How SAF Mandates in the EU and UK Are Reshaping Aviation Fuel Markets

Key Takeaways

• Carbon credits are one of several instruments for decarbonizing cement, alongside environmental attribute certificates (EACs) and direct procurement of lower-carbon products. Each serves a different purpose, and buyers and developers should understand how they interact before engaging. 
• Article 6.4 of the Paris Agreement is becoming a reference point for public and private carbon credit procurement, so the quality of its methodologies now holds significant weight. 
• Proposed methodology A6.4-PMM010 - Partial substitution of fossil fuels by MSW in cement manufacture largely aligns with Relae and Microsoft’s Criteria for High-Quality EACs in the Concrete and Steel Sectors. However, Relae identified opportunities to strengthen provisions addressing interactions between carbon credits and environmental product declaration (EDP), where credited reductions are deducted from the product's EPD, with the aim of reducing the risk of the same mitigation being claimed more than once.

Article 6.4 Joins the Cement Decarbonization Toolkit 

Article 6.4 of the Paris Agreement is expanding the financing options for decarbonizing cement and concrete. Environmental attribute certificates (EACs) let buyers pay for lower-carbon production without taking physical delivery of the product, while carbon credit methodologies reward manufacturers for storing captured CO₂ in their products. 

Relae is actively shaping this market: conducting technical diligence for buyers of cement EACs, providing project assurance and go-to-market support for industrial decarbonization projects, and leading market development through the publication of the Criteria for High-Quality EACs in the Concrete and Steel Sectors, in collaboration with Microsoft. 

To build on these efforts, Relae (as Carbon Direct) recently participated in the public consultation for a proposed carbon credit methodology under the Paris Agreement Crediting Mechanism (PACM). Methodology A6.4-PMM010 would credit emissions reductions from replacing fossil fuels with municipal solid waste (MSW) in the production of cement clinker. The approach was proposed by the Inter-American Cement Federation (FICEM), which in 2026 partnered with the UN Industrial Development Organization to work to decarbonize the sector across Latin America. 

The PACM, established under Article 6.4 of the Paris Agreement, could underpin national climate strategies and voluntary offsetting demand for years to come. One potential avenue of influence is the SBTi Corporate Net Zero Standard V2.0, which has introduced formal recognition of market-based instruments. As both public and private entities weigh their carbon credit procurement options, this is a critical juncture for getting the methodologies right. 

Two Key Options for Decarbonizing Cement: Carbon Credits and EACs

Concrete and steel are indispensable to modern construction and together account for approximately 13% of global CO₂ emissions. With demand for infrastructure continuing to rise, including via data centers, decarbonizing these sectors is essential for new construction to remain consistent with climate commitments. 

Carbon credits are one route to financing that work. A credit is issued for each tonne of emissions reduced below a baseline, meaning the emissions that would have occurred without the intervention. For a cement plant, credits might be issued for switching to low-carbon fuels or installing new equipment that reduces emissions. Companies buy credits to offset emissions outside their own value chains, and in doing so channel finance to projects that would not otherwise proceed. 

EACs are a second route, and one that Relae is helping to shape. An EAC assigns a measured environmental characteristic to a unit of product (e.g., tonnes of CO₂ per tonne of cement), usually established through an attributional life cycle assessment. The buyer pays for the lower-carbon attribute of a product and reports it against its own value chain emissions, which makes EACs a tool for scope 3 decarbonization rather than for offsetting. 

While methodology A6.4-PMM010 is for carbon credits, we use the Relae EAC criteria as our reference point, as both instruments depend on the same foundations. An intervention must be traceable to a specific facility, the carbon impact must be quantifiable with a defensible method, and the project must be assessed for its social and environmental harms and benefits. The criteria set out in depth how Relae tests those foundations for an EAC claim, and the same tests apply with little adjustment to a crediting methodology.

Regardless of the preferred market instrument, replacing fossil fuels in cement production should be read as a partial solution. Kiln fuel combustion accounts for roughly 35% of the CO₂ emitted in clinker production, while the remaining 65% arises from process emissions inherent to calcination: when the heated limestone breaks down into lime and releases CO₂ as a byproduct. As such, Relae considers this as part of a multi-step decarbonization strategy that should ultimately address calcination emissions through carbon capture, novel binders, or substitution of the clinker itself. 

Why the PACM Matters for Carbon Credit Buyers

While there is a lack of supply today, PACM credits have the potential to underpin carbon credit demand. Corporate buyers looking to make recognized offsetting claims have reason to favor units issued under a government-endorsed UNFCCC mechanism. The European Climate Law references Article 6.4 quality standards, and the EU is expected to tie the eligibility of procured international credits to its methodologies. The German federal government has used UN-recognized credits to offset its business travel emissions since 2014, and UK government agencies have also sought PACM credits to fulfill their offsetting needs. 

A strength of the PACM is its centralized structure. The 12-person Supervisory Body (SB) makes all final approvals, following methodology recommendations from the Methodological Expert Panel (MEP). All methodologies draw on the same Article 6.4 standards and tools. For example, A6.4-PMM010 relies heavily on the Standard on Baselines and the Tool on Emissions from Solid Waste Disposal Sites. Together, these can be used to calculate the counterfactual emissions from waste diverted from landfill, and dictate how to monitor waste conditions over the crediting period.

The potential for the PACM to scale is conditional. As the market matures, voluntary buyers can choose from a widening range of high-quality carbon credits. Moreover, the European Commission has shown, via its criticism of CORSIA, that the EU will make robust efforts to prohibit procurement from projects it considers flawed. As such, the PACM will only succeed if it provides compelling methodologies to accompany solid governance. That is the standard against which Relae reviewed the fossil fuel substitution methodology.

Relae’s Response to the Cement Methodology A6.4-PMM010 

Alignment With Our High-Quality Criteria

We found methodology A6.4-PMM010 for carbon credits to largely align with our high-quality criteria. Certain gaps in the methodology are addressed by the Article 6.4 standards and tools it references, and the combination provides additional safeguards intended to support robust integrity. 

In both the methodology and our criteria, additionality must be shown on regulatory, financial, and common practice grounds. Crediting is limited to the capacity installed at validation, so carbon finance improves existing production rather than funding new clinker capacity, which aligns with our catalytic impact criterion. The methodology also credits both displaced fossil fuel and avoided landfill methane, a dual benefit that strengthens the case for these projects, especially where landfill sites are poorly managed (e.g., do not flare methane). 

We proposed only two major refinements: updating the landfill methane baseline at each verification, and closing the double-counting gap with environmental product declarations (EPDs). 

Landfill Methane Baseline

Under Article 6.4, an independent verifier checks a project’s reported results for each monitoring period before new credits are issued. Relae proposed that the landfill methane baseline be re-established at each of these verifications: from site measurements where available, and by re-selecting the default value to match current conditions where they are not. 

The baseline rests on two factors that can shift as a waste disposal site is capped, compacted, or drained: the oxidation factor (the share of methane absorbed by landfill cover before release), and the methane correction factor (how much of the waste decomposes without oxygen). 

The Article 6.4 Tool on Emissions from Solid Waste Disposal Sites offers measured and default routes for setting these values, but the methodology does not specify which applies. A project developer could apply default values from the tool and leave them static for the whole crediting period. Re-selecting those values at each verification, rather than locking them in at the outset, keeps the baseline tied to how the site is actually performing throughout its crediting period.

