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Energy Regulation Solutions

  • Energy Regulation Solutions

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    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

Category Archives: Regulation news

Author Image Posted By : admin 22 Apr, 2025

SAF Flexibility Mechanism

SAF Flexibility Mechanism

Let’s talk about the SAF Flexibility Mechanism in the EU.

✅ Main Documents:

☑️ What is the SAF Flexibility Mechanism?

📌 the SAF flexibility mechanism allows an aviation fuel supplier to supply the minimum shares of SAF as a weighted average over all the aviation fuel it supplied across all EU airports for each reporting period.

📌 the SAF flexibility mechanism is intended to give the SAF industry sufficient time to scale up its production and supply capacities.

📌 this means that aviation fuel suppliers may supply aviation fuels containing higher shares of SAF in certain EU airports to compensate for aviation fuels containing zero or lower shares of SAF in other EU airports.

📅 The SAF flexibility mechanism applies from 1 January 2025 until 31 December 2034.

✅ Some key conclusions from SAF flexibility mechanism report:

📌 Compliance with targets:

  • Aviation fuel suppliers can claim the supply of SAF for the purposes of complying with their ReFuelEU Aviation obligations and contributing to the national RED targets.
  • EU law does not prevent a batch of SAF to be certified under more than one certification scheme (e.g. RED, CORSIA certified fuels).
  • Aircraft operators can claim the use of a given quantity of SAF under one GHG reduction scheme, including the EU ETS and ICAO’s CORSIA.

📌 Virtual trading of SAF sustainability certificates

  • there is no unified industry-wide position neither on the design or the necessity of implementing such an accounting mechanism system for the purposes of complying with current blended SAF obligations and of claiming their use under other pieces of EU law, such as the EU ETS that does not allow aircraft operators to claim the use of blended SAF without physically delivery.
  • virtual trading of SAF sustainability certificates may bring new dynamics to the market on the demand side, but it is not clear whether this would have any real impact on the production side at this early stage.

📌 Availability of blended SAF at EU airports

  • the risk of a significant geographic concentration of blended SAF in few EU airports is limited.
  • most aviation fuel suppliers operate only within the borders of their respective Member State, so the possibility of significant geographic concentration is already largely limited to national markets.
  • many EU airport managing bodies have clearly communicated their intention to make blended SAF available in the coming years on their premises.
  • projects for new SAF capacities are appearing in various locations across the EU.
Author Image Posted By : admin 20 Apr, 2025

Public Consultations. EU ETS for maritime, aviation and stationary installations

EU ETS for maritime, aviation and stationary installations

The European Commission has commenced the public consultation regarding EU ETS for maritime, aviation and stationary installations, and market stability reserve.

📄 Type of Act – Proposal for a Directive

📅 Feedback period – 14 April 2025 – 08 July 2025

✅ The following aspects are subject to review:

📌 Aviation emissions:

  • the EU has temporarily limited the scope to intra-EEA flights that encourages the development of an effective global carbon pricing scheme by the ICAO.
  • by mid-2026, the Commission should make a report on CORSIA.
  • the ETS Directive suggests assessment criteria and indications on geographical scope.

📌 Maritime emissions:

  • the European Commission will have to assess the GHG pricing mechanism and market-based measures that will possibly be adopted at the IMO in 2025 and review the ETS accordingly to avoid a significant double burden on maritime operators;
  • the European Commission will have to consider extending the EU ETS to cover emissions from smaller ships (i.e. ships below 5 000 gross tonnage but not below 400 gross tonnage);
  • the European Commission should monitor implementation of the recent extension of the EU ETS to maritime transport, and consider legislative improvements to ensure the effective implementation of the extension;
  • the European Commission should simplify and improve the system where possible.

📌 Municipal waste incineration:

  • This looks at the feasibility of including such installations in the EU ETS from 2028.

📌 Non-permanent carbon capture and use:

  • the impact assessment will look at whether all GHG emissions covered by the EU ETS are effectively accounted for and whether double counting is being avoided, in particular regarding GHG emissions considered to have been captured and utilised in a product non-permanently.

📌 Carbon removals:

  • the possible inclusion of domestic permanent carbon removals in the EU ETS.
  • how the EU ETS could account for negative emissions resulting from GHGs that are removed from the atmosphere and safely and permanently stored underground or permanently stored in products;
  • how those negative emissions, if appropriate, could be covered by ‘emissions trading’ or other policies, setting a clear scope and strict criteria;
  • putting in place of safeguards to ensure that such removals do not offset necessary emissions reductions.

☑️ WHAT NEXT?

📌 At the end of this consultation process, a factual summary report and a synopsis report will be drafted.

📌 The Commission Adoption – Q3 2026.

➡️ Source: EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve – review

Author Image Posted By : admin 10 Apr, 2025

Hydrogen in Coalition Agreement

Hydrogen in Coalition Agreement

On 9 April 2025, the German political parties published their coalition agreement.

✅ Parties of the agreement:

  • CDU/CSU – the Christian Democratic Union of Germany / Christian Social Union
  • SPD – the Social Democratic Party of Germany.

☑️ What is a Coalition Agreement:

  • is an agreement between the parties that form a coalition government.
  • identifies the most important shared goals and objectives of a new government.
  • is legally not binding for Parliament.

➡️ The Coalition Agreement is available via this link

✅ Hydrogen in the Coalition Agreement:

📌 Hydrogen economy:

  • climate-friendly hydrogen from various sources.
  • the long-term goal is to transition to climate-neutral hydrogen from domestic production and imports.

📌 Reduction of Overregulation:

  • to advocate for pragmatic national and European regulations and their rapid implementation.
  • overregulation must be reduced.

📌 Hydrogen Production:

  • through large, system-supporting electrolysis plants; and
  • increasingly in a decentralized and nationwide manner.

📌 Hydrogen Import:

  • to consistently expand energy partnerships and the cross-border and necessary domestic infrastructure for imports of hydrogen and its derivatives in all directions.
  • this includes connections to all German and European ports.

📌 Hydrogen Funding:

  • to utilize national and European funding instruments, such as H2 Global, IPCEI projects, and specific programs for SMEs.

📌 Hydrogen Infrastructure:

  • the hydrogen core network must connect industrial centers throughout Germany, including in southern and eastern Germany.
  • hydrogen storage facilities must also be taken into account.
  • the financing conditions must ensure that the core network is implemented and the distribution network is also developed in an integrated plan.