ReFuelEU: Europe's new anti-tankering rules explained

Key Points

There are new anti-tankering rules from 1st Jan 2025 that heavily restricted large commercial operators from tankering fuel into or within Europe.
There are also complex reporting obligations for these operators to prove they are not breaking the rules.

There’s a newish thing in Europe called ReFuelEU, and it looks like it’s going to be a real headache for operators.

Effective this month, the new rules say that all large commercial operators (those doing 500+ flights from EU airports each year) must uplift at least 90% of their required annual fuel from that specific airport.

This part of the new rules is totally wild! So over the course of a calendar year, operators must ensure that, on average, 90% of the fuel required for flights departing from a specific EU airport is uplifted at that airport. The reporting is done annually, so it’s about maintaining compliance as a yearly average rather than for each individual flight.

These rules applies to ALL operators – both EU-based and non-EU-based. Private flights and all non-commercial operations are exempt.

This whole ReFuelEU thing is being run by the EU. They claim it’s part of the general push to “make things more green” – come on guys, think about your emissions, come on guys, use more SAF; come on guys, stop tankering so much fuel around! GGGUUUYYYSSS!!

Maybe. Or maybe these anti-tankering rules are actually more to do with the EU getting fed up with big airlines blazing into Europe with their tanks still half-full of the cheap fuel they brought from “home”. European airports, unable to sell as much of their expensive fuel, have been missing out.

But remember – the rules apply to intra-EU flights as well! So it’s not just the likes all those Middle East to Europe flights that are affected. For example, a flight from Bulgaria (cheap fuel) to Germany (expensive fuel) will not be allowed to tanker either.

Politics aside, these new rules are going to be disproportionately tough on bizjet operators with unscheduled, last-minute flights. Whilst one could claim this whole thing might make some sense for airlines, it will make planning extremely tricky for other large non-scheduled commercial operators who don’t necessarily know what they’ll be doing next week, let alone across the entire year! Also, there’s really not so much value on the “make things more green” front either. 777s, A380s and A380s often tanker tonnes of fuel; Citations, Falcons and Gulfstreams – not so much. Then there’s the added complexities with reporting, reduced fuel flexibility, and even potential safety risks if operators start running tighter fuel margins.

Reporting rules for operators

Welcome to hell. We’re not going to dive deep down into this basket of snakes here, but just to give a rough outline of what operators have to do…

1. Prepare an annual report.

This should include:

The yearly aviation fuel required (trip and taxi fuel for all flights departing from a given EU airport).
The yearly aviation fuel uplifted at that airport.
Any fuel shortfalls below the 90% requirement, with justifications (e.g., safety or other exemptions).

2. Pay to get the report verified.

The verifier will ensure the report is accurate, complete, and compliant with the rules. They will review the operator’s data, including:

Fuel uplift records.
Supporting docs (e.g. flight logs, fuel invoices, operational flight plans) to justify fuel usage, especially for exemptions.
Justifications for exemptions (if applicable). If operators want an exemption, they have to justify it with detailed reasons (e.g. safety concerns, operational difficulties) and provide evidence to the authorities.

Any discrepancies or missing data must be resolved before the report is finalized.

3. Submit the report.

After verification, the report has to be submitted to the competent authority of the Member State responsible for the operator, as well as the European Union Aviation Safety Agency (EASA).
The report must follow a specific format (specified in Annex II). This includes tables and fields for annual aviation fuel required, fuel uplifted, and justifications for exemptions.

Key dates for reporting.

The reporting period is the calendar year, from January 1 to December 31. So the key dates for this are as follows:

January 1 – December 31: Reporting period.
January – March: Verification by an independent verifier.
March 31: Submission deadline to competent authorities and EASA.

What airports in the EU are impacted?

Not all of them!

The rules apply to “Union Airports” that meet certain thresholds – mainly those where pax traffic exceeds 800,000 passengers annually. Smaller airports that do not meet these thresholds are excluded to avoid placing “undue operational and financial burdens” on them.

Also, airports in “Outermost Regions” (e.g. the Azores, Madeira, Canary Islands, and French overseas territories) are generally excluded too, due to their geographic and logistical challenges. These airports can opt-in to the rules if they like though.

The EU publishes an annual list of airports that fall under the scope of these rules. You can access it here.

Other concerns for Business Aviation

Business Aviation’s dynamic and diverse operations require more flexibility than what the anti-tankering rule allows. The European Business Aviation Association are currently working on presenting some of the issues to the EU. But ultimately, there are three big issues:

Lack of flexibility. Business aviation’s dynamic and diverse operations require more flexibility than what the anti-tankering rule allows.
Administrative Burden. Reporting requirements, including detailed fuel data, create significant workload and could divert resources away from safety-critical tasks.
Safety Risks. Increased risks include in-flight fuel emergencies, crew fatigue, missed ATC slots, fueling-related hazards, and more. There are also concerns about compromised fuel quality and strained infrastructure due to increased refueling requirements.

For more info on all this, check the ReFuelEU website. It includes the list of airports affected, plus the official rules in full (Article 5) – check the docs at the bottom of the webpage.

ReFuelEU: Europe’s new anti-tankering rules explained