The EU’s automotive package has dominated the e-fuel debate this autumn – and with good reason, as the Franco-German breakthrough for VEEFs shows. But three less visible files will decide just as much about whether Power-to-X has a business case after 2030: the next Renewable Energy Directive (RED IV), the revision of the EU Emissions Trading System (ETS) and the review of ReFuelEU Aviation. One of them threatens the demand signal for e-fuels. Another could open the door for imported e-fuels made with industrial CO₂. Switzerland is not at the table in any of them – but it will live with the outcome.

RED IV: binding targets or a forecast?

RED III sets targets for renewable fuels of non-biological origin (RFNBOs) only up to 2030. A draft impact assessment for its successor, reported by Argus, indicates that the Commission is considering replacing binding national targets for renewable hydrogen with an indicative EU-wide consumption target of 8 million tonnes a year by 2040 – the least ambitious of the scenarios examined. Aviation and shipping would be left to ReFuelEU Aviation and FuelEU Maritime; for road transport, the carbon price under ETS2 would be expected to do the job.

An indicative target is a forecast, not a market. Electrolysers, synthesis plants and offtake contracts are financed against demand that is legally secured – not against demand that might materialise. Investors who committed capital on the basis of RED III would see the rules change halfway through the race. In September, more than 170 companies called on the Commission to keep the binding targets in a letter coordinated by Hydrogen Europe, the Hydrogen Council and the eFuel Alliance. SPIN co-signed, and has joined a second round of the letter that is now open to associations. The Commission’s legislative proposal is expected by the end of the year.

ETS revision: an accounting change with big consequences

The Commission’s proposal for revising the ETS would price the fossil carbon contained in e-fuels where the fuel is distributed (“midstream”), rather than where the CO₂ was originally emitted (“upstream”). This sounds technical. It could remove one of the biggest obstacles for imported e-fuels made with industrial CO₂.

Under the current RED delegated acts, RFNBOs produced outside the EU from industrial CO₂ during the transition period must prove that the CO₂ source was subject to effective carbon pricing – a hurdle that many projects outside Europe cannot clear. According to the eFuel Alliance, which sought clarification together with CO2 Value Europe, the Commission’s Directorate-General for Climate Action (DG CLIMA) has confirmed that the carbon accounting was changed to enable imports of RFNBOs made with industrial CO₂ – and that the RED rules would be adjusted accordingly if the ETS revision ends up with this approach.

From SPIN’s perspective, this is the right direction. Our members ask that the emission reduction achieved by recycling CO₂ can be credited both to the source and to the e-fuel, at least during the ramp-up – otherwise CO₂ recycling for fuels will never reach scale. Midstream accounting is a step towards a system that rewards recycling carbon instead of penalising it twice. One condition remains non-negotiable from a Power-to-X perspective: e-fuels only make climate sense when the carbon they contain is recycled CO₂ from biogenic, atmospheric or industrial sources, and when that recycling displaces fossil carbon instead of providing a reason to burn more of it.

Parliament is moving in an accelerated procedure. ENVI rapporteur Peter Liese (EPP) proposes earmarking allowances for e-fuels in aviation and shipping, and the draft opinion of the transport committee suggests 200 million allowances each to support sustainable aviation and maritime fuels. The ENVI vote is planned for 1 December, the plenary vote for the end of the year.

ReFuelEU Aviation: the ambition stays

Another good news comes from aviation. At the European Parliament’s transport committee on 28 September, the Commission said that its review of ReFuelEU Aviation, expected in the second half of 2027, will not lower the mandates; the focus will be on simplification. According to the EASA ReFuelEU Aviation Annual Technical Report 2026, sustainable aviation fuel reached almost 2.8 per cent of the fuel supplied at EU airports in 2025, above the mandate. Around 50 e-SAF projects are in the pipeline – but none has yet reached a final investment decision. That is exactly why stable rules in RED IV and the ETS matter: the e-SAF sub-mandate from 2030 needs plants that are financed now.

Why Switzerland should care

  • Switzerland will import. In its report of 2 September 2026 on synthetic energy carriers and seasonal storage, the Federal Council states that a significant share of Swiss demand for Power-to-X derivatives will have to be covered by imports. How the EU accounts for, certifies and incentivises imported e-fuels therefore shapes Swiss supply directly.
  • Same quotas, same market. Switzerland applies the same SAF blending quotas as the EU, and its ETS has been linked with the EU’s since 2020. Decisions in Brussels on support mechanisms for aviation and shipping fuels will sooner or later raise the question of how Swiss operators are treated.
  • A narrower definition at home. The Federal Council’s report considers synthetic fuels CO₂-neutral only if their carbon comes from biogenic or atmospheric sources. If Brussels opens a path for industrial CO₂ through midstream accounting, Switzerland’s narrower definition becomes harder to justify – and more expensive for Swiss consumers.

Renewable fuels and electrification are not rivals; together they reduce cumulative CO₂ emissions faster than either on its own. Whether Europe keeps a reliable demand signal for e-fuels after 2030 will be decided in the coming months. SPIN follows these files closely together with its partners in the eFuel Alliance – and will make sure that the Swiss perspective is heard in Bern before the rules are set in Brussels.

Sources: eFuel Alliance member information, 20 October 2026; Argus; EASA, 17 September 2026; Federal Council report «Synthetische Energieträger und saisonale Energiespeicher» (2 September 2026, postulate 23.3023).

🤖 AI transparency: This text and its visual were created using AI, reviewed and approved by a human.