Why allowing "e-HEFA" to count towards the ReFuelEU e-SAF mandate would be a strategic mistake
Lead author
Under the ReFuelEU regulation, jet fuel suppliers face a dedicated sub-mandate requiring a growing share of synthetic aviation fuel (e-SAF), i.e. SAF produced from green hydrogen combined with captured CO2, starting in 2030.
Despite this obligation being known for years, most fuel suppliers have not developed their own e-SAF production capacity, nor made meaningful investments in, or offtake agreements with, third-party e-fuel producers.
As a result, e-SAF project developers are failing to materialize and the EU’s ability to meet its targets is becoming tighter as we speak, exposing fuel suppliers and the whole aviation industry to heavy financial penalties.
Instead of accelerating their investments to avoid the potential shortage of e-SAF and meet their obligations, the big oil and gas industry has come up with an accounting trick: they would like to be allowed to relabel part of their biofuel production as e-fuel, with the excuse that they (sometimes) use green hydrogen in the production process of these biofuels.
The consequences of this accounting trick would be genuinely harmful at many levels:
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It undermines the genuine e-SAF targets, originally developed to boost the scale up of clean fuels for aviation. Instead, it would stifle a growing European market of 40+ big projects being developed at a time when it needs support to continue expanding. It puts these projects at risk by harming investors’ confidence in the stability of the regulatory framework and making it harder to secure offtake agreements. The EU could lose yet another industrial opportunity to China.
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It rewards fuel suppliers’ inaction by giving them an easy way out: instead of paying for their failure to pilot the transition to green fuels, they could get windfall profits by selling so-called e-HEFA just below genuine e-SAF (whereas it costs them much less to produce).
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It harms the environmental integrity and credibility of the EU’s main aviation climate regulation in place. The pathway in question keeps us tied to limited and largely imported waste oils and fats.
Learn more about why allowing "eHEFA" to count towards the eSAF mandate would be a mistake by reading the full briefing.
T&E recommends
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1
Align the RFNBO Delegated Acts with the Low Carbon Fuels Delegated Act by explicitly excluding any RFNBO used as an intermediate input in biofuel production, whether via HEFA hydrotreatment or co-processing, from the calculation of RFNBO output. This single clarification would close the current legal ambiguity, end the inconsistent interpretations by certification schemes, and ensure that the e-SAF sub-mandate continues to drive genuine investment in new e-fuel production capacity rather than allowing existing biofuel volumes to be relabelled as compliance.
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2
Uphold dedicated e-SAF sub-target in ReFuelEU and protect the integrity of future synthetic fuel requirements under FuelEU Maritime to ensure regulatory stability. Any non-compliance penalties incurred by fuel suppliers are a direct consequence of their failure to proactively invest and prepare, despite having had ample time and clear regulatory signals.
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3
Accelerate the deployment of key support mechanisms, like the pilot double-sided auctions of the Early Movers Coalition as a stepping stone toward a wider EU market intermediary, and the ETS SAF allowances.
