The obligations of aircraft operators under the ReFuelEU Aviation Regulation are defined in articles 5, 8 and 9.
In accordance with Article 5 the yearly quantity of aviation fuel uplifted by a given aircraft operator at a given Union airport shall be at least 90 % of the yearly aviation fuel required. This is to avoid so-called tankering, which causes more emissions due to the extra weight of the aircraft.
Request for exemptions
An aircraft operator may request for exemptions from the refuelling obligation based on article 5(3) of the Regulation.
Please note that the exemptions according to article 5(3) of the Regulation must be requested three months prior to beginning of the requested exemption period, and approved before the exemption period begins. The administrative decision on an exemption request by Traficom is subject to a fee (External link).
Reporting
The exemptions according to article 5(2) for fuel safety rules are reported and justified retroactively in the aircraft operator's annual report.
In accordance with Article 8 by 31 March of each year, and for the first time in 2025, aircraft operators shall report the required and verified information with respect to a given reporting period (previous year) to the competent authorities, which in Finland is Traficom.
The reporting is also done through the EASA Sustainability Portal.
According to Article 9, aircraft operators shall not claim benefits for the use of an identical batch of SAF under more than one greenhouse gas scheme.
The obligations of the Union airport managing body
The obligations of the Union airport managing body can be found in Articles 6 and 7 of the ReFuelEU Aviation Regulation.
Pursuant to Article 6, Union airport managing bodies shall take all necessary measures to facilitate the access of aircraft operators to aviation fuels containing minimum shares of SAF in accordance with the Regulation.
Pursuant to Article 7, the Union's airport managing bodies, aviation fuel suppliers and fuel handlers shall, if necessary, cooperate with their own Member State in order to promote hydrogen and electricity deliveries.
Union airport managing bodies report to Traficom in Finland.