Bundesverband der Deutschen Luftverkehrswirtschaft - BDL e.V.

The objectives of the Packaging and Packaging Waste Regulation (PPWR) cannot be achieved by the requirements of the PPWR in an international aviation environment due to many specificities. PPWR therefore need to be harmonised with aeronautical-specific rules. This applies in particular to the requirements of ICAO, EASA, aviation security law (e.g.

Filed in German · English published by the European Commission

The German aviation industry as one of the hard-to-decarbonise-sectors is committed to the EU climate goal of greenhouse gas neutrality by 2050. The German Aviation Association very much welcomes the initiative to revise the RED II earlier. In order to be able to fly carbon-neutral, fossil fuels must be replaced by Sustainable Aviation Fuels (SAF).

Statement by the German Aviation Association (BDL) on the public consultation on The EU emissions trading system for maritime, aviation, and stationary installations, and market stability reserve – review 8. July 2025 We support the EU Emissions Trading System (EU ETS) as a key climate protection instrument of the European Union.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The revised EU-CO2 pricing will lead to carbon leakage to third countries: production could be located outside the EU and replaced by imports with a higher CO2 footprint. CBAM could turn the table: Instead of reducing emissions inside the EU by ETS, CBAM proposes to impose certificates on the price level of the EU-ETS for imports from third countries with a CO2 emission imbalance.

We consider emissions trading as a market-based measure to limit and reduce CO2 emissions and to price CO2 in aviation to be the most appropriate solution. The inclusion of global aviation in the EU ETS could not be achieved in the international community, so EU-ETS is limited to intra-EU flights. This means that EU ETS distorts competition with regard to transfer traffic.

The German aviation industry supports the EU-goal of climate neutrality by 2050. CO2 emission pricing plays a pivotal role along with other measures such as increasing the fuel efficiency by exchanging old aircraft with new aircraft. Alone fleet renewal reduced the emissions per passenger by 44% since 1990.

Achieving the 70 % SAF blending requirement in the ReFuelEU Regulation in 2050 requires the creation of significant production capacities for both biogenic SAFs and electricity-based SAFs in the EU. This is not least necessary to maintain the EU’s technological leadership and limit dependence on imports. The market upscaling for SAF is currently delayed and calls into question the accessibility of the quotas set.

Filed in German · English published by the European Commission

Aviation connects people, cultures and economies, is essential for trade, is essential for tourism value creation, affordable mobility, regional development, international accessibility, and thus ensures cohesion between peoples and states.

Filed in German · English published by the European Commission

Replacing fossil kerosene with SAF is the decisive lever to achieve the goal of CO2-neutral flying. A binding blending quota can help accelerate the market ramp-up of SAF/PtL, therefore the aviation industry welcomes the Commission’s approach as a boost for the SAF market. The ecologically best solution are fuels that are produced from atmospheric CO2, which is why the sub-quota for PtL is rated positively.

Position of the German Aviation Association (Bundesverband der Deutschen Luftverkehrswirtschaft | BDL) The German Aviation Association very much welcomes the initiative “ReFuelEU Aviation – Sustainable Aviation Fuels” of the European Commission.

The BDL supports the objective of presenting transport services in a transparent and comparable manner by standardising the methodology and the use of generally binding emission factors to calculate emissions of transport services. In particular, the following elements are to be welcomed in the draft: —The application of the internationally recognised standard (EN ISO 14083:2023) as a basis for the Regulation.

Filed in German · English published by the European Commission

In order to achieve the ambitious goal of CO2-neutral aviation by 2050, the companies of the German aviation industry presented a joint ‘Master Plan Climate Protection in Aviation’ in 2020. The German airlines, airports and air traffic control have committed themselves to seven fields of action, which are actively pursued: •Renew fleets by deploying lower-emission aircraft •Replace fossil kerosene with sustainable…

Filed in German · English published by the European Commission

BDL believes that Regulation 1008/2008 has worked quite well and sees no urgent need for a revision of the Regulation. Instead, European Commission should prioritize promoting the competitiveness of EU aviation.

BDL believes that Regulation 1008/2008 has worked well and sees no urgent need for a revision of the Regulation. Instead, the European Commission should prioritize promoting the competitiveness of EU aviation. In case the European Commission moves ahead with a revision a few elements should be considered: 1.

Feedback German Aviation Association Directive on the revision of the EU ETS in aviation The European Emission Trading System (ETS) is a market-based system to reliably reduce CO2 emissions. The aviation sector is included in the ETS since 2012. The BDL assesses ETS as a very effective climate protection instrument and therefore we are highly welcoming the revision of EU ETS.

The German aviation industry is committed to the EU climate goal of greenhouse gas neutrality by 2050. We welcome the EU's support for the UN aviation organization ICAO in designing the climate protection and CO2 pricing instrument CORSIA. The ICAO has thus fulfilled its responsibility to include CO2 pricing in the emissions of international flights (i.e. including flights between two EEA member states).

Generally, we welcome the revision of Regulatiob 1008/2008. 1. If the revision should consider the objectives of the "Fit for 55" package, it must include a framework for effective climate protection that eliminates carbon leakage and distortions of competition, esp. towards non-EU airlines and airports.