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ReFuelEU Aviation 2026–2030: SAF Supply, Procurement Costs and the 6% Mandate Challenge

From 2% Compliance to the 2030 Supply Stress Test — What Industrial Strategists Must Decide Now


Green Fuel Journal Research & Intelligence Team  |  Published: August 2026


Green Fuel Journal cover with white jet, titled ReFuelEU Aviation 2026–2030 and subtitle on SAF compliance and supply challenge.

1. Executive Intelligence Synthesis

FINDING | ReFuelEU Intelligence

ReFuelEU Aviation has moved SAF from a voluntary decarbonisation product into a binding EU procurement obligation — yet the 2024 baseline showed only 193 kt of SAF supplied, equivalent to 0.6% of EU aviation fuel, against the 2025 obligation of 2%. Five Member States account for 99% of supply, 69% of feedstocks are imported, SAF costs €2,085/t versus €734/t for conventional jet fuel, and no EU synthetic SAF facility had reached a Final Investment Decision as of the 2024 EASA assessment. The strategic question is not whether Europe can reach 6% — it is whether the market can deliver the right SAF, at the right airports, in the right pathways, at an economically acceptable price.


1.1 Five Executive Signals


Signal 1 — Supply Adequacy

  • FINDING:  EU SAF supplied in 2024 was 193 kt, representing 0.6% of EU aviation fuel — less than one-third of the 2025 regulatory obligation of 2%, despite aircraft operators voluntarily procuring 358 kt in the same period.

  • SO WHAT:  The gap between operator demand and actual supply delivery confirms that the constraint is not airline willingness — it is production, certification and physical availability at qualifying airports.

  • NOW WHAT:  Industrial Strategists with EU aviation exposure must verify not whether SAF volumes exist globally, but whether certified, airport-available, pathway-compliant SAF can be secured under long-term offtake agreements before 2027.


Signal 2 — Cost Premium

  • FINDING:  EASA's 2024 benchmark places SAF at €2,085/t versus €734/t for conventional jet fuel — a premium of approximately 2.84×, with HEFA production costs in the UK ranging from £821/t to £1,786/t and advanced Biomass-to-Liquid pathways reaching £2,988–£6,078/t.

  • SO WHAT:  At current pricing, SAF procurement is a material balance-sheet exposure that airlines cannot absorb without structural hedging or cost pass-through strategies, particularly as mandated volumes rise toward 2030.

  • NOW WHAT:  Begin mapping SAF-cost exposure to fleet size and EU-route network now, and evaluate long-term fixed-price offtake structures before spot-market SAF premiums widen under mandate pressure.


Signal 3 — Supplier Concentration

  • FINDING:  Five EU Member States account for 99% of EU SAF supply, with only 25 suppliers delivering across 33 airports in 12 Member States — leaving more than half of EU Member States with no domestic SAF production capacity whatsoever.

  • SO WHAT:  Airlines operating from airports in non-producing Member States face a dual risk: physical unavailability of SAF uplift and elevated spot-market premiums driven by transport and logistics costs.

  • NOW WHAT:  Conduct airport-level availability mapping across your EU route network and identify which hub airports have contracted SAF delivery versus which remain exclusively dependent on spot purchases or cross-border logistics.


Signal 4 — Feedstock Dependency

  • FINDING:  69% of EU SAF feedstocks were imported in 2024, with China supplying 38% of imported feedstock and China plus Malaysia together supplying approximately 50% — creating a concentrated supply-chain dependency on two non-EU jurisdictions that are simultaneously building their own SAF production capacity.

  • SO WHAT:  As China and Malaysia develop domestic SAF consumption and export their own SAF to third markets, EU SAF producers face feedstock competition precisely as mandated volumes must rise — tightening supply and elevating costs simultaneously.

  • NOW WHAT:  Treat feedstock origin as a first-order due diligence criterion in SAF offtake negotiation — not a secondary sustainability consideration.


Signal 5 — Synthetic SAF Readiness

  • FINDING:  No EU synthetic SAF facility had reached Final Investment Decision as of EASA's 2024 assessment, despite ReFuelEU introducing a specific synthetic fuel sub-mandate starting in 2030.

  • SO WHAT:  The overall 6% SAF target may prove achievable on paper through HEFA and advanced biofuel volumes, while the synthetic sub-mandate remains unachievable due to absent production infrastructure — creating a pathway-specific compliance failure that headline supply figures would obscure.

  • NOW WHAT:  Do not rely on aggregate SAF supply projections to determine compliance risk; distinguish between total SAF volume, pathway-compliant SAF, and airport-physically-available SAF in every procurement scenario.


1.2 The Core Strategic Finding

ReFuelEU Aviation's market question shifted definitively in 2024: Regulation (EU) 2023/2405 guarantees SAF demand through binding mandates, making supply adequacy — not demand visibility — the strategic constraint Industrial Strategists must solve before 2030. When the regulation was adopted in October 2023, the primary concern was whether airlines would procure SAF voluntarily. That question is settled by law. The question now is whether the supply chain can deliver compliant SAF — correct pathway, correct certification, correct geography, at an economically viable price — as mandated volumes escalate from 2% in 2025 to 6% in 2030 and beyond.


EASA considers the headline 6% target achievable across favourable supply scenarios. That assessment rests on aggregate volume projections of 1.4–5.2 Mt plus 0.7 Mt of synthetic SAF by 2030 — a range wide enough to render the EASA statement analytically incomplete rather than reassuring. A 3.8 Mt uncertainty range cannot support bankable procurement planning. This report stress-tests the supply adequacy question beyond the headline volume: who has the SAF, where is it available, which pathways qualify, and what should decision-makers do before the 2027 regulatory checkpoint arrives.


For further context on green molecule supply chains and industrial decarbonisation competition, see GFJ's analysis at greenfueljournal.com/post/green-molecules-economy-2035 and the E-Fuels & SAF Hub at greenfueljournal.com/e-fuels-and-sustainable-aviation-fuel-hub.

 

2. Macro Context & Strategic Drivers

FINDING | ReFuelEU Intelligence

ReFuelEU Aviation — formally Regulation (EU) 2023/2405, adopted 18 October 2023 — establishes a binding SAF share obligation on aviation-fuel suppliers at EU airports, with minimum thresholds of 2% in 2025, 6% in 2030, 20% in 2035, 34% in 2040, 42% in 2045 and 70% in 2050. Aircraft operators face a parallel 90% annual uplift requirement designed to prevent competitive distortion through economic tankering. The regulation applies to aviation-fuel suppliers, aircraft operators and qualifying Union airports — three distinct actors with distinct compliance obligations that must coordinate across a single physical supply chain.


