Firm Goals, Optimise the Mechanism: What the 2027 ReFuelEU Review Can Build

Europe legislated the demand for sustainable aviation fuel. The 2027 review can help build the supply by keeping the goals firm and optimising the mechanism.

My last article examined why a uniform SAF obligation lands differently across airline business models as a mandate measured in fuel volume does not fully capture those differences: the obligation scales with volume, while the capacity to absorb its cost is shaped by business model, customer mix, network structure, margins, procurement arrangements, and competitive position. That distinction runs through the whole value chain, shaping the demand producers can rely on, how suppliers pass compliance costs through, the infrastructure airports must build, and the consistency of the framework. It leads directly to the question this article takes up: how can Europe preserve the certainty of the quota trajectory through the 2027 ReFuelEU review while improving the mechanisms through which the market delivers it, including how its costs are carried?

Europe did something consequential when it adopted ReFuelEU Aviation. It converted years of ambition into a binding, long-dated demand signal and gave producers, lenders, airlines, airports, and fuel suppliers a market against which they could plan. It also set a standard beyond its own borders. While many regions are still working out how to turn aviation climate ambition into durable policy, Europe built a framework that others can study, adapt, and build on. Its continued credibility matters to the development of a global SAF market. The task for 2027 is to strengthen what Europe has begun. The certainty of the trajectory should be protected, because it allows producers to develop projects, lenders to assess risk, suppliers to organise future volumes, airports to plan infrastructure, and airlines to prepare for the cost of transition. The regulation’s title sets a second test: whether the market it creates supports a level playing field for sustainable air transport. A demand signal does its best work when participants trust both its durability and the consistency of the market it creates, and the 2027 review is an opportunity to reinforce both, and to show that ambitious climate policy can become more effective through disciplined improvement while keeping its direction.

Article 17 requires the European Commission to report by January 2027 on the functioning of the regulation. Its scope includes SAF market development, investment needs, competitiveness, connectivity, carbon leakage, eligible fuels, minimum shares, penalties, and the regulation’s broader effectiveness. It therefore gives the review a practical mandate to examine the mechanisms that now matter most, including the cost-effectiveness of lifecycle emissions reductions, investment support, price-gap measures, and the level of fines. The review was built into the framework from the beginning. It offers a disciplined opportunity to learn from the market, complete the enabling architecture around the mandate, and increase the likelihood that each milestone is supported by additional qualifying fuel entering the aviation system. The organising principle should remain steady: keep the goals firm and optimise the mechanism.

One Union framework, implemented through a varied market

ReFuelEU operates at two levels.

  1. At Union level, the regulation establishes a common trajectory measured by energy content. The minimum SAF share begins at 2 percent in 2025, rises to 6 percent in 2030, 20 percent in 2035, 34 percent in 2040, 42 percent in 2045, and 70 percent in 2050. A synthetic aviation fuel sub-mandate begins in 2030. Suppliers must achieve an average synthetic share of 1.2 percent across 2030 and 2031, with at least 0.7 percent supplied in each year. The average rises to 2 percent over 2032 to 2034, followed by annual requirements of 5 percent in 2035, 10 percent in 2040, 15 percent in 2045, and 35 percent in 2050. The regulation also establishes common rules around fuel eligibility which draw on the Renewable Energy Directive and direct the market toward qualifying wastes, residues, advanced feedstocks, recycled-carbon fuels, synthetic fuels, and other eligible low-carbon aviation fuels. Food and feed crops are excluded from the SAF mandate. Responsibilities are distributed across the value chain. Aviation fuel suppliers carry the obligation to place the required SAF shares into the Union aviation fuel market. Aircraft operators are generally required to uplift at least 90 percent of their annual aviation fuel requirement at each Union airport, limiting tankering undertaken to avoid local fuel costs. Airport managing bodies must take the necessary measures to facilitate access to SAF. Airlines therefore experience most of the mandate’s direct economic effect through the fuel they purchase, even though the blending obligation legally sits with suppliers. That distinction matters when considering how costs move through the market.

