Energy Regulation Solutions offers specialized regulatory consulting at the intersection of innovation, climate goals, and market readiness. We support developers, investors, and policymakers in navigating complex regulatory landscapes for hydrogen, CO₂, and Power-to-X technologies in the EU, Germany, and the US.

As part of my research, I closely follow recent developments regarding Germany’s national Power-to-Liquid (PtL) quotas for aviation and would like to share the key updates with you.

🔹 What do PtL quotas mean?

Power-to-Liquids (PtL) refers to liquid hydrocarbons produced using electricity, water, and CO₂ as inputs. Based on these characteristics, PtL quotas cover targets and obligations for hydrogen-based fuels, such as e-SAF for aviation.

🔹 What happened in Germany?

• In September 2021, Germany adopted ambitious PtL quotas for aviation through amendments to the Federal Immission Control Act (BImSchG).
• These mandatory national quotas required a minimum share of RFNBOs in aviation fuel of:
  • 0.5% in 2026
  • 1% in 2028
  • 2% in 2030.
• The basis for adopting such ambitious quotas was the German PtL roadmap for aviation fuels, published in April 2021.
• However, these national PtL quotas were more ambitious than those established under the ReFuelEU Aviation Regulation, which introduces a minimum PtL sub-quota only from 2030 onwards.
• As a result, the European Commission opposed the German national quotas, emphasizing the binding nature of ReFuelEU Aviation as an EU regulation that replaces national PtL quotas for aviation.

🔹 How was this PtL quota issue resolved?

• In October 2024, the German Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV) announced revisions to the national PtL quotas for aviation.
• In June 2025, BMUV published the Draft Law for a Second Law on the Further Development of the GHG Reduction Quota (the Draft Law on the GHG Reduction Quota), proposing the removal of national PtL quotas for aviation from the BImSchG.
• In December 2025, the national PtL quotas for aviation were formally abolished through the Draft Law on Accelerating the Expansion of Geothermal Energy Plants, Heat Pumps and Heat Storage Facilities, and on Amending Other Legal Framework Conditions for the Climate-Neutral Expansion of Heat Supply.

➡️ The German PtL quota will expire on January 1, 2026.

✅ What’s next?

The PtL quotas for aviation are included in the Draft Law on the GHG Reduction Quota and will be based on the minimum share of e-SAF set out in the ReFuelEU Aviation Regulation.

If you have any questions about PtL quotas, I’d be happy to discuss them.

🔗 The Draft Law: Gesetz zur Beschleunigung des Ausbaus von Geothermieanlagen, Wärmepumpen und Wärmespeichern und zur Änderung weiterer rechtlicher Rahmenbedingungen für den klimaneutralen Ausbau der Wärmeversorgung sowie zur Änderung des Baugesetzbuchs und zur Änderung des BundesImmissionsschutzgesetzes

🔗 Source: Bundesrat beschließt Abschaffung der nationalen PtL-Quote