The eFuel Alliance has published its response to the European Commission’s Call for Evidence on the new EU Aviation and Aeronautics Strategy. The message is unambiguous: the 2015 Strategy was drafted in a fundamentally different geopolitical and energy-policy context and treated defossilisation as a side topic. A decade later, defossilising European aviation, securing kerosene supply, and building resilient fuel value chains have become first-order strategic priorities.

From a Competitiveness Paper to a Resilience Policy

The 2015 Aviation Strategy focused on competitiveness, market access, capacity, and safety. Sustainable aviation fuels were not a strategic industrial or security priority. Since then, the picture has changed fundamentally. The closure of the Strait of Hormuz and the wider Middle East crisis exposed the structural vulnerability of European aviation to fossil kerosene imports. ReFuelEU Aviation introduced binding blending mandates for SAF and eSAF from 2025 onwards. EU ETS for aviation, the SAF Allowances, the European Hydrogen Bank, and the eSAF Early Movers Coalition together form the first elements of a financing architecture for sustainable aviation fuels.

The eFuel Alliance calls on the new Strategy to reflect this reality — and to place defossilisation and security of supply at the centre, rather than relegating them to an environmental chapter at the margins.

Defossilisation as a Structural Pillar

Aviation remains structurally dependent on liquid energy carriers. Even under ambitious efficiency, hydrogen, and electric-flight scenarios, the bulk of aviation energy demand in 2050 and beyond will have to be met by liquid fuels. This is not a transitional phenomenon but a long-term reality. The eFuel Alliance positions eSAF as a strategic technology with European industrial leadership potential — comparable in importance to hydrogen, batteries, or critical raw materials.

Kerosene Security of Supply as a Standalone Objective

Unlike electricity or heating oil, kerosene is not substitutable in the short, medium, or long term. The response calls for kerosene security of supply to be established explicitly as a policy objective and to be linked to the defossilisation agenda. SAF and eSAF can be produced in a decentralised manner from diversified feedstock and energy sources — an advantage no fossil supply chain can offer. The Alliance recommends a European procurement framework that combines domestic production with structured supply partnerships in renewables-rich regions.

ReFuelEU Aviation: A Foundation That Must Be Defended

ReFuelEU Aviation is the single most important regulatory instrument for the European SAF market. The binding blending mandates — rising to 6% SAF by 2030 with a dedicated 1.2% eSAF sub-quota — create the demand signal producers, investors, and off-takers need to sign long-term contracts and reach Final Investment Decisions. The eFuel Alliance asks the new Strategy to confirm ReFuelEU Aviation as a cornerstone and to resist any weakening of the quota trajectory or the eSAF sub-quota. At the same time, operational challenges should be addressed — in particular the risk of carbon leakage to non-EEA hubs. The response proposes competition-neutral solutions such as a passenger- and destination-based mechanism or a CBAM-style adjustment for extra-EU air traffic.

The eSAF Ramp-Up Is Stalling — What Needs to Change

Despite the regulatory foundation, the eSAF ramp-up is not on a trajectory compatible with the 2030 sub-quota. The response identifies the Delegated Acts on RFNBO production as technically over-restrictive and economically counterproductive. The switch from monthly to hourly temporal correlation from 2030 alone is estimated to increase the cost of renewable hydrogen by 25 to 35%. Restrictions on industrial point-source CO₂ raise the cost of the feedstock base further.

The eFuel Alliance recommends targeted adjustments — with cumulative savings of EUR 54 to 168 billion by 2050:

  • A temporary exemption from the electricity supply criteria for early projects
  • Postponement of additionality requirements until 2035, with monthly temporal correlation retained
  • A grandfathering rule for ongoing investments from pre-certification onwards
  • Inclusion of unavoidable industrial point-source CO₂ from cement and steel
  • Explicit recognition of eSAF co-production via the HEFA pathway

On the demand side, the SAF Allowances mechanism under the EU ETS — which can cover up to 95% of the cost gap of RFNBO eSAF — is one of the most targeted instruments available. In its current design, however, it is capped at 20 million allowances, expires in 2030, and operates on a first-come-first-served basis. The eFuel Alliance calls for a dedicated eSAF sub-pool, an extension of the mechanism’s lifetime to at least 2034 — ideally 2040 — and a reallocation mechanism for unused allowances.

AccelerateEU: Anchoring the Crisis Response Structurally

The eFuel Alliance welcomes the AccelerateEU Communication as a meaningful shift: kerosene security of supply is recognised, for the first time, as a first-order political concern. The risk: the instruments it contains — a targeted revision of the RFNBO production criteria, a possible extension of the ETS SAF Allowances, support for the eSAF Early Movers Coalition, and the inclusion of sustainable aviation and shipping fuels among the priorities of the Clean Energy Investment Summit — could be framed as a temporary crisis response and lose political momentum once the supply situation eases. The response therefore calls for structural anchoring: the Fuel Observatory as a permanent institution, the RFNBO revision as a lasting framework, the ETS SAF Allowances extension built into the long-term ETS architecture, and the eSAF Early Movers Coalition strengthened and made attractive for additional Member States.

SPIN Perspective: What This Means for Switzerland

Switzerland is tied directly into the ReFuelEU Aviation regime through bilateral air transport agreements and through the adoption of central EU regulations. For the Swiss site — and for the domestic Power-to-X industry, which is already working on concrete eSAF projects such as the planned DIPS demo plant in the Sisslerfeld — the EU’s direction of travel is strategically decisive. A strong European demand side with binding quotas, a functioning financing mechanism for the cost gap, and a reliable regulatory environment are preconditions for Swiss eSAF projects to reach Final Investment Decisions.

The same logic applies in reverse: a weakening of the EU framework would directly damage Swiss project pipelines. SPIN therefore has every reason to follow the new EU Aviation and Aeronautics Strategy closely — and to support the eFuel Alliance’s call for ambition.

Conclusion

The new EU Aviation and Aeronautics Strategy is an opportunity to correct the structural blind spots of the 2015 Strategy and to bring European aviation policy into line with the realities of this decade. Defossilisation, kerosene security of supply, and the industrial ramp-up of sustainable aviation fuels are not three separate agendas but three dimensions of the same strategic challenge. They demand a coherent and ambitious political response.

Source: eFuel Alliance, «Response to the Call for Evidence on the EU Aviation and Aeronautics Strategy», May 2026. The Commission’s Call for Evidence closed on 21 May 2026.