The e-HEFA dispute and the e-SAF sub-target

Europe is debating which routes may count towards the synthetic aviation fuel sub-target under ReFuelEU Aviation. In a letter to the European Commission dated 14 September 2026, Transport & Environment and co-signatories ask that electrolytic hydrogen used as an intermediate input in biofuel refining not count as e-SAF.

The letter rests on Regulation (EU) 2023/2405, which creates the e-SAF sub-target from 2030, and on Delegated Regulation (EU) 2025/2359, which already excludes RFNBOs used as intermediate products from low-carbon fuel output. By T&E's analysis, the e-HEFA route could displace up to 50% of the 2030-2031 target and 25% of the 2032-2034 target.

For Brazil, the distinction decides which feedstock counts. The HEFA route depends on waste oils, fats and intermediate crops, a limited pool Europe largely imports, according to the letter. The synthetic route needs renewable hydrogen plus carbon, and biogenic CO2 from ethanol and biomass is the advantage the article assigns to the country.

With the gap closed, European demand concentrates on new synthetic capacity. T&E cites around 40 industrial-scale European e-SAF projects that depend on long-term contracts to reach a final investment decision. The definition coming out of Brussels determines where those contracts go.