T&E's recommendations for Sustainable Transport Investment Plan (STIP)
The European Union Aviation Safety Agency (EASA) has published its first annual technical report on the implementation of the ReFuelEU regulation, which monitors how airlines and fuel suppliers are complying with the new sustainable aviation fuels (SAF) mandate. The findings paint a sobering picture of the state of the energy transition of the EU’s aviation sector.
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SAF uptake is still low, but the EU is on track to meet its early SAF targets: In 2024, SAF represented just 0.6% of jet fuel supplied to EU airports, but these were only voluntary deliveries as the mandatory quotas were not yet into force. The report shows that operational SAF production capacity in the EU already stands at 1.4 Mt, which is sufficient to meet not only the 2025 target of 2% but also the 2030 target of 4.8%. Including facilities currently under construction, the EU’s total SAF production capacity is expected to reach around 3.6 Mt by 2030.
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Over-reliance on imported biofuels: All SAF consumed in 2024 were biofuels, 80% of which were derived from used cooking oils (UCOs), and 17% from animal fats. Alarmingly, 69% of these feedstocks were imported, with China contributing 38% and Malaysia 12%. Imported UCOs are a feedstock stream particularly vulnerable to fraud and lacking robust verification mechanisms. Europe should prioritise European feedstocks instead, T&E underlines.
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E-fuels absent from the mix: Despite 40+ projects under development across Europe, not a single drop of e-fuel has yet reached the market. Without stronger public support to de-risk investments and provide long-term revenue certainty, these projects risk stalling before they even materialize.
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Climate benefits undermined by air traffic growth: SAF deliveries in 2024 avoided 714,000 tonnes of CO₂ emissions — equivalent to just 0.5% of the sector’s total emissions. Yet European aviation emissions as a whole rose by 8% last year due to increasing traffic.
While SAFs will play a key role in the decarbonisation of the aviation sector, they cannot compensate for the ever-increasing emissions caused by uncontrolled air traffic growth. T&E’s Down to Earth study finds that due to exponential growth, in 2049, the sector could be burning as much fossil kerosene as it did in 2023, even when using 42% of SAF, as required by RefuelEU.
For the aviation sector to start reducing its emissions in the same way that other sectors are already doing, the EU must urgently:
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1
Ramp-up investment in zero emission aviation and e-fuels.
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2
End airport infrastructure expansion
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3
Address frequent flying
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4
Put an end to the sector’s chronic under-taxation
“Europe’s aviation transition is slowly taking off. SAF uptake remains small (0.6% of jet fuel in 2024) but production capacity suggests the 2025 and 2030 targets are within reach. However, today’s supply largely relies on imported feedstocks, particularly used cooking oil, a feedstock with high fraud risks and limited scalability. At the same time, not a single drop of e-SAF has yet been delivered, even though it is the only truly scalable solution for the sector. Unless the EU preserves its SAF targets, develops a home-grown SAF industry, provides revenue certainty for e-fuels, and addresses unsustainable air traffic growth, aviation emissions will keep rising.”, Camille Mutrelle, aviation policy officer, said.
The upcoming Sustainable Transport Investment Plan (STIP) offers a unique opportunity to channel support where it matters most: into scalable e-fuel projects that can provide a genuine, long-term climate solution for the aviation sector. Read our proposals here.
