Compliance by stakeholders under ReFuelEU
The implementation of ReFuelEU entails obligations for fuel suppliers, Union airports and aircraft operators, which are discussed in the following subsections.
- Aircraft operators: Aircraft operators must ensure that the annual quantity of aviation fuel refuelled at a given EU airport corresponds to at least 90% of the annual aviation fuel requirement (trip fuel and cab fuel). This should be checked against actual flight plans to avoid economic refueling practices, which may lead to additional emissions due to the extra weight.
- Union airports and their managing bodies: Managing bodies are also required under ReFuelEU Aviation to take the necessary measures to ensure that aircraft operators have access to fuels containing SAF. If aircraft operators encounter difficulties in accessing SAF at EU airports, they can report this to the appropriate authority, which will raise the matter with the relevant EU airport management body.
- Fuel suppliers: jet fuel suppliers must ensure that all fuel at EU airports meets the minimum SAF and synthetic fuel with flexibility mechanisms available until 2034. Suppliers must also provide relevant information free of charge to aircraft operators on or before Feb. 14 of each reporting year.
How can aircraft operators monitor and report under RFEUA?
To accurately monitor, the aircraft operator must implement a robust management system, with well-defined procedures and control activities to track flights subject to RFEUA reporting requirements.
The key monitoring activities that aircraft operators must perform
- Record data on all flights departing from and arriving at Union airports.
- Keep records of scheduled trip and cabin fuel (according to the final version of the OFP), actual fuel consumption (fuel blocking - fuel blocking), the amount of fuel filled and other fuel categories listed in the ReFuelEU Aviation Manual for Aircraft Operators and Verification Bodies.
- Ensure completeness of flights, including flights departing from and arriving at Union airports.
- Monitor block time in hours per flight and fuel density factors.
- Record and log data gaps to address issues during verification.
- Aircraft operators should ideally keep supporting documents for a minimum of four years.
- Aircraft operators should have the RFEUA report verified by an independent verifier.
- The deadline to submit the verified RFEUA report to the competent authority is March 31 of the reporting year.
Scope of flights to be reported.
Only flights that are the responsibility of the aircraft operator must be reported, determined primarily by the ICAO designation used as the ATC call sign in item 7 of the flight plan. If not available, responsibility is based on the aircraft registration serving as ATC call sign in item 7 of the flight plan.
| REPORTABLE FLIGHTS | NON-REPORTABLE FLIGHTS. |
| Passenger and cargo flights. | Non-EU state flights, military flights, customs and police flights |
| Maintenance flights | Humanitarian, search and rescue flights |
| Diverted flights | Scientific research flights |
| Repositioning flights | Medical and firefighting flights |
| Ferry flights | Training flights of cockpit personnel for certification of their type rating, Circular flights |
| Flights performed in the context of public service obligations. | Flights performed on exempted routes during the temporary period in accordance with Article 5(3) of the RFEUA |
| Repatriation flights, return flights, including readmission |
Exemptions for specific routes.
Aircraft operators may apply for temporary exemptions from the requirement to refuel prior to departure on specific routes departing from Union airports. These exemptions apply to specific routes, limited to a distance not exceeding 850 km or routes departing from airports on islands with no rail or road connection, limited to a distance not exceeding 1200 km, under the specific circumstances set forth in Article 5(3)(a) and (b) of the RFEUA.
Operators must submit an application to the competent authority of the respective Member State via the EASA sustainability portal three months before the planned start date, including a detailed justification and supporting evidence. The strength of the submitted documentation determines the approval of exemptions.
Approved exemptions remain valid for up to 1 year and extensions can be requested up to 3 months before the expiration date.
Contact Normec Verifavia for ReFuelEU Aviation verification and finalize contracts as soon as possible to avoid last-minute hassles.
Conclusion
The ReFuelEU Aviation Regulation is a crucial part of the EU's climate strategy to achieve significant emissions reductions by promoting the use of sustainable aviation fuels (SAF) and preventing harmful practices such as economical refueling. The regulation imposes clear obligations on aircraft operators, fuel suppliers and airports in the Union to ensure compliance, transparency and accountability. Aircraft operators must meet specific targets regarding the amount of fuel refueling and maintain robust monitoring systems to accurately meet reporting requirements.