The key take aways from the article:
- ReFuelEU fails to create a level playing field for SAF supply: ReFuelEU Aviation aims to promote Sustainable Aviation Fuel (SAF) but fails to ensure a level playing field, as supply and pricing vary across Member States due to different rule interpretation.
- ReFuelEU relies on RED for sustainability criteria: ReFuelEU uses the Renewable Energy Directive (RED) to define eligible SAF feedstocks, categorizing them as Annex IX A (advanced biofuels), IX B (other biofuels), or non-Annex IX (capped at 3%). However, the RED allows Member States to interpret feedstock eligibility themselves.
- Feedstocks are interpreted differently across countries: Member States apply inconsistent interpretations of RED feedstocks, with some approving broader categories or more feedstocks than others. This results in unequal SAF supply potential and market advantages for certain countries.
- Uneven interpretations create pricing disparities: Countries with more lenient interpretations will likely have access to a larger SAF feedstock pool, which will lead to lower costs and prices, while others face feedstock limitations, which will lead to higher costs, disrupting fair competition.
- EU Commission must provide guidance: The Commission should harmonize feedstock definitions, create a unified approval list, and require Member States to share information, ensuring a fair and consistent SAF market across Europe in line with ReFuelEU Aviation.

Download the full article, written by our Policy Team.
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