Mixed aviation fuels contain SAF blended with conventional aviation fuel. Under the EU ETS, SAF can receive zero-rating, meaning their use lowers an aircraft operators surrender obligation, and they can also benefit from FEETS support. Under ICAO’s CORSIA scheme, the use of SAF may reduce CO2 offsetting obligations.

SAF in the EU ETS: zero-rating and FEETS support

By using SAF, aircraft operators can zero-rate their emissions and reduce the number of ETS allowances they need to surrender. They can also apply for FEETS support, which helps cover the higher cost of SAF compared to fossil kerosene.

There are different types of fuel, depending on the feedstock, conversion process or origin of energy, that can either be used for zero-rating or are eligible for FEETS support. The scheme below depicts under which schemes the different types of fuels are applicable:

Image: © SENASA

To qualify for a zero-rating or apply for FEETS support, aircraft operators must demonstrate that the sustainable component of the mixed aviation fuel meets the sustainability and greenhouse gas (GHG) savings criteria outlined in the Renewable Energy Directive II (RED). This compliance is in principle evidenced through a Proof of Sustainability (PoS). Additionally, aircraft operators must ensure adherence to the provisions in the MRR related to the zero-rating of biomass, RFNBO, RCF, or synthetic low-carbon fuels.  

Reporting SAF under the EU ETS may only be done in accordance with an emissions monitoring plan approved by the NEa. Additionally, documentation is required to support this claim and demonstrate compliance with the RED criteria, as defined in the MRR and the national regulation Regeling handel in emissierechten. 

Small emitters reporting annual emissions using the small emitters tool (SET) from Eurocontrol are currently not able to report biofuels. If a small emitter wishes to zero-rate the alternative aviation fuels used or apply for FEETS support, they can supplement their annual emissions report with the required information and have it verified by an accredited verifier.

Additionally, relevant monitoring procedures must be provided in the monitoring plan. 

Monitoring plan

Appropriate monitoring and reporting procedures for the use of alternative and eligible fuels should be included in the monitoring plan (Section 8: Emission factors) in accordance with the MRR. The procedures should cover the following aspects:

  • Determination of fraction alternative and eligible fuels (as neat fuel) in mixed fuels (Article 53 & Article 54)
  • Determination of CO2 emissions by multiplying the annual consumption of each neat fuel (tonnes) by the respective emission factor (Article 53)
  • Attribution of alternative and eligible fuels to flights (physical and non-physical delivery of fuels to flights), including proportionality principle (Article 53a & 54a)
  • How compliance will be demonstrated to the satisfaction of the competent authority that (Article 53a):
    • The total amount of alternative aviation fuel claimed does not exceed the total fuel usage of that aircraft operator for flights for which allowances have to be surrendered in accordance with Article 12(3) of Directive 2003/87/EC and for flights covered by Article 3c(8) of that Directive, originating from the aerodrome at which the eligible aviation fuel is supplied
    • The amount of alternative aviation fuel for flights for which allowances have to be surrendered in accordance with Article 12(3) of Directive 2003/87/EC does not exceed the total quantity of alternative aviation fuel purchased from which the total quantity of alternative aviation fuels sold to third parties is subtracted
    • The ratio between alternative aviation fuels and fossil fuels attributed to flights aggregated per aerodrome pair does not exceed the maximum blending limit for that fuel type as certified according to a recognised international standard;
    • There is no double counting of the same quantity of alternative aviation fuel, in particular that the alternative aviation fuel purchased is not claimed to be used in an earlier report or by another aircraft operator, or in another carbon pricing system
  • Compliance to RED criteria (Article 54c)

Required information and documentation for demonstrating the sustainability and GHG savings criteria

Under the EU ETS, airlines can claim reduced emissions or apply for FEETS support if the fuels used  comply with the RED. There are several options to demonstrate sustainability and GHG savings under the RED, which may also be used in combination. The approach can depend on where the fuel is delivered and on the type of sustainability proof the fuel supplier is able to provide.

Option 1: Proof of Sustainability

A Proof of Sustainability (PoS) is a declaration issued by a certification body within the framework of a voluntary scheme or national certification scheme, which is approved by the European Commission under the sustainability framework of the RED. It allows for the assessment of whether a specific quantity of fuels meets the sustainability and GHG savings criteria outlined in the RED. The PoS travels the entire production and commercial chain until a registering company redeems the document for their obligations. For zero-rating biomass or a FEETS support claim, aircraft operators submit the PoS to the verifier to demonstrate the sustainability and GHG savings criteria of the alternative aviation fuels and eligible aviation fuels used and reported. 

