Between 2022 and 2023, Raven covered the EU’s sustainable aviation fuel (SAF) rules and carbon market as they were being negotiated: a broad overview of SAF policy in the EU, UK and USA, a report on the provisional ReFuelEU political agreement, a look at the airline and NGO push to reform the EU Emissions Trading System (EU ETS), and a primer on aircraft emissions and alternative fuels. All four are still live on the site, but they describe proposals and negotiating positions, not the rules as they actually stand today. This article picks up where they left off.

ReFuelEU Aviation: from provisional deal to binding law

The provisional agreement our 2023 article covered became law: Regulation (EU) 2023/2405, adopted on 18 October 2023. The blending schedule reported at the time held, and is now in force rather than proposed:

• 2% SAF at EU airports from 2025
• 6% from 2030
• 20% from 2035
• 34% from 2040
• 42% from 2045
• 70% from 2050

A separate synthetic-fuel (e-kerosene) sub-mandate also stands: 1.2% from 2030, 2% from 2032, 5% from 2035, rising to 35% by 2050.

Two things our earlier coverage couldn’t have known: Switzerland adopted a parallel mandate of its own, requiring 2% SAF blending at Zurich and Geneva from 1 January 2026, ramping to 70% by 2050 in step with the EU schedule. And the mandate now has an implementation gap worth flagging – Europe hosts 41 of the 64 large-scale e-kerosene projects announced worldwide, but as of this writing none of them, anywhere globally, is yet operating at scale. China has roughly ten large-scale synthetic-fuel projects under way and is closing the gap quickly, which puts the EU’s early lead in production capacity somewhat at odds with actual output.

EU ETS: the reform campaigners wanted didn’t happen – a different one did

In 2022, easyJet, Ryanair, Jet2 and Wizz Air joined Transport & Environment in calling for the EU ETS to cover all flights departing the EU, not just intra-EU ones, on the basis that roughly 60-75% of European aviation emissions were escaping the scheme entirely. That specific ask has not been granted. The ETS’s geographical scope is still restricted to intra-EEA flights, and that restriction has been extended through the start of 2027, pending a Commission review (due July 2026) of whether ICAO’s CORSIA offsetting scheme is doing enough to justify keeping extra-EU flights out of the EU’s own carbon market. Transport & Environment’s current estimate is that CORSIA will only cover around 26% of the EU’s aviation CO2 by 2035, so the scope question our 2022 article covered is, if anything, still unresolved four years on.

What did change is the cost side. Free allowances for aviation under the ETS are being phased out on a fixed schedule: a 25% cut in 2024, a 50% cut in 2025, and full auctioning – zero free allowances – from 2026. That’s a materially higher carbon cost for intra-EU flying than existed when the 2022 article was written, even though the scope of the scheme itself hasn’t widened the way the airline-NGO coalition asked for.

Aircraft emissions and the fuel-of-the-future question

Our 2021 primer on aircraft emissions and alternative fuels framed hydrogen as a post-2035 technology and SAF as the nearer-term lever, citing SAF’s roughly 80% lifecycle carbon reduction versus conventional jet fuel. Both of those points still hold. Airbus’s ZeroE hydrogen concepts have not moved to a firm production timeline, and industry consensus still treats hydrogen-powered commercial aviation as a 2040s-and-beyond prospect at the earliest – which is exactly why the ReFuelEU and UK/Swiss mandates above are built entirely around SAF and e-kerosene rather than hydrogen.

UK and US: worth checking current figures directly

Our 2022 EU/UK/USA overview described the UK’s Jet Zero Council consultation and the US SAF Grand Challenge while both were still in the policy-design stage. The UK has since put its own SAF Mandate into force, running on a similar trajectory to ReFuelEU; the US picture has moved through several rounds of federal incentive and administration changes since 2021. Because both are genuinely live policy areas with figures that keep shifting, treat the specific percentages and dollar amounts in the 2022 article as historical rather than current, and check gov.uk and the relevant US federal agencies directly if you need today’s numbers for either.

This article supersedes four earlier Raven pieces on SAF and EU carbon policy, which remain on the site for historical reference: ReFuelEU: EU Agrees to Leading SAF Mandate (2023), An Overview of SAF in the EU, UK and USA (2022), Airlines and NGOs Call for Revamp of EU ETS (2022), and Sustainability: Aircraft Emissions and the Rise of Alternative Fuels (2021).