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UK ETS Consultation on Sustainable Aviation Fuel Emissions Reduction Claims
The UK Government has launched a consultation on potential changes to the treatment of Sustainable Aviation Fuel (SAF) under the UK Emissions Trading Scheme, including fuel eligibility, sustainability criteria, greenhouse gas savings thresholds and emissions accounting for Emissions Reduction Claims (ERCs).
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Full summary and practical implications
The consultation considers updating the UK ETS treatment of Sustainable Aviation Fuel to better align with the UK SAF Mandate while maintaining the environmental integrity of Emissions Reduction Claims.
Under the current UK ETS framework, only biofuels meeting Renewable Transport Fuel Obligation (RTFO) sustainability criteria and delivering at least a 65% greenhouse gas saving are eligible for Emissions Reduction Claims.
Eligible Sustainable Aviation Fuel is currently treated as producing zero emissions for UK ETS allowance surrender purposes, regardless of its actual lifecycle greenhouse gas emissions.
The consultation proposes expanding eligible fuel types to include Recycled Carbon Fuels (RCFs) and Power-to-Liquid (PtL) fuels, which are already recognised under the UK SAF Mandate and the EU ETS.
Government is also seeking views on aligning UK ETS sustainability criteria with the UK SAF Mandate, lowering the greenhouse gas savings threshold from 65% to 40%, and revising the fossil fuel comparator from 94 gCO₂e/MJ to 89 gCO₂e/MJ.
Another proposal considers replacing the current zero-rating approach with lifecycle-based emissions accounting, allowing emissions reductions to reflect the actual lifecycle greenhouse gas performance of Sustainable Aviation Fuel.
The consultation does not introduce immediate compliance changes but signals potential amendments that could significantly influence future UK ETS reporting, allowance surrender obligations and Sustainable Aviation Fuel procurement strategies.
Key UK ETS SAF Consultation Proposals
| Consultation Topic | Current UK ETS | Proposed Change |
|---|---|---|
| Eligible Fuel Types | Biofuels meeting RTFO sustainability criteria | Include Recycled Carbon Fuels and Power-to-Liquid fuels |
| Sustainability Criteria | Renewable Transport Fuel Obligation (RTFO) | Align with UK SAF Mandate criteria |
| Minimum GHG Savings | 65% | Reduce to 40% |
| Fossil Fuel Comparator | 94 gCO₂e/MJ | Revise to 89 gCO₂e/MJ |
| Emissions Accounting | Zero-rated eligible SAF | Potential lifecycle-based accounting |
Operator actions
What your team should do next
Review current Sustainable Aviation Fuel procurement against existing UK ETS eligibility requirements.
Assess the potential impact of the proposed consultation options on future allowance surrender obligations.
Model Sustainable Aviation Fuel eligibility using both the current 65% and proposed 40% greenhouse gas savings thresholds.
Maintain robust sustainability evidence and chain-of-custody documentation for all Sustainable Aviation Fuel purchases.
Review Emissions Monitoring Plans to ensure Emissions Reduction Claim procedures remain accurately documented.
Monitor the outcome of the consultation and prepare for potential amendments to UK ETS compliance requirements.
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