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Aviation is a key industry in Europe, playing a vital role in economic prosperity and facilitating the free movement of people and goods. One of the latest regulatory measures affecting the sector is the so-called ReFuelEU Aviation Regulation. When analysed objectively, however, several practical questions arise.
One of the most significant is whether it is realistic to push aircraft operators to load a specific type of fuel when the infrastructure necessary to support alternative fuels remains under development.
This question highlights one of the principal challenges facing the aviation industry in relation to the ReFuelEU Aviation Regulation, one of the European Union’s flagship initiatives under the Fit for 55 package. The Regulation aims to reduce aviation emissions by increasing the use of Sustainable Aviation Fuel (SAF). At the same time, however, it effectively increases refueling activity at airports, raising associated operational and safety concerns and requiring a rapid expansion of fuel supply and distribution logistics, including at smaller regional airports.
Under the Regulation, SAF is regarded as a key tool for reducing aviation emissions. However, the production and distribution of SAF remain subjects of considerable debate.
For example, SAF supply is currently concentrated in only a few major European hubs, including France, Germany, and Spain. Moreover, SAF remains significantly more expensive than conventional jet fuel, while scaling up production capacity requires substantial long-term investment.
The legislator’s objective was to discourage the practice of tankering.
Tankering refers to the practice of carrying additional fuel from the departure airport so that the aircraft can avoid purchasing fuel, or reduce fuel purchases, at the destination airport, where fuel may be more expensive or less readily available.
To address this practice, the Regulation requires airlines to uplift at least 90% of their annual aviation fuel requirement at Union airports, subject to specified conditions and exemptions (Article 5 of the Regulation).
If airlines are expected to rely on local fuel supplies rather than carrying additional reserves, can airports throughout Europe guarantee the consistent availability of SAF?
Ultimately, if SAF is unavailable and operators satisfy their obligations through compliance mechanisms or by purchasing credits, it is legitimate to question the extent to which such arrangements contribute to actual reductions in carbon emissions.
The availability of SAF is itself a critical issue. At present, SAF accounts for only a very small proportion of global aviation fuel consumption. However, the challenge extends well beyond fuel production.
A large-scale transition to SAF requires substantial investment in production facilities, distribution networks, storage systems, airport infrastructure, and renewable energy generation. SAF production plants will need to become operational across Europe within the next decade if the Regulation’s targets are to be achieved. In the case of synthetic aviation fuels, vast quantities of renewable electricity will also be required, creating additional pressure on Europe’s energy infrastructure.
Many SAF production pathways rely on waste oils, biomass, and agricultural residues—resources that are finite and increasingly sought after by other industries. Consequently, expanding SAF production is not simply a matter of building new facilities; it also requires securing sufficient sustainable feedstock without creating competition with food production or other industrial uses.
ReFuelEU Aviation may also raise concerns regarding competitiveness. Airlines operating within the European regulatory framework are subject to stricter fuel requirements and potentially higher operating costs than competitors based in jurisdictions with less demanding sustainability obligations.
Perhaps the most significant aspect of the Regulation is that it seeks to create demand through legislative intervention while many of the conditions necessary to meet that demand, including production capacity, feedstock availability, long-term financing, distribution networks, and supporting infrastructure, are still developing. Whether regulatory ambition can successfully align with economic and operational realities remains one of the key questions for the future of European aviation.