Additionally, the aircraft operator should collect the following information and provide this to the verifier:

  • Purchase date
  • Volume

This information can be found on Product Transfer Documents (PTD), fuel delivery ticket, invoices, or similar documents. 

Image: © NEa

Issues with receiving a Proof of Sustainability

In some countries, including the Netherlands, fuel suppliers use the PoS to receive a national subsidy or fulfil a national mandate in accordance with the national RED implementation until 2026. A PoS can only be issued and used once, so if the fuel supplier uses it for its own purposes, it becomes unavailable to the aircraft operator. In such cases, the aircraft operator is unable to prove compliance with sustainability criteria for sustainable aviation fuels and, therefore, cannot claim these fuels under the EU ETS.

Using the Union Database

The European Commission is developing a union database which will facilitate the use of a PoS by both the fuel supplier and the end-user of the fuel, such as an aircraft operator. The Union Database will be linked to national registers and ensures a chain of custody of sustainable fuels between fuel supply and fuel purchase. The UDB ensures a trustworthy system for supporting the multiple use of a PoS, while ensuring no double claims. The UDB is still in development for this purpose.

Option 2: Proof of Compliance

If a fuel supplier cannot provide the Proof of Sustainability (PoS) to the aircraft operator due to other obligations, the supplier can provide documents with equivalent “evidence of compliance”, such as a Proof of Compliance (PoC), which the aircraft operator can use to demonstrate the sustainability and GHG savings criteria of the neat biomass fraction. The International Sustainability and Carbon Certification (ISCC) has introduced a framework to offer a 'Proof of Compliance' (PoC) for the use of low-emission fuels. The ISCC has a guidance document available. 

Together with the PoC, the aircraft operator should collect the following information and provide this to the verifier:

  • Purchase date
  • Volume

This information can be found on Product Transfer Documents (PTD), fuel delivery tickets, invoices, or similar documents. 

The PoC framework is a temporary solution until the Union Database is updated to fully integrate the aircraft operator end user module. 

Image: © NEa

Option 3: the NEa Registry: temporary measure to enable the zero-rating of biofuels in the EU ETS

For the 2024 and 2025 annual emissions reporting, the Ministry of Infrastructure and Water Management (IenW) has instructed the NEa to implement a temporary measure that allows double claims of sustainable fuels by both fuel suppliers under the national mandate and aircraft operators under the EU ETS until the UDB is fully functional for this purpose. This temporary solution is intended only for cases where the aircraft operator is unable to obtain a PoS from their fuel supplier. 

The NEa maintains a national registry (REV) where fuel suppliers report sustainable fuel supplied in the Netherlands under the national mandate. In the REV, fuel suppliers submit the PoS along with details such as the delivery date and the recipient of the fuel. This allows the NEa to link the PoS from the fuel delivered to the fuel purchased, mirroring the functionality that will be provided by the UDB once it is operational. The aircraft operators are required to supply additional evidence, containing the volume and purchase date, as demonstrated in purchase records/PTDs/fuel delivery tickets/etc., that can be linked to fuel registered in the REV. The temporary solution is legally secured in Article 26 of the amended Regeling handel in emissierechten. You can find the publication of the amended scheme here. 

Note that this temporary solution is only applicable to fuel deliveries in The Netherlands, where fuel suppliers report sustainable fuel supplied in The Netherlands for their RED obligation in the REV. 

Image: © NEa

Outlook 2026

In 2026, it will no longer be possible to apply the temporary solution. At the same time, the UDB is expected not yet to be fully operational for its intended purpose. Demonstrating sustainability will likely still be possible through a Proof of Compliance (PoC). This means that fuel suppliers will need to hold the appropriate accreditation in order to issue a PoC.

Annual emissions report

Reporting of alternative and eligible aviation fuels 

For the annual EU ETS emissions report, aircraft operators must carry out the determination of neat fuel fractions in mixed fuel and the calculation of CO2 emissions from mixed fuel, distinguishing between the CO2 for which allowances must be surrendered and the zero-rated CO2 from the biomass fraction. They must also ensure that the correct share of fuel is attributed to flights covered by the EU ETS. If an operator wishes to apply for FEETS support, the separate tab in the report (FEETS application) must be completed.

Helpful guidance

For further guidance on monitoring and reporting of sustainable biomass in aviation activities pursuant to the EU ETS please consult guidance available here: