Air Operators

Obligations for Air Operators

Refuelling obligations for aircraft operators are defined in Article 5.1 of the Regulation, which specifies that:

The annual amount of aviation fuel refuelled by a given aircraft operator at an airport in the Union shall be at least 90% of the annual aviation fuel requirement, in order to avoid emissions related to excess weight caused by overfuelling practices, known as tankering.

The practice of tankering is a real problem for the climate, as the additional weight of the excess or fuel leads to higher fuel consumption and thus to increased greenhouse gas emissions during flight..

	The annual aviation fuel requirement is defined as the amount of aviation fuel referred to as "taxi fuel" and "trip fuel" in Annex IV of Commission Regulation 965/2012.

Application for Exemptions

In accordance with Article 5.3 of the Regulation, an aircraft operator may, exceptionally and when duly justified, apply to the competent authority or authorities for a temporary exemption from the refuelling obligation laid down in Article 5.1.

Therefore, an aircraft operator may make a justified request to the competent authority that flights on a route of less than 850 kilometres, or 1 200 kilometres for routes connecting to airports located on islands without rail or road connections, departing from an airport in the Union are temporarily and exceptionally exempted from the 90% annual aviation fuel refuelling obligations.

Exemptions must be submitted 3 months before their entry into force and be the result of:

• Recurrent operational difficulties: Problemas constantes para repostar aeronaves en un aeropuerto de la UE, que impiden realizar las maniobras en un plazo razonable.
• Structural supply difficulties: Problems arising from the geographical location of an EU airport, resulting in much higher fuel prices compared to other EU airports, causing a significant competitive disadvantage for the operator..

The granting of an exemption may not exceed 1 year, and the person concerned shall have a right of appeal in the event of refusal..

Interpretative guidelines on the application of the exemptions contained in Article 5 of the Regulation can be consulted and downloaded at this link.

Annual Report for Air Operators

In accordance with Article 8 of the Regulation, not later than 31 March of each reporting year, aircraft operators shall report to the competent authorities and EASA information on aviation fuel supply and sustainable aviation fuel procurement for a specific reporting period.

The report must be submitted in accordance with the templates set out in Annex II of the Regulation.(Available for download at the following link: OA ReFuel EU OA reporting template)

The report shall be checked by an independent verifier in accordance with the requirements set out in Articles 14 and 15 of Directive 2003/87/EC and in the implementing acts adopted pursuant to that Directive.

OUTLINE OF THE ANNUAL REPORTING PROCESS FOR AIRCRAFT OPERATORS

Available to aircraft operators and verifiers, the Handbook for Aircraft Operators and Verification Bodies provides guidance on reporting and verification of data as set out in Article 8 and Annex II of the ReFuelEU Aviation Regulation (RFEUA)..

This manual is available for download at ReFuelEU EASA website.

Conferences and materials of interest

On 30 January 2025, AESA held an Information Day on the Implementation of the ReFuel EU Aviation Regulation for Air Operators and Verification Entities.

Included below, for free download, are the materials used during it, as well as a general question-and-answer section that may be of interest.

1. Introduction to regulations
2. Report of linked data for the year 2024
3. ReFuelEU Aviation Fuel Monitoring Tool
4. ReFuelEU Aviation Sustainability Portal
5. Application and processing of exemptions referred to in Article 5 of Regulation (EU) 2023/2405

Questions and Answers Sustainability Day 30 January 2025

Links of interest

• Link to EASA website dedicated to ReFuel EU.
• Regulation (EU) 2023/2405 of the European Parliament and of the Council of 18 October 2023 on ensuring a level playing field for sustainable air transport (ReFuelEU Aviation).
• Link EASA Web Platform for requesting exemptions: ReFuel Digital Reporting Tool.
• Link to the European Commission website dedicated to ReFuelEU Aviation.
• ReFuelEU Aviation Manual for Aircraft Operators and Verification Bodies 2024.
• Template Report for Air Operators.
• Communication from the Commission — Interpretative guidelines on the application of the exemptions contained in Article 5 of Regulation (EU) 2023/2405 of the European Parliament and of the Council on ensuring a level playing field for sustainable air transport (ReFuelEU Aviation).

Frequently asked questions

This set of Frequently Asked Questions (FAQs) published by the European Commission clarifies the interpretation of certain provisions of Regulation (EU) 2023/2405, ReFuel EU Aviation.

By means of this set of frequently asked questions, the Commission intends to make it easier for interested parties to understand and therefore comply with the legal requirements laid down in that Regulation. The legal obligations set out in Articles 4, 5 and 6, as well as the reporting obligations set out in Articles 8 and 10, apply from 1 January 2025. The answers to the frequently asked questions contained in this Notice clarify the provisions of the applicable legislation. They do not extend in any way the rights and obligations deriving from such legislation or introduce additional requirements.

Questions can be found at the following link: Frequently asked questions on the interpretation of certain provisions of Regulation (EU) 2023/2405,

For translations of these FAQs into all EU languages, please refer to the Commission Communication on the interpretation and application of certain legal provisions of Regulation (EU) 2023/2405 of the European Parliament and of the Council on ensuring a level playing field for sustainable air transport (ReFuelEU Aviation).

Contacto

If you have any questions, you can contact us through the email sustainability.aesa@seguroaerea.es