2.1 ReFuelEU: From Regulation to Market Mechanism

Regulation (EU) 2023/2405 mandates minimum SAF shares directly on aviation-fuel suppliers, making SAF incorporation a commercial prerequisite for supplying jet fuel at Union airports. For an airline, the SAF premium is not optional — it is embedded in the fuel price whether or not the carrier actively manages its SAF procurement strategy. For a fuel supplier, the obligation introduces a compliance cost that must be recovered through pricing, making the supplier's feedstock economics, certification status and geographic coverage determinative of commercial viability.


The 90% annual uplift requirement on aircraft operators is a critical anti-distortion clause. Without it, airlines could fill tanks at non-EU airports to avoid the SAF-embedded premium — a practice known as economic tankering. The regulation's architects recognised this structural risk explicitly. Airlines that fail the 90% uplift test face penalties under the national enforcement frameworks mandated by the regulation — removing the economic incentive to evade through routing adjustments.


The June 2026 infringement action against 13 Member States for failure to establish national penalty regimes reveals that the enforcement architecture underpinning this mechanism was still incomplete in parts of the Union three years after the regulation's adoption. Until national penalties are fully operational across all Member States, the economic deterrent against non-compliance remains structurally fragile — creating an uneven competitive environment across EU airports.


2.2 The 2026–2030 Mandate Escalation

The 2025 obligation of 2% is the regulatory floor; the commercially decisive inflection arrives in 2030, when the mandatory SAF share triples to 6%. For an airline with significant EU flying, this translates from a manageable procurement challenge into a supply-chain transformation: the volume of certified SAF required must approximately triple within five years, across a supplier base that currently delivers only 0.6% of EU aviation fuel from 25 suppliers at 33 airports.

 

Year

ReFuelEU Minimum SAF Share

Synthetic SAF Sub-Mandate

Strategic Significance

2025

2%

—

2024 actual supply was 0.6%

2030

6%

0.7% (RFNBO/e-fuel sub-mandate)

First synthetic sub-mandate; threefold volume increase required

2035

20%

See operative regulation text

Advanced biofuels and e-SAF at scale required

2040

34%

See operative regulation text

Major feedstock and infrastructure transition

2045

42%

See operative regulation text

Structural SAF dominance required across EU network

2050

70%

35%

Net-zero aviation pathway anchor

The procurement implication is arithmetic: airlines and fuel buyers who have not begun structured SAF procurement negotiations by 2026–2027 will find themselves competing for limited certified supply in the final approach to the 2030 deadline, at prices set by scarcity rather than contract.


2.3 Global SAF Policy Competition

FINDING | ReFuelEU Intelligence

The EU, UK, US, China, India and Singapore have each chosen structurally different SAF policy instruments — creating competing incentive landscapes that determine where SAF production capacity gets built. The EU pulls demand through a binding mandate. The US pushes supply through a production tax credit. Singapore pools procurement through a levy-funded central buyer. China develops production through industrial pilots. India is formalising indicative blending targets. The UK blends demand mandate with tradeable certificates and buy-out provisions. The EU cannot assume global SAF capacity will orient toward European demand simply because EU demand is mandated.

 

Region

Instrument

Approach

2030 Target

EU

Regulation (EU) 2023/2405 — ReFuelEU Aviation

Binding SAF supplier mandate + aircraft operator uplift obligation

6% SAF share

UK

UK SAF Mandate (2025–)

Binding supplier obligation + tradeable certificates + buy-out provisions

10% SAF share

US

IRC §45Z Clean Fuel Production Credit

Production incentive; no federal blending mandate; North American feedstock eligibility from post-2025

3 bn gallons/year aspirational

Canada

Aviation Climate Action Plan

Aspirational target; revenue-certainty support approach

10% aspirational

China

NDRC/CAAC SAF Application Pilot (2024–)

National pilot covering four airports + three carriers; industrial policy orientation

~600 kt/year production capacity (2025)

India

ATF Control Order 2001, amended April 2026; indicative targets

Indicative international-flight blending targets

5% in 2030 (indicative)

Singapore

SAF Levy + SAFCo central procurement (deferred to Jan 2027)

Mandatory levy + centrally pooled SAF procurement through SAFCo

3–5% by 2030


2.4 Demand Pull vs Supply Push

Europe and the UK pull demand through regulatory obligation. The US pushes supply through production incentives structured around feedstock origin — with the §45Z credit explicitly restricted to fuel produced from feedstocks grown or produced in the US, Mexico or Canada from 1 January 2026. This geographic restriction removes the incentive for US producers to use Asian imported waste oils, potentially tightening the global pool of compliant feedstocks available to European SAF producers even as EU mandated volumes must rise.


A producer choosing between building capacity oriented toward EU ReFuelEU compliance and building capacity to claim US §45Z credits faces different feedstock requirements, different offtake structures and different revenue profiles. The net effect is that global SAF production capital is being pulled in multiple directions simultaneously. IEA projects global SAF consumption to rise from approximately 1 billion litres in 2024 to approximately 9 billion litres by 2030. No authoritative regional volume breakdown for the EU within that projection is available from the cited IEA publication; regional sufficiency cannot be inferred from the global headline figure alone.

 

3. India-Specific Analysis

FINDING | ReFuelEU Intelligence

India has formalised indicative SAF blending targets for international flights — 1% in 2027, 2% in 2028 and 5% in 2030 — and in April 2026 amended the ATF Control Order to bring SAF-blended aviation fuel within India's aviation-fuel regulatory framework for the first time. IndianOil's Panipat facility, with 86.8 kt/year of Alcohol-to-Jet capacity and India's first ISCC-CORSIA SAF certification, represents the country's most significant near-term production asset. India's position on the EU SAF supply question is analytically distinct from its role as a domestic SAF market — and each must be assessed on its own merits.


3.1 India's Emerging SAF Market

India formalised the regulatory infrastructure for SAF commercialisation in April 2026, when the ATF Control Order, 2001 was amended to bring SAF-blended aviation fuel within the aviation-fuel regulatory framework — a technically essential step that enables certification, liability allocation and commercial SAF supply to operate within a legally defined structure.

