EU SAF Mandate: Who Paid The Surprising Year One Bill?

EASA, the EU’s aviation safety agency, reported in September that sustainable aviation fuel reached 2.8% of the fuel supplied at EU airports in 2025. The target was 2%. Suppliers delivered 1.1 million out of 39.3 million ton fuel in total. So the EU SAF mandate cleared its first full year with room to spare. It cleared mostly on waste oil bought abroad, which sits in the lowest of the scheme’s four support brackets. The fuels the 2030 step depends on were barely there. So 2025 measured the cheap end of the problem, the hard end arrives in 2030.

What year one cost

The European Commission published the support figures on 15 September. Airlines claimed just over 530,000 tonnes of eligible fuel. For that they received about 5.2 million free ETS allowances, worth roughly 430 million euro. That is about 811 euro for every tonne claimed. In 2024 the same mechanism handed out 1.3 million allowances worth about 100 million euro. So support quadrupled in the first year the mandate applied. In 2024 there was no blending obligation, only the scheme.

Two numbers sit oddly beside each other. Suppliers delivered 1.1 million tonnes. But airlines claimed 530,000. The gap is not waste. ETS support attaches only to fuel burned on flights the ETS covers, which today means mostly intra-European flying. So under half of the EU SAF mandate’s volume earned an allowance at all.

Eighty percent used cooking oil

EASA’s report puts used cooking oil at 80% of the 2025 volume. Meanwhile EU refineries made 86% of the fuel. But 85% of the feedstock came from outside the EU. Europe met the EU SAF mandate’s first year on plants it owns and waste oil it buys abroad.

That trade is tightening. Transport and Environment found four fifths of Europe’s used cooking oil imported, with 60% of those imports from China. S&P Global reported in December 2025 that the five largest producing countries have added export restrictions or levies to feed their own blending mandates. So the pathway that cleared year one runs on a feedstock Europe neither produces nor controls.

The tier that paid year one

The EU SAF mandate’s support scheme pays in tiers. The Commission’s own design note sets four rates against the price gap. Renewable fuels of non-biological origin draw 95%. Advanced biofuels and renewable hydrogen draw 70%. Small island airports draw 100%. Everything else eligible draws 50%. Used cooking oil and animal fat sit in that last bracket, because ReFuelEU does not treat them as advanced.

EASA’s 2025 reference prices put conventional jet fuel at 640 euro a tonne. Conventional aviation biofuel sits at 1,925 euro. That is a gap of 1,285 euro, and the 50% rate covers about 643 euro of it. Advanced biofuels cost 2,760 euro, which at 70% of a 2,120 euro gap draws about 1,484 euro. Then comes synthetic fuel, or e-SAF, at 7,520 euro a tonne. Its gap runs to 6,880 euro and the scheme covers 95%, so about 6,536 euro leaves the pool for every tonne burned.

A tonne of it therefore draws roughly ten times what a tonne of 2025’s fuel drew. The Commission’s own description of the 2025 claims covers biofuels and advanced biofuels without splitting them, so how much volume reached the 70% tier stays unknown. It names no synthetic fuel either, so the 95% tier went unclaimed.

What 2030 will ask

The pool does not grow. Article 3c(6) of the ETS Directive reserves at most 20 million allowances for this purpose, from 1 January 2024 to 31 December 2030. 2024 used 1.3 million. 2025 used 5.2 million. That leaves 13.5 million, worth near 1 billion euro at the Commission’s own valuation of the full reserve. The Commission’s November 2023 note said the allowances “should last for most of this period”, not all of it.

Then put 2030 against it. The EU SAF mandate steps from 2% to 6%, and a 1.2% sub-target for synthetic fuel applies from the same year. On a fuel base the size of 2025’s that is about 472,000 tonnes, and the French institute IFRI puts it at 600,000 tonnes on a 2030 base. At roughly 6,536 euro a tonne the support bill reaches 3 billion euro a year, several times what remains. ReFuelEU softens the timing. The total stays. Article 4(1) makes the synthetic share a two-year average, and Article 4(7) lets a shortfall run to the end of 2034.

But supply is the harder problem. Transport and Environment counts 41 large-scale e-SAF projects in Europe and no final investment decision among them. IFRI reported in June 2026 that funded capacity covers 0.71% of what the sub-target needs. So the pool survives 2030, because there will be almost nothing to claim the 95% tier against. The blending duty sits with fuel suppliers, and Article 12 prices their shortfall at twice the price gap, about 13,760 euro a tonne.

Mandate’s support rates cut

On 17 July 2026 the Commission proposed COM(2026) 616, which extends the mechanism to 2040 and adds up to 110 million allowances. That reads as more money for the EU SAF mandate. But the same proposal cuts every rate. Climate Catalyst’s policy tracker, which read the draft, puts synthetic fuel at 60%, down from 95%, and advanced biofuels at 50%, down from 70%. The bracket that carried most of 2025 falls to 30%, then stops entirely in 2029. The operative article for this piece could not be verified, so the exact percentages are reported and unconfirmed. But their direction is not in question.

Transport and Environment reads the same scheme as generous. Its March 2026 factsheet puts the whole mandate at about 4% on ticket prices by 2030, with the synthetic component worth roughly 3 euro on a short-haul fare.

Still, Parliament and Council have not agreed any of it. The target for political agreement is the end of the first quarter of 2027.

What this means for your business case

Feedstock is the first constraint. Year one rested on imported waste oil. The EU SAF mandate does not cap that oil the way it caps other non-advanced biofuels, so nothing in the regulation pushes a supplier up the feedstock ladder. Export policy in the producing countries will. If your business case turns on used cooking oil, test it against the 2.4 million tonnes a 6% mandate needs on a fuel base this size. Year one supplied 1.1 million.

The support rate is the second. A synthetic fuel project modelled on 95% faces a proposed 60%. An advanced biofuel project modelled on 70% faces 50%. A waste-oil project faces 30%, and then nothing after 2029. Read that in euros a tonne. The scheme covers 95% of synthetic fuel’s 6,880 euro gap but only 70% of advanced biofuel’s 2,120. So today the most expensive fuel leaves its producer less to find, 344 euro against 636. The proposed rates reverse that, to 2,752 against 1,060.

Then look at what is left to pay for it. Support now runs to 2040 on about 15 billion euro, which also covers electrification and non-CO2 effects. That averages 1.25 billion a year. One year of 2030 compliance at the proposed rates costs about 4 billion. Three times the average, before the mandate steps to 20% in 2032. So the rates came down before a single commercial synthetic fuel plant existed. The gap stays with whoever is building the plant. So model the rate as a scenario. Then watch what Parliament and Council do to it, because that is where the number gets set.

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