  2. Enforcement is administered by member states within the common European framework. Article 12 requires penalties to be effective, proportionate, and dissuasive. For a supplier that misses the required SAF share, the minimum penalty is based on at least twice the annual price differential between the relevant SAF and conventional aviation fuel, multiplied by the shortfall. The supplier must also compensate for the missing volume in a later reporting period; hence, payment does not replace the underlying obligation. EASA supports consistency by publishing annual reference prices and administering common reporting infrastructure. For 2025, EASA reported a SAF reference price of €1,925 per tonne, compared with €640 per tonne for conventional aviation fuel. The €1,285 differential illustrates both the continuing cost gap and the value of a common reference framework. These figures are average neat-fuel reference prices for regulatory purposes and do not capture every downstream cost involved in delivering blended SAF to individual airports. Although the architecture is harmonised, the market through which it operates remains varied. Member states appoint competent authorities, administer enforcement, collect penalties, implement related Renewable Energy Directive requirements, and may pursue complementary national policies. Airlines also differ in where they uplift fuel, which suppliers serve them, the structure of their networks, and their capacity to pass additional costs through to customers. The review can preserve the benefits of national initiative while improving consistency across the shared market.

A market with a credible foundation

EASA’s first ReFuelEU Aviation Annual Technical Report provides a useful baseline for entering the mandate. It found that approximately 193,000 tonnes of SAF were supplied at Union airports in 2024, representing around 0.6 percent of reported aviation fuel supply and delivering an estimated 714,000 tonnes of lifecycle carbon dioxide-equivalent savings. The supply was overwhelmingly based on hydroprocessed esters and fatty acids, commonly known as HEFA, demonstrating the value of commercial maturity of the HEFA pathway. HEFA is currently the most established SAF production route, supported by operating facilities, recognised certification systems, existing refinery capabilities, and established feedstock markets. It remains more expensive than fossil kerosene in normal market conditions, but it provides the most readily deployable foundation for early mandate compliance.

The same baseline identifies where further development can create value: twenty-five suppliers reported SAF deliveries to 33 airports across 12 member states. Airports in France, Germany, the Netherlands, Spain, and Sweden accounted for approximately 99 percent of reported supply. Around 69 percent of the feedstock originated outside the Union, with China and Malaysia among the largest sources. These figures describe an early market with room to broaden its geographical participation, production pathways, feedstock base, domestic supply chains, and liquidity across airports. The Commission’s flexibility mechanism is designed to help manage this concentration during the mandate’s early years. Until the end of 2034, suppliers can meet their SAF obligations on a weighted-average basis across the Union airports they serve. This allows more fuel to be supplied where infrastructure and logistics are ready while the wider system develops. That flexibility is one of the most important design features available to the review. In particular, the period from 2030 to 2035 deserves close attention. Over those five years, the overall SAF requirement rises from 6 percent to 20 percent, while the synthetic share reaches 5 percent. That acceleration will coincide with the period in which several emerging pathways must move from demonstration and first-of-akind deployment into repeatable commercial construction.

The review should therefore examine the shape of the ramp alongside the milestones themselves. A smoother annual progression, continued averaging, or tightly governed temporal flexibility could reduce discontinuities in project demand and compliance cost while preserving the cumulative obligation and the long-term destination. Any adjustment should strengthen the probability of delivery while maintaining the investment signal.

The next stage requires more than a demand signal

EASA’s current outlook indicates that the overall 6 percent SAF requirement in 2030 can be met if announced European capacity is completed and qualifying supply remains available to the Union market. The synthetic component presents a different commercial challenge. Synthetic aviation fuel combines renewable hydrogen with an eligible carbon source and can offer deep lifecycle emissions reductions when produced with appropriate electricity and carbon inputs. Its technical basis is established, and early commercial production has begun. Current facilities, however, remain far smaller than the capacity required to fulfil the European sub-mandate at scale.

In June 2026, KLM Cityhopper operated a passenger flight from Amsterdam to Hamburg using a 5 percent blend containing approximately 200 litres of synthetic kerosene produced by INERATEC. The flight demonstrated that the fuel can enter normal aviation operations through established blending and handling systems. The central question is how to reach commercial scale, including how to address the cost, financing, sponsor capacity, and operational reliability challenges involved in moving from early commercial volumes to the much larger market the sub-mandate requires. Most planned European synthetic fuel facilities still need long-term revenue certainty, affordable renewable electricity, dependable hydrogen and carbon supply, engineering completion, and committed buyers before reaching final investment decision. Available volumes are therefore expected to remain limited during the first years of the sub-mandate.