The political commitment behind this move was stated clearly by Union Minister for Civil Aviation Ram Mohan Naidu in September 2025:

"SAF is a practical and immediate solution to decarbonize the aviation sector, with the potential to cut lifecycle CO₂ emissions by up to 80% compared to conventional fuel."

— Ram Mohan Naidu, Union Minister for Civil Aviation, Government of India, Government of India press release, 3 September 2025, PIB


India's indicative targets are strategically meaningful in two directions simultaneously. As domestic targets, they create a growing local demand environment for Indian SAF producers — one that is proximate, legally integrated, and scaling from 1% to 5% over a three-year window. As a supply signal, they also confirm that Indian SAF production capacity — including the IndianOil Panipat plant — will face intensifying domestic demand competition precisely as European buyers seek to diversify away from Chinese and Malaysian feedstocks.


For GFJ's analysis of India's carbon market architecture, see greenfueljournal.com/post/indian-carbon-market-2026-the-new-industrial-operating-system.


3.2 India as a Potential EU SAF Supplier

IndianOil's Panipat facility has received India's first ISCC-CORSIA SAF certification — the internationally recognised standard that provides the baseline sustainability credential for SAF under ReFuelEU Aviation. IndianOil's 86.8 kt/year Alcohol-to-Jet plant uses ethanol as feedstock, and the company signed a SAF-supply Letter of Intent with Akasa Air in January 2026 — demonstrating commercial traction in the domestic market before any EU export strategy is confirmed.


The analytical assessment of India's EU export viability must address two structural barriers. First, economics: India's Alcohol-to-Jet process uses ethanol whose feedstock cost and availability are subject to India's domestic agricultural policy and sugar-sector dynamics — variables not controlled by the SAF producer. Whether Indian production economics translate into competitive EU pricing at delivered cost requires producer-level data not publicly available from the sources reviewed. Second, domestic demand competition: with Panipat at 86.8 kt/year and India's indicative 5% by 2030 target for international flights applying to a growing aviation market, domestic demand could absorb Panipat's output well before EU-bound export volumes become commercially viable.


GFJ Assessment: India's SAF export potential to Europe is real but not near-term at material scale. The ISCC-CORSIA certification at Panipat removes the largest single regulatory barrier. Economic competitiveness and domestic demand saturation remain unresolved constraints. Industrial Strategists should track IndianOil's next capacity announcement and any EU-airline LOI progression as the primary indicators of whether Indian SAF will reach EU airports before 2030.

 

4. Operational & Technical Deep-Dive

FINDING | ReFuelEU Intelligence

Four primary SAF production pathways are relevant to ReFuelEU compliance: HEFA (Hydroprocessed Esters and Fatty Acids), Alcohol-to-Jet, advanced biofuels including Biomass-to-Liquid, and synthetic/e-SAF (Power-to-Liquid). Of these, only HEFA operates at commercial scale today in the EU market. ATJ is at early commercial deployment, BtL remains expensive and pre-commercial, and no EU e-SAF plant has reached Final Investment Decision. Each pathway faces distinct cost, feedstock and scalability constraints — and the higher-cost pathways required to meet the synthetic sub-mandate are precisely those furthest from commercial readiness.


4.1 Where the SAF Molecule Comes From

HEFA is the dominant EU SAF pathway and will remain the largest volume contributor through 2030. It converts waste oils and fats — used cooking oil, animal fats, distillers' corn oil — into jet-range hydrocarbons through hydroprocessing. UK government cost analysis benchmarks HEFA production at £821–£1,786/t in 2025, making it the cheapest available SAF pathway by a significant margin. Its limitation is feedstock: the EU's primary HEFA feedstocks are heavily import-dependent, with China supplying 38% of imported feedstock and China plus Malaysia accounting for approximately 50% of total imports.


Alcohol-to-Jet uses fermentation-derived alcohols — ethanol or isobutanol — converted into jet-range hydrocarbons. The Rebound joint venture at Dunkirk (targeting ~160 kt/year ATJ capacity, launched June 2026) and IndianOil Panipat (86.8 kt/year ATJ, ISCC-CORSIA certified) represent the most commercially advanced ATJ projects in Europe's supply orbit. ATJ is more feedstock-diverse than HEFA but production costs are higher and feedstock sustainability verification is more complex.


Biomass-to-Liquid (BtL) converts solid biomass through gasification and Fischer-Tropsch synthesis into synthetic paraffinic kerosene. UK cost benchmarks place BtL at £2,988–£6,078/t in 2025 — three to eight times HEFA costs. No large-scale BtL plant is operating in Europe as of mid-2026.


SAF Pathway

Primary Feedstock

Approx. Cost (2025)

Commercial Scale EU?

ReFuelEU Eligibility

Key Constraint

HEFA

Used cooking oil, animal fats

£821–£1,786/t

Yes — dominant pathway

Full eligibility

69% imported feedstock; China/Malaysia concentration

Alcohol-to-Jet

Ethanol, agricultural residues

Higher than HEFA

Early commercial (Dunkirk, Panipat)

Full eligibility

Higher capital cost; feedstock certification complexity

BtL

Woody biomass, MSW

£2,988–£6,078/t

No — pre-commercial

Full eligibility

Extremely high cost; no FID-stage EU plant

e-SAF / Power-to-Liquid

Green hydrogen + captured CO₂

Significantly above BtL at present

No — no EU FID as of 2024

Qualifies for synthetic sub-mandate

No FID; green hydrogen economics; CO₂ source availability

 

4.2 The 2030 Synthetic SAF Stress Test

No EU synthetic SAF facility had reached Final Investment Decision as of EASA's 2024 assessment — a critical constraint given that ReFuelEU introduces a specific sub-mandate for synthetic fuel beginning in 2030. Synthetic SAF, produced through Power-to-Liquid processes combining renewable-electricity-derived green hydrogen with captured CO₂, is technically viable at pilot scale but has no commercial-scale EU production capacity whatsoever.


ReFuelEU's RFNBO sub-mandate — the specific obligation for synthetic e-fuels produced from renewable electricity — stands at 0.7% in 2030, rising to 35% by 2050, per EASA's operative framework.