Double-Counting Concerns

The Article 6.4 Activity Standard rightly requires that issued credits do not overlap with other emissions mitigation crediting schemes. However, the A6.4-PMM010 does not explicitly say how that applies to EPDs, which report a cement product's carbon intensity. Relae proposed closing that gap directly: the EPD should report the new, lower carbon intensity achieved after the intervention without subtracting the avoided emissions again. The methodology should also require an annual declaration confirming that the credit and the EPD aren’t claiming the same reduction twice. 

An EPD reports a cement product’s carbon intensity, so a lower-carbon cement can earn value in two places at once: through the carbon credit, and through the EPD itself, which is exactly where the double-counting risk sits. EPD standards already keep the avoided emissions out of a product’s carbon intensity, reporting them separately from the product’s life-cycle stages, but A6.4-PMM010 never references that separation. 

Explicitly addressing this distinction in the methodology, and pairing it with Relae’s proposed annual declaration, could strengthen transparency and reduce the risk of overlapping claims associated with the same emissions reductions, where the same emissions reduction can’t be claimed once through the credit and again through the product’s own carbon footprint.

How Relae Can Help

A6.4-PMM010 is a well-designed methodology, but market-based mechanisms for enabling cement decarbonization are evolving faster than practical guidance on how to use them credibly. Relae works with buyers and cement producers navigating this landscape. For buyers, we conduct technical due diligence, advise on procurement strategy, and guide robust claims. For producers and project developers, we assess which market-based mechanism suits a given plant and provide the analytical, market intelligence, and go-to-market support needed to monetize the chosen mechanisms credibly.

Frequently Asked Questions 

What is the difference between a carbon credit and an Environmental Attribute Certificate (EAC)?

A carbon credit represents one tonne of emissions reduced below a baseline, and a buyer uses it to offset emissions outside their value chain. An EAC attaches a measured carbon attribute to a unit of product, such as cement, which the buyer reports against its own scope 3 emissions rather than for offsetting.

What is the relationship between Article 6.4 of the Paris Agreement and the Paris Agreement Crediting Mechanism (PACM)?

Article 6.4 of the Paris Agreement establishes the PACM, which refers to the registry itself along with the methodologies, standards, and tools that govern the credits listed on it. Article 6.4 is the treaty provision, and PACM is the mechanism built under it, so people often use the two terms interchangeably.

How do PACM credits differ from other credits available on the voluntary carbon market (VCM)?

PACM methodologies and standards are developed through a transparent UNFCCC process, which sets them apart from most VCM credits. This does not make PACM credits inherently higher quality, but some buyers, especially governments, prefer to tie procurement to PACM standards. Another key difference is that 7% of PACM credits are deducted at issuance–5% are transferred to the UN Adaptation Fund, and 2% are cancelled for overall mitigation.

Key Takeaways

1. The decision to fund a project is determined by a holistic review of project development maturity. This applies across capital-intensive projects, including low-carbon power generation, carbon capture and storage (CCS) solutions, sustainable aviation fuel (SAF), and broader transition infrastructure build-out. Both technical and commercial workstreams must be developed in parallel to avoid project failure. 
2. Early scope decisions, such as site selection, core technology selection, and nameplate capacity, are cheap to make but become exponentially disruptive and costly to reverse. 
3. Independent challenge and verification is tangible evidence of a disciplined, well-managed capital development process. 

Bridging the Gap from Announcement to Delivery

Among project developers, a perception often persists: seeking external review signals a project in distress. In capital budgeting discussions, subjecting engineering scope and commercial assumptions to third-party interrogation can be misconstrued as a vote of no confidence in the primary delivery team.

In reality, the reverse is true. Across complex infrastructure, independent challenge is the disciplined stage-gate practice that protects capital by reconciling technical reality with commercial terms before designs are locked.

Independent Challenge Is a Sign of Strength, Not Doubt 

Across capital projects, and in particular within emerging low-carbon industrial infrastructure, the gap between announced projects and delivered assets remains stark. Data from the Mission Possible Partnership’s Global Project Tracker reveals that fewer than 17% of announced commercial-scale clean industrial facilities worldwide have reached Final Investment Decision (FID) or commercial operations, leaving more than 800 major decarbonization projects stalled in front-end development.

The causes of developmental paralysis are multifaceted. While macroeconomic interest rate shifts and global supply chain disruptions sit largely outside a developer's control, project definition and developmental discipline remain entirely manageable. Even amid external volatility, a project designed with resilience will have a far greater likelihood of success.

Independent review and assurance directly strengthen a project’s chance of success and overall value. Large global project delivery organizations have applied this discipline for decades by deploying independent teams to evaluate project readiness at every stage gate. For teams lacking a dedicated internal oversight organization, or those deploying first-of-a-kind facilities, third-party independent review provides the necessary rigor to facilitate project success.

Relae’s (formerly Carbon Direct) work with Stockholm Exergi is a clear example: independent assurance helped build funder and regulator confidence in a first-of-a-kind carbon removal facility with no direct precedent to benchmark against.

Why Projects Stall Between Announcement and FID 

Low-carbon infrastructure and net-zero industrial projects carry unique risks compared to the repeat delivery of established designs. Exciting new developments run a higher risk of falling victim to optimism bias or compressing development timelines to meet public announcement milestones.

It is a natural human tendency for project champions to focus on the upside during early development. However, early momentum must be balanced with processes that reintroduce industrial lessons, supply-chain realities, and operational resilience.

Front-End Loading (FEL) is a well-evidenced approach for improving capital project outcomes. Decades of benchmarking by Independent Project Analysis (IPA) show that approximately two-thirds of industrial megaprojects suffer capital cost overruns or schedule slippage of 25% or more, or encounter severe operational problems lasting more than two years post-startup. This pattern is repeating in low-carbon infrastructure: IPA’s analysis of 12 completed low-carbon projects found average cost escalation of 31% and schedule slip of almost 50%. Rigorous front-end definition remains the single strongest predictor of whether a project will achieve its cost and schedule targets. 

As highlighted in the CDR 2.0: Five Pillars of Successful Project Deployment and Delivery report published by Relae, projects falter when developers push ahead without stress-testing the full delivery framework. Stage gate reviews are the mechanisms that evaluate the total project concept and underlying business case. They are most effective when executed as independent cold-eye evaluations prior to each funding gate, identifying and mitigating vulnerabilities long before final investment decisions are reached. 

What Funders Need to See at Each Gate 

Different stages of project development rely on distinct capital sources, each requiring specific proof points before deploying funds.

Before FEED Funding: Justifying the Engineering Spend

Front-End Engineering Design (FEED) is a major financial commitment, typically costing between 2% and 4% of total project capital cost. The funders backing this stage are usually the developer’s own balance sheet equity, strategic partners, or public grant programs. Before allocating millions of dollars to detailed engineering, these funders need confidence on the fundamentals:

• A technically sound process concept, confirmed utility balances, and an energy integration scheme that fits the site.
• Secured site control, clear zoning pathways, and no environmental fatal flaws that could derail permitting.
• Documented availability of required feedstocks, water and power, paired with demonstrable interest from target off-takers.

Before FID: Proving Bankability and Commercial Closure

As a project approaches FID, the funding audience shifts to conservative commercial lenders, infrastructure funds, and binding offtake counterparties. These capital providers are not underwriting strategic vision; they are underwriting long-term operational cash flows and debt service. Depending on the project and financing structure, capital providers may require:

• A high-confidence capital cost estimate (AACE Class 2 or Class 3) backed by frozen Piping and Instrumentation Diagrams (P&IDs), firm equipment quotes, and a realistic execution schedule with clear critical paths.
• Bankable engineering, procurement, and construction (EPC) structures that clearly allocate risk, include performance guarantees and enforceable liquidated damages.
• Fully executed, binding offtake and feedstock agreements, along with non-appealable permits and completed utility interconnection agreements, with remaining conditions clearly understood.
• An objective, third-party challenge review that assesses operational viability and distinguishes an executable engineering plan from an aspirational concept.

Commercial and Technical Co-Development: The Stage-Gate Method in Practice

A project rarely fails because of an isolated mechanical issue or a purely commercial misstep; failure happens when technical decisions and commercial terms are negotiated in silos and decisions are made without understanding of the wider implications. 

We see this disconnect play out in several ways, including: 

• Sizing capacity before testing market demand: An engineering team may size a facility to maximize thermodynamic efficiency and economies of scale, only for the commercial team to discover buyers will only commit to half that volume. The developer is left with an oversized, unbankable design requiring fundamental rework. 
• Setting product specifications before negotiating offtake: Process engineers frequently design systems around standard vendor packages. However, when downstream transport, processing, or storage networks enforce strict purity standards, the facility faces costly equipment redesigns. This issue has materialized directly within European CCS networks. Open-access offshore storage operators, such as Norway's Northern Lights project, established strict cross-border CO₂ specifications requiring tighter moisture and impurity thresholds than originally designed for. 
• Locking Electrical Loads Prior to Interconnection Verification: As detailed in Relae’s analysis of physical infrastructure bottlenecks, scale is rarely constrained by capital availability; it is dictated by electrical transmission queues, substation headroom, and 24/7 firm power availability. Freezing electrical demand before verifying utility interconnection timelines risks stranding engineering work on an asset that cannot connect to the grid. 

How Relae Stress Tests Projects at Each Gate 

Independent reviews at each stage-gate improve success rates by stress-testing assumptions before presenting to lenders, infrastructure investors, or corporate buyers. Relae reviews projects across five categories using the TECOP framework:

• Technical: Verifying technology readiness levels (TRL), mass and energy balances, plot plan constructability, and operational availability under real-world conditions.
• Economic: Capex benchmarking, operating contingency adequacy, utility tariff sensitivities, and financial model cash-flow resilience.
• Commercial: Offtake agreement structures, feedstock contracts, contracting boundaries, EPC contract structures, and counterparty creditworthiness.
• Organizational: Owner's team capabilities, internal stage-gate governance, contractor oversight mechanisms, and execution capabilities. 
• Political: Statutory permitting status, regulatory durability, carbon market policy exposure, and local community social license.

The TECOP framework is relevant for evaluating delivery risk across all project types, see more in Relae’s Criteria for High-Quality Carbon Dioxide Removal, Delivery Risk Appendix.

What makes this approach effective is sitting on both sides of the table. Having completed over 250 deep-dive technology reviews, 900+ project evaluations, and advised on more than $6 billion in industrial project finance, Relae has extensive experience evaluating the considerations important to institutional funders and buyers.

The Value of Early Independent Project AssuranceIncorporating independent review should be standard practice for modern infrastructure delivery. Because funders will perform their own rigorous diligence regardless, conducting an independent evaluation early enables developers to address vulnerabilities proactively and present a more resilient business case.

Commissioning an independent team for a cold-eye review during early project formation can be a  cost-effective way to identify potential risks before they become expensive to address. Catching an unworkable process assumption, an oversized capacity plan, or a misaligned commercial interface during pre-FEED costs a tiny fraction of what it takes to fix those issues during construction

Ultimately, independent challenge is not an admission of doubt, but the disciplined stage-gate practice that protects capital by reconciling technical reality with commercial terms before designs are locked, signaling to partners, and your future funders that your project is built to deliver. 

To dive deeper into the frameworks that support successful projects, read Relae's white paper: CDR 2.0: Five Pillars of Successful Project Deployment and Delivery and take a look at project assurance in action through our Stockholm Exergi Case Study.

Frequently Asked Questions

What is independent project assurance?

Independent project assurance is a structured review of a capital project by a team that sits outside the project’s delivery organization. Reviewers test the engineering scope, cost estimate, schedule, commercial agreements and permitting position against what funders will require at the next stage gate. The developer receives a clear list of gaps, risks and proposed mitigations prior to presenting the project to lenders, investors or buyers.

When should a developer commission an independent project review?

Periodically throughout the project development process - at a minimum before each major funding gate, but smaller reviews are also beneficial at earlier stages when key concept and technology decisions are being made. A review before Front-End Engineering Design (FEED) tests whether the process concept, site and supply of feedstock, water and power justify the engineering spend. A review before Final Investment Decision (FID) tests whether the cost estimate, EPC structure and binding agreements will satisfy lenders. Site, technology and capacity decisions are cheap to change in pre-FEED and expensive to reverse once detailed engineering starts.

What does an independent project review assess?

Relae structures its reviews around the TECOP framework, which covers five risk areas: technical (technology readiness, mass and energy balances, constructability), economic (capex benchmarking, contingency, financial model resilience), commercial (offtake, feedstock and EPC contracts), organizational (owner’s team capability and stage-gate governance) and political (permitting, regulatory durability and social license). Reviewers also check that technical and commercial decisions are aligned, because projects often fail where the two are developed in silos.

How does an independent project review differ from lender due diligence?

An independent project review applies a holistic approach identifying not only gaps, but also opportunities to add value and strengthen the business case. Lender and investor due diligence is often purely looking at risks and gaps, prior to committing capital. Lender diligence protects the funder and reports its findings at a point when changes are costly and can delay financial close. A developer-commissioned review takes place earlier, so the project team can fix weaknesses in scope, cost or contracts before funders see them.

Key Takeaways

• Concrete and steel contribute 13% of global CO2 emissions. These materials represent substantial scope 3 emissions for companies that are building new infrastructure, including data centers.
• Low-emission alternatives and production technologies are nascent and not yet widely deployed.
• Environmental attribute certificates (EACs) are an innovative solution that can stimulate manufacturing of sustainable commodity materials and overcome market barriers to direct physical procurement.
• Relae (formerly Carbon Direct) and Microsoft developed criteria to guide Microsoft’s high-quality EAC procurement, accelerate decarbonization, and catalyze market expansion for decarbonized materials across supply chains. 
• These criteria cover seven key areas: qualifying conditions, social harms and benefits, environmental harms and benefits, additionality and baselines, catalytic impact, verifiability, and leakage.

A Vision for Low-Carbon Concrete and Steel

Concrete and steel are essential for modern construction, but are carbon-intensive. Combined, they account for approximately 13% of global carbon dioxide (CO2) emissions. ​As the demand for data centers and infrastructure development continues to grow, so do the embodied emissions from concrete and steel. There is an urgent need to decarbonize these sectors so that construction of new facilities remains consistent with climate commitments.​

However, the markets for low-carbon concrete and steel are still in their infancy. Market barriers such as low production volumes, contracting complexity, geographic concentration of supplies, and long-distance transportation limit buyers’ ability to directly procure low-carbon building materials. As buyers and sellers overcome these barriers, the market for low-carbon building materials will mature, giving producers the confidence to invest in new manufacturing facilities and giving buyers access to decarbonized materials directly in their supply chain.