The fragility of the project pipeline became more visible in June 2026. Only weeks after Germany formally presented €350 million in public support for Brandenburg eSAF, Sasol and Topsoe announced that Zaffra, the joint venture developing the project with ENERTRAG, would be wound down. Brandenburg eSAF was intended to produce more than 30,000 tonnes annually from 2030, equivalent to approximately one-quarter of Germany’s expected synthetic aviation fuel requirement. The project may continue through a restructured ownership or development model, and its public funding, industrial site, engineering work, and remaining partners provide meaningful reasons to preserve it. The change nevertheless exposes a central policy question. If a strategically important project can secure a binding future market, substantial public support, established industrial partners, and a defined site, yet still lose its development vehicle before final investment decision, which risks remain insufficiently covered?

The answer should inform the review. A grant can fund a project, and a mandate can create its market, but neither automatically creates the sponsor capacity required to carry it through FID. First-of-a-kind projects also require durable project governance, committed development capital, clearly allocated construction and integration risk, affordable inputs, credible long-term revenue, and institutions capable of carrying the asset through development, construction, and operation. Part of the remaining risk begins upstream of the fuel plant. Synthetic fuel economics depend on abundant renewable electricity, affordable renewable hydrogen, access to an eligible carbon source, and the infrastructure required to bring those inputs together. Europe’s investment in hydrogen provides an industrial foundation on which e-SAF can build, but hydrogen and electricity costs have not yet fallen far enough to make the resulting fuel broadly affordable. EASA’s 2025 reference prices illustrate the current scale of the challenge. Its estimated production cost for synthetic aviation fuel was €7,520 per tonne, compared with €640 per tonne for conventional aviation fuel, producing a reference differential of €6,880 per tonne. The practical question is how support can build a strategically important pathway while producing measurable learning, repeatable deployment, stronger sponsor capacity, and a credible route toward lower cost.

The European Commission has begun responding. Its Sustainable Transport Investment Plan identifies the investment required for renewable and low-carbon aviation and maritime fuels. An e-SAF Early Movers Coalition involving eight member states is intended to support a pooled €500 million pilot auction for European synthetic aviation fuel projects. This is a constructive beginning, and the review can build on it by connecting the certainty of the mandate with the revenue structures and project-development capacity required to finance and deliver the plants that will fulfil it. The same financing and market-development logic applies to additional biological pathways. HEFA can carry an important share of early demand, but its traditional waste-lipid feedstocks are constrained and contested across aviation, road transport, maritime fuels, chemicals, and international markets. A resilient 2035 market will require a broader portfolio that includes advanced waste and residue pathways, Fischer-Tropsch fuels, ethanol-to-jet, methanol-to-jet, synthetic fuels, and other qualifying technologies as they secure ASTM D7566 approval and reach commercial readiness.

The opportunity is to match each pathway with support appropriate to its stage of development. Mature pathways benefit from clear eligibility, efficient logistics, transparent markets, and feedstock expansion. Emerging commercial pathways need first-of-a-kind risk support, long-term offtake, dependable revenue, and credible sponsors capable of carrying projects through construction. Earlier technologies need targeted research, demonstration, and certification support. A differentiated supply strategy can serve one common mandate.

The scale of these cost and maturity differences makes the allocation of support especially important. The mandate uses fuel shares to create dependable demand, while its ultimate purpose is to reduce aviation’s lifecycle emissions. The relevant question for each euro of public support, compliance expenditure, or price-gap assistance is therefore how much durable emissions reduction it enables. Pathways differ in cost, maturity, scalability, feedstock availability, lifecycle performance, and long-term strategic value. Support will go furthest when it expands credible, cost-effective abatement today while reducing the cost and delivery risk of the pathways aviation will need at greater scale later. Designing the mechanism around emissions reduced per euro, supply resilience, future scalability, and demonstrated delivery is how firm ambition becomes increasingly affordable.

Cost visibility strengthens the market

The mandate creates value by establishing dependable demand, and its effectiveness also depends on how transparently that value moves through the supply chain. Fuel suppliers incur the cost of sourcing, blending, certifying, transporting, and reporting SAF. Airlines receive that cost through fuel prices and compliance-related charges, while passengers, freight customers, corporate buyers, or airline shareholders ultimately carry it through fares, contracts, surcharges, or margins. Transparent pass-through is therefore important to the legitimacy of the system.