Given extended project development and construction timelines, a project that does not reach FID by 2026–2027 is unlikely to deliver commercial volumes before 2030 — with no buffer for construction delays or commissioning failures. The constraint is not technology: the chemistry is proven at pilot scale. The constraint is economics. Green hydrogen production costs remain high relative to fossil-derived hydrogen, CO₂ sourcing from biogenic or atmospheric capture adds further cost and complexity, and the combined levelised cost of e-SAF production significantly exceeds HEFA even at optimistic renewable electricity price assumptions.



The unresolved intelligence question is therefore not whether synthetic SAF can be produced. It is whether the combination of ReFuelEU sub-mandate penalties, EU ETS interaction effects and any additional support instruments will create sufficient revenue certainty for project developers to commit capital to FID before the window closes for 2030 delivery.


4.3 Feedstock Security

Feedstock dependency is the most immediate structural vulnerability in the EU SAF supply chain. 69% of EU SAF feedstocks were imported in 2024. China alone supplied 38% of imported feedstock; combined with Malaysia, two non-EU jurisdictions account for approximately half of total EU SAF feedstock supply. This is a supply-chain concentration risk of the first order, not a secondary sustainability consideration.


The UK government's cost-benefit analysis for its SAF mandate explicitly warns that dependence on limited waste-oil feedstocks can generate supply bottlenecks as more countries introduce SAF mandates simultaneously. That warning was issued before India formalised its blending targets, before Singapore announced its SAF levy, and before China's SAF pilot expanded to national scale. The competitive pressure on the global pool of compliant waste-oil feedstocks has materially intensified since the UK analysis was published.


See GFJ's Biofuels & Feedstocks Hub at greenfueljournal.com/biofuels-and-feedstocks-hub.


For EU SAF producers, the implication is direct: volume growth constrained by HEFA pathway dominance is volume growth constrained by imported feedstock availability. Diversifying toward ATJ and BtL reduces feedstock concentration risk but increases production cost. There is no structurally low-cost route to feedstock independence — only a set of trade-offs between cost, concentration and supply security that each project developer must price explicitly.


4.4 Airport & Physical Supply Infrastructure

SAF availability at the wrong airport does not solve an airline's operational compliance problem. ReFuelEU's 90% uplift obligation requires SAF to be physically available at the airports from which an operator's EU flights depart. The current coverage — 33 airports across 12 Member States — leaves significant gaps in the EU network, particularly at smaller hubs and in Eastern European Member States.

Physical SAF supply requires co-mingled or dedicated blending infrastructure at each supplying airport: tankage, blending capability and quality-assurance documentation at point of uplift. These are capital investments made by fuel suppliers and airport operators, not airlines.


The gap between SAF purchased by aircraft operators (358 kt in 2024) and SAF physically supplied against the ReFuelEU obligation (193 kt) demonstrates the operational reality: airlines were procuring SAF volumes that could not be physically delivered in certified form at qualifying airports in the quantities required.

 

Infrastructure Requirement

Operational Challenge

Strategic Implication

SAF blending at airport fuel farm

Capital investment by fuel supplier or airport JIG member

Airlines cannot compel blending without infrastructure partner agreement

Dedicated SAF tankage

Contamination risk; QA complexity with co-mingled fuels

Larger hubs have advantage; smaller airports face higher per-litre cost

ReFuelEU traceability documentation

Chain-of-custody from feedstock to uplift must be certified

Documentation failure invalidates SAF credit even if physical SAF is used

Anti-tankering enforcement

Monitoring aircraft fuel loads at departure and arrival

Enforcement gaps in non-compliant Member States reduce economic deterrent

 

5. Named Company Case Studies: Who Is Positioning for ReFuelEU

FINDING | ReFuelEU Intelligence

Four companies — Rebound (Europe), IndianOil (India), Keppel and Aster Zhaoqing (Singapore) and China Eastern (China) — illustrate the four key dimensions of the ReFuelEU supply challenge: European domestic supply response, non-EU supply competition, Asian capacity entering the EU demand orbit, and the direct compliance exposure of non-EU carriers. Together they demonstrate that the ReFuelEU supply question is a global procurement contest, not a European production problem.



5.1 Rebound — European Domestic Supply Response

The June 2026 announcement of the Rebound joint venture between Airbus, Safran, Technip Energies and Tereos at Dunkirk is the most significant single European SAF supply development of the year. The project targets approximately 160,000 tonnes per year of Alcohol-to-Jet SAF, using agricultural ethanol from Tereos as its primary feedstock — a strategy that reduces reliance on imported waste-oil feedstocks. That Airbus and Safran — two of the aviation industry's largest OEMs — are co-investors rather than offtakers signals a structural bet on EU SAF demand depth beyond any single airline relationship.


The strategic implication for ReFuelEU is positive but bounded. At 160 kt/year, Rebound's projected output would be roughly equivalent to 83% of all EU SAF physically supplied in 2024 — which underscores both the significance of the project and the comparative smallness of today's EU supply base. The limitation is timing: the project launched in June 2026 and, as of the research data reviewed, no confirmed FID date or first-production target appears in the public record. Development-stage capacity cannot be contracted as bankable supply.


5.2 IndianOil — Non-EU Supply Competition

IndianOil's Panipat facility represents the clearest example of non-EU SAF production capacity that has achieved the certification threshold required for EU market access. With 86.8 kt/year of Alcohol-to-Jet capacity, ISCC-CORSIA certification — India's first — and a domestic SAF-supply Letter of Intent with Akasa Air signed in January 2026, IndianOil has built the regulatory and commercial infrastructure required for SAF commercialisation at scale.


The friction is market orientation. The domestic LOI with Akasa Air confirms IndianOil's primary commercial priority is serving India's own growing SAF market — consistent with the government's indicative blending targets of 1% in 2027, 2% in 2028 and 5% in 2030. As India's domestic aviation sector grows, the economic attractiveness of domestic SAF sales — with shorter logistics chains — may structurally limit the volume available for export to European buyers. IndianOil is best understood as a prospective EU supply diversification option, not as a near-term European supply solution.


5.3 Keppel + Aster — Asian Capacity Entering the EU Demand Orbit

Keppel and Aster Zhaoqing are developing one of Asia's first commercial-scale Ethanol-to-Jet SAF facilities on Jurong Island, Singapore, with planned capacity of up to 100,000 tonnes per year. The project is at Front End Engineering and Design (FEED) stage and remains subject to Final Investment Decision and regulatory approvals. Singapore's SAFCo central procurement framework — though deferred to January 2027 — is the intended domestic offtake anchor.


FEED-stage capacity cannot be contracted as bankable EU supply for 2030 compliance. The strategic risk is that Singapore's mandatory levy and central procurement model may absorb the majority of Jurong Island output before European airlines can access it.

"The introduction of the SAF Levy marks a major step forward in Singapore's effort to build a more sustainable and competitive air hub."

— Han Kok Juan, Director-General, Civil Aviation Authority of Singapore, Government media release, 10 November 2025


5.4 China Eastern — Direct ReFuelEU Compliance Exposure

China Eastern's participation in China's national SAF pilot and its reported use of 2% SAF on flights departing the EU from 1 January 2025 demonstrates an often-overlooked dimension of ReFuelEU: the regulation applies to all aircraft operators at Union airports, not exclusively to European carriers. Non-EU airlines with significant EU route networks face direct and immediate ReFuelEU procurement obligations.

China Eastern's 2% SAF use on EU-departing flights aligns with the 2025 mandate threshold, but scaling to 6% by 2030 depends on whether certified SAF supply can be secured at the EU airports it serves — not merely whether SAF volumes exist in China. Airport-level procurement infrastructure is the critical operational variable for compliance, regardless of airline nationality.


For GFJ's analysis of energy capital flows in adjacent sectors, see greenfueljournal.com/post/new-energy-m-a-playbook-2026-2027.

 

6. Friction, Risk & Systemic Bottlenecks

FINDING | ReFuelEU Intelligence

The ReFuelEU supply challenge is not a single bottleneck but a system of compounding constraints: 5 Member States control 99% of EU supply; 69% of feedstocks are imported; SAF costs 2.84× the conventional jet-fuel benchmark; infringement proceedings against 13 Member States expose enforcement gaps; and no EU synthetic SAF facility has reached FID. Together they define a market that could produce compliance on paper — total volume — while producing systemic shortfalls in practice: in pathway composition, geographic availability and synthetic sub-mandate coverage.


6.1 Supply Concentration Risk

Five EU Member States accounting for 99% of EU SAF supply is not merely a statistical anomaly — it is a structural vulnerability in the ReFuelEU compliance architecture. Fuel supplied in the five dominant producing Member States can satisfy uplift obligations at their own airports but cannot satisfy a carrier's obligations in the remaining 22 Member States without physical distribution infrastructure that does not currently exist at EU-wide scale.


Any production disruption, feedstock shortage or regulatory challenge in one of the five producing Member States has an outsized impact on EU-wide SAF availability. The supply chain has no redundancy at the Member State level — a risk that intensifies as mandated volumes must triple between 2025 and 2030.


6.2 Feedstock Competition

69% of EU SAF feedstocks were imported in 2024, with China alone contributing 38% of all imported feedstock. This dependency is not coincidental — Chinese used cooking oil has been commercially attractive due to price and volume, and European HEFA producers have built supply chains around it. The strategic risk crystallises as Chinese domestic SAF production capacity (~600 kt/year as of China's 2025 annual report) begins consuming Chinese waste oils domestically rather than exporting them to European refiners.


China exported approximately 7,300 tonnes of SAF from Jiaxing Port in April 2026 — the country's first significant SAF export shipment. This is double-edged for European buyers: it demonstrates Chinese SAF production maturity, but it also signals that China is building an SAF export market that competes with European buyers for the same feedstock molecules the EU was previously importing in raw form.


6.3 Cost Premium & Airline Exposure

EASA's 2024 benchmark — SAF at €2,085/t versus conventional jet fuel at €734/t — establishes the baseline cost premium of approximately 2.84×. This premium is subject to upward pressure from three converging forces: rising mandated volumes increasing SAF demand faster than supply can scale; feedstock competition from growing Asian SAF mandates; and the requirement to incorporate higher-cost pathways (ATJ, e-SAF) as HEFA feedstock constraints tighten.



IEA analysis suggests that a 15% SAF blending share could translate into an increase in average air-ticket prices of approximately 5–7%, depending on the proportion of more expensive emerging technologies in the SAF mix. At the 6% threshold required by 2030, the ticket-price impact is lower but still material for price-sensitive routes. Procurement scenario analysis should therefore frame SAF cost exposure as a range — anchored on the EASA 2024 benchmark with upside sensitivity to feedstock tightening and synthetic pathway requirements — rather than a single forward price.


6.4 Regulatory Enforcement Risk

The European Commission's June 2026 infringement action against 13 Member States for failure to establish national ReFuelEU penalty regimes is commercially significant beyond the legal dimension. Without functioning national penalties, the economic deterrent against non-compliance — for fuel suppliers, airports and aircraft operators — is structurally incomplete. An uneven playing field within the single aviation market contributes to SAF availability disparities across EU airports.

"This first Annual Technical Report marks an important milestone and makes clear that the EU has taken important first steps."

— Maria Rueda, Safety Management, Sustainability and Global Outreach Director, EASA, EASA press release, 22 October 2025


The quote is diplomatically measured. Its analytical implication is direct: the EU entered 2025 with foundational supply structures in place, not operational readiness sufficient for the 2030 mandate. Important first steps taken in 2024–2025 do not constitute the supply infrastructure required to deliver 6% SAF across a 27-Member State network.


6.5 The Unresolved Question: Can the EU Have Enough Compliant SAF?

EU aggregate SAF supply projections conflate four analytically distinct categories — total volume, pathway-compliant volume, airport-available volume, and synthetic-sub-mandate volume — that cannot be treated as equivalent for compliance planning. Each is a subset of the previous, and each carries different supply constraints, different costs and different risk of shortfall.

  • Total SAF volume refers to the aggregate quantity of all certified SAF that could be physically produced and delivered within the EU market. EASA's projection ranges from 1.4 Mt to 5.2 Mt by 2030, with an additional 0.7 Mt of synthetic SAF in the optimistic scenario. The upper range is sufficient in volume terms to clear the 6% mandate. The lower range — 1.4 Mt — likely is not.

