Business Aviation Groups Demand Emissions Policy Changes

The European Business Aviation Association (EBAA) is calling on the European Parliament for fairer treatment of the industry under the European Union Emissions Trading Scheme (EU-ETS). In a position paper published this week with the General Aviation Manufacturers Association (GAMA), the groups renewed an appeal for changes to proposals made in July they say would bring 383 additional business aircraft operators into the scheme’s remit by reducing the threshold for minimum levels of carbon dioxide emissions.

The proposals would replace the current EU-ETS distinction between commercial and non-commercial aircraft operators with a single de minimis threshold per company of 1,000 tonnes of CO2 annually. The European Commission also proposed that, from 2029, the EU-ETS would apply to all flights from the European Economic Area to third-country destinations within 5,000 kilometers (2,700 nm) of the EU’s geographical center. 

“This reduction is particularly significant and will be difficult for smaller operators to implement, given the technical, administrative, and financial complexity of the current system,” the EBAA paper states. “Many of these operators do not have the resources, specialized teams, or predictable operating schedules available to larger commercial airlines.”

GAMA and EBAA stress that their members are willing to contribute to the decarbonization of aviation and even “to make a greater contribution under the EU-ETS.” However, they insisted, this is only viable with “equal treatment” for business aircraft operators, taking account of their different scale, and with “a substantially simpler compliance framework.”

Denied SAF Allowances

According to the groups, the proposals do not amount to a so-called level playing field because business aviation would face broader carbon-pricing obligations than airlines while being denied access to sustainable aviation fuel (SAF) allowances. “This is neither proportionate nor technology neutral,” the paper argues.

Another criticism of the planned changes to the EU-ETS: they do not take account of passenger and carbon taxes specifically levied by individual EU member states including France, Portugal, Italy, and the Netherlands. EBAA and GAMA also complain that EU officials have not considered the impact of cost and operational constraints of the separate, but related, ReFuelEU requirements for operators to demonstrate that they have purchased fuel at European airports, rather than tankering supplies for trips in and out of the region. 

Regarding the extension of EU-ETS to flights outside Europe, the paper says this would introduce “a new and arbitrary geographical boundary into an already complex regulatory framework.” More specifically, the authors argue that it will place a disproportionate burden on operators emitting less than 10,000 tonnes of emissions as they would otherwise fall outside the scope of the related CORSIA decarbonization requirements. They maintained that this disconnect would impact smaller business aviation companies more than some airlines.

Safety Concerns

“A framework that places excessive and unpredictable financial pressure on smaller operators could also constrain resources available for crew training, operational preparation, and safety management,” the report notes. “Aviation safety must remain the overriding priority and must not be undermined by an unnecessarily complex or disproportionate carbon-pricing framework.”

Specifically, EBAA and GAMA are asking the European Parliament and Council to remove the business-flight exclusion from the European Commission proposals under Article 3c(6) and provide business aviation with access to SAF allowances and associated accounting flexibility as other aircraft operators. They also want the 5,000 kilometer extension scrapped and replaced with “a geographical scope” that provides for equal treatment across routes and among different groups of operators.

“The principle should be straightforward: if an aviation operator is required to pay the EU carbon price, it should have fair access to the EU mechanisms intended to help aviation reduce those emissions,” the paper concludes. “Business aviation should not face more extensive carbon pricing and less access to decarbonization support simply because of the type of aircraft it operates.”

The industry groups drew legislators’ attention to the €100 billion annual contribution to European gross domestic product identified by the Oxford Economics Report they commissioned in 2025. This also showed that the industry supports more than 449,000 jobs.