Environmental attribute certificates (EACs) represent the sustainability attributes of a material commodity, unbundled and transacted separately from the physical commodity. EACs are transacted at a price that reflects the additional cost of sustainably producing the material. While barriers to direct procurement of low-carbon materials persist, EACs can serve as a powerful tool to signal demand for low-carbon concrete and steel, catalyze market expansion, and accelerate decarbonization.

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Microsoft’s Approach to Emissions from Building Materials ​

To address embodied emissions and help achieve its ambitious 2030 carbon-negative goal, Microsoft aims to deeply reduce its scope 3 emissions, including from building materials, by more than half compared to a 2020 baseline. In 2023, scope 3 emissions made up over 96% of Microsoft’s total greenhouse gas footprint. To meet its 2030 target, Microsoft is focusing on addressing supply-chain emissions related to data center construction and the embodied carbon of the commodity materials used to build them. Microsoft is already working to decarbonize its building material supply chain using the following three tactics:

• Reduce the need for concrete and steel through innovative building design or the use of lower-carbon alternatives, such as sustainably sourced mass timber.
• Directly engage with suppliers to procure low-carbon alternatives to conventional concrete and steel.‍
• Invest in and help pilot new low-carbon production pathways.

EACs represent a fourth approach to decarbonization that can both reduce emissions and catalyze industry growth. Taken together with Microsoft’s design, procurement, and investment tactics, these actions underpin a comprehensive strategy for long-term decarbonization of the built environment.

High-Quality EACs Support Decarbonization

EACs offer a virtual, market-driven solution to decarbonize the built environment by allowing companies to support low-carbon material production when physical supply chain barriers impede direct procurement. ​EACs for concrete and steel function similarly to other market-based decarbonization mechanisms such as sustainable aviation fuel (SAF) certificates in the aviation sector and renewable energy certificates (RECs) in the energy sector.

These mechanisms work by decoupling the environmental benefits of low-carbon production from the physical materials themselves. EACs allow companies to claim the environmental benefits of physical low-carbon concrete or steel production, even if they do not directly or physically source those materials. EACs provide a verified claim that a purchaser has procured a product with lower emissions, enabling companies to meet climate targets and demonstrate their commitment to sustainability.

Due to their virtual nature, which limits physical oversight of the supply chain, EACs also exacerbate risks such as double counting, greenwashing, fraud, social harms, and environmental harms. Therefore, adhering to transparent, rigorous criteria is foundational to mitigating these risks.

New Criteria to Guide Procurement of High-Quality EACs

To support the integrity and effectiveness of EACs in these sectors, Relae and Microsoft have co-developed Criteria for High-Quality Environmental Attribute Certificates in the Concrete and Steel Sectors. These robust criteria serve as a public resource for companies seeking credible and impactful EAC procurement pathways for low-carbon concrete and steel.

The criteria address seven key areas:

1. Qualifying conditions: EACs must complement, not displace, direct procurement and represent significant emissions reductions. ​
2. Social harms and benefits: EACs must not further social harms and should promote community engagement and social benefits such as meaningful workforce development opportunities and community climate resilience.
3. Environmental harms and benefits: EACs must not perpetuate environmental harm, but instead should mitigate risks and, ideally, provide additional environmental benefits.
4. Additionality and baselines: Projects funded by EACs must drive real, meaningful emissions reductions ​in terms of financial, regulatory, and common practice additionality.
5. Catalytic impact: Prioritize transformative technologies with sector-wide decarbonization potential. ​
6. Verifiability: Set a high bar for documentation, transparency, and independent auditing. ​
7. Leakage: Address risks of emissions displacement to support net-positive outcomes. ​

These criteria provide a robust framework for companies and stakeholders to evaluate and implement commodity EACs effectively, supporting impactful change. ​They balance rigor with flexibility and acknowledge the nascent state of the markets for low-carbon concrete and steel. Sectoral decarbonization will advance over time, shifting the thresholds for what is considered significant, additional, and catalytic in EAC transactions. This science-driven framework can adapt to advancements in policy, industry practices, and technological readiness, ensuring EACs remain a relevant and impactful tool for years to come. ​

Sector-Specific Insights

In addition to providing overarching criteria and guidance on procuring EACs for the built environment, Criteria for High-Quality Environmental Attribute Certificates in the Concrete and Steel Sectors also provides insights into the unique challenges and opportunities of decarbonizing concrete and steel.

Decarbonizing Concrete

EACs can support innovative decarbonization strategies for concrete, such as producing alternatives to clinker and cement, adopting supplementary cementitious materials (SCMs), and reducing emissions from cement kilns through electrification or integrating carbon capture and storage (CCS). ​Performance-based standards and evolving building codes may also unlock new opportunities for low-carbon concrete. ​

The Global Cement and Concrete Association (GCCA) publishes a rating system, Low Carbon Concrete (or Cement) Ratings, which defines eight separate low-carbon grades (AA through G). These grades correspond to the depth of decarbonization and are based on a sliding scale related to the material’s compressive strength. When developing these criteria, Microsoft considered grades AA through D to be eligible for consideration in its EAC procurements.

Decarbonizing Steel

EACs can support transformative technologies for decarbonizing steel, like direct reduced iron (DRI) with electric arc furnaces (EAF) powered by green or blue hydrogen. This support can enable the steel sector to move beyond incremental improvements and focus on capital-intensive solutions that have the potential to reshape the industry. ​

ResponsibleSteel, an independent standards and certification organization with membership that is broadly representative of the steel industry, publishes decarbonization progress levels, with four separate grades (PL1–PL4). These grades correspond to the depth of decarbonization and are based on a sliding scale related to the fraction of recycled scrap use in the steel manufacturing process. When developing these criteria, Microsoft included levels PL2 through PL4 for consideration in its EAC procurements.

A Blueprint for EAC Market Development ​

Relae and Microsoft crafted Criteria for High-Quality Environmental Attribute Certificates in the Concrete and Steel Sectors as a public resource that can help shape the future of the commodity EAC market. ​

These criteria are designed to:

• Communicate intent: Communicate Microsoft's intent to support the decarbonization and scaling of physical commodity supply chains where they have been previously limited.‍
• Guide decision-making: Serve as a public guide for Microsoft's decision-making process, explaining the rationale behind pursuing or declining specific EAC pathways.‍
• Set high-integrity standards: Maintain high integrity for EACs at an early stage, ensuring they are used to enable future physical procurement by supporting market development.‍
• Stimulate partnership opportunities: Encourage potential partnerships and purchasing pipelines by clearly describing criteria for high-quality EACs.‍
• Publicly share detailed thinking: Build on previous work and publicly share detailed thinking, aiming to stimulate market development and guide procurement decisions.

Practical Recommendations for Implementing EACs

Whether you are a supplier, buyer, policymaker, or sustainability advocate, these new criteria offer actionable insights to help you navigate the complexities of EACs in the built environment. ​From setting significance thresholds to ensuring verifiability to avoiding double counting, the criteria provide clear guidance to maximize the impact of EAC-supported projects.