  • Pathway-compliant SAF is the narrower question: of whatever total SAF volume exists, how much satisfies the specific pathway eligibility criteria under Regulation (EU) 2023/2405, including feedstock sustainability criteria, lifecycle emissions thresholds and chain-of-custody documentation requirements? SAF that fails any of these criteria does not count toward ReFuelEU compliance regardless of its physical availability.

  • Airport-available SAF is narrower still: of pathway-compliant SAF, how much can physically reach the specific airports where mandated uplift must occur? A volume of certified SAF produced in Rotterdam cannot satisfy uplift obligations in Athens without physical distribution infrastructure that does not currently exist at EU-wide scale.

  • Synthetic-sub-mandate SAF is the fourth and most challenging category: on current evidence — no EU synthetic SAF plant at FID, production costs significantly above any other pathway — the answer for 2030 is inadequate relative to the sub-mandate threshold, whichever of the two conflicting percentage figures proves correct.

 

Supply Question

GFJ Assessment (Base Case)

Risk Scenario

Total SAF volume vs 6% mandate

Achievable in optimistic EASA scenario (5.2 Mt); uncertain in pessimistic scenario (1.4 Mt)

Feedstock tightening + delayed projects = volume shortfall

Pathway-compliant SAF

HEFA dominance means most volume will be compliant; ATJ certification adds to pool

Documentation failures and sustainability criteria revisions could reduce compliant pool

Airport-available SAF

Western EU hubs covered; Eastern EU and smaller airports remain gaps

Infrastructure investment lags mandate escalation; geographic compliance failure

Synthetic sub-mandate coverage

Highly unlikely at the sub-mandate level by 2030 on current FID trajectory

No EU plant at FID; 2030 synthetic supply essentially zero


GFJ Conclusion: Europe can likely reach a headline SAF supply figure close to 6% in favourable scenarios — but the synthetic sub-mandate creates a compliance failure that headline figures obscure, and the geographic distribution of supply leaves significant parts of the EU network unable to source certified SAF physically at point of uplift. Compliance on aggregate does not equal compliance for every operator at every airport. Industrial Strategists must assess their specific route networks, not the EU-wide average.


For a parallel analysis of infrastructure bottlenecks in clean energy deployment, see greenfueljournal.com/post/renewable-energy-grid-bottlenecks-2026.

 

7. Capital & Investment Implications

FINDING | ReFuelEU Intelligence

The key financial distinction in ReFuelEU-related SAF investment is between announced capacity and bankable capacity. Announced capacity comprises project concepts, feasibility studies and development-stage initiatives — commercially valuable signals of market intent, but not contractable supply. Bankable capacity is operational, FID-reached or under construction with confirmed offtake — the only category that supports binding procurement agreements. The EU currently has significant announced SAF capacity in its supply orbit and materially less bankable capacity. Investors and procurement officers who conflate the two categories face planning assumptions that cannot be operationally delivered by 2030.


7.1 Where Capital Is Moving

European SAF investment is concentrating in HEFA capacity expansion and early-stage Alcohol-to-Jet projects. The Rebound Dunkirk project (~160 kt/year ATJ) represents the largest single announced European investment in non-HEFA SAF capacity as of mid-2026. Its OEM co-investors — Airbus and Safran — bring aviation industry credibility but not fuel-supply operational experience, making Technip Energies' engineering role critical to execution.


Green bonds and sustainability-linked debt are the primary financing instruments in EU SAF project development. India's experience with the green bond market — an active and expanding feature of its clean energy financing landscape — is relevant for IndianOil's future SAF capacity expansion.


For GFJ's analysis of long-term energy procurement financing structures, see greenfueljournal.com/post/corporate-ppa-2027.


7.2 What Investors Should Watch

Five criteria distinguish bankable SAF investment from announced-capacity risk.

  • First, feedstock security: projects with long-term, price-fixed feedstock supply agreements outperform those dependent on spot waste-oil markets.

  • Second, offtake structure: binding multi-year offtake agreements with creditworthy counterparties at fixed or price-floor rates are the essential pre-condition for project finance.

  • Third, certification status: ISCC-CORSIA or equivalent sustainability certification must be in place, not planned.

  • Fourth, FID confirmation: development-stage announcements should be treated as options on future supply, not bankable delivery commitments.

  • Fifth, policy exposure: SAF project economics are sensitive to ReFuelEU penalty calibration, EU ETS SAF interactions and national-level support instruments — all subject to regulatory revision.


No authoritative source reviewed supports a robust point estimate of future SAF prices across pathways. Cost analysis should use the EASA 2024 benchmark of €2,085/t as the anchor for procurement scenario sensitivity, with upside ranges reflecting feedstock tightening and synthetic pathway cost structures.


For a methodology applicable to clean energy capital allocation decisions, see greenfueljournal.com/post/why-ccus-adoption-remains-slow-despite-massive-global-investment.


7.3 Procurement Economics

The EASA cost benchmark translates into specific airline balance-sheet implications. At €2,085/t SAF versus €734/t conventional jet fuel — a €1,351/t premium — a carrier consuming 1 million tonnes of jet fuel annually and meeting a 2% SAF obligation faces an incremental SAF cost of approximately €27 million per year. At 6% in 2030, the same incremental cost rises to approximately €81 million per year, before accounting for any premium widening.


These are minimum floor estimates. They do not incorporate spot-market SAF premiums, geographic availability costs, logistics and blending charges, or the additional premium accompanying synthetic SAF procurement. Long-term fixed-price offtake agreements, hedging structures and SAF book-and-claim mechanisms are essential components of any airline's SAF procurement strategy.


IEA's analysis, noting that a 15% SAF blend could add 5–7% to average ticket prices, frames the upper-range cost trajectory. At 6% mandate the passenger-facing impact is lower in absolute terms but remains material for price-sensitive leisure markets. Airlines demonstrating SAF cost transparency to corporate customers — through sustainability-linked contracts or verified SAF certificates — are likely to find more cost recovery latitude than those absorbing the full premium within undifferentiated ticket pricing.

 

8. Future Scenarios: GFJ ReFuelEU Outlook 2026–2035


FINDING | ReFuelEU Intelligence

Four analytical scenarios characterise the ReFuelEU supply environment between 2026 and 2035. None should be interpreted as market forecasts. They represent structurally distinct outcomes based on different combinations of supply investment realisation, feedstock availability, synthetic SAF development velocity and global SAF competition dynamics. Labelled as GFJ analytical scenarios, they are designed to frame procurement and investment strategy rather than predict specific market prices or volumes.

