Strengthening Climate Protection and Fair Competition: Aviation Associations BDL and FNAM Submit Steer Report on the Further Development of the "Fit for 55" Climate Package to the European Commission

The associations representing the German and French aviation industries, BDL and FNAM, submitted a report to the European Commission in Brussels this Thursday, outlining solutions for fair competition and enhanced climate protection in air travel. The independent study was conducted by the internationally recognized consulting firm Steer.

At its core, Steer proposes two models to distribute the significant additional costs associated with using Sustainable Aviation Fuels (SAF) across all airlines in a competition-neutral manner: a SAF levy on all flights departing from an EU airport to their final destination—or a ticket surcharge exclusively for journeys involving a stopover at a hub outside the European Union.

According to BDL and FNAM, these proposals are well-suited to counteracting competitive distortions, particularly on flights from Europe to Asia and Africa. After North America, Asia is the second-largest long-haul destination region from Europe and is therefore of great importance to the European aviation industry.

“To sustainably advance climate protection, we need economically healthy companies,” said FNAM Managing Director Laurent Timsit. “Only in this way can billions of euros be invested annually in efficient next-generation aircraft and sustainable aviation fuels. This can only succeed if we establish fair competitive conditions for European airlines—a level playing field. The solutions identified in the study reflect the spirit of the ‘Clean Industrial Deal’: reconciling decarbonization with competitiveness.

The background to the Steer report is the SAF blending mandate introduced this year for all departures from EU airports, a key component on the path to carbon-neutral flying by 2050. “The aviation industry in Germany and France explicitly supports the goals of the EU’s ‘Fit for 55’ climate package and the associated climate protection instruments, including the SAF blending mandate,” said BDL Managing Director Dr. Joachim Lang. “However, the rules of the ‘ReFuelEU Aviation’ regulation on the use of sustainable fuels do not currently apply equally to all airlines. Carriers from third countries such as Turkey, Dubai, or Qatar can offer tickets—particularly between Europe, Asia, and Africa—at significantly lower prices.”

Since the beginning of the year, a minimum SAF blending requirement of 2% for jet fuel has been mandated. By 2030, the blending mandate will rise to 6% SAF, including 1.2% e-fuels (synthetic PtL fuels). By 2050, sustainable fuels should account for 70%, with half of that being e-fuels.
However, SAF is currently in very short supply and three to five times more expensive than conventional jet fuel. While the additional costs—around €2,000 per ton of SAF—apply to the entire journey on direct flights from EU hubs such as Paris or Frankfurt to destinations like Hong Kong or Singapore, increasing ticket prices significantly over time, the same costs under the current ‘ReFuelEU’ regulations only apply to the first, much shorter segment when transferring at a hub outside the EU, such as Istanbul, Doha, or Dubai.

Compared to today’s price levels, an economy ticket on an EU airline to Hong Kong could become up to 70% more expensive by 2050, while for competitors from third countries, the increase would be less than 10%.
The aviation associations highlight this as a severe competitive distortion, putting the European aviation industry at a disadvantage. This threatens jobs and economic value creation within the European Union. “Emissions are merely shifted to other regions of the world, severely weakening the European aviation industry. This cannot be in the interest of a strong Europe,” Timsit remarked.

At its core, Steer proposes the following measures:

1. A SAF levy would be a fee for all passengers departing from EU airports, added as a surcharge on flight tickets. The revenue would be used to offset the additional costs of SAF compared to conventional jet fuel for all flights departing from an EU airport. The fee would apply to the passenger’s entire travel route to their final destination—regardless of whether a stopover at a non-EU hub is involved.

2. The SAF Rebalancing Charge (SRC) would also be a ticket surcharge but would only apply to passenger routes where a flight segment does not comply with the SAF requirements of the ‘ReFuelEU’ regulation (e.g., connecting flights outside the EU operated by non-EU airlines). The revenue from this charge would be significantly lower and would be used for decarbonization measures in EU aviation.

• Additionally, extending the free allocation of emissions allowances when using SAF (‘SAF Allowances’) beyond 2030, as well as increasing the free allocation up to 2030, could help reduce the price gap between SAF and conventional jet fuel, mitigating competitive distortions.

“BDL and FNAM urge the European Commission to address the competitive distortions caused by ‘ReFuelEU Aviation’ now, rather than waiting for the planned review process in 2027. This will strengthen both climate protection and the European industry in a sustainable manner,” emphasized Dr. Lang. The EU Commission should engage with the aviation industry, using the Steer report as a basis to discuss measures that combine climate protection with fair competition. In any case, an european SAF levy should replace all national aviation taxes.

Furthermore, the EU should advocate for a global scaling of SAF and an expansion of the international climate protection instrument CORSIA. The UN aviation organization ICAO’s system has the most effective global impact in promoting climate protection while ensuring fair competitive conditions. “It is crucial to act now to achieve decarbonization goals and secure the long-term competitiveness of the European economy,” was the joint appeal from the top representatives of BDL and FNAM to the new European Commission.

You can find the report here for download.