Beyond the technical aspects of EACs, these criteria aim to address their broader social and environmental implications. The criteria focus on the importance of community engagement, transparency, and equitable distribution of benefits in EAC project planning, ensuring that decarbonization efforts contribute to a more sustainable and just economy. ​The criteria are backed by extensive research, stakeholder consultations, and industry expertise.

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Frequently Asked Questions

What is an environmental attribute certificate (EAC), and how does it differ from buying low-carbon concrete or steel directly? 

An environmental attribute certificate represents the sustainability attributes of a commodity material such as concrete or steel, unbundled from the physical material and transacted separately from it. Direct procurement means a buyer purchases low-carbon concrete or steel and takes physical delivery of it for a specific project. An EAC purchase instead allows a buyer to fund and claim the environmental benefit of sustainably produced materials that are sold as typical commodities, and apply that benefit against conventional commodities in their own supply chain. EACs are priced to reflect the additional cost of producing the material sustainably, which sends a demand signal to producers. This makes EACs useful where market barriers—limited production volumes, geographic concentration of supply, or long-distance transportation—prevent buyers from sourcing low-carbon materials directly.

How do EACs for concrete and steel compare to renewable energy certificates (RECs) or sustainable aviation fuel (SAF) certificates?

Environmental attribute certificates for concrete and steel share a structure with renewable energy certificates and sustainable aviation fuel certificates: each decouples the environmental benefit of low-carbon production from the physical product, letting a buyer fund and claim that benefit without taking physical delivery. There are two key differences. First, conventional RECs represent electricity with a zero-emissions footprint, while every tonne of concrete or steel behind an EAC still carries embodied emissions — the certificate demonstrates reduction against a baseline, not a zero-emission product. Second, REC and SAF markets are established, while EACs for concrete and steel are nascent. Both differences are why rigorous criteria matter: quantifying the reduction credibly is harder, and the virtual structure carries risks of double counting, greenwashing, and fraud.

Will EACs let companies claim emissions reductions without actually reducing their built environment climate footprint?

An EAC purchase does not change the materials in a buyer's own buildings; it funds lower-emission production elsewhere in the market. Credible EAC frameworks therefore require that certificates complement rather than displace direct procurement, that they represent significant reductions against a defensible baseline, and that the funded project would not have proceeded without EAC revenue. The criteria published by Relae and Microsoft enable buyers to address these requirements directly in their procurement processes - addressing the climate and reputational risks of low-quality certificates. Used this way, EACs become an additional tool to address emissions from the built environment, supplementing design changes, direct procurement, and investment in new production pathways.

Who should use these criteria?

Criteria for High-Quality Environmental Attribute Certificates in the Concrete and Steel Sectors, co-developed by Relae and Microsoft, is a public resource intended for four audiences. Buyers pursuing scope 3 reductions can use it to evaluate whether a given certificate represents a credible, additional emissions reduction. Suppliers and project developers can use it to understand what purchasers of high-quality certificates look for before bringing a project to market. Policymakers and standards bodies can draw on it while shaping rules for an emerging market. Sustainability practitioners and advocates can use it as a reference point for assessing claims made about low-carbon concrete and steel. The criteria are designed to evolve as these sectors decarbonize, and users may adapt them to meet their own levels of capability and ambition. 

Key Takeaways

• Buyers have been navigating the low-carbon fuels (LCF) market without a map.  The LCF market is expanding rapidly, but standards, definitions, and quality claims vary widely across regions, certification schemes, and regulatory systems, leaving voluntary buyers without a holistic framework for evaluating what they procure.
• Certifications cover some of the picture, not all of it. Existing certification schemes provide valuable assurance but vary in scope and rigor, and few, if any, were designed specifically with voluntary market buyers in mind. 
• The 2026 criteria give buyers a legible quality framework. The 2026 Criteria for High-Quality Low Carbon Fuels bring together key sustainability considerations across six principles, including social and environmental integrity, carbon accounting, additionality, feedstock sourcing, and leakage, giving buyers and producers a legible, living framework to navigate procurement decisions with confidence.

Verifying Quality Is Challenging in the Current Low-Carbon Fuels Market

For airlines, logistics companies, and large corporations with hard-to-abate transportation emissions, low-carbon fuels (LCFs) have become an important part of the decarbonization toolkit. Yet it remains difficult for procurement teams to answer a fundamental question: what does high-quality procurement actually look like? 

Standards, definitions, and sustainability claims vary widely across regions, certification bodies, and regulatory programs. The result is a market where quality is difficult to verify, certifications are difficult to compare, and the gap between a fuel's claims and its actual sustainability profile can be hard to close. Sustainable production will be especially critical as the market scales, because low-carbon fuel systems are deeply embedded in land, agriculture, forestry, and communities. 

The 2026 Criteria for High-Quality Low Carbon Fuels are designed to close this gap, giving voluntary buyers a consistent framework to evaluate the quality of what they procure and identify where additional diligence is still needed.

What Is a Low-Carbon Fuel?

For the purposes of the criteria, a low-carbon fuel, or LCF, is defined as a fuel or energy source whose lifecycle greenhouse gas (GHG) emissions are lower than those of a relevant, use-case-specific fossil fuel alternative. In this case, we are referring to the physical biofuel and its associated environmental attributes. 

While LCFs may be produced through biological, synthetic, or other non-fossil pathways, the 2026 edition focuses on biofuels for transportation, which currently represent the majority of LCF production and use. 

Understanding the Complex LCF Regulatory and Certification Landscape

The LCF market sits at the intersection of multiple regulatory and voluntary markets. In the US, this includes compliance programs such as the Renewable Fuel Standard (RFS) and state-level Low Carbon Fuel Standards (LCFS). Europe, the United Kingdom, Canada, and many other nations host comparable programs, often with specialized regulatory regimes for various transport sectors, e.g., aviation or maritime. 

These regulatory markets coincide with and often intersect voluntary markets, which contain a multitude of standards and certifications. For producers, this creates a complex landscape of market options. For buyers, it creates a signal problem: a fuel may carry one or more certifications, comply with one or more regulatory programs, and still leave meaningful sustainability questions unaddressed.

Several organizations, including the Roundtable on Sustainable Biomaterials (RSB) and the International Sustainability and Carbon Certification (ISCC), have developed widely used standards for LCFs. These certifications assess supply chains from feedstock to end use and provide important baseline assurance. 

However, they were developed with different primary audiences in mind and can vary in scope and rigor. Few existing schemes were designed to serve as a comprehensive sustainability reference for voluntary market buyers evaluating what a given fuel's certification covers and where gaps may still exist.

Simplifying High-Quality Procurement for Voluntary Buyers 

The 2026 Criteria for High-Quality Low Carbon Fuels are not designed to replace or compete with existing certification schemes. Rather, they consolidate key sustainability considerations from across the landscape of existing frameworks into a single, legible reference built specifically for voluntary market decision-makers.

The criteria apply across the full LCF supply chain, covering not only fuel producers but also fuel blenders, aggregators, and certificate traders. This LCF systems view encompasses the full set of production, certification, and procurement arrangements through which LCFs are generated and claimed. This reflects the reality that sustainability outcomes in this market are shaped by many actors, not just at the point of production.

The criteria distinguish between requirements that must be met (minimum thresholds for quality and integrity) and considerations that should be addressed, reflecting best practices and aspirational standards. This distinction is intentional: the criteria set a floor while leaving room for market participants to demonstrate quality in ways appropriate to their specific context. 

