ReFuelEU Aviation: Sustainable Aviation Fuel Regulation

The ReFuelEU Aviation Regulation, which became applicable in 2025, establishes a progressive mandate for the blending of sustainable aviation fuels at airports across the European Union. The regulation requires fuel suppliers to ensure that a minimum share of aviation fuel made available at EU airports consists of sustainable aviation fuel, with the blending obligation increasing incrementally from two percent in 2025 to seventy percent by 2050. A sub-mandate for synthetic aviation fuels produced from renewable electricity further tightens the sustainability requirements over time. This legislative initiative forms a central pillar of the EU’s Fit for 55 package and aims to decarbonize one of the most emissions-intensive segments of the transport sector.

 

Leasing and Financing Implications

The regulation’s impact extends well beyond fuel suppliers to encompass airlines, airport operators, aircraft lessors, and aviation financiers. Airlines departing from EU airports must ensure that their fuel uplift at those airports corresponds at least to ninety percent of the fuel required for the relevant flight, a measure designed to prevent the practice of fuel tankering to avoid SAF obligations. Non-compliance exposes airlines to financial penalties calculated on the basis of the price differential between conventional jet fuel and sustainable alternatives. For aircraft leasing companies and financial institutions, the regulation introduces a new dimension of risk assessment, as the operational costs and compliance obligations associated with SAF mandates may affect the creditworthiness and lease economics of airline counterparties.

 

Contractual Considerations

From a contractual perspective, the ReFuelEU mandate necessitates a thorough review of existing leasing, financing, and fuel supply agreements. Lease agreements that allocate operational cost risk between lessor and lessee may require amendment to address the incremental costs of SAF procurement. Similarly, fuel hedging arrangements and airport service agreements should be evaluated in light of the new blending obligations. Airlines operating routes connecting Turkish airports with EU destinations must pay particular attention to the compliance requirements applicable at their EU departure points, as the regulation applies on the basis of fuel supply location rather than airline nationality.

 

Impact on Turkish Airlines

Topluyıldız Legal Co. advises aviation sector clients on the regulatory and contractual implications of the ReFuelEU mandate and related EU sustainability legislation. Our team assists airlines, lessors, and financial institutions in reviewing and renegotiating commercial agreements to appropriately allocate SAF-related costs and compliance risks. We also provide strategic guidance on the broader regulatory trajectory of aviation decarbonization policy, enabling our clients to plan long-term fleet and route strategies in alignment with the evolving legal requirements of the European market.

 

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This article was prepared by Topluyıldız Legal Co. for informational purposes and does not constitute legal advice.