IATA reported in 2025 that some SAF compliance charges were materially higher than the fuel-price differential the organisation estimated was necessary to meet the initial mandate. The relationship between the underlying premium and a supplier’s full compliance cost can vary because logistics, working capital, certification, infrastructure, market risk, and administration also carry costs. The broader lesson remains useful: buyers should be able to understand what they are paying for and how that expenditure contributes to compliant fuel supply.

Recent market conditions have also shown that the SAF cost gap is not fixed. During the 2026 jet fuel disruption associated with the Strait of Hormuz, General Index estimated Rotterdam HEFA production cost at approximately $1,550 per tonne, while fossil jet fuel reached about $1,633 per tonne. For a brief period, the estimated cost of producing HEFA was therefore close to, and slightly below, the spot price of conventional jet fuel. That comparison does not mean airlines could purchase delivered SAF at parity. SAF contracts and market prices are often structured as a fossilfuel benchmark plus a premium, so a sharp increase in conventional jet fuel can raise the total SAF price even when the underlying HEFA production cost remains relatively stable. The episode nevertheless provides a useful policy signal: SAF economics are shaped by both renewable-fuel costs and the volatility of the fossil benchmark against which the product is frequently priced.

Greater transparency around production cost, fossil-fuel indexing, logistics, environmental attributes, and supplier margins would help the market distinguish the cost of making SAF from the structure through which it is priced. Common reporting standards, clear reference prices, contractual transparency, and a more liquid certificate market could support that distinction and help develop more independent SAF price discovery as the market grows. These measures would help airlines evaluate their fuel costs, give producers clearer signals about genuine demand, and give policymakers better information about how effectively the mandate is functioning. Cost visibility is therefore part of market development, not simply a procurement concern.

One obligation reaches different airline businesses differently

A common mandate is necessary for a functioning single market. Its economic effect nevertheless varies by business model. A long-haul network carrier may have premium cabins, corporate contracts, cargo revenue, and a broader range of mechanisms through which to recover a fuel-cost increase. A low-cost airline may depend heavily on price-sensitive leisure demand and have less room to pass through incremental costs. Regional operators serve routes whose economic and public-connectivity value may not be fully reflected in fare levels. Cargo carriers work through freight-market cycles and customer contracts. Business aviation frequently serves customers with greater willingness to support an early SAF premium. The mandate does not need airline-level margin tests or a separate quota for each business model as such a system would be complex, intrusive, and vulnerable to inconsistent interpretation. It does need mechanisms that allow participants with greater willingness and capacity to fund early SAF to do more, while preserving the common demand floor.

Book-and-claim is particularly valuable here as a credible system for allowing the environmental attributes of a qualifying SAF batch to be purchased separately from its physical delivery, while maintaining clear chain-of-custody rules and preventing double claiming. Fuel can enter the Union aviation system where production, blending, and distribution are most efficient, while the associated cost and environmental claim can be allocated to the customer financing it. This creates value across the system, allowing corporate travel buyers to support aviation decarbonisation through their travel emissions. Freight customers can participate through their transport supply chains, and business aviation customers can fund greater early uptake. Airlines operating from airports without immediate SAF access can participate without waiting for identical infrastructure at every location. Producers gain access to a wider market of creditworthy buyers. The underlying demand obligation can remain intact while financial participation becomes broader.

The Union’s external boundary matters

The review must also consider how ReFuelEU affects competition between European and non-European connecting hubs. The mandate applies to fuel supplied for departures from Union airports. On some long-haul itineraries, this can create a cost difference between a passenger connecting through an EU hub and one connecting through a hub outside the regulation’s scope. A shift in connecting traffic may transfer economic activity without producing a corresponding reduction in global aviation emissions. Article 17 expressly places competitiveness, connectivity, and carbon leakage within the review. Industry-sponsored modelling has estimated meaningful cost differences on some EU-to-Asia itineraries and proposed a SAF Border Adjustment Mechanism as one possible response. Such an instrument would require careful legal, operational, diplomatic, and emissions-accounting analysis. It should be evaluated alongside route-level leakage monitoring, stronger international alignment, cooperation through ICAO and CORSIA, and measures that recognise the connectivity role of European hubs.

The objective is straightforward: preserve the environmental value of the European mandate by reducing incentives to route around it.

Building the supply-side half of the framework

The clearest opportunity for the review is to complete the connection between mandated demand and financeable supply.

  • A binding quota creates a market.

  • A capital-intensive first-of-a-kind facility also needs enough revenue certainty to support debt and equity investment.

