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On 27 February 2025, the European Commission published a final report on the Assessment of the Production and Supply of SAF in Union Airports and the Feasibility of a System of Tradability of SAF in the EU. The report is a key element in evaluating the progress of ReFuelEU Aviation Regulation (EU) 2023/2405, which mandates a gradual increase in the share of sustainable aviation fuel (SAF) supplied at Union airports from 2025 onwards.

The regulation aims to decarbonise the aviation sector while ensuring a level playing field for sustainable air transport. To facilitate this transition, a SAF flexibility mechanism was introduced, allowing fuel suppliers to meet their SAF obligations through a weighted average across all Union airports they operate in, rather than ensuring physical delivery at each individual airport. The study assesses how this flexibility mechanism is functioning and explores potential enhancements to improve efficiency, supply, and market accessibility. The report provides a detailed overview of the current state of the European aviation fuel market, outlining key challenges to scaling up SAF production and supply. These challenges include:

• Limited Physical Access to SAF: Many Union airports - especially smaller or remote ones - may not have access to SAF for the foreseeable future due to geographical and logistical constraints.
• High Costs & Investment Barriers: SAF remains significantly more expensive than fossil jet fuel, with price variations ranging from 1.5x to 10x higher. Uncertainty over feedstock definitions and policy frameworks is delaying investment in new production capacity.
• Supply Chain Imbalances: The rigid requirement for physical SAF availability at all major airports could lead to supply inefficiencies, preventing an optimal market-based allocation of SAF across the EU.

The report briefly considers how a book and claim system could be considered to allow more flexibility for how aviation fuel suppliers or aircraft operators can claim volumes of SAF.

As noted in a recent news article, CLECAT along with other key stakeholders across the aviation ecosystem, have in a recent joint letter highlighted the need for additional regulatory action to support investment in SAF production and ensure a fairer and more efficient SAF market. A book and claim system would enhance market efficiency, enable a more flexible allocation of SAF, and help bridge the cost gap with conventional aviation fuels. Without such measures, there is a risk that structural imbalances will persist, making it more difficult for the industry to meet the ambitious sustainability targets set by ReFuelEU Aviation.

Given the urgency of scaling up SAF production, industry stakeholders are urging the Commission to take swift action and introduce regulatory improvements that will facilitate a more competitive and effective SAF market in the EU.