GFJ Scenario 1 — Managed Compliance (2026–2030)

EU SAF supply expands on schedule through HEFA capacity additions and early ATJ commercial scale-up. Development-stage projects, including Rebound, reach FID by 2027 and deliver initial volumes before 2030. Feedstock availability remains adequate through geographic diversification beyond China and Malaysia. Airlines secure long-term offtake agreements at manageable premiums. The headline 6% mandate is achieved by the EU-wide aggregate. The synthetic sub-mandate remains problematic — no EU synthetic SAF plant at FID by 2026 means 2030 synthetic volumes are near-zero — but penalty mechanisms absorb the compliance gap.


Probability driver: EU policy stability, infringement enforcement completion, and at least 3–4 major ATJ project FIDs in 2026–2027.


GFJ Scenario 2 — Supply-Constrained Transition (2026–2030)

Headline SAF volume remains close to the 6% mandate but feedstock tightening, airport-availability gaps and synthetic sub-mandate shortfalls create binding operational constraints. Spot SAF premiums widen significantly above the EASA 2024 benchmark. Airlines without long-term offtake agreements face material cost exposure. Geographic compliance failures emerge in Eastern European Member States with no domestic production. Chinese and Malaysian feedstock exports to EU HEFA producers decline as Asian domestic SAF mandates absorb more local waste-oil supply.


Probability driver: Asian domestic SAF consumption exceeds current projections; EU synthetic SAF FIDs delayed to 2028–2029; enforcement gaps persist in multiple Member States.


GFJ Scenario 3 — Synthetic SAF Bottleneck (2026–2035)

Total SAF availability approaches mandate requirements by 2030 through HEFA and ATJ volume growth, but the synthetic sub-mandate remains structurally unachievable. No EU e-SAF facility is operational by 2030; the first commercial plants deliver initial volumes in 2032–2033. The 2035 mandate of 20% faces a credibility gap that forces a regulatory review of the synthetic pathway timeline and sub-mandate structure. Airlines and investors who positioned on the assumption that synthetic SAF would develop on schedule face stranded costs.


Probability driver: Green hydrogen economics remain challenging through 2028; CO₂ sourcing infrastructure insufficient at scale; no major EU e-SAF project achieves FID before 2027. See greenfueljournal.com/post/green-hydrogen-cost-economics-2026-the-real-path-to-price-parity.


GFJ Scenario 4 — Global SAF Competition (2026–2035)

US §45Z production incentives, UK SAF Mandate demand, Singapore's SAFCo procurement scale and India's formalised blending targets create four distinct certified SAF demand centres simultaneously competing for limited global feedstock supply and certified production capacity. SAF producers with multi-jurisdiction offtake structures command premium pricing across all markets. EU buyers — particularly smaller airlines and non-hub operators — find themselves bidding against well-capitalised US, UK and Asian buyers for spot SAF volumes at airports where EU mandates apply.


Probability driver: US IRA incentives maintain high bankability for North American producers; UK mandate demand creates a competing European-adjacent market; Singapore SAFCo reaches scale before EU airport infrastructure catches up.


9. Strategic Recommendations

FINDING | ReFuelEU Intelligence

The four recommendation sets below are drawn directly from the supply analysis, feedstock risk assessment, cost premium benchmarks and scenario framework in Sections 4–8. Each recommendation connects to a specific verified finding. Industrial Strategists, SAF producers, investors and policymakers each face distinct decision windows that are closing faster than the 2030 mandate date implies.


9.1 For Airlines & Aviation-Fuel Buyers

  • Secure diversified SAF offtake before 2027. GFJ Scenario 2 becomes significantly more likely for airlines that approach 2028 without contracted SAF supply. Feedstock tightening and spot-market premium widening are the predictable consequence of rising mandated volumes intersecting with concentrated supply geography.

  • Map airport-level SAF availability, not EU-average supply. The gap between 358 kt purchased and 193 kt supplied in 2024 proves that SAF procured does not equal SAF uplifted. Identify which airports in your EU network have contracted fuel-farm blending capability.

  • Build price-premium scenarios using the EASA €2,085/t benchmark as a floor, not a ceiling. Procurement planning that treats the 2024 benchmark as a stable long-term price is analytically indefensible given feedstock competition dynamics and synthetic pathway cost structures.

  • Separate synthetic SAF exposure from total SAF compliance. Treat synthetic sub-mandate obligations as categorically distinct from HEFA procurement — different supply sources, different cost structure, different availability timeline, different penalty regime.


9.2 For SAF Producers

  • Secure feedstock supply agreements before announcing capacity. The EU's 69% imported feedstock dependency confirms that feedstock is the binding constraint, not technical production capacity.

  • Achieve ISCC-CORSIA certification as the minimum EU market entry credential, followed by ReFuelEU-specific sustainability documentation for chain-of-custody compliance at EU airports.

  • Prioritise multi-jurisdiction offtake structures. EU ReFuelEU compliance, UK SAF Mandate and Singapore SAFCo demand create three certified demand markets. Producers with multi-jurisdiction offtake agreements have structurally stronger revenue certainty.

  • Evaluate e-SAF economics now, not at the 2028 synthetic sub-mandate approach. Investment decisions made in 2026–2027 determine whether any EU synthetic SAF is commercially available in 2030–2031.


9.3 For Investors

  • Distinguish announced capacity from bankable capacity in every due diligence process. Development-stage SAF projects are options on future supply, not operating assets for financial modelling.

  • Treat feedstock security, certification status and airline offtake as first-order investment criteria — not secondary sustainability indicators. A SAF project without all three cannot achieve project-finance conditions.

  • Evaluate UK SAF Mandate exposure alongside EU ReFuelEU exposure. The UK's 3.6% obligation in 2026, rising to 10% by 2030, creates a complementary certified demand environment for North Atlantic-oriented producers. See greenfueljournal.com/post/new-energy-m-a-playbook-2026-2027.


9.4 For Policymakers

  • Complete national penalty implementation across all 27 Member States immediately. The infringement proceedings against 13 Member States confirm that enforcement architecture remains incomplete three years after the regulation's adoption.

  • Address synthetic SAF infrastructure through dedicated investment instruments, not mandate escalation alone. Raising sub-mandate targets without improving e-SAF project economics creates compliance obligations that cannot be physically met.

