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CLECAT has submitted comprehensive comments to the European Commission in response to the targeted consultation supporting the study on a possible EU “book & claim” system for Sustainable Aviation Fuels (SAF).

In its contribution, CLECAT stressed that freight forwarders are already engaging in voluntary book & claim arrangements to facilitate SAF uptake and to meet increasing customer demand for lower-emission air cargo solutions. However, under the current EU regulatory framework, these voluntary initiatives remain disconnected from compliance mechanisms under ReFuelEU Aviation and recognition under the EU ETS, as well as from the traceability provisions under the Renewable Energy Directive (RED III). This misalignment creates legal and operational uncertainty across the SAF value chain. 

CLECAT argued that a properly regulated EU-level book & claim system, embedded in the Union Database for Biofuels, could significantly improve market functioning. By allowing environmental attributes to be allocated independently of the physical location of fuel uplift, such a system would broaden access to SAF across routes and carriers, reduce distortive effects linked to local supply concentration, and enhance transparency in the allocation of SAF volumes and associated surcharges. For freight forwarders in particular, this is crucial in the context of Scope 3 emissions reporting, where credible and verifiable emissions-reduction claims are increasingly required by customers.

A key concern raised in the submission relates to the existing traceability gap. While blending obligations are imposed upstream and SAF batches are registered, downstream actors lack sufficient visibility on verified volumes and cannot systematically link SAF-related costs to recognised emissions reductions. Without regulatory alignment and a standardised certificate-based allocation mechanism, companies investing in SAF face uncertainty in translating these efforts into legally recognised carbon reductions.  CLECAT therefore called for coordinated adjustments across RED, ReFuelEU Aviation and the EU ETS to ensure full recognition of SAF certificates, alignment of monitoring and reporting rules, and a robust EU-wide registry framework capable of issuing, transferring and cancelling certificates in a transparent and legally secure manner.