14. October 2026

Key Demands

We ask that you advocate for proportionality and fair competition in the revision of the EU ETS. The simultaneous, significant reduction of the de minimis threshold and the expansion of the geographical scope are disproportionate and disproportionately impact smaller operators in general aviation.

The GBAA calls for

1. Maintaining the threshold: The current 10,000-metric-ton CO₂ limit for EASA Part-CAT operators must remain in place.
2. An impact assessment that must examine:
   – the inclusion of inbound and outbound general aviation flights,
   – lowering the threshold from 10,000 metric tons to 1,000 metric tons of CO₂, and
   – the additional administrative burden on aircraft operators and competent authorities.
3. Equal Treatment: Business aviation and airlines must be treated equally; there should be no separate, stricter definition of “business flight” and “business aircraft.”
4. SAF Access: Unrestricted access to SAF subsidies and “Book & Claim.”
5. Consider Cumulative Burden: The existing cost burden from the EU ETS, Swiss ETS, UK ETS, CORSIA, and ReFuelEU must be taken into account with any further tightening of regulations; European operators must not face any additional competitive disadvantages.

Why the GBAA Strongly Opposes This Commission Proposal

• Double Expansion. The proposal combines a significantly lower reporting threshold with a broader scope (flights up to 5,000 km around Frankfurt). Together, these measures hit small operators with few aircraft and employees the hardest and cannot be justified without a robust impact assessment.
• Unequal Treatment. Operators below the CORSIA threshold of 10,000 metric tons of CO₂ are to be subject to a significantly higher levy than much larger airlines operating the same international routes. This cannot be objectively justified, especially since the costs of offsetting CO₂ emissions covered by CORSIA are significantly lower than those under the EU ETS.
• Exclusion from SAF funding. “Business flights” are to be excluded from the certificates reserved for sustainable aviation fuels, even though the industry is already subject to significant obligations under the EU ETS, CORSIA, and ReFuelEU. Those who impose obligations must also grant access to the tools that make it possible to fulfill them. SAF is aviation’s most important short-term, scalable mitigation measure; withholding it from part of the industry contradicts the Commission’s stated goal.