  • Lenders need confidence in contracted volumes, creditworthy counterparties, technology performance, feedstock availability, construction execution, and the policy environment.

  • Producers need enough certainty to commit capital years before the resulting fuel enters the market.

  • A Union-level or coordinated member-state revenue-certainty mechanism could help bridge this gap.

Competitive double-sided auctions, contracts for difference, fixed-premium mechanisms, or other bankable structures can provide a dependable floor while allowing competition to reveal cost and protect public value. The United Kingdom’s developing revenue-certainty mechanism and the European eSAF Early Movers Coalition provide useful models. Support should prioritise projects with credible technology, feedstock or energy supply, certification, construction, and offtake plans. This creates distinct value across the system:

  • Producers receive the revenue visibility needed to reach final investment decision.

  • Lenders gain a more dependable basis for assessing debt service.

  • Airlines gain access to future fuel at more predictable prices.

  • Policymakers gain confidence that mandated volumes will be met through supply.

  • The public gains stronger cost discipline through competitive allocation.

This is how the mandate can move from demand creation into market construction.

Turning carbon expenditure into fuel

The EU Emissions Trading System provides another opportunity to connect existing aviation expenditure more directly with fuel deployment. As free aviation allowances are phased out, airlines’ ETS costs are increasing. Airlines for Europe estimates that its members could face approximately €5 billion in annual ETS payments by 2030, around twice their 2024 cost. The association has proposed allowing more of that expenditure to support SAF directly. The existing ETS SAF allowance mechanism already recognises this principle by reserving allowances to help cover part of the price differential for eligible aviation fuels. The review and related ETS processes can examine whether that connection can be strengthened while preserving the environmental integrity of both instruments.

A well-designed approach could allow aviation carbon expenditure to support additional SAF offtake, project development, or price-gap coverage without weakening the carbon-price signal. Any mechanism must avoid double counting, maintain transparent accounting, protect fair competition, and ensure that support produces additional fuel or emissions reduction. The opportunity is attractive because it links two costs experienced by the same sector. One prices emissions, the other can finance a practical route to reducing them.

Altogether, the review’s options can be judged against a common test: does each mechanism preserve demand certainty, enable additional supply, allocate cost transparently, widen credible participation, and produce durable lifecycle emissions reduction?

A practical package for 2027

A coordinated package could materially improve the mandate’s effectiveness.

  1. Create bankable revenue certainty and carry first-of-a-kind projects through FID. Build on the European e-SAF pilot and establish durable competitive mechanisms that help qualifying projects reach final investment decision and remain viable through construction. Support should address the risks that mandates and capital grants do not fully resolve, including long-term revenue, sponsor continuity, input-cost exposure, construction and integration risk, and credible project governance. It should remain linked to measurable delivery, sound project fundamentals, and transparent value for public money.

  2. Develop and assess a high-integrity book-and-claim framework. Evaluate tradable certificates and book-and-claim and, where the legal, sustainability, and accounting conditions are met, establish a common Union framework with harmonised chain-ofcustody rules, clear ownership of environmental attributes, and safeguards against double claiming. Preserve the requirement that qualifying fuel enters the relevant aviation supply system while allowing credible participation independently of physical airport access.

  3. Preserve flexibility and examine the shape of the ramp. Evaluate the weighted-average supplier mechanism before allowing it to expire after 2034, and assess whether the progression between 2030 and 2035 can be delivered without creating abrupt discontinuities in project demand, supply availability, or compliance cost. Any averaging or temporal flexibility should preserve the cumulative obligation and a clear schedule for delivery. The long-term design should also recognise that efficient deployment does not require identical physical supply at every airport in every year.

  4. Improve cost transparency. Use EASA reference prices, supplier reporting, contractual disclosure principles, and market monitoring to clarify the relationship between fuel premiums, logistics costs, compliance charges, and environmental value.

  5. Recycle penalties into additional supply. The regulation already requires member states to endeavour to use fine revenues, or an equivalent amount of public financial support, for SAF research and innovation, production, or price-gap mechanisms. The review can assess whether this best-efforts provision should become a more consistent and coordinated Union commitment, directing proceeds toward production, enabling infrastructure, certification, or targeted market development, so that expenditure arising from a shortfall helps reduce the probability of future shortfalls.

  6. Respond proportionately to verified market-wide scarcity. Maintain credible enforcement while distinguishing persistent individual non-compliance from a system-wide shortage that no single obligated party could reasonably resolve. Any flexibility should be activated through objective Union-level criteria, remain time-limited, preserve the cumulative obligation, and include a clear schedule for replacing missing volume.

