By 2035, every flight departing a European airport must carry at least 20% sustainable aviation fuel — including a mandatory 5% Power-to-Liquid e-SAF sub-target. Today's global SAF production covers barely 0.5% of aviation's fuel needs. The gap is enormous. The clock is running.
See the 2035 roadmap →ReFuelEU Aviation sets legally binding SAF blending targets for all flights departing EU airports. The targets tighten progressively — with specific sub-mandates for Power-to-Liquid e-SAF beginning in 2030. Missing the targets triggers financial penalties for fuel suppliers.
EU-departing flights consume approximately 50–55 million tonnes of kerosene per year. A 20% SAF mandate in 2035 requires roughly 10–11 million tonnes of SAF for EU airports alone.
Of this, the 5% PtL sub-mandate requires approximately 2.5–3 million tonnes of PtL e-SAF specifically — fuel that must be produced by Power-to-Liquid, not by any other SAF pathway.
Today's global PtL e-SAF production capacity is estimated at less than 50,000 tonnes per year. The gap to 2035 is a factor of 50–60× in just nine years. A typical large PtL plant takes 5–8 years from investment decision to first production. Investment decisions needed to meet 2035 must be made by 2027 at the latest.
Fuel suppliers that fail to deliver the mandated SAF quantities at EU airports face financial penalties calculated as the difference between the cost of SAF and the cost of conventional kerosene, multiplied by the missing volume — plus a multiplier of 2.
This penalty structure means that the cost of non-compliance will exceed the cost of SAF procurement in most scenarios from 2030 onwards. Airlines are already locking in long-term SAF offtake agreements to guarantee supply ahead of mandates — and in doing so, providing the revenue certainty that new PtL plant developers need to reach financial close.
CORSIA (the ICAO global carbon offset scheme for international aviation, mandatory from 2027) adds a parallel incentive: SAF generates CORSIA credits at a premium to carbon offsets, rewarding early movers with a competitive cost advantage.
Meeting the 2035 mandate depends on three variables: the pace of PtL plant investment decisions, the cost trajectory of green and natural hydrogen, and the speed of the regulatory and permitting environment. Three scenarios are plausible.
The 2035 mandate is not in question — it is law. What is uncertain is whether the supply of Power-to-Liquid e-SAF will be sufficient to meet it. The answer depends almost entirely on hydrogen feedstock cost. Natural geological hydrogen from Lorraine could make the difference between the base and accelerated scenarios.
jetfuel2035.com · Editorial analysis · July 2026The cost of e-SAF is dominated by the hydrogen feedstock — roughly 55% of total production cost. Everything else is secondary. The difference between the accelerated and delayed scenarios for 2035 is essentially a question of hydrogen cost.
| H₂ feedstock scenario | H₂ cost | E-SAF cost (PtL) | vs Jet-A1 + €70/t CO₂ | 2035 mandate economics |
|---|---|---|---|---|
| Green H₂ today | €3–6/kg | ~€2.50–3.50/L | ×3–4 premium | Mandate needs penalties to work |
| Green H₂ 2030 target | €1.50–2/kg | ~€1.80–2.20/L | ×2–2.5 premium | Mandate partially viable |
| Natural H₂ (Lorraine 2028) | €0.50/kg | ~€1.10–1.30/L | ~1.1–1.3× premium | Commercially viable · mandate exceeded |
All costs indicative · vary by site, scale and electricity price · FDE €0.50/kg is a declared production target, not a confirmed commercial price · consult official sources
The numbers are stark. EU-departing aviation consumes roughly 50–55 million tonnes of kerosene per year. A 20% SAF mandate in 2035 means approximately 10–11 million tonnes of SAF must be available and delivered at EU airports that year.
Of that, the 5% PtL sub-mandate requires ~2.5–3 million tonnes of e-SAF produced specifically by Power-to-Liquid — not HEFA, not ATJ. Estimated global PtL e-SAF production capacity in 2025: less than 50,000 tonnes. The gap is a factor of 50–60× in nine years.
A large PtL plant producing 100,000 tonnes per year requires roughly €1–2 billion in capital investment and 5–8 years from investment decision to operation. To meet the 2035 mandate, approximately 25–30 plants of this scale need to be in operation by 2035 — most of which do not exist today even as announced projects.
The HEFA pathway (used cooking oil, animal fat) is expected to contribute the bulk of the 20% SAF mandate — but it faces a hard ceiling. The global supply of waste cooking oil and animal fats is finite and is already contested between aviation, road transport biofuels and industrial uses. HEFA cannot physically scale to meet more than ~5–7% of aviation's needs.
This means the gap between 7% and 20% — and all of the PtL sub-mandate — must come from Power-to-Liquid. There is no other certified SAF pathway with the scale potential to fill it.
The implication is unambiguous: the aviation industry's ability to comply with ReFuelEU in 2035 depends almost entirely on the speed of PtL plant construction between now and 2032, and on the cost of hydrogen feedstock — particularly the potential availability of natural geological hydrogen from Lorraine and other European sites from 2028 onwards.
For information only: jetfuel2035.com is a documentary portal of a strictly informational nature. Information published comes from third-party sources not controlled by BESS Energie SRL. No guarantee of accuracy, completeness or timeliness is given.
Consult official sources before any decision: ReFuelEU Aviation official text (eur-lex.europa.eu), ICAO CORSIA (icao.int), IATA (iata.org), IEA (iea.org), IRENA (irena.org), FDE/REGALOR II (fde-corp.com), company investor relations and official press releases.
Scenarios are illustrative: The three scenarios presented are editorial analyses based on publicly available information and do not constitute forecasts, projections or recommendations. Actual outcomes will differ materially.
Not investment advice: Nothing here constitutes financial, legal, commercial or investment advice. BESS Energie SRL accepts no liability for errors, omissions or inaccuracies.
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