Transport & Environment (T&E) reiterates that the review ETS proposal, the Emissions Trading System is not enough to support investments in fuels for the aviation and maritime transport sectors, two sectors that also contribute significantly to revenue ETS. The European non-governmental organisation, active in the field of sustainable transport and the decarbonisation of the transport sector transport, specifies that, however, the extension of the application of the Emissions Trading System to multiple flights outside Europe and to smaller ships proposed last July by the The European Commission is a step in the right direction, even if it is if insufficient ( of 17 July 2026).

In a new briefing published today, Transport & Environment recalls that the Commission proposes to tie up 50% of national ETS revenues to decarbonisation measures in the priority areas. Welcoming the inclusion of transport air and sea between them, T&E nevertheless calls for stricter enforcement of the obligation to spend the remainder for climate and energy purposes, with requirements of reporting. Today - underlines the Briefing - Many Member States pay revenues into budgets without a specific destination, making it difficult to track use.

In addition to being a price tool for polluters - says the organisation - the ETS can become a lever of industrial policy, provided that the principle of "those who polluter pays". To achieve the objectives of the regulations ReFuelEU Aviation and FuelEU Maritime of the climate package Fit for 55 with truly green and scalable fuels - notes T&E - in the next decade we need rapid growth in production and use of e-fuels (RFNBOs, renewable source fuels non-biological). The organization believes that financial support is also crucial for the domestic supply chain, the autonomy strategic strategy and industrial competitiveness in the clean technologies.

Transport & Environment explains that there is also a problem of size, given that after 2030 the threshold of 50% will apply to a much smaller pool of as the starting figures suggest. 30% of the proceeds would feed into the long-term EU budget from 2028, a an additional 20-25% would finance ETS funds at European level, and the compensation of indirect costs for energy-intensive industries (CCIs) may absorb 25% or more of national quotas, while 50% only applies to what remains.

At the European level - T&E recalls again - the proposal to The revision of the ETS strengthens the architecture of the funds by extending the Innovation Fund and the Modernisation Fund beyond 2030 and introducing two new instruments, the Investment Booster (30 billion euros between 2027 and 2030) and Industrial Decarbonisation Bank (IDB) from 2031. Air and sea transport not however, they are included in these tools and remain dependent by the Innovation Fund alone, which after 2030 would fall from the about 530 million allowances to 200 million, while covering a wider range of sectors. In addition, the Briefing - The proposal removes the current dedicated contribution of the air transport to the Fund (five million allowances).

T&E therefore calls for e-fuels for aviation and shipping are explicitly included in the Investment Booster perimeter, and IDB, and that the Modernisation Fund can support them in their Member States with lower incomes.

He then emphasized that the volumes of financing alone are not enough to launch sustainable fuels projects, T&E notes that the nascent e-fuel market is blocked by a classic problem of the chicken and the egg: producers, often small developers with limited capital, they need ten-year purchase agreements to obtain financing, while buyers (airlines, shipowners, fuel suppliers) they think about cycles of 1-3 years, they fear the disadvantage of the "first arrived" and are also held back by uncertainty about possible regulatory backwards, as in the planned revision of ReFuelEU by January 1, 2027. The result is that many final investment decisions remain at a standstill, while competitors as China and the United States gain ground.

To resolve this stalemate, T&E proposes the creation of a market intermediary that buys fuel from manufacturers with long-term contracts and resell it with contracts users by managing double-sided rods: manufacturers offer the minimum selling price, buyers the maximum purchase, and the intermediary covers the difference with the budget. According to T&E, this would create pressure competitiveness on both sides, reducing the need for subsidies and producing transparent price signals. The briefing recalls that in the Sustainable Transport Investment Plan, the European Commission has committed to "working for" the creation of a similar intermediary for the sustainable fuels market. T&E specifies that, although the feasibility assessment is to be concluded by 2027, design and financing remain undefined. The support - underlines the briefing - should focus on RFNBOs produced in the EU, the only fuels that are sustainable at the same time, scalable and sovereign.

To finance the intermediary, T&E proposes an E-fuels Funding Pool to be established in the ETS Directive, powered by Investment Booster, IDB and national revenues, and open also contributions from the Innovation and Modernisation Funds, national sanctions under ReFuelEU Aviation and FuelEU Maritime and voluntary contributions from Member States. Designed as Autonomous mechanism for T&E outside the EU budget in the long term It could be created right away and managed by a dedicated entity or hosted by the IDB, becoming fully operational in 2028 with windows for air freight, sea freight and level and EIB trade guarantees.

T&E also recalls that the proposal for the revision of the ETS of the EU Commission strengthens fuel quota mechanism sustainable aviation (SAF) and introduces a similar one for the shipping, the SMAP (Sustainable Maritime Alternative Propulsion). For aviation, to the current 20 million allowances until 2030 would add 110 million. For maritime transport, the SMAP would be worth up to 110 million allowances between 2028 and 2040, including for technologies such as electric or wind-assisted propulsion. T&E asks to improve the design by tying up 80% of the 110 million of the additional SAF allowances (approximately 90 million) to e-SAF and approximately 70% of the SMAP (76 million) to RFNBOs, of which 30.5 million products in the EU, as well as introducing or expanding mechanisms for Advance booking to support long-term purchase contracts term.

Specifying that these tools, however, act as decentralized subsidy that supports demand and only indirectly the offer, while double-sided auctions are a top-down intervention that reduces risk on both fronts, T&E considers that for this reason quotas should not be at the expense of auctions, while complementarity should be assessed, weighing the benefits of cumulation against the risk of overcompensation, and ensuring that the total support does not exceed 100% of the costs eligible.