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A4E’s Position on Sustainability and the Environment



With this paper Airlines for Europe A4E sets out its approach for an environmentally sustainable European aviation community. A4E is committed to support the drive towards zero and low-carbon air transport in Europe. Specific positions on international and European market-based measures complement the priorities outlined in this paper.


A4E airlines are committed to address the climate challenge that faces all of mankind, minimise their environmental impact and contribute to efforts to move towards a sustainable European economy.

EU transport policy can be linked to the sustainability agenda, by integrating social and environmental goals in an appropriate and balanced way, based on the economic sustainability of the air transport sector. In many ways the transport sector is a prerequisite for achieving many Sustainable Development Goals.The United Nations, 2016, Mobilising Sustainable Transport for Development Transport underlines the right to access what people need: jobs, markets and goods, social interaction, education and other services. Improved access can help address general concerns such as depopulation of rural areas or socio-economic cohesion throughout the EU.

European airlines at large stand behind the EU ambition to move towards a zero or low-carbon economy, thereby support efforts to achieve the objectives of the Paris Agreement.Although the Paris Agreement does not establish sector-specific goals for addressing potential temperature rise, the aviation sector’s 2050 goal to halve net CO2 emissions on a 2005 baseline is in line with the Paris Agreement goal to limit global temperature rise to below 2ºC above pre-industrial levels. A4E welcomes the Intergovernmental Panel on Climate Change — IPCC report on limiting the impacts of climate change to less than 2 degree temperature rise and preferably no more than a 1.5-degree temperature rise.

European airlines have made strong commitments and invest heavily to ensure that air transport supports Europe’s common environmental goals, for instance:

  • In Europe’s aviation industry, average aviation fuel consumption fell by 24% per passenger kilometre between 1990 and 2017.EASA, 2019. European Aviation Environmental Report.
  • Aviation adopted short-, medium- and long-term climate goals in 2009, the world’s first for any single industry. The medium-term goal, to achieve carbon-neutral growth from 2020 and the long-term goal, of halving net CO2 emissions from the sector by 2050, relative to 2005 levels, are particularly ambitious goals for this growing sector.

Our efforts to minimise fuel and energy consumption to limit our emissions of greenhouse gases and pollutants impacting air quality will increase in the next years. An integrated approach is needed that takes into account market realities to make this shift possible in a way that improves the efficiency of Europe’s air transport network as a whole, enhances EU competitiveness and increases growth. European airlines are closely exploring potential pathways towards a zero or low-carbon European air transport. In this respect, A4E is committed to:

  • Complete Europe’s Single Aviation market by reforming the architecture of Europe’s Air Traffic Management. Improving Europe’s airspace architecture and adapting airspace design to traffic flows, would lead to at least a 10% decline in CO2. This initiative would reduce CO2 emissions in Europe by 18 million tonnes per year.
  • Develop the right policies and investment to scale-up Sustainable Aviation Fuels (SAFs).
  • Fully implement the global aviation emissions offsetting system, CORSIA, whilst contributing to meaningful work programmes to support and develop more ambitious long-term ICAO targets.
  • Support and invest in research and development initiatives, such as electric and hybrid engine technologies to reduce dependency on fossil fuels.

Moreover, European airlines heavily invest in modern and cleaner aircraft. New, more efficient planes reduce fuel consumption, thereby decreasing CO2 emissions, whilst in the same time reducing noise impacts on local communities. On average, a new generation of aircraft is 25% cleaner and less noisy. To illustrate the significant investments that are done; the cost of one new generation aircraft that can carry 350 people is about 300 million euro.

Commitments of European aviation to decarbonise are often linked to billions of Euros in investments — yet it is not certain that these investments will be made in Europe. The right incentives must be there for players across the mobility value chains to invest by ensuring that the many pieces of legislation create tangible benefits for both consumers and producers and incentivise low-carbon solutions.

Moreover, low-carbon air transport should not be considered in isolation. Focus must also be on how other legislation can be useful to achieve its goals. For this reason, A4E participates actively in civil aviation environmental committees as well as in industry workgroups at European and national level, promoting the reduction of the aviation sector’s environmental impact. An open dialogue with different stakeholders and continuous development of operations according to the latest available information are prerequisites for environmental responsibility.


Aviation’s contribution to man-made greenhouse gas emissions is between 2 and 3% globally. However, with the growth in air traffic over the coming decades, if no action is taken, aviation’s contribution will increase as a share of Europe’s emissions. Carbon pricing puts a cost on emissions to incentivise organisations to reduce their carbon footprint. All airlines should have a cap on their emissions and if they produce more than they are allowed to, they will have to buy carbon credits. If less emissions are produced companies get credits to finance additional reduction measures.