The criteria are organized around six core principles that together define what high-quality LCF production and procurement looks like. 

Six Principles for Procuring High-Quality Low-Carbon Fuels

1. Social harms, benefits, and environmental justice: preventing new harms to communities, reducing existing ones, and ensuring equitable distribution of benefits
2. Environmental harms and benefits: minimizing impacts on air, soil, water, and biodiversity
3. Carbon accounting: accurately quantifying lifecycle GHG emissions using credible methodologies and tracking environmental attributes to prevent double-counting
4. Additionality: demonstrating that voluntary market support enables outcomes that would not otherwise occur
5. Feedstock sourcing: ensuring responsible and equitable sourcing practices and requiring end-to-end chain-of-custody documentation traceable to the point of generation
6. Leakage: assessing and mitigating activity-shifting and market leakage associated with the LCF system

Where a fuel's existing certification or regulatory program adherence already addresses one or more of these core principles, that coverage should be disclosed to the buyer by the producer. Buyers can then use the criteria to identify where certification coverage aligns with quality expectations, and where supplemental diligence is needed.

A Living Framework for a Market in Motion  

The LCF market will continue to evolve as policy frameworks are shifting, certification systems are maturing, and new production pathways are emerging. The 2026 edition reflects the current state of the LCF market and is intended as a living resource, with future updates possible as the market develops and new science emerges. Future editions may expand to cover synthetic LCF pathways, renewable natural gas, and sector-specific considerations such as maritime fuels.

For buyers navigating voluntary LCF procurement, the criteria offer a practical starting point: a framework to evaluate what existing certifications cover, identify where additional diligence is needed, and build procurement decisions on a consistent quality foundation. For producers, they provide clear guidance on what a sustainability demonstration looks like for voluntary market buyers.

Read the 2026 Criteria for High-Quality Low Carbon Fuels to learn more about how the criteria apply to your procurement strategy or production system.

Frequently Asked Questions

What is a low-carbon fuel?
A low-carbon fuel is a fuel whose lifecycle greenhouse gas emissions are lower than a comparable fossil fuel alternative for the same use case. The 2026 LCF Criteria focus specifically on biofuels for transportation, which currently make up most LCF production and use.

What do the 2026 Criteria for High-Quality Low Carbon Fuels cover?
The criteria are organized around six principles: social harms, benefits, and environmental justice; environmental harms and benefits; carbon accounting; additionality; feedstock sourcing; and leakage. Together they give buyers and producers a consistent way to evaluate what high-quality LCF production and procurement looks like.

Do the LCF criteria replace existing certifications like RSB or ISCC?
No. The criteria aren't designed to replace or compete with existing certification schemes such as the Roundtable on Sustainable Biomaterials (RSB) or the International Sustainability and Carbon Certification (ISCC). Instead, they consolidate key sustainability considerations from across those frameworks into a single reference so buyers can see what their certification already covers and where supplemental diligence may be needed.

Who do the LCF criteria apply to across the supply chain?
The criteria apply across the full LCF supply chain, not just producers, but also feedstock suppliers, fuel blenders, aggregators, and certificate traders, reflecting that sustainability outcomes are shaped by many actors, not only the producer.

What's the difference between the "must" and "should" requirements in the LCF criteria?
"Must" requirements set minimum thresholds for quality and integrity that need to be met, while "should" considerations reflect best practices and aspirational standards market participants can work toward. This sets a floor while leaving room for participants to demonstrate quality in ways suited to their specific context.

Key Takeaways

• High-quality carbon dioxide removal (CDR) projects require robust project management and oversight to deliver credits on time and at the promised volume; delivery risk is a distinct concern that quality standards alone don't catch.
• The sixth edition of the Criteria for High-Quality Carbon Dioxide Removal is the first to provide an approach to evaluating both credit quality and delivery risk, adding a new delivery risk appendix built around the TECOP framework: technical, economic, commercial, organizational, and political risk.
• The 2026 Criteria provides a framework for developers, investors, and buyers to evaluate both project quality and delivery risk.
• This year's update draws on 170 new diligence reports from 2025 and the input of more than 60 subject matter experts, building on a foundation of six years of lessons from professional diligence across hundreds of real-world CDR projects.

The Criteria Create a Shared Standard for Credit Quality

Relae (formerly Carbon Direct) first launched the Criteria for High-Quality Carbon Dioxide Removal (the Criteria) in collaboration with Microsoft in 2021 to help rapidly and justly scale the development of high-quality carbon dioxide removal (CDR) credits. The market didn't yet have a shared definition of what "high-quality" meant, so we laid out transparent, science-based benchmarks that gave developers, investors, and buyers a common foundation to work from. Every year since, we have gone back and sharpened those benchmarks so that they keep pace with the quickly evolving industry.

But a shared definition of quality doesn't guarantee the delivery of credits as planned. The 2026 edition is the first to tackle that gap directly, pairing the Criteria's quality benchmarks with a new framework for evaluating delivery risk.

The Six Principles of High-Quality Carbon Removal

The Criteria defines six science-based principles that apply across engineered, hybrid, and nature-based CDR approaches:

• Social harms, benefits, and environmental justice: The extent to which the project prevents new social harms to people and communities, reduces existing harms, and provides meaningful benefits distribution.
• Environmental harms and benefits: The extent to which the project minimizes and mitigates environmental harms, as well as provides environmental benefits.
• Additionality and baselines: The evidence that the project’s carbon removal would not have occurred without carbon finance.
• Measurement, monitoring, reporting, and verification (MMRV): The ability to accurately quantify carbon removal in a repeatable and verifiable way, and to develop a plan for long-term monitoring of the project.
• Durability: The likelihood that removed carbon remains stored over time, with mechanisms in place to mitigate reversal risk.
• Leakage: The extent to which project activities cause increased emissions elsewhere.

These principles provide a consistent foundation for carbon removal procurement, evaluation, and project benchmarking.

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Supporting the Delivery of High-Quality CDR Credits

"Projects must work better operationally and be more commercial. Quality and delivery risk shape a project's risk profile at every point in its life, and this edition of the Criteria is the first to give buyers a way to judge both at once." Dr. Julio Friedmann, Chief Scientist, Relae

Designing projects to meet high-quality CDR criteria is only part of the challenge. Effective project planning, management, and execution are also essential to ensure that high-quality CDR tonnes successfully reach the market as planned. As discussed in CDR 2.0: Five Pillars of Successful Project Deployment and Delivery, managing delivery risk requires developers, investors, and buyers to understand the risks that can affect project success and align on how these risks are assessed and mitigated.

To support this alignment, the 2026 Criteria introduced a new Delivery Risk Appendix, which establishes a common framework and language for identifying and evaluating key delivery risks for the first time. Drawing on our broader observations of the carbon removal market and established approaches to project risk management, the appendix highlights common delivery risks across two broad CDR project types: open systems and closed systems. It organizes these risks into five categories: technical, economic, commercial, organizational, and political factors, also known as the TECOP framework. 

The TECOP Framework for CDR Delivery Risk

• Technical delivery risks are associated with the technical feasibility of the project design, implementation, and long-term operation of the project
• Economic delivery risks are associated with the project’s financing structure, financial modeling assumptions, and expenditure profile
• Commercial delivery risk reflects the extent to which a project's purchase agreements, supply arrangements, and key contractual relationships are secured or well-advanced. 
• Organizational delivery risks center on the project developer's capacity and capability to successfully plan, execute, and manage a project of the appropriate size and complexity.  
• Political delivery risks are associated with governance, policies, and potential changes in regulatory environments, as well as the local communities’ perception of and willingness to participate in projects.

New Additions to the 2026 Criteria

Since publishing the 2025 Criteria, Relae has conducted an additional 170 diligence reports across established and emerging CDR pathways, ranging from reforestation and enhanced rock weathering (ERW) to direct air capture (DAC). To date, less than 10% of all 900+ projects the team has reviewed have met the bar for high-quality. These diligence efforts, together with insights from market analysis and ongoing synthesis of the latest scientific and technical literature, have deepened our understanding of how CDR project quality has evolved over the past year. 

The 2026 Criteria leverage these insights and the expertise of more than 60 subject matter experts to reflect advances across the CDR industry and address key weaknesses that remain in the market across all pathways. 

A few of the most significant updates to the Criteria include:

Addition of Direct Counterparty Considerations: Direct counterparties are the organizations that developers partner with, and are structurally dependent on, to generate credits. This can include: 

• Primary feedstock providers (e.g., mines, biomass providers, tree nurseries)
• Major implementing partners (e.g., local implementation partners, base facilities, transportation and storage providers, major product offtakers)
• Land owners that make up a significant proportion of project land 

To reflect the key role that direct counterparties play in high-quality credit generation, developers must conduct diligence and disclose on their direct counterparties to demonstrate that they are not causing social or environmental harm.

Increased Rigor for Enhanced Rock Weathering Projects: Over the past year, ERW’s presence in the CDR market has grown substantially, and so too has the market’s understanding of the corresponding scientific and technical rigor required to deliver high-quality tonnes. The 2026 Criteria raised the bar for how ERW projects:

• Measure and prove their carbon removal claims
• Mitigate risks related to potentially toxic elements (PTEs)
• Incorporate more sophisticated farmer protections and benefits 

Projects now have to back up their numbers with multiple physical field measurements, not just computer models; and they must now track and account for every significant loss pathway, from plants taking up minerals to carbon escaping from rivers and oceans.

Use of Dynamic Baselines for ARR Projects: ARR projects are increasingly using dynamic baselines to provide a more accurate reflection of the counterfactual scenario (e.g., what would have happened in the absence of the project). This is reflected in the 2026 Criteria with a requirement that ARR projects, with the exception of agroforestry projects, use dynamic baselines with statistically matched controls.

What’s Next?

The 2026 Criteria create a clear, science-driven framework for both designing and delivering measurable, just, and durable carbon removal. However, the Criteria cannot ensure high-quality tonnes reach the market on its own; good criteria do not replace robust diligence. To put these criteria into practice, we encourage developers, standard-setting bodies, buyers, investors, and policymakers to consider how the Criteria can be used to inform their role in enabling the carbon market to deliver high-quality tonnes and to engage in deep diligence and ongoing monitoring over the life of a project.

This edition of the Criteria reflects what we have learned over the past year, but our work is not done. We will continue to update it so that it remains a living document that evolves with the science and the market. To do so effectively, it must be a collaborative effort; we welcome input from carbon market actors, academia, and communities.

Frequently Asked Questions

Who publishes the Criteria for High-Quality Carbon Dioxide Removal, and how often is it updated?

Relae (formerly Carbon Direct) first published the Criteria for High-Quality Carbon Dioxide Removal with Microsoft in 2021 and have updated it every year since. The 2026 edition reflects six years of lessons from real-world project diligence and advances in climate science.

What are the six principles of the Criteria for High-Quality Carbon Dioxide Removal?

The Criteria define six science-based principles that apply across all CDR pathways: social harms, benefits, and environmental justice; environmental harms and benefits; additionality and baselines; measurement, monitoring, reporting, and verification (MMRV); durability; and leakage.

What CDR pathways does the Criteria cover?

The Criteria include pathway-specific criteria across nine CDR pathways: afforestation, reforestation, and revegetation (ARR); mangrove forestation; improved forest management (IFM); soil carbon; enhanced rock weathering (ERW) in croplands; biomass carbon removal and storage (BiCRS); abiotic marine CDR; carbon mineralization; and direct air capture (DAC).

What is delivery risk in carbon removal?

Delivery risk is the likelihood that a project generates credits on the timeline and at the quantity committed to buyers. It's a distinct concern from credit quality: even a high-quality project can fail to deliver as planned because of technical, economic, commercial, organizational, or political risk, the five categories the Criteria's TECOP framework evaluates. The 2026 Criteria's new Delivery Risk Appendix gives developers, investors, and buyers a shared benchmark for identifying and managing these risks before they derail a project.

What's the relationship between carbon removal credit quality and delivery risk?

Credit quality and delivery risk are distinct but interrelated. A project that fails to deliver credits as planned reduces the availability of high-quality CDR tonnes in the market, and weaknesses in credit quality can themselves increase delivery risk by creating buyer uncertainty or limiting access to project financing. The 2026 Criteria provides a framework for evaluating both quality and delivery risk.

Key Takeaways

• SAF and e-SAF mandates are reshaping the aviation fuel market. The EU and UK impose steep non-compliance penalties, turning regulatory requirements into a strategic lever for those who act early.
• Non-compliance is costly. Penalties run roughly 3 times the cost of compliance in the EU and from about 2 to 13 times in the UK, making long-term planning essential to mitigate risk.
• e-SAF producers have a unique opportunity. Mandates and penalties are shifting the economics of aviation fuel, making e-SAF more attractive despite historically high production costs.

How SAF Compliance Stacks Up

Airlines and fuel suppliers operating in Europe and the UK face growing economic uncertainty due to stringent mandates requiring the adoption of sustainable aviation fuels (SAF) with carve-outs for SAF produced from renewable hydrogen, also known as Power-to-Liquids (PtL) or e-SAF.¹ These mandates, aimed at reducing aviation emissions, carry steep penalties (up to 13 times the cost of compliance) for fuel suppliers who fail to meet required quotas. While this creates cost uncertainty for airlines and passengers, it opens a strategic opportunity for e-SAF producers. These producers are challenged by high production costs relative to other SAF on the market and a limited set of buyers that can afford the premium on a voluntary basis.

This piece explores the cost implications for aviation being shaped by these EU and UK SAF mandates and outlines how airlines and suppliers can respond strategically to minimize risk and maximize opportunities. By understanding these dynamics, industry stakeholders can turn regulatory compliance into a source of competitive advantage. 

Understanding SAF Mandates in the EU and UK

The EU Commission’s ReFuelEU Aviation regulation, part of the European Green Deal, sets binding targets for aviation sustainability. Beginning in 2025, ReFuelEU mandated that aviation fuel suppliers offer a minimum percentage of SAF and e-SAF at EU airports. By 2030, suppliers must blend at least 6% SAF, including 1.2% e-SAF. To discourage tankering practices (carrying excess fuel for return trips, increasing emissions), ReFuelEU Aviation requires airline operators to refuel at least 90% of their annual aviation fuel needs at a given EU airport before departure. 

In parallel, the UK Department for Transport (DfT) mandates a higher SAF blend of 10% by 2030 and places greater emphasis on reducing reliance on hydrogenated esters and fatty acids (HEFA) SAF fuels, which face eventual limitations on feedstock supply. HEFA’s allowable share will decline annually from 100% in 2025 to 42% in 2040. The UK also includes a sub-mandate specifically for PtL SAF.

The Real Cost of Falling Behind on SAF Mandates

The financial impact of these mandates is significant. Each year, the European Union Aviation Safety Agency (EASA) publishes regulatory reference prices for SAF, e-SAF, and conventional jet fuel (CJF) that anchor non-compliance penalties in the EU, most recently the 2025 Aviation Fuels Reference Prices for ReFuelEU Aviation. Using these reference prices for current-year costs and projected production costs or prices for SAF, e-SAF, and CJF from 2030–2050, the following analysis compares EU and UK compliance versus non-compliance penalties, converting all figures to US$/gallon.²

The price gap between SAF and fossil jet fuels remains wide. In 2025, SAF is approximately three times the price of CJF, while e-SAF is nearly twelve times more expensive. Projections indicate this price gap narrows by 2030, but far more for SAF than for e-SAF. The projected price of SAF in 2030 is US$5.46/gallon, more than double the estimated US$2.41/gallon for CJF. The price difference is even greater for e-SAF: with no traded e-SAF market yet, projected 2030 prices span US$5.70/gallon to US$33.00/gallon, with a central estimate around US$18/gallon, or roughly seven times the price of CJF.

Estimated Jet Fuel Prices 2025-2050 (US$/Gallon)

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Source: European Union Aviation Safety Agency. 2025 Aviation Fuels Reference Prices for ReFuelEU Aviation. (link); UK Department for Transport. SAF Mandate: Final-stage Cost Benefit Analysis. (link); EUROCONTROL. Aviation Outlook 2050: Main Report. (link)

The mandates carry strict penalties for non-compliance. Penalties for non-compliance in the EU are set at a minimum of two times the price difference between SAF and CJF per gallon of unmet obligation. Additionally, fuel suppliers must supply any unmet fuel obligations in subsequent reporting periods, which pushes the cost of non-compliance in the EU to three times the cost of compliance.

In the UK, penalties work differently: fuel suppliers must pay a fixed buy-out price per megajoule (MJ) of unmet obligation, which translates to US$24.64/gallon of unmet SAF obligation and US$26.08/gallon of unmet e-SAF obligation.³ Because the buy-out is fixed while compliance costs vary, UK penalties range from about 2 times the cost of compliance for e-SAF to 13 times for SAF in later years. The intent is clear: regulators are serious about pushing aviation towards sustainable fuels.

Cost-Comparison of Compliance vs Non-Compliance (US$/Gallon)

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Note: The cost of compliance under both mandates is calculated as the price premium of SAF/e-SAF over CJF per ton, using region-specific SAF prices: the EU SAF price reflects HEFA-based supply (ReFuelEU imposes no HEFA cap), while the UK SAF price is a weighted average of HEFA and higher-cost advanced pathways based on the UK's declining HEFA cap. The e-SAF (PtL) price is the same in both regions. 

Cost-Comparison of Complicance vs Non-Compliance (US$/Gallon)

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e-SAF Has a Policy-Driven Market Opportunity 

These price differentials present risk and opportunity. Airlines and fuel suppliers that fall short of compliance will face steep penalties. Those who comply strategically, can mitigate those risks and benefit from financial incentives that help offset higher fuel costs.

Incentive structures support SAF and e-SAF production. For example, the EU’s Emissions Trading System (ETS) has allocated allowances to offset SAF costs, especially for renewable fuels of non-biological origin (or e-SAF). Similarly, the UK offers tradable certificates and has now legislated a Revenue Certainty Mechanism (Sustainable Aviation Fuel Act 2026) that will guarantee SAF producers a set strike price through contracts-for-difference-style agreements, funded by a levy on fuel suppliers, with the first allocation round expected in 2027. The UK’s ETS also provides an indirect incentive as SAF use by airlines lowers compliance costs through reducing required allowances. 

Strategic Recommendations for Airlines and Suppliers

To navigate this shifting landscape, airlines and fuel suppliers must think strategically about procurement and compliance, potentially including:

• Proactive procurement: Airlines and fuel suppliers should prioritize securing long-term contracts with SAF and e-SAF producers. Early engagement can help ensure access to limited supply and stable pricing.
• Leverage incentive programs: Actively participate in available incentive schemes, such as the EU ETS and UK tradable certificates, to minimize compliance costs.
• Invest in e-SAF production: Consider strategic investments or partnerships in e-SAF production to align sustainability goals with regulatory requirements and financial incentives.
• Plan for volatility: Develop robust risk mitigation plans, using flexible procurement strategies and financial instruments to buffer against supply chain disruptions and price swings.

Turning Mandates into Market Momentum

As 2030 approaches, the pressure on airlines and fuel suppliers to comply with SAF mandates will intensify. Those who proactively respond to and embrace the mandates can transform regulatory requirements into strategic opportunities. Rather than viewing mandates as burdens, forward-looking stakeholders can use them to drive sustainable innovation and long-term resilience.

The EU and UK mandates for SAF and e-SAF represent an emerging shift in aviation fuel markets. Stakeholders that act now, by engaging with incentives and investing in sustainable fuel solutions, will emerge as industry leaders. Now is the time for airlines, fuel suppliers, and e-SAF producers to act decisively, transforming regulatory compliance from a costly obligation into a clear competitive advantage.

Frequently Asked Questions 

What happens if an airline or fuel supplier misses its SAF mandate quota?
Fuel suppliers—the obligated parties—pay a penalty on every unmet tonne: in the EU, twice the price gap between SAF and jet fuel, plus supplying the shortfall in a later period; in the UK, a fixed buy-out price (£0.137/MJ for SAF, £0.145/MJ for e-SAF). Combined, non-compliance runs roughly 3 times the cost of complying in the EU and from about 2 to 13 times in the UK.

What is e-SAF, and how is it different from other SAF?
e-SAF, also called Power-to-Liquid (PtL) fuel, is made from renewable or low-carbon electricity, hydrogen, and captured CO₂ rather than biomass feedstocks. It costs more to produce than conventional SAF today, but both the EU (from 2030) and UK (from 2028) mandates carve out a specific, growing sub-quota for it.

What is the UK's Revenue Certainty Mechanism?
It is a UK government scheme, modeled on the Contracts for Difference structure used in the power sector, that guarantees SAF producers a set strike price for up to 10 years, funded by a levy on aviation fuel suppliers. It became law through the Sustainable Aviation Fuel Act 2026, and the first contract allocation round is expected in 2027.

Is the EU considering changes to its SAF mandate timeline?
The EU has scheduled a formal review of ReFuelEU Aviation for 2027, following calls from airline groups to delay the 2030 e-SAF sub-target. No delay has been adopted, and the European Commission has said it remains "fully committed" to both the SAF and e-SAF mandates and that the 2027 review will evaluate the regulation rather than revise it.

Can corporate buyers still claim SAF benefits from fuel used to meet these mandates?
No, mandated volumes are claimed in the compliance market, so to avoid additionality concerns, voluntary corporate scope 3 claims (typically made through SAF certificates and book-and-claim) must come from supply beyond what the mandates require. As mandate demand grows, the pool available to voluntary buyers tightens, which is why early procurement locks in both supply and price.