{"id":26722,"date":"2026-01-04T00:00:18","date_gmt":"2026-01-04T05:00:18","guid":{"rendered":"https:\/\/ops.group\/blog\/?p=26722"},"modified":"2026-01-14T07:36:19","modified_gmt":"2026-01-14T12:36:19","slug":"refueleu-europes-new-anti-tankering-rules-explained","status":"publish","type":"post","link":"https:\/\/ops.group\/blog\/refueleu-europes-new-anti-tankering-rules-explained\/","title":{"rendered":"ReFuelEU: Europe&#8217;s new anti-tankering rules explained"},"content":{"rendered":"<h6>Jan 2026 update:<\/h6>\n<p class=\"p1\"><strong>ReFuelEU Aviation now also applies at LSZH\/Zurich and LSGG\/Geneva.<\/strong> Switzerland isn\u2019t in the EU, but it has chosen to adopt the rules, which means both airports are treated just like Union airports. The <a href=\"https:\/\/transport.ec.europa.eu\/document\/download\/35a047a8-ee61-48e3-a61e-8ae93a2a1943_en?filename=ReFuelEU_list_airports_2026_reporting.pdf\" target=\"_blank\" rel=\"noopener\">official list<\/a> is attached if you want to double-check. It does look like the Swiss ICAO codes are wrong, but it\u2019s just a typo. Zurich and Geneva are clearly intended and this should be fixed in a future update.<\/p>\n<h6>Jan 2025 update:<\/h6>\n<ul>\n<li><strong>New anti-tankering rules came into force on Jan 1 2025, heavily restricting large commercial operators from tankering fuel into or within Europe.<\/strong><\/li>\n<li><strong>The first annual reporting deadline fell in March 2025, marking the first real compliance test for operators.<\/strong><\/li>\n<\/ul>\n<p>There\u2019s a still relatively new framework in Europe called <a href=\"https:\/\/transport.ec.europa.eu\/transport-modes\/air\/environment\/refueleu-aviation_en\" target=\"_blank\" rel=\"noopener\">ReFuelEU<\/a>, and it looks like it\u2019s going to be a real headache for operators.<\/p>\n<p>Since January 2025, <strong>the rules have applied to all large commercial operators<\/strong>\u00a0(those doing 500+ flights from EU airports each year). 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. <strong>The reporting is done annually, so it\u2019s about maintaining compliance as a yearly average rather than for each individual flight.<\/strong><\/p>\n<p>These rules applies to <strong>all commercial operators<\/strong> &#8211; both EU-based and non-EU-based. Private flights and all non-commercial operations are exempt.<\/p>\n<p>This whole ReFuelEU thing is being run by the EU. They claim it&#8217;s part of the general push to <strong>&#8220;make things more green&#8221;<\/strong>. Maybe. Or maybe these anti-tankering rules are actually more to do with the <strong>EU getting fed up with big airlines blazing into Europe with their tanks still half-full<\/strong> of the cheap fuel they brought from &#8220;home&#8221;. European airports, unable to sell as much of their expensive fuel, have been missing out.<\/p>\n<p><strong>But remember &#8211; the rules apply to intra-EU flights as well!<\/strong> So it&#8217;s not just 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.<\/p>\n<p>Politics aside, these new rules are going to be <strong>disproportionately tough on bizjet operators <\/strong>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&#8217;t necessarily know what they&#8217;ll be doing next week, let alone across the entire year! Also, there&#8217;s really not so much value on the &#8220;make things more green&#8221; front either. 777s, A380s and A380s often tanker tonnes of fuel; Citations, Falcons and Gulfstreams &#8211; not so much. Then there&#8217;s the added complexities with reporting, reduced fuel flexibility, and even potential safety risks if operators start running tighter fuel margins.<\/p>\n<h4>Reporting rules for operators<\/h4>\n<p>Welcome to hell. We&#8217;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&#8230;<\/p>\n<p><strong>1. Prepare an annual report.\u00a0<\/strong><\/p>\n<p>This should include:<\/p>\n<ul>\n<li>The yearly aviation fuel required (trip and taxi fuel for all flights departing from a given EU airport).<\/li>\n<li>The yearly aviation fuel uplifted at that airport.<\/li>\n<li>Any fuel shortfalls below the 90% requirement, with justifications (e.g., safety or other exemptions).<\/li>\n<\/ul>\n<p><strong>2. Pay to get the report verified.<\/strong><\/p>\n<p>The verifier will ensure the report is accurate, complete, and compliant with the rules. They will review the operator\u2019s data, including:<\/p>\n<ul>\n<li>Fuel uplift records.