In 2016, the International Civil Aviation Organization (ICAO) adopted a global carbon pricing instrument for international aviation (the Carbon Offsetting and Reduction Scheme for International Aviation or CORSIA). Under CORSIA, airlines are required to compensate the increase in CO2 emissions above 2020 levels covered by the scheme. It is forecast that CORSIA will mitigate over 2.5 billion tonnes of CO2 between 2020 and 2035.

CORSIA is the first global carbon pricing instrument covering an entire sector. The significance of this agreement cannot be underestimated. The agreement in ICAO was a major political achievement as the diverging views of ICAO’s 193 member states were reconciled in a single mechanism which takes into account their respective circumstances and capabilities. From 2021 already 81 countries accounting for about 76% of global traffic will implement this scheme. Overtime, it is expected that coverage of this global scheme will be further extended.

Europe’s airlines have already been paying for their emissions in Europe since 2012 via the EU Emissions Trading System (ETS). Aviation is currently the only transport sector that is part of the ETS scheme where the cost of emissions is at its highest ever, and four times today as high as it was in the middle of 2017 to reach €26 per ton of CO2.Harttree European Market Update 24. August 2018 Over this period, 100 Mt of CO2 emissions in Europe have been mitigated by Europe’s airlines. In total, the net reduction in aviation related emissions for the entire 2013–2020 phase is estimated to be 193.4 Mt of CO2 emissions.EASA, 2019. European Aviation Environmental Report.

A4E airlines will work to fully implement the global aviation emissions offsetting system, CORSIA, whilst in parallel warn against regulatory overlaps with EU measures and potential double-burden on the same emissions from 2021 onwards.

In parallel, carriers will continue to give customers information on their travel-related CO2 emissions and how to offset these. Concretely, we will increasingly develop voluntary mechanisms to mitigate the carbon impact of journeys, as well as improve existing mechanisms.


Owing to the energy-intensive nature of its operations and the resulting costs, air carriers naturally have a strong aspiration to make their operations more energy efficient, particularly by striving to reduce jet fuel consumption. A4E airlines strive to efficiently operate modern fleets to reduce the required fuel and emissions. Airlines’ measures to improve their fuel efficiency focus primarily on flights operated by the carriers themselves. Efficiency improvements of Europe’s air traffic management (ATM) such as — e.g. through harmonised and more widespread implementation of Free Route Airspace allowing airlines to fly their preferred trajectories — have also significant implications on fuel burn.

Meanwhile, research and innovation on alternatives to fossil fuels are ongoing and should be supported. In the absence of an alternative source of energy in the next years, coupled with the commitment for aviation to reduce its CO2 footprint, this reduction will have to be achieved by continuing to use kerosene but switching to a kerosene that is increasingly CO2 neutral, whilst remaining cost-competitive.

New sources of energy through sustainable aviation fuels (SAFs) produced from a variety of feedstocks — including waste by-products, non-food crops and potentially synthetic fuels present promising results. One of the major obstacles encountered for the deployment of sustainable fuels for aviation is the significant cost differential between fossil JetA-1 and Sustainable Advanced JetA-1. Sustainable Advanced JetA-1 is currently three times more expensive than standard kerosene. This can be largely explained by the lack of supply in Europe. In fact, at the moment there is no factory in Europe dedicated to the productions of SAFs for aviation. This lack of supply is driving up the price. For sustainable aviation fuel to become more cost-competitive and to support further uptake, fuel suppliers require a stronger market signal, harmonized at global level, to develop production for the aviation sector. At the same time, this new generation of fuels needs to meet strict sustainability criteria, taking into consideration the greenhouse gas (GHG) reductions and the land use change impact.

To mobilise the huge amounts of investment needs,According to the European Commission’s long-term climate strategy, investment needs for low-emission transport alone under the current energy and climate policy will amount to EUR 685 bn/year between 2021–2030, and EUR 904 bn/year between 2031–2050. European Commission, 2018. 2050 long-term strategy. financing for research, development and deployment must be improved. To this end, measures to support the development of SAFs are crucially missing and were not sufficiently considered in the 2018 Review of the Renewable Energy Directive (REDII); the remaining structural funds and the new Multiannual Financial Framework (MFF) should be leveraged; incentives could be improved under the Alternative Fuels Infrastructure Directive and infrastructure and technology solutions could be further standardised; projects with the potential to significantly contribute to aviation decarbonisation efforts, notably through the development of alternative fuels for aviation should also be supported by the ETS Innovation Fund.

To complete the integrated approach, it will be important to connect low-emission mobility ambitions to efforts in the development of a lifecycle approach, and to integrate the potential of sustainable, synthetic and advanced fuels and gases into the CO2 reduction targets.


Tackling plastic pollution and its negative impact on the environment has emerged as a major challenge for today’s economy; unfavourably affecting lands, waterways, oceans, animals and humans. A4E is fully committed to the initiative of eliminating all avoidable single-use plastics. Our airlines are working on numerous green initiatives such as recycling, fuel and waste reduction including plastics, glass, metal cans, paper and waste food.

A4E airlines are committed to the framework laid down by the new Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment. Adopting a full life-cycle approach to assess alternatives to plastics is essential, as production of the alternatives, weight and recyclability all need to be considered to measure full environmental and CO2 impact of such alternatives.

Going beyond this, A4E carriers will explore numerous green initiatives to replace plastics with environmentally more friendly alternatives where possible, such as paper packaging, wooden cutlery, bio-based plastic cups and biodegradable materials, whilst never compromising on (food) safety, security and life-cycle considerations.

Such effort will include careful assessments of the advantages and drawbacks of the phase-out from a CO2 emissions perspective.


European airlines are committed to limit the impact of aircraft noise on local environments and on health; Advances in aerodynamics and engine technology help mitigate aircraft noise.

Through investments in “next generation” aircraft and engine technologies and the implementation of operating and commercial processes, carriers will seek to minimise the noise impact of aircraft operations on local communities. Along the lines of the Balanced Approach,ICAO Doc 9829, Guidance on the Balanced Approach to Aircraft Noise Management. A4E remains committed to work on solutions to demonstrated noise issues on an individual airport-by-airport basis and subject to specified processes which include stakeholder consultation, involvement of airports and ANSPs and cost-benefit analyses.


Together with a number of airlines globally, A4E airlines committed to assist the private sector with supporting enforcement authorities in combatting the illegal wildlife trade.In particular, the United for Wildlife (UFW) Buckingham Place Declaration on the illegal trade in wildlife. See further details here: In this context, A4E airlines adopt or encourage the adoption of a zero-tolerance policy regarding illegal wildlife trade. Concretely, airlines committed to: Increase passenger, customer, client, and staff awareness about the nature, scale, and consequences of illegal wildlife trade; Promote these commitments across the entire transport sector and encourage further support; Develop a secure, harmonised system for passing information about suspected illegal wildlife trade from the transport sector to relevant customs and law enforcement authorities, where permitted by law; Notify relevant law enforcement authorities of cargoes suspected of containing illegal wildlife and their products and, where able, refuse to accept or ship such cargoes.

Circular Economy

A4E airlines are committed to deliver ecological and cost-efficient manufacturing, maintenance, operations, reuse and recycling technologies, including end-of-life procedures in line with the circular economy.


At the moment, all catering waste from outside the EU is classified as Category 1 (CAT1) Waste. CAT1 Waste is a type of waste that has been classified as potentially dangerous to animal and/or plant health, CAT1 being the highest degree of hazard on a three-level scale. This type of waste is subject to strict EU legislation, prohibiting recycling. All CAT1 Waste must be disposed of by incineration or buried in an authorised landfill. Due to regulatory responsibilities, only a fraction of all catering waste handled in 2018 has been recycled or separated due to the obligations regarding international waste, despite the aviation sector’s efforts to recycle a higher percentage of total waste.

While supporting its aims to avoid spreading diseases, A4E believes there is room for improvement and a more sensible risk-based approach for handling international catering waste from aviation. The legislation is nearly 10 years old and does not reflect the reality of increased health and food safety standards globally. It is simple: without a revision, the EU will be unable to meet its own set targets for moving towards a fully circular economy.Laid down in the EU Circular Economy Package (2018).

A4E airlines ask for a revision of Regulation (EU) 1069/2009, updating the risk assessments, to increase the percentage of waste that EU carriers can recycle and so that the aviation industry as a whole can move forward with its ambitions and expectation from passengers to become more sustainable.

Investing in a Sustainable Industry


Over the next 10 years, European airlines will invest €169 bn in greener aircraft technologies. Projects include:

airBaltic’s E-GEN enabling high-precision approaches, cutting CO2 emissions across Europe.

easyJet partnering with Wright Electric to develop an electric aircraft with the intention that it will be viable for short-haul routes in Europe by 2030.

IAG investing $400 million in sustainable fuel development over next 20 years.

KLM committing to development/purchase of 75.000 tonnes of sustainable fuel per year for the next 10 years, starting in 2022.

Lufthansa Group to become carbon-neutral for ground ops in Germany, Austria, and Switzerland by 2030.

Ryanair purchasing 200 × B737 in next five years (with a value of more than €20bn), reducing emissions by 16% per seat.