#aviation - Archives - Energy Regulation Solutions

Germany’s national Power-to-Liquid quotas

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

Posted By : admin 12 Dec, 2025

Updates about RED III and ReFuelEU Aviation in Germany

Updates about Transposition of RED III and ReFuelEU Aviation in Germany

On 10 December, the German Federal Cabinet approved the draft of a Second Law on the Further Development of the Greenhouse Gas Reduction Quota.

This quota, as the central legal instrument for reducing greenhouse gas (GHG) emissions from fuels, shall gradually make refueling more climate-friendly. It specifies the extent to which fuel suppliers must reduce CO2 emissions by using sustainable biofuels, renewable hydrogen-based fuels, or electricity for electric vehicles.

➡️ The Draft of Law is available via this link: Entwurf eines Zweiten Gesetzes zur Weiterentwicklung der Treibhausgasminderungs-Quote

✅ Key Points of the Draft Law:

📌 The draft law implements the amendments to the Renewable Energy Directive (RED III), whose targets must be achieved by 2030. To provide greater investment security, the German government extends the timeline to 2040, going beyond the RED III, to support long-term corporate investment planning.

📌 The law serves to implement the ReFuelEU Aviation Regulation at the national level with regard to fuels.

📌 The draft law includes amendments to the Federal Immission Control Act (BImSchG) and the Regulation on the crediting of electricity-based fuels and co-processed biogenic oils towards the greenhouse gas quota (37th BImSchV).

📌 It introduces definitions of aviation fuel suppliers and distributors, as well as penalties for aviation fuel suppliers that fail to comply with their obligations under the ReFuelEU Aviation Regulation with regard to the share of sustainable aviation fuel (SAF):

EUR 4,700 per tonne for SAF
EUR 17,000 per tonne for synthetic aviation fuels or e-SAF.

📌 It defines the eligibility criteria for e-SAF and renewable hydrogen for aviation.

📌 It establishes minimum shares of RFNBOs for fuel suppliers (excluding aviation fuel suppliers):

0.1% from 2026
0.5% from 2028
1.2% from 2030
1.5% from 2032
2.5% from 2034
4.0% from 2036
5.0% from 2037
6.0% from 2038
7.0% from 2039
8.0% from 2040

☑️ Next Steps:

The law will enter into force on the second day after its publication in the Federal Law Gazette.
The Draft Law must now be submitted to the Federal Council (Bundesrat) and the German Bundestag for debate. Approval by the Federal Council is not required. However, the Bundestag may still introduce amendments.
After adoption by the Bundestag, the law can be submitted to the Federal President for signature and then published.
The legislative process is expected to be completed in the first quarter of 2026.

🔗 Source: Klimafreundlicher tanken, neue Nachfrage für grünen Wasserstoff: Bundesregierung beschließt Gesetzesnovelle zur Treibhausgasminderungs-Quote

Posted By : admin 23 Oct, 2025

ReFuelEU Aviation Annual Technical Report

✈️ The European Union Aviation Safety Agency (EASA) has published the first ReFuelEU Aviation Annual Technical Report.

☑️ Synthetic Aviation Fuels (e-SAF) Market Development as of June 2025:

The global pipeline for e-SAF facilities comprises 94 announced demonstration or commercial projects, with a combined capacity of 7.2 million tonnes per year.
The European Economic Area (EEA) is the frontrunner, accounting for 59% of projects and 42% of planned capacity.
Due to the absence of binding e-SAF mandates outside the EU and UK, many projects are oriented toward exporting to the European market.
Planned non-EEA capacity faces both slow project progress and the challenge of meeting the EU’s stringent sustainability criteria before these fuels can be imported into the EU.

✅ Key Takeaways:

📌 EU SAF production capacities are projected to be sufficient to meet the minimum SAF shares defined under the ReFuelEU Aviation Regulation for 2030 (excluding e-SAF).

📌 A continuous scale-up of production will be necessary to establish a well-functioning market and achieve the 2035 ReFuelEU targets, which rise to 20% that year. The scale-up of e-SAF production in the EU is still lagging.

📌 As of today, none of the se-SAF facilities in the EU have reached Final Investment Decision (FID), putting at risk the 2030 sub-target for e-SAF. To meet that target, given development lead times, several facilities must reach FID by 2026 at the latest.

