T&E Warns 'e-HEFA' Loophole Could Displace Up to 50% of EU's 2030–2031 e-SAF Targets
Why It MattersThe loophole risks undermining Europe's genuine synthetic-fuel investment pipeline, deepening biomass import dependence and pushing the bloc toward importing synthetic fuels rather than building domestic e-fuel capacity.
Transport & Environment (T&E) has warned that an accounting workaround known as 'e-HEFA' threatens the integrity of the EU's synthetic fuel mandates under ReFuelEU Aviation and FuelEU Maritime. Under the proposed compliance route, electrolytic hydrogen used as an intermediate input in existing HEFA/HVO hydrotreatment processes would generate a synthetic fuel share in the resulting biofuel output, allowing existing biofuel refiners to claim they are delivering e-fuels without building new synthetic fuel plants.
T&E analysis estimates the workaround could displace up to 50% of the 2030–2031 e-SAF sub-mandate targets and up to 25% of the 2032–2034 targets, deepening EU reliance on imported waste oils, fats and intermediate crops rather than genuine new synthetic fuel capacity. The group also warned of knock-on effects for shipping: although Regulation (EU) 2023/1805 (FuelEU Maritime) does not currently include an RFNBO target, a 2% uptake requirement takes effect from 2034, and the same loophole could dilute that target if Delegated Act (EU) 2023/1185 is not amended.
T&E further cautioned that the workaround could put at risk a pipeline of roughly 40 industrial-scale European e-SAF projects and 69 e-fuels projects targeting the maritime sector, potentially damaging European technological leadership. The group called on the European Commission and EU Member States to rectify what it calls a regulatory paradox in Delegated Act 2023/1185, citing the Commission's own Delegated Regulation (EU) 2025/2359, which excludes RFNBOs used as intermediate products in conventional fuel and biofuel production from Low-Carbon Fuels output share calculations, and urging that the same exclusion apply to e-SAF accounting. ReFuelEU Aviation was adopted in 2023, with the e-SAF sub-mandate entering into force in 2030.
