Deloitte has cautioned that the European Union’s current sustainable aviation fuel (SAF) policies, particularly the ReFuelEU mandate, risk weakening the competitiveness of European airlines while potentially slowing progress toward decarbonisation.
In a new study for Airlines for Europe, Deloitte warned that ReFuelEU, which requires airlines to steadily increase SAF usage, could drive passengers to non-EU carriers and hubs that are not bound by similar regulations. This shift may lead to carbon and business leakage, undermining both climate objectives and market fairness. The report estimates that cost disparities could rise by up to 15 percent on key EU–Asia routes by 2030.
To address this, Deloitte proposed a SAF Book and Claim Accounting Mechanism (SAF-BAM), which would help maintain competitive balance without inflating ticket prices. The study also highlighted how current policies might push passengers to non-EU hubs like Istanbul or Dubai, opt for indirect non-EU routes, or even choose holiday destinations outside the EU to avoid extra costs.
The report noted that while the EU already employs a Carbon Border Adjustment Mechanism (CBAM) for sectors like steel and cement, extending CBAM to aviation is neither legally nor practically feasible. Instead, it recommended a tailored SAF-BAM system that integrates passenger and flight operations data to track SAF usage, with revenue from SAF-BAM certificates channelled into green transition projects for the aviation sector.
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