📌 Of the feedstock used for SAF supplied in the EU, 69% originated from non-EU countries, with China contributing 38%, Malaysia 12%, and Finland 10% as the largest European contributor.

📌 In 2024, 25 aviation fuel suppliers (out of 83) reported a total supply of 193 kt of SAF. Fewer than ten suppliers accounted for 80% of this amount, indicating a high level of market concentration. This suggests that the EU SAF market remains nascent and dominated by a few mature or well-capitalized players.

📌 SAF was delivered to 33 Union airports across 12 EU Member States, with 5 Member States – France, the Netherlands, Spain, Sweden, and Germany – accounting for 99% of the total amount supplied.

📌 According to Eurostat, the EU imported 80 kt of SAF in 2024, representing over 40% of the total EU SAF supply that year, highlighting the continued importance of imports despite the gradual growth of domestic production.

➡️ Source: European Union Aviation Safety Agency. ReFuelEU Aviation Annual Technical Report 2025

Posted By : admin 18 Jul, 2025

Interaction of Certification and Standards for e-SAF Production

Last week, I had the opportunity to present my paper “Interaction of Certification and Standards for e-SAF Production” at a conference hosted by the Florence School of Regulation. This research is part of my broader PhD work on the interaction between law and technology in the regulation of Power-to-X (PtX) technologies.

✅ Key Points of the Presentation:

📌 General requirements

To be used in aviation, e-SAF must be certified under either the EU Renewable Energy Directive (RED) or the CORSIA scheme, and blended with conventional jet fuel in accordance with international standards such as ASTM D7566 and Def Stan 91-091.

📌 Legal Framework

There is a lack of harmonization between the EU legal framework and international aviation fuel standards.
The definition of SAF in the ReFuelEU Aviation Regulation does not align with the definition used in international standards.

📌 Certification

Particular attention should be given to the concept of “dual conformance” — i.e., a single batch of SAF being compliant with two different certification schemes (such as EU RED and CORSIA).
The coexistence of two certification schemes – EU RED and CORSIA within the EU raises questions about the feasibility of such dual conformance, a concept that is not yet defined under EU law.

☑️ Conclusion

A harmonized and coherent legal framework is essential for scaling up e-SAF production and deployment in aviation.
Aligning EU regulations with international safety and sustainability standards will help remove existing regulatory barriers and support the widespread adoption of e-SAF across the EU.

Maryna Hritsyshyna. Interaction of certification and standards for e-SAF production

GHG Emissions: aviation emits about 3% of global carbon dioxide, about 96% of GHG emissions in aviation belong to the large airplanes.
Sustainable aviation fuel: a solution for medium and long-haul airplanes, allow reducing carbon emissions by 50-80% in comparison with the conventional fuel.

Posted By : admin 11 Jul, 2025

2nd Florence Aviation Regulation Conference

Just returned from the 2nd Florence Aviation Regulation Conference, co-organized by the International Institute of Air and Space Law (IIASL), Leiden University and the Florence School of Regulation.

It was an honor to contribute to such a high-level exchange of ideas shaping the future of aviation regulation.

I had the pleasure of presenting my paper on “Interaction of Certification and Standards for e-SAF Production”, exploring how regulatory frameworks and technical standards impact the uptake of sustainable aviation fuels in Europe.

The conference addressed a wide range of topics, including:

Interaction between CORSIA and the EU ETS
Implementation of the AI Act in aviation
Market incentives and social sustainability in the net-zero transition
Regulation of non-CO₂ effects in aviation

Posted By : admin 31 May, 2025

ICAO dashboard update

Source: ICAO web site

✈️ The International Civil Aviation Organization (ICAO) updated the dashboard with publicly-available information on sustainable aviation fuel (SAF) offtake agreements.

📌 This dashboard covers various locations worldwide.

📌 Volumes refer to neat SAF; in case of blended SAF announcements the volumes refer to the fraction of SAF in the blend.

➡️ Source: ICAO web site. Offtake Agreements

Posted By : admin 22 Apr, 2025

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.

Energy Regulation Solutions

About us

Tag Archives: #aviation