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.

โœ… Key Points of the Presentation:

๐Ÿ“Œ 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.

๐Ÿ“Œ 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.

๐Ÿ“Œ Certification

  • Particular attention should be given to the concept of โ€œdual conformanceโ€ โ€” 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.

โ˜‘๏ธ 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.

2nd Florence Aviation Regulation Conference

2nd Florence Aviation Regulation Conference, Florence School of Regulation

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-COโ‚‚ effects in aviation

Public Consultations. Delegated Act about reporting of CORSIA-eligible fuels

Delegated Act about reporting of CORSIA-eligible fuels

โœˆ๏ธ The European Commission conducts the Public Consultation regarding the draft of the Delegated Act about reporting of CORSIA-eligible fuels and CORSIA emissions unit cancellation reports.

๐Ÿ“… Feedback Period – 01 April 2025 – 29 April 2025

โœ… What is the CORSIA?

The Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA):

  • has been in operation since 2019 for monitoring, reporting and verification of carbon dioxide emissions.
  • is intended to be a globally applied market-based measure, which aims to offset international aviation carbon dioxide emissions from January 2021.

โœ… Key Points:

๐Ÿ“Œ This Delegated Act aims to update the current rules to facilitate:

  • reporting of fuels eligible under the CORSIA; and
  • submission and verification of CORSIA emissions unit cancellation reports.

๐Ÿ“Œ โ€˜CORSIA eligible fuelโ€™ means an aviation fuel certified as CORSIA (Carbon Offsetting and Reduction Scheme for International Aviation) eligible fuel by sustainability certification schemes listed in Annex I;

๐Ÿ“Œ Annex I: CORSIA approved sustainability certification schemes:

  • International Sustainability and Carbon Certification (ISCC)
  • Roundtable on Sustainable Biomaterials (RSB)
  • ClassNK SCS

๐Ÿ“Œ It should be possible to certify a batch of alternative aviation fuel under several schemes if it fulfils the criteria for each of those schemes. In order to prevent double claiming, aircraft operators should submit a declaration listing all GHG schemes they participate in, confirming that no amount of the alternative aviation fuel is reported more than once.

๐Ÿ“Œ This Delegated Act should apply to the emissions and use of CORSIA eligible fuels that have occurred since 1 January 2024.

โžก๏ธ Source: EU Emissions Trading System (ETS) โ€“ reporting of CORSIA-eligible fuels and CORSIA emissions unit cancellation reports