  7. Diversify pathways, feedstocks, and sources of supply. Support a portfolio of eligible fuels appropriate to Europe’s resources, industrial capabilities, and sustainability safeguards. This includes widening responsibly sourced domestic feedstocks, advancing waste and residue conversion, and accelerating Fischer-Tropsch, alcohol-to-jet, synthetic, and other qualifying routes. The review should also assess the role of intermediate and rotational crops that can strengthen European feedstock supply and farm economics where they meet robust sustainability, land-use, and lifecycle-emissions requirements. A more diverse production base strengthens decarbonisation and energy resilience by reducing the aviation system’s exposure to disruptions in imported fossil fuels, refined products, and individual renewable feedstocks.

  8. Connect ETS expenditure with additional abatement. Assess how the ETS SAF support mechanism and related funding tools can direct more aviation carbon expenditure toward physical fuel, additional offtake, and financeable projects while retaining the integrity of the carbon market.

  9. Address external leakage. Evaluate border, route-based, and international coordination measures that ensure the mandate reduces emissions rather than redirecting connecting traffic toward jurisdictions with lower equivalent obligations.

These measures are mutually reinforcing: revenue certainty builds plants, book-and-claim widens the buyer base, flexibility improves logistics, transparency strengthens trust, feedstock and pathway diversification improve resilience, productive enforcement turns shortfall into future supply, leakage measures protect both climate integrity and European connectivity.

What the review can build

Europe has already created a durable foundation for a SAF market, and the 2027 review can strengthen the structures that turn that demand signal into investment, fuel, connectivity, and measurable emissions reduction. For policymakers, suppliers, producers, and lenders, the prize is a more financeable and transparent market in which targets are backed by credible supply. For airlines and airports, it is greater cost visibility, more dependable access, efficient infrastructure, and stronger protection against leakage. For corporate travel and freight customers, it is a credible route to take part.

The challenges remain substantial: synthetic fuel still needs bankable revenue, emerging pathways still need to cross the first-of-a-kind gap, feedstock supply is concentrated, infrastructure is uneven, and the cost of compliance reaches different airline businesses in different ways. Naming those realities plainly strengthens the response and improves the odds that mandated demand produces additional fuel, resilient supply, and durable lifecycle emissions reductions. The mandate needs its enabling architecture completed. Its goals should remain firm, because their certainty allows capital to commit, while the mechanisms around them stay practical, adaptive, and attentive to the different commercial realities through which the market must deliver them.

No single stakeholder can complete that architecture alone. Producers cannot finance supply without dependable demand, airlines cannot sustain demand without a cost structure their customers and businesses can carry, airports and suppliers cannot provide access without infrastructure, and policymakers cannot design an effective framework without the operational knowledge held across the market. The opportunity in 2027 is therefore larger than a regulatory review. It is a chance to bring those perspectives together and co-create the conditions under which the mandate can work.

It is also a chance for Europe to sustain the leadership it has shown. Other regions are watching how the first major regional binding SAF framework performs, and whether ambition can be paired with affordability, investment, and competitiveness. A stronger ReFuelEU would offer them more than a target to copy: a working model for how durable demand and effective market design advance together. That model should be transferable rather than uniform as countries differ in historical emissions, aviation demand, fiscal capacity, energy systems, feedstocks, development priorities, and access to affordable capital. International expansion should preserve a common direction while allowing national and regional mechanisms to reflect those differences. The opportunity is for more countries to participate as producers, technology partners, and beneficiaries of investment, jobs, infrastructure, and rural economic value, rather than only as sources of raw materials or markets for compliance. Europe should lead with confidence, especially as economic, energy, and geopolitical pressures test long-term climate commitments, by preserving the direction of travel while improving the mechanisms that make progress possible.

Aviation connects families, communities, economies, and opportunity across distance. Its transition matters because those connections should endure within a climate that remains habitable for the people and places they serve, and Europe’s continued leadership can help show that aviation decarbonisation is both a regional responsibility and a shared global project. The question for the consultation is practical and shared: what should each part of the aviation value chain contribute to turn the mandate’s certainty into financeable supply, broader participation, and greater emissions reduction?

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Same Mandate, Different Reality: Why SAF Policy Mistakes "Airline" for One Kind of Business