<\/li>\n<li>Supporting docs (e.g. flight logs, fuel invoices, operational flight plans) to justify fuel usage, especially for exemptions.<\/li>\n<li>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.<\/li>\n<\/ul>\n<p>Any discrepancies or missing data must be resolved before the report is finalized.<\/p>\n<p><strong>3. Submit the report.<\/strong><\/p>\n<ul>\n<li>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).<\/li>\n<li>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.<\/li>\n<\/ul>\n<h4>Key dates for reporting.<\/h4>\n<p>The reporting period is the calendar year, from January 1 to December 31. So the key dates for this are as follows:<\/p>\n<ul>\n<li><strong>January 1 &#8211; December 31:<\/strong> Reporting period.<\/li>\n<li><strong>(following year) January &#8211; March:<\/strong> Verification by an independent verifier, with March 31 submission deadline to competent authorities and EASA.<\/li>\n<\/ul>\n<p>The first annual report was due by March 31 2025, covering the reporting period from Jan 1 to Dec 31 2024.<\/p>\n<h4>What airports in the EU are impacted?<\/h4>\n<p>Not all of them!<\/p>\n<p>The rules apply to &#8220;Union Airports&#8221; that meet certain thresholds &#8211; mainly <strong>those where pax traffic exceeds 800,000 passengers annually.<\/strong> Smaller airports that do not meet these thresholds are excluded to avoid placing &#8220;undue operational and financial burdens&#8221; on them.<\/p>\n<p>Also, airports in\u00a0<strong>&#8220;Outermost Regions&#8221;<\/strong> (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.<\/p>\n<p>The EU publishes and updates an<strong> annual list of airports<\/strong> that fall under the scope of these rules. You can access it <a href=\"https:\/\/transport.ec.europa.eu\/transport-modes\/air\/environment\/refueleu-aviation_en\" target=\"_blank\" rel=\"noopener\">here.<\/a><\/p>\n<h4>Other concerns for Business Aviation<\/h4>\n<p><strong>The European Business Aviation Association (EBAA)<\/strong> are currently working on presenting some of the issues to the EU. But ultimately, they highlight <strong>three big issues:<\/strong><\/p>\n<ol>\n<li><strong>Lack of flexibility.<\/strong> Business aviation\u2019s dynamic and diverse operations require more flexibility than what the anti-tankering rule allows.<\/li>\n<li><strong>Administrative Burden.<\/strong> Reporting requirements, including detailed fuel data, create significant workload and could divert resources away from safety-critical tasks.<\/li>\n<li><strong>Safety Risks.<\/strong>\u00a0Increased 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.<\/li>\n<\/ol>\n<hr \/>\n<p><strong>For more info on all this, check the <a href=\"https:\/\/transport.ec.europa.eu\/transport-modes\/air\/environment\/refueleu-aviation_en\" target=\"_blank\" rel=\"noopener\">ReFuelEU website<\/a>.<\/strong> It includes the list of airports affected, plus the official rules in full (Article 5) &#8211; check the docs at the bottom of the webpage.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>Jan 2026 update: ReFuelEU Aviation now also applies at LSZH\/Zurich and LSGG\/Geneva. Switzerland isn\u2019t in&#8230;<\/p>\n","protected":false},"author":32,"featured_media":26727,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[3],"tags":[332,2280],"class_list":{"0":"post-26722","1":"post","2":"type-post","3":"status-publish","4":"format-standard","5":"has-post-thumbnail","7":"category-briefings","8":"tag-eu","9":"tag-refueleu"},"_links":{"self":[{"href":"https:\/\/ops.group\/blog\/wp-json\/wp\/v2\/posts\/26722","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/ops.group\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/ops.group\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/ops.group\/blog\/wp-json\/wp\/v2\/users\/32"}],"replies":[{"embeddable":true,"href":"https:\/\/ops.group\/blog\/wp-json\/wp\/v2\/comments?post=26722"}],"version-history":[{"count":15,"href":"https:\/\/ops.group\/blog\/wp-json\/wp\/v2\/posts\/26722\/revisions"}],"predecessor-version":[{"id":29454,"href":"https:\/\/ops.group\/blog\/wp-json\/wp\/v2\/posts\/26722\/revisions\/29454"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/ops.group\/blog\/wp-json\/wp\/v2\/media\/26727"}],"wp:attachment":[{"href":"https:\/\/ops.group\/blog\/wp-json\/wp\/v2\/media?parent=26722"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/ops.group\/blog\/wp-json\/wp\/v2\/categories?post=26722"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/ops.group\/blog\/wp-json\/wp\/v2\/tags?post=26722"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}