  • Develop EU-wide airport SAF infrastructure standards and co-investment mechanisms that enable Eastern EU Member States and smaller hubs to receive physical SAF supply.

  • Resolve the synthetic SAF sub-mandate percentage discrepancy between legislative text and legislative summary publications. Regulatory ambiguity between 0.7% and 1.2% creates compliance planning uncertainty no commercial participant can afford to carry to 2030.

 

For Industrial Strategists: the window to secure bankable SAF supply at manageable cost premiums is narrowing. Airlines, fuel buyers and SAF-exposed operators that begin structured procurement, airport-level availability mapping and synthetic sub-mandate risk assessment before the end of 2026 will be positioned materially better than those who treat 2030 as a distant deadline. The 6% mandate is four years away. The supply chain to deliver it reliably is still being built.

 

10. Executive FAQ


What is ReFuelEU Aviation and what SAF percentage does it require?

ReFuelEU Aviation is Regulation (EU) 2023/2405, adopted 18 October 2023, requiring minimum sustainable aviation fuel shares of 2% in 2025, 6% in 2030, 20% in 2035, 34% in 2040, 42% in 2045 and 70% in 2050. The obligation applies to aviation-fuel suppliers at qualifying Union airports, aircraft operators (who face a 90% annual uplift requirement), and Union airports. A synthetic fuel sub-mandate begins in 2030. A synthetic fuel sub-mandate for renewable e-fuels (RFNBOs) begins in 2030 at 0.7%, rising to 35% by 2050.


How much SAF does the EU need to meet the ReFuelEU 2030 target?

EASA projects EU SAF production potential for 2030 in a range of 1.4–5.2 Mt of conventional SAF plus up to 0.7 Mt of synthetic SAF, depending on investment realisation and feedstock availability. The headline 6% mandate is achievable at the optimistic end of this range. The 3.8 Mt gap between pessimistic and optimistic scenarios means individual airline and airport compliance cannot be guaranteed by EU-wide average projections — airport-level availability and pathway composition matter as much as aggregate volume.


Will there be enough SAF supply in Europe by 2030?

On aggregate volume, the 6% target is achievable in EASA's optimistic scenario. In practice, the EU faces four compounding constraints: 5 Member States control 99% of supply; 69% of feedstocks are imported; the synthetic sub-mandate has no operational EU production capacity; and 13 Member States had not established national penalty regimes as of June 2026. Total SAF volume and compliant, physically available, pathway-specific SAF are not the same thing — compliance planning must address all four dimensions.


Why could synthetic SAF become the main ReFuelEU bottleneck?

No EU synthetic SAF facility had reached Final Investment Decision as of EASA's 2024 assessment. Given extended development and construction timelines, a project that does not reach FID by 2026–2027 is unlikely to deliver commercial volumes before 2030. ReFuelEU's synthetic sub-mandate creates a compliance obligation for a specific SAF category that has essentially zero available EU production capacity — making it the most analytically unresolved element of the 2030 compliance picture.


How much more expensive is SAF than conventional jet fuel?

EASA's 2024 reference benchmark places SAF at €2,085 per tonne versus €734 per tonne for conventional jet fuel — a premium of approximately 2.84×. UK government pathway analysis benchmarks HEFA production at £821–£1,786/t and advanced Biomass-to-Liquid pathways at £2,988–£6,078/t. IEA estimates that a 15% SAF blending rate could translate into an air-ticket price increase of approximately 5–7%.


What should airlines do now to secure SAF supply before 2030?

Begin multi-year offtake negotiations immediately, prioritising producers with confirmed feedstock supply and FID-reached or operational capacity. Conduct airport-level availability mapping across EU routes — aggregate EU supply projections do not resolve individual operator compliance at specific airports. Model SAF cost exposure using the EASA 2024 benchmark of €2,085/t as a floor, with upward sensitivity for feedstock tightening. Separating HEFA-eligible SAF procurement from synthetic sub-mandate exposure is the single most important analytical step in compliance planning.


Which SAF producers and projects are best positioned for ReFuelEU demand?

As of mid-2026, Rebound (Airbus/Safran/Technip Energies/Tereos, Dunkirk, ~160 kt/year ATJ) is the most significant announced European domestic supply response. IndianOil's Panipat facility (86.8 kt/year ATJ, ISCC-CORSIA certified) is the most advanced certified non-EU producer in Europe's supply orbit. Keppel + Aster's Singapore ETJ plant (up to 100 kt/year) is at FEED stage and subject to FID. Both non-EU projects face domestic demand competition that may limit EU-export volumes before 2030.


Can Indian, Chinese and Singaporean SAF producers supply the European market?

IndianOil has ISCC-CORSIA certification but its primary commercial orientation is domestic — consistent with India's indicative targets of 1% in 2027, 2% in 2028 and 5% in 2030. China exported approximately 7,300 tonnes of SAF in April 2026 — demonstrating export capability — but growing domestic consumption from its ~600 kt/year base reduces export availability. Singapore's Keppel + Aster is at FEED stage and subject to SAFCo domestic demand priority. None of these represents a reliable primary EU supply source for 2030 compliance — but all merit monitoring as secondary diversification options.

 

Scope & Disclaimer

This report is published by Green Fuel Journal (GreenFuelJournal.com), a research and intelligence publication operated by Sekason Research Limited (Company No. 14339910), registered in England and Wales. It is produced for general intelligence and informational purposes only. It does not constitute legal, financial, investment, engineering, regulatory or procurement advice. Nothing in this report should be relied upon as the basis for any business, investment, compliance or procurement decision without independent professional verification. All regulatory obligations under Regulation (EU) 2023/2405 and related national legislation must be verified against current operative legal texts and confirmed with qualified legal counsel. Company-claimed figures and capacity targets are reported as stated by the relevant organisations and have not been independently audited by Green Fuel Journal. Forecasts and scenarios are analytical constructs intended to frame strategic thinking and do not constitute market predictions.

For full terms and editorial standards, see greenfueljournal.com/disclaimers.

 

References & Strategic Sources

 

This report is backed by authoritative research, institutional analysis, industry intelligence, and strategic data sources.

 

Green Fuel Journal — Strategic Intelligence for the Global Energy Transition

GreenFuelJournal.com  |  Published by Sekason Research Limited (Co. No. 14339910), England & Wales

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