CLECAT has submitted comprehensive comments to the European Commission in response to the targeted consultation supporting the study on a possible EU “book & claim” system for Sustainable Aviation Fuels (SAF).
In its contribution, CLECAT stressed that freight forwarders are already engaging in voluntary book & claim arrangements to facilitate SAF uptake and to meet increasing customer demand for lower-emission air cargo solutions. However, under the current EU regulatory framework, these voluntary initiatives remain disconnected from compliance mechanisms under ReFuelEU Aviation and recognition under the EU ETS, as well as from the traceability provisions under the Renewable Energy Directive (RED III). This misalignment creates legal and operational uncertainty across the SAF value chain.
CLECAT argued that a properly regulated EU-level book & claim system, embedded in the Union Database for Biofuels, could significantly improve market functioning. By allowing environmental attributes to be allocated independently of the physical location of fuel uplift, such a system would broaden access to SAF across routes and carriers, reduce distortive effects linked to local supply concentration, and enhance transparency in the allocation of SAF volumes and associated surcharges. For freight forwarders in particular, this is crucial in the context of Scope 3 emissions reporting, where credible and verifiable emissions-reduction claims are increasingly required by customers. (....)