European Regions Airline Association (ERA) and Airlines for Europe (A4E) have released a new joint paper that discusses the early challenges in implementing ReFuelEU Aviation and sets out targeted adjustments to improve how the system works.
The associations say targeted fast-track revision in 2026 could strengthen legal certainty and reduce unnecessary administrative burden. It would also ensure that the money spent on SAF translates into real decarbonisation.
The paper highlights the following issues:
1) Anti-tankering rule
Issue: Operational realities create a heavy administrative workload under the current rules and sometimes even additional fuel burn.
Proposed solution: Introduce more proportionate thresholds and a harmonised EU exemption framework.
2) SAF documentation & ETS alignment
Issue: Late and inconsistent sustainability documentation, combined with misalignment between ReFuelEU and EU ETS, creates audit risk and can prevent airlines from claiming emissions benefits for SAF they have paid for.
Proposed solution: Introduce harmonised EU documentation templates, earlier delivery timelines, and stronger alignment between ReFuelEU and EU ETS reporting frameworks.
3) Supplier market behaviour & pricing transparency
Issue: SAF surcharges are often opaque and not clearly linked to verifiable SAF volumes, while limited supplier competition at some airports weakens airlines’ negotiating leverage.
Proposed solution: Improve transparency of SAF surcharge methodologies and implement Book & Claim to strengthen market transparency and competition.
