• Fit for 55 (FF55) policies should support future industry investments in new aircraft technologies and sustainable aviation fuels (SAF) – two key tools to decarbonise aviation by 2050. 
• Unilateral and double pricing of CO₂ under several market-based mechanisms is economically and ecologically counter-productive and could distort competition within the EU and globally.
• Sector’s Destination 2050 decarbonisation roadmap shows alignment with EU climate goals without the need for further cost increases. 
• Carbon leakage and competitive distortion within and outside Europe will need to be mitigated.

The European Commission’s “Fit for 55” package published today includes several proposals which will significantly impact European airlines in the years to come. For aviation, future European policies are crucial to ensure investment in new fleet, Sustainable Aviation Fuels (SAFs), new technologies — such as electric and hydrogen aircraft, and to achieve more efficient air traffic management via an updated Single European Sky. Europe’s airlines have ambitious targets in line with the COP21 Paris Agreement. The sector is committed to accelerating its emissions reductions to reach net zero CO2 emissions by 2050 for all flights within and departing Europe, and to significantly reduce emissions by 2030 as per the sector’s Destination 2050 roadmap. Aviation is responsible for around 3% of global emissions.

Relevant policies for aviation in Fit for 55 include: A SAF blending mandate under the ReFuel EU Aviation initiative; the review of the Energy Taxation Directive (ETD); the proposals on EU ETS and CORSIA; the review of the Renewable Energy Directive (RED) and the alternative fuels infrastructure Directive.

“The proposals unveiled today will have a transformative impact on the sector. We look forward to working with policy-makers to ensure airlines can deliver on our commitments, while at the same time making sure regulators also play their part. In the end, we must keep air transport affordable and accessible to all citizens”, said Thomas Reynaert, Managing Director, A4E.

“We reaffirm our position, however, that climate policy regulation can be ecologically and economically counterproductive. Badly designed European taxes will not reduce emissions. By making flying more expensive, it may shift demand globally and reduce traffic locally. But it will not tackle the source of the emissions. We need to invest in solutions that offer real reductions in CO2 emissions per aircraft. Increasing costs reduces our capacity to make these investments whilst CO2 emissions are potentially shifted to other regions“, Reynaert added.

In this regard, unilateral and double pricing of CO₂ under several market-based measures would be economically counterproductive. If airlines pay for their CO₂ under the EU ETS, for instance, they should not have to pay for it again elsewhere. Inefficient policies leading to a disproportionate cost burden hamper aviation’s decarbonisation plans. As one of the sectors hardest hit by the pandemic and with an essential role in kick-starting societal and economic recovery – future EU policies must guarantee and support the sector’s competitiveness. The Fit for 55 policies risk affecting this competitiveness and that of the entire aviation ecosystem, Europe’s tourism industry and the wider EU economy. Carbon leakage will need to be mitigated through appropriate measures, such as uniform regulations, carbon border adjustment or designated finance mechanisms preserving competition neutrality.

Destination 2050 (D2050) showed that decarbonisation and an alignment of the aviation industry with the EU’s climate targets is possible without further significant cost increases on the sector. The European aviation sector’s pathway would guarantee that air transport can decarbonise without compromising its ability to continue delivering social and economic benefits globally.

Any further taxes on aviation must also take into account the overarching costs which are unique to airlines in Europe, and how these relate to decarbonisation efforts. This includes, among others: ticket taxes, solidarity taxes, air traffic control charges, airport charges and security costs – the latter of which is paid for by the State in other sectors. These costs are unevenly carried by other modes of transport and should be better considered when designing future economic policies.

Brussels, 14 July 2021

A4E member KLM also reacted to the European Commission’s proposal:

KLM’s response to the European Commission’s Fit for 55 proposals (Green Deal)

Today (14^th of July 2021), the European Commission presented its Fit for 55 package, containing important proposals for making Europe more sustainable. A number of these proposals will affect KLM directly and the airline industry as a whole.

KLM supports the EU’s goal of becoming the first continent to achieve climate neutrality by 2050 wholeheartedly. We, therefore, welcome the Fit for 55 package as part of the European Green Deal. Our full support can be relied upon for measures in this package that will truly help the airline industry to become more sustainable.

The challenge we are facing is global, making unambiguous policy at a global level essential. A European Union that sets the tone with good European policies using strong instruments to improve sustainability is important for furthering this transition. It is vital that everyone participates and that a level playing field is maintained globally. We must become more sustainable, while ensuring that we can continue to compete with the rest of the world.

The European airline industry presented its own ambitious roadmap in February of this year, entitled Destination 2050. It was written by the Netherlands Aerospace Centre (NLR) and SEO Amsterdam Economics and contains concrete steps and recommendations for achieving net-zero CO₂ emissions by 2050 for all flights departing from European airports.

We are delighted that many of the proposals the European Commission presented today correspond well with the vision we presented in Destination 2050. We support measures for upscaling the production and use of Sustainable Aviation Fuels (SAF), which emit up to 85% less CO₂ than regular kerosene. In addition, we advocate for indisputable sustainability criteria for such alternatives. A Single European Sky is also essential alongside this package of measures, because ensuring airlines can take the most direct routes in Europe could reduce CO₂ emissions in Europe by up to 10%.

Such measures are effective in helping the airline industry to become more sustainable. Introducing general levies, such as a European kerosene tax, will not achieve this, because they do not directly lead to a reduction in CO₂ emissions and moreover the revenues raised are not invested in boosting sustainability in the industry. Kerosene tax may well have the opposite effect, leading to aircraft flying longer routes to circumvent the tax and thereby increasing emissions.

We need to implement those measures that will actually efficiently and effectively reduce CO₂ emissions. EU policy must support the airline industry’s efforts to become more sustainable. We will now take sufficient time to thoroughly analyse the European Commission’s extensive proposals.

Amstelveen, 14 July 2021