Current Treatment of SAF in the UK ETS
Under the UK Emissions Trading Scheme (UK ETS), aircraft operators can currently claim emissions reductions from Eligible SAF, reducing the number of allowances required to surrender under the scheme. Eligible SAF is presently treated as “zero-rated”, meaning it is accounted for producing zero emissions.
| Criteria | Requirement |
|---|---|
| Eligible Fuel Types | Biofuels only |
| Sustainability Criteria | RTFO sustainability criteria |
| GHG Emissions Saving Threshold | 65% (55% for older production plants) |
| Fossil Fuel Comparator | 94 gCO₂e/MJ |
| How SAF is Recognised | Zero rated |
Future Treatment of SAF in the UK ETS
The UK ETS Authority is consulting on potential changes to the future treatment of Eligible SAF to improve alignment with the UK SAF Mandate and strengthen aviation decarbonisation efforts. The consultation further presents illustrative policy packages combining different SAF policy options to demonstrate how future UK ETS approaches could operate in practice.
UK ETS Authority Illustrative policy packages
| Counterfactual (Do Nothing) | Policy Package 1 | Policy Package 2 | |
|---|---|---|---|
| Eligible Fuel Types | Biofuels only | Expand beyond biofuels (Recycled Carbon Fuels and Power-to-Liquid) | Expand beyond biofuels (Recycled Carbon Fuels and Power-to-Liquid) |
| Sustainability Criteria | RTFO sustainability criteria | UK SAF Mandate sustainability criteria | UK SAF Mandate sustainability criteria |
| GHG Emissions Saving Threshold | 65% | 40% | 40% |
| Fossil Fuel Comparator | 94 gCO₂e/MJ | 89 gCO₂e/MJ | 89 gCO₂e/MJ |
| How SAF is Recognised | Zero rated | Zero rated | Lifecycle assessment |
Operational Issues
The consultation also seeks views on various operational issues with respect to SAF.
Purchase and delivery
The consultation also proposes clarifying legislative requirements relating to the purchase and delivery of SAF for emissions reduction claims under the UK ETS. The UK ETS Authority proposes that the Eligible SAF must be purchased within, or up to three months prior to, the relevant scheme year and delivered before 31 March of the following year. Operators would also be required to provide proof of SAF purchase and delivery to prevent double-counting and strengthen verification controls.
Claim Limits
The consultation proposes clarifying legislative limits on SAF emissions reduction claims under the UK ETS. The UK ETS Authority states that claims should not exceed an operator’s total fuel consumption associated with UK ETS aviation activities within a given scheme year. In addition, emissions reduction claims from Eligible SAF would not be permitted to carry over into subsequent scheme years, ensuring surrender obligations reflect emissions within the relevant reporting period.
Ensuring monitoring plan requirements apply to small emitters
The consultation proposes extending SAF-related monitoring plan requirements to all aircraft operators, including small emitters. The UK ETS Authority is considering amending the UK ETS Order to ensure that all operators eligible to claim emissions reductions from SAF are subject to consistent monitoring and reporting requirements.
Geographical Limits
The consultation highlights that the UK ETS currently imposes no geographical restrictions on where Eligible SAF can be purchased or delivered for emissions reduction claims. This differs from the EU ETS, which requires SAF to be physically linked to eligible flights departing from specific aerodromes. The Authority is therefore seeking stakeholder views on the potential benefits and challenges associated with maintaining the current UK ETS approach.
Conclusion
The UK ETS consultation represents an important step toward refining the regulatory treatment of eligible SAF within the UK aviation sector. By exploring greater alignment with the UK SAF Mandate, the UK ETS Authority aims to create a more consistent framework for SAF eligibility, emissions accounting, and lifecycle assessment. Key considerations such as new SAF fuel types, revised GHG emissions thresholds, updated fossil fuel comparators, and alternative SAF recognition approaches could significantly influence future compliance obligations under the UK ETS. The consultation also proposes additional clarifications relating to SAF purchase and delivery timelines, claim limitations, monitoring requirements for small emitters, and geographical limits. Collectively, these proposals aim to strengthen verification controls, improve regulatory consistency, and support long-term aviation decarbonisation efforts in the UK.
References
References
- UK Emissions Trading Scheme: Treatment of sustainable aviation fuel – GOV.UK
- UK Emissions Trading Scheme (ETS): Treatment of sustainable aviation fuel (SAF) consultation (accessible webpage) – GOV.UK
- RTFO – Renewable Transport Fuel Obligations Order 2007
- UK Emissions Trading Scheme (ETS): Treatment of Sustainable Aviation Fuel (SAF) Consultation
- The SAF Mandate: an essential guide – GOV.UK
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