By the end of Q2 2026, partial disclosures from the first full year under ReFuelEU Aviation showed SAF supply concentrated unevenly across Europe. The result was neither a clear success nor a failure. It exposed a gap between the supply chain structure assumed by the regulation and the one operating in practice.
We drew on public EU fuel quality monitoring summaries, interim supplier disclosures, and recent discussions between our sustainability team and compliance officers at European fuel supply companies. The complete dataset is not available. National competent authority reports for 2025 compliance will not be consolidated at EU level until Q2 2026 at the earliest. The available evidence still shows the problem's shape.
The 2% Floor in Practice
ReFuelEU Aviation (Regulation 2023/2405) obliges aviation fuel suppliers to make at least 2% SAF available at every EU airport from January 1, 2025. The duty belongs to the supplier, not the airline. Airlines must take up the SAF offered, but they are not primarily liable for a shortfall in total supply.
Eligibility for the 2% share follows Annex I of the Renewable Energy Directive together with ASTM-certified fuel categories. Electrofuels, including methanol-to-jet products certified under ASTM D7566 Annex A7, are expressly eligible. The e-fuel sub-mandate starts only in 2030, at 1.2% of total aviation fuel, and reaches 35% by 2050. In 2025, HEFA and other established SAF pathways carry the full compliance load.
So 2025 is not primarily a test of whether e-SAF is market-ready. It tests whether the established HEFA chain can coordinate European-scale logistics for a modest blending obligation. H1 2026 data indicate that some airports can do this, while many still cannot.
Sources of Reported Volumes
The clearest pattern in the available data is SAF supply concentrated at a few major hubs. Suppliers holding pre-negotiated HEFA offtake contracts were prepared to deliver in 2025 at Amsterdam Schiphol, Frankfurt, and Paris Charles de Gaulle. H1 supply disclosures put blending at or close to the 2% floor at those airports.
Most of the HEFA feedstock was used cooking oil, supplemented by a smaller share of animal fats. Its geographic source was mainly Southeast Asia and North America, where collection and rendering systems, as well as HEFA plants, already operate. Much of the route into European airports was therefore established before ReFuelEU began.
At tier-2 EU airports, including several in Poland, Romania, and the Baltic states, supply was much thinner. Multiple airports serving between 1 million and 5 million passengers annually reported almost no SAF blending in H1 2025. Smaller regional distributors typically supply these airports and had no HEFA contracts when the compliance year began.
The Book-and-Claim Reporting Gap
Book-and-claim is expected to cover a substantial portion of compliance at non-hub airports. Under ReFuelEU, physical SAF supplied at one EU airport creates tradeable certificates that an airline operating elsewhere can claim. That certificate can satisfy the airline's obligation even when its airport uses 100% conventional jet fuel.
Book-and-claim is lawful and expressly allowed. Its purpose is to place physical SAF where delivery is most efficient while spreading the compliance benefit across the network. The result is a reporting gap: total physical SAF in the supply chain is below the level implied by total compliance claims.
We are not saying book-and-claim is the wrong mechanism; we are saying it is likely the only practical near-term route to consistent compliance across European aviation. Compliance percentages and physical blending rates at individual airports measure different things, and treating them as identical exaggerates SAF's physical reach.
What the Gap Reveals About the 2030 Sub-Mandate
The 1.2% e-fuel sub-mandate for 2030 may sound small. With EU aviation fuel consumption at approximately 45 million tonnes per year, it equates to roughly 540,000 tonnes of e-SAF each year. European e-SAF capacity across pilot and early-commercial facilities remains in the low tens of thousands of tonnes per year, leaving a substantial gap.
Reaching the 2030 sub-mandate requires certified production capacity to operate well before the deadline. ReFuelEU-qualifying e-SAF must be certified under ASTM D7566 Annex A7. Proper completion of that process requires sustained pilot operation, extensive process records, and qualification testing over a minimum of 18 to 24 months. Producers starting in late 2027 are unlikely to be ready for the 2030 market.
For our work at Metafuels, the implication is practical. We are assembling the process records and operating history needed for pathway certification. Starting earlier gives pilot data more value within the certification package.
Three Things to Watch in H2 2026
First, national competent authority reports on 2025 compliance should start appearing in Q3 2026. They will provide the first systematic cross-EU dataset and show whether hub concentration extends across the network or whether smaller airports formed supply links earlier than expected.
Second, enforcement. ReFuelEU includes financial penalties for non-compliance, but national application of those penalties has varied. With a new regulation and developing supply infrastructure, it remains uncertain how firmly year-one shortfalls will be pursued. That enforcement signal will affect investment decisions by fuel producers and logistics providers.
Third, e-SAF projects awarded EU Innovation Fund support in 2024 are nearing their first operational milestones. Their scale-up path will influence supply in 2028 and beyond. Early operating results should also clarify the cost of commercially viable e-SAF production under European conditions.
The first ReFuelEU compliance year is calibrating the SAF supply chain. Hub concentration and book-and-claim use show where physical infrastructure is missing, rather than indicating regulatory failure. For a producer starting certification today, the 2030 sub-mandate math means certified capacity work must already be underway.