The European Business Aviation Association (EBAA) has raised serious concerns over the European Commission’s proposal to revise the EU Emissions Trading System, warning that it could impose broader obligations on business aviation while excluding the sector from key support for sustainable aviation fuel uptake.

EBAA’s initial assessment indicates that the proposal would affect business aviation through three principal changes: broader operator coverage; a potentially wider geographical scope for business jets; and the explicit exclusion of business flights from EU ETS allowances intended to support the use of sustainable aviation fuels.

The Commission states that emissions from business aircraft have ‘largely been exempted’ from the EU ETS. This does not reflect the reality of the sector. The majority of EBAA’s operator members are already covered and have been monitoring and reporting their emissions, purchasing allowances and complying with EU ETS obligations for years.

Under the proposal, the existing flight-frequency exemption would be removed and the current distinction between commercial and non-commercial aircraft operators would be replaced by a single annual emissions threshold. Smaller operators may be able to use simplified monitoring and reporting tools, but they would still be required to register, purchase and surrender allowances.

EBAA is also concerned about the proposed geographical scope. For aviation generally, the Commission proposes extending the EU ETS from 2029 to departing flights from the European Economic Area to third-country destinations located within 5,000 kilometres of the EU’s geographical centre.

However, the Commission’s accompanying Q&A appears to suggest that all incoming and departing flights operated by business jets could be included, without the same distance or directional limitation. EBAA has not identified a corresponding provision in the legal text and considers that urgent clarification is required.

If confirmed, this could mean that an airline and a business jet operating the same long-haul route would face different carbon-pricing obligations solely because one aircraft is classified as a business jet.

The proposal would also explicitly exclude business flights from the allowances reserved to help cover part of the price difference between conventional kerosene and eligible sustainable aviation fuels. Business flights would only be eligible for support related to electricity.

This restriction is particularly concerning because SAF remains the only realistic and scalable near-term decarbonisation solution for most of the existing business aviation fleet.

“Business aviation is already contributing to the EU ETS and is fully committed to Europe’s climate objectives,” says Roman Kok, EBAA director of public affairs and communications. “What the sector cannot accept is being subjected to yet again discriminatory and broader obligations than other aviation while being deliberately excluded from the principal support mechanism designed to help aviation decarbonise.

“The proposal describes the SAF support mechanism as transparent, based on equal treatment and non-discrimination. Explicitly excluding business flights immediately afterwards is difficult to reconcile with those principles.”

EBAA is also disappointed by the consultation process. Despite repeated requests, it was not granted a meaningful consultation with DG CLIMA on measures directly targeting business aviation, while environmental NGOs were given opportunities to engage. Legislation with significant and potentially unequal consequences should be based on balanced, transparent and inclusive consultation.

The Annex setting out the precise aviation exemptions and thresholds had not been made available by the Commission at the time of publication, meaning that some elements of the proposal still require clarification.