Considerations for the ReFuelEU aviation trilogue

Alternative fuels
Aviation Fuels
Fuels GHG emissions

This briefing paper assesses the differences between the European Commission proposal for a ReFuelEU aviation regulation and the European Parliament and the Council of European Union’s amendments. It identifies which proposals would increase low-greenhouse gas (GHG) compliance options and reduce GHG emissions. The assessment finds that the Commission’s original proposal for a sustainable aviation biofuel definition would provide more GHG savings compared to the Parliament and Council amendments because it would only qualify advanced biofuels with lower lifecycle emissions. However, a cap on the oily feedstocks found in Annex IX, B would help reduce fraud risk and would help to direct investment to the nascent advanced biofuel industry.

The Parliament’s proposal to expand the sustainable aviation fuel (SAF) definition to include electrolysis hydrogen and renewable electricity would encourage investment and innovation in these zero emission technologies for the aviation sector, increasing zero-carbon compliance options. Expanding the definition of synthetic fuels to include these fuels would also mean that the ambition of the synthetic aviation fuel submandate can be increased.

The inclusion of low-carbon fuels in ReFuelEU, namely hydrogen produced from fossil fuel and its derivatives, could risk significantly undermining the ambition of the regulation due to upstream methane leakage and poor carbon capture and storage. Only fuel pathways that utilize green hydrogen produced from renewable electricity can provide the GHG reductions that policymakers seek in the aviation sector with certainty.