European airlines expected to have exceeded the EU's 2% sustainable aviation fuel mandate for 2025, marking a decisive turnaround from 0.6% uptake the prior year
Europe's aviation sector met — and may have surpassed — the 2% sustainable aviation fuel (SAF) blending mandate set under the ReFuelEU Aviation regulation for calendar year 2025, a regulatory official and industry source told Reuters. The achievement represents a dramatic acceleration from 0.6% SAF uptake in 2024, a year in which airlines including Deutsche Lufthansa, International Consolidated Airlines Group (IAG) and Ryanair had repeatedly warned publicly that targets would be missed. A formal confirmation is expected in a European Commission report later in 2026. SAF (sustainable aviation fuel, produced from non-fossil feedstocks including waste materials, agricultural residues, or synthetic processes) is the aviation industry's primary tool for reducing lifecycle carbon emissions under EU climate law. The ReFuelEU Aviation regulation, which entered into force as part of the Fit for 55 legislative package, progressively escalates the SAF blending mandate — rising to 6% by 2030 and 70% by 2050 — creating a long-term structural compliance obligation for European carriers and fuel suppliers. The 2025 outperformance substantially strengthens the political and legal case for maintaining or tightening future targets, and reduces the risk that airlines will seek regulatory relief through the courts or via Commission consultation processes. It also validates SAF supply chain investment made by fuel producers and offtake agreements signed by airlines in anticipation of the mandate.
Why this matters
Confirmation that the ReFuelEU mandate has been met shifts the regulatory dynamic materially: airlines and fuel producers who negotiated SAF offtake agreements in anticipation of mandatory compliance now see those contracts validated, and the political pathway for the 2030 6% target strengthens. For lawyers, this creates advisory demand around SAF supply agreements, carbon credit (EU Emissions Trading System) compliance, and the structuring of long-term fuel supply contracts as airlines seek to lock in SAF volumes for 2030 compliance. The 'why now' driver is the Iran war's impact on conventional jet fuel costs — with Brent crude above $114 a barrel, the relative cost premium of SAF narrows, making compliance commercially less painful than in 2024. Regulatory filing coordination and licence condition summaries relating to the Fit for 55 framework are areas where specialist energy and regulatory practices are engaged.
On the Ground
A trainee on an airline or fuel producer mandate would assist with regulatory filing coordination for ReFuelEU compliance reporting, summarise licence condition obligations under the blending mandate, and review technology transfer or feedstock supply agreements relevant to SAF production. Due diligence on IP portfolios for SAF production processes would also be relevant on transactional mandates.
Interview prep
Soundbite
ReFuelEU compliance likely cleared in year one — SAF supply contracts and ETS credits are now the central legal battleground for European aviation.
Question you might get
“How does the ReFuelEU Aviation regulation interact with the EU Emissions Trading System for airlines, and what are the key legal risks for a carrier that misses its annual SAF blending obligation?”
Full answer
European airlines are expected to have beaten the ReFuelEU 2% SAF blending mandate in 2025, reversing a year in which uptake was only 0.6% and airlines were warning of regulatory failure. The expected outcome transforms the legal landscape: SAF offtake agreements signed in 2024 and 2025 are now commercially validated, and pressure to deliver the 2030 6% target is intensifying across the supply chain. For law firms advising airlines and fuel producers, the work centres on long-term SAF supply contracts, ETS (Emissions Trading System) credit management, and compliance documentation under the Fit for 55 framework. The Iran war's effect on conventional fuel prices is a structural tailwind — it compresses the cost premium of SAF, making the 2030 mandate look materially less onerous than it did twelve months ago. This will sustain a busy pipeline of energy and regulatory advisory work across European aviation.
My notes
saved