitted under Article 5(3) of the regulation.

What exemptions are available to operators?

Two types of exemptions can be used by operators to justify tankering deficits. The first, safety-based exemptions, justify uplifting less fuel for the next flight due to leftover fuel from the safety reserve of the prior flight. These exclusions are applied retrospectively during the annual reporting submission; however, safety procedures cannot be abused to try to hide economic tankering decisions. The second exemption, known as the operational exemption, must be requested three months in advance for a specified period and for certain routes departing from airports with limited fuel supply or significant operational refueling challenges. These exemptions must be approved through the EASA Sustainability Portal and must be re-requested once they expire.

What is the timeline for implementation?

ReFuelEU sets a phased timeline for increasing the use of SAF at Union airports. Beginning in 2025, SAF must account for 2% of aviation fuel, with percentages rising steadily over time:

Synthetic fuels, made from hydrogen and CO2, are also included, with a separate requirement starting at 1.2% in 2030 and increasing to 35% by 2050.

Aircraft operators must begin reporting data on their fuel usage by March 31, 2025, based on their 2024 operations. While tankering deficit penalties will not apply for the 2024 reporting year, these fines will take effect in 2025 once Member States have finalized penalty values. Operators should start preparing for compliance and assessing potential obligations.

Who is ReFuelEU reported to?

While individual EU member states are responsible for enforcing ReFuelEU, the EU Aviation Safety Agency (EASA) has been appointed by the European Commission to oversee reporting and compliance.

Fuel suppliers must report key SAF supply details, including feedstock origin and lifecycle emissions, to ensure transparency and traceability. Similarly, operators are required to submit specific planned flight fuel estimates and actual fuel uplift data annually.

EASA has developed the Sustainability Portal, a digital reporting tool for aircraft operators covered by the ReFuelEU Aviation Regulation, enabling them to meet their reporting obligations and apply for potential exemptions. EASA also launched tools like the Fuel Monitoring Tool, Reporting Template, and a detailed manual to further support operators and verification bodies in meeting the new requirements.

What is the ReFuelEU flexibility mechanism?

The ReFuelEU regulation incorporates a flexibility mechanism to assist fuel suppliers in meeting their obligations through December 31, 2034. During the first ten years, this mechanism allows the SAF blending obligation to be averaged across all Union airports.

Is anything else included under ReFuelEU?

ReFuelEU also introduces a voluntary environmental labelling scheme for flights, aimed at providing consumers with insight into the environmental impact of their travel. Aircraft operators can request an environmental label for flights departing from EU airports, which will certify the flight's environmental performance based on its expected carbon footprint per passenger and CO2 efficiency per kilometer.

Participation in this program will take place through EASA’s Sustainability Portal. Starting in 2025, operators can voluntarily apply for the environmental label, and this labelling may become compulsory as early as 2027.

ReFuelEU is set to directly impact business aviation operators in 2025 and beyond. Operators should take proactive steps to monitor regulatory developments and ensure compliance. Stay informed through 4AIR's PolicyWatch tool and Newsletter— resources for the latest updates on policies shaping the business aviation landscape. For assistance with regulatory monitoring and compliance, learn more about how 4AIR can provide support today.

Sources: