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A4E’S Position on the European Green Deal

By  Brussels, — Last updated on 8 December 2023


Guided by the ambitions of the European Green Deal in ensuring that transport makes its important contribution to climate neutrality by 2050, the European Commission has expressed its desire to put forward a Strategy on Sustainable and Smart Mobility later this year.

This paper sets out A4E’s views of the European Commission Green Deal proposals and sets initial guidance on how European airlines suggest to approach the shift towards a European air transport that is fit for a clean, digital and modern economy.


European Commission President Ursula von der Leyen presented in December 2019 the European Green Deal,The European Green Deal, European Commission Communication, Brussels, 11.12.2019 COM(2019) 640 a plan to make Europe the first climate-neutral continent by 2050. The Green Deal is an impressive step towards a more holistic and integrated approach to addressing climate and environment-related challenges. It also attempts to mainstream environmental policy by bringing together — and improving, several existing policies, initiatives, and programmes dedicated to addressing resource efficiency, sustainability and climate change. In addition, it includes a variety of new proposals, some of which are very ambitious — such as the proposed changes to the provisions of the Treaty in the field of energy taxation, or the introduction of measures to prevent carbon leakage. The Green Deal has the potential of being transformative and will certainly create many debates.

The Green Deal calls for an integrated approach to sustainability. This means taking into account market realities to make the decarbonisation shift possible in a way that also improves the efficiency of Europe’s air transport network, enhances EU competitiveness and increases growth.

With an aim to transform the EU into a fair and prosperous society, one with a modern, resource-efficient and competitive economy whose growth is decoupled from its use of resources —, the Green Deal foresees that climate neutrality is only achievable through a significant reduction in all transport emissions by 2050.

What does the Green Deal mean for European airlines?

European airlines are closely exploring potential pathways towards a net-zero, or low-carbon European air transport through reduction of CO2 emissions in absolute terms and CO2 mitigation (offsets or market-based measures). It is crucial to recognise the magnitude and the urgency of the commitment adopted by the European Commission. Airlines know the importance of not failing in turning this pledge into a future reality.

Carrying more than 720 million passengers each year and operating around 3000 aircraft, A4E airlines are ready and willing to contribute to making the European Green Deal a success. Over the next 10 years, European airlines will invest €169 billion in greener aircraft technologies which are on average 25% cleaner and less noisy than their predecessors. The breadth of knowledge, best practices, track record in efficiency and especially the competencies that Europe’s aviation sector holds are valuable tools in reaching these

ambitious goals. Air transport is a prerequisite for achieving many UN Sustainable Development Goals.The United Nations, 2016, Mobilising Sustainable Transport for Development see here It represents the right to access essential human needs: jobs, markets and goods, social interaction, education and other services. Improved access helps address general concerns such as socio-economic cohesion throughout the EU or the depopulation of rural areas.

Essential policy suggestions put forward by the Green Deal

In this respect, the Green Deal is mainstreaming sustainability in all EU policies by putting forward essential policy suggestions in order to tackle climate change, an approach which A4E commends:

  • A swift updating of the Single European Sky Regulation. 
    (+) Europe’s single aviation market remains incomplete and in need of reform. A digital and seamless European Sky and a fully implemented Single European Sky regulatory framework are key to reducing aviation’s carbon footprint, both for passenger transport and air cargo alike. In particular, improving Europe’s airspace architecture, adapting airspace design to traffic flows and implementing new forms of operations based on digital and smart technologies could lead to an up to 10% reduction in CO2 emissions. This initiative would reduce CO2 emissions in Europe by 18 million tonnes per year.
  • Legislative options to boost the production and uptake of sustainable aviation fuels (SAFs).
    (+) In 2012, the EU defined a target of two million tons of SAFs produced in Europe by 2020. Yet, eight years later, production is significantly behind schedule. Well-designed 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). A dedicated EU industrial policy for the deployment of innovative aviation fuels through financing and legislation is urgently needed.Link to A4E’s position paper on sustainable aviation fuels and recommendations for a revised long-term policy framework to create realistic ROI possibilities:
  • Full implementation of the United Nation’s global aviation climate protection system, CORSIACORSIA — Carbon Offsetting and Reduction Scheme for International Aviation. 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. This system will offset growth-related emissions from global air traffic and makes international air traffic growth CO2-neutral. whilst contributing to efforts to develop more ambitious long-term goals at the International Civil Aviation Organisation (ICAO) level.
    (+) Due to the international nature of air traffic, only globally coordinated measures are effective. The EU must step up its climate diplomacy efforts to ensure a full implementation of CORSIA and work to ensure more reluctant countries such as China, Russia, India and Brazil join the CORSIA system by 2021.
  • Investment and support for future innovations that generate actual reductions in emissions. 
    (+) More EU support is needed for research, development and innovation plans including electric and hybrid engine technologies, which would reduce airlines’ dependency on fossil fuels and be essential in developing a green aviation industry of the future. Structural funds, the new Multiannual Financial Framework (MFF) and programmes such as the Emissions Trading System (ETS) Innovation Fund, but also the future research and innovation “Partnerships” with industry and Member States, should be aligned to boost the sector’s decarbonisation transformation. Supportive policies should reduce time to market for those technical solutions to take hold and ensure a positive impact in society.

The Green Deal also includes new proposals, by suggesting to:

  • Set into law a carbon-neutrality objective by 2050, possibly also revising the EU’s current 2030 carbon reduction targets.
    (-) European airlines are closely exploring potential pathways towards a decarbonised air transport. The challenge is daunting, and the effort will be enormous. How airlines respond will be closely linked to the reform of the continent’s airspace, the availability of innovative solutions (SAFs, future aircrafts and engines) and future economic policies
  • Revise the Energy Taxation Directive to assess, notably, the current taxation regime of aviation fuel.
    (-) Industry is convinced that climate policy regulations through national taxes, levies or bans are ecologically and economically counterproductive. Imposing taxes without reinvesting their revenues in de-carbonization projects does not help effectively lower CO2 emissions from flying, as the only thing it achieves is hampering connectivity for passengers in peripheral and insular regions. Taxes divert the industry’s capacity to invest and innovate in a crucial moment where research and development in low carbon technologies should be supported while shifting CO2 emissions to other regions. Any review should therefore consider positive incentives for the production and deployment of innovative fuels instead of new forms of taxation.
  • Reform the European Emissions Trading Scheme (ETS) for aviation.
    (-) The market-based EU ETS is the most appropriate solution to limit and reduce CO2 emissions and to price CO2. Aviation is part of the ETS since 2012 and over that period, the net reduction in aviation-related emissions reached 193.4 Mt of CO2 emissions.European Aviation Environmental Report, 2019 In 2018, European airlines have purchased CO2 certificates for more than 58 % of their emissions for a value of €450 million. The future of the EU’s flagship scheme will need to avoid regulatory overlaps among both EU and global market-based measures (CORSIA) and prevent potential double-burdens for airlines paying for the same emissions from 2021 onwards.
  • Propose a carbon border adjustment mechanism, for selected sectors, to reduce the risk of carbon leakage.
    (-) Regional climate solutions risk shifting CO2 at the expense of the respective domestic industry. Aviation is a global economic activity and air traffic is international. Global solutions are the most effective in terms of climate and environmental policy. While CORSIA as a global instrument has no negative competitive effect, the EU ETS hinders EU airlines’ global competitiveness. The drafting of regional climate measures should therefore avoid creating competitive disadvantages and market distortions at an international level.


In order to achieve the Green Deal’s ambitions, it will be essential to focus on demand-driven solutions, placing the passenger at the center and not foregoing the social impact of climate policies. This shift is within reach if done in close coordination between industry and policymakers, in a way that improves the efficiency of Europe’s air transport network as a whole, enhancing EU competitiveness and increasing growth.

A4E members want to be part of the Green Deal solution. It is a challenge we face head-on, and one we will only achieve through integrated, cross-sector efforts across policy fields: transport, climate, energy and research. Airlines’ efforts to minimise fuel and energy consumption will increase in the next decade, in order to limit greenhouse gas emissions and pollutants affecting air quality.

It is clear that the drive towards a decarbonization of Europe’s aviation sector will only accelerate, with the objective of making the continent’s skies the most efficient and environmentally friendly in the world. As an industry, we have a special responsibility to contribute to this transition, whilst also better communicating our ambitions and our efforts to both passengers and policy makers alike. The solution is not to fly less, but to fly more efficiently and more sustainably. A4E airlines look forward to this future.


  • The starting point of European environmental policy applied to aviation should be to improve the efficiency of the air transport network as a whole.
  • The creation of a competitive European single market for aviation should remain a top political priority.
  • Ambitious climate targets pose major challenges to air transport. Preconditions for achieving more sustainability include support for industry-led initiatives and technological solutions, in addition to avoiding a diversion of airlines’ investment capacities.
  • The international dimension of aviation policy is more important than ever. This applies to the risks of a double burden for European carriers and to the competitive distortion effect of certain regional policies.