A multi-stakeholder industry coalition sent an open letter to the European Commission on 16 September 2026 demanding rejection of a proposed accounting rule that would allow electrolytic hydrogen consumed during HEFA and HVO hydrotreatment to count toward the ReFuelEU Aviation e-SAF sub-mandate — a move the signatories call a ‘dangerous regulatory precedent’ that conflates conventional bio-based pathways with genuine Power-to-Liquid production.
2.8%
EU SAF blending share achieved in 2025 (vs. 2% mandatory minimum)
1.1 Mt
SAF volume supplied across EU in 2025
39.3 Mt
Total aviation fuel consumed in EU in 2025
16 Sep 2026
Date of industry open letter to the European Commission
- The loophole explained: H₂ in hydrotreatment ≠ e-SAF
HEFA and HVO processes require hydrogen as a process input for deoxygenation and hydrocracking of bio-based feedstocks. The contested proposal would treat electrolytic (RFNBO) hydrogen injected at this step as equivalent to the full Power-to-Liquid synthesis route — an accounting shortcut the coalition argues misrepresents both carbon accounting and the engineering reality of PtL. - Why process engineering makes the distinction non-negotiable
In a genuine PtL pathway, CO₂ is catalytically converted with green hydrogen via Fischer-Tropsch or methanol-to-jet synthesis, producing a fully synthetic hydrocarbon chain; the carbon and energy balance is radically different from simply substituting fossil H₂ in a bio-oil refinery. Conflating the two undermines the investment case for purpose-built e-fuel plants and the infrastructure — electrolysers, CO₂ capture units, reactor trains — they require. - 2025 compliance beat the headline target, but e-SAF volumes remain marginal
EASA’s first ReFuelEU compliance report, published 17 September 2026, confirmed the EU exceeded the 2025 blending obligation with a 2.8% SAF share (1.1 Mt from 39.3 Mt total aviation fuel). However, the vast majority of that volume came from HEFA, not from electrolytic PtL — making the sub-mandate’s integrity critical to driving genuine e-fuel scale-up toward the 2030 and 2035 step-changes. - Regulatory precedent risk extends to FuelEU Maritime
The coalition’s letter explicitly flags FuelEU Maritime as a second front: the same accounting logic, if accepted for aviation, could migrate to maritime e-methanol and e-ammonia compliance tracking, further diluting incentives for electrolyser deployment and integrated PtL plant construction. Digital twin and AI-based process control systems being developed for next-generation PtL facilities depend on a clear regulatory signal to attract the capital expenditure needed for commercial-scale build-out. - EC decision window and what industry is asking
The coalition is urging the Commission to reject the credit mechanism in the forthcoming delegated act and to maintain a strict technology-based definition of e-SAF tied to the full Power-to-Liquid or Power-to-X synthesis chain, consistent with the RFNBO criteria established under RED III.
Bottom Line
The ReFuelEU accounting dispute is not a procedural footnote: it determines whether the e-SAF sub-mandate drives capital into electrolysers, CO₂ capture units and Fischer-Tropsch reactors, or merely subsidises an incremental feedstock switch in existing bio-refineries. With the EU having already beaten the 2025 blending floor — 2.8% versus the 2% minimum — the real test is whether the regulatory framework can sustain the investment trajectory needed for the 2030 step-up. A ruling that blurs the line between HEFA hydrotreatment and genuine PtL would, as the coalition argues, set a precedent corrosive to both targets.
Sources
- Safeguarding the Integrity of EU Synthetic Fuels Targets under ReFuelEU Aviation & FuelEU Maritime – CleanTechnica
- EU sustainable aviation fuel supply exceeds 2025 ReFuelEU Aviation target | EASA
Featured image via Unsplash.
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