Germany is planning to impose penalties of €17,000 for each tonne that fuel suppliers fall short of their hydrogen-based synthetic aviation fuel (e-SAF) obligations, under a draft bill implementing the EU's revised Renewable Energy Directive (RED III).
The draft, seen by Argus, allows for the penalty level to be adjusted in future.
The EU's ReFuelEU Aviation legislation mandates e-SAF blending from 2030. Fuel suppliers must ensure that e-SAF makes up at least 1.2pc of their overall aviation fuel supply on average in 2030–31, with a minimum of 0.7pc each year. The share rises to 2pc in 2032, 5pc in 2035 and 35pc by 2050.
Member states are required to set penalties at least twice the price difference between e-SAF produced from renewable hydrogen and conventional jet fuel.
Reference prices published by the European Union Aviation Safety Agency earlier this year implied minimum penalties of €13,922/t. Germany's proposed €17,000/t penalty would significantly exceed that level.
E-SAF can be produced using renewable or non-fossil low-carbon hydrogen, such as hydrogen from nuclear-powered electrolysis. The legislation also permits the direct use of hydrogen in aviation, although this is widely seen as a longer-term prospect.
Germany had previously proposed its own national e-SAF quotas but scrapped those plans following the introduction of EU-wide mandates.
Most planned e-SAF production facilities in Europe and globally remain in early development stages. Industry participants have repeatedly called for greater regulatory clarity — including on penalties — and additional support to unlock final investment decisions.
