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The year exposed a clear paradox: while physical availability remained limited for much of the second half of the year, keeping the CIF Amsterdam-Rotterdam-Antwerp (ARA) prices high; the cost of production swung sharply, affected by the price of Dutch HBE (renewable fuel) credits, and at times moved into negative territory.
With the first compliance year nearly complete, attention is turning to what 2026 may look like when obligations rise and if supply growth remains slow.
The compliance picture for 2025 suggests the mandate was manageable but not without challenges. Supply was concentrated and was heavily reliant on a small number of producers, with limited prompt liquidity throughout the fourth quarter.
The UK’s second provisional dataset for 2025, covering supplies up to October 27, reported aviation fuel deliveries of 10 billion liters under the mandate, with SAF volumes reaching 163 million liters, or just under 1.63% of total supplies. All reported volumes were from conventional bio-based pathways, with no power-to-liquid production recorded.
The data broadly reflects what market participants said throughout the year – that Europe had enough material to meet the 2% requirement, but the market operated with very little flexibility.
Airlines also pointed to a system that worked, but required careful planning. A spokesperson for Wizz Air told Fastmarkets that compliance with the 2% mandate was met smoothly through fuel suppliers, although not all EU airports currently receive SAF.
“With supply still limited and prices rising, at the end of 2024, we decided to secure SAF at a fixed-unit price,” the spokesperson said. “The sharp increase in market prices between April and October 2025 proved that we made the right decision.”Spot prices mirrored the tight physical picture. CIF ARA values were firmly supported through October and November, often heard at around $2,700-2,900 per tonne on the back of tight prompt supplies, limited feedstock availability and compliance-driven demand.
One producer told Fastmarkets that SPK was “very strong” throughout the fourth quarter. And a Chinese producer said it had no spot volumes available for sale, with all output committed to term clients, adding that it did not expect to offer material into Europe before February 2026.
Conditions shifted in early December, when price indications fell to around $2,270-2,340 per tonne. Market participants attributed this to a pause after peak compliance buying and slightly looser prompt availability, but stressed that overall liquidity remained thin.
Cost-of-production assessments, meanwhile, held within a narrow base range even as credit dynamics injected some volatility. From June to early December, Fastmarkets’ price assessment for sustainable aviation fuel (SAF max), base cost, exw Netherlands generally hovered around $2,040–2,150 per tonne, with feedstock and hydrogen movements influencing its weekly direction but not fundamentally altering levels.
The sharper shifts came from the credit side. Rising Dutch HBE IX-B values steadily pushed down credit-adjusted breakevens. Net values that sat above $500 per tonne in early July slipped below $200 per tonne in early September, turned negative in late October, with Fastmarkets’ price assessment for sustainable aviation fuel (SAF max), base cost, exw Netherlands (incl. HBE-IXB credits) falling as low as $(130) per tonne by December 5.
However, feedstock constraints remain the most significant structural bottleneck heading into 2026, sources said.
Data from the European Union Aviation Safety Agency (EASA) shows roughly 81% of SAF feedstock inputs in 2024 were used cooking oil (UCO), with animal fats making up most of the remainder. These streams are limited, import-dependent and exposed to competition from Asia.
Sources said UCO availability did not expand meaningfully in 2025 and that Europe’s reliance on imported material was likely to grow, with the lack of diversification into non-lipid pathways continuing to limit growth from existing European units.
On the supply side, production capacity expansion has been slower than required by the ReFuelEU trajectory. EASA estimates operational European SAF capacity at around 1.4 million tonnes per year. Announced projects could lift this to between roughly 3.6 and 5.2 million tonnes if delivered, but this will still be well below the approximate 9.6 million tonnes needed for the 6% mandate in 2030.
Several large projects were canceled or postponed in 2025, including developments linked to oil majors BP and Shell. Shell told Fastmarkets that the company would not be commenting on the cancellations.
Although producers such as Neste reported strong operational performance through 2025, including higher capacity utilization rates, the gains did not offset the wider lack of new supplies.
Demand continues to rise as blending requirements scale. ReFuelEU moves from 2% in 2025 toward 6% in 2030, while the UK mandate rises toward 10% by the end of the decade, driving structural demand growth already visible across the market.
Airlines are increasingly adjusting procurement strategies in response and Wizz Air said its SAF needs in 2025 were fully covered through term contracts, with no reliance on the spot market.
“We expect SAF prices to continue to rise in 2026. We’ve already been notified by some suppliers about increases for contracted volumes until the end of March 2026, and growing demand in the aviation industry will put further pressure on both the jet fuel and SAF markets,” the Wizz Air spokesperson said, citing feedstock constraints, higher UK mandates and new tariffs on non-EU SAF.
KLM Royal Dutch Airlines told Fastmarkets that achieving the joint ambition of a 14% SAF blend in the Netherlands by 2030 would require alternative fuels to become more affordable and more widely available.
The International Air Transport Association’s (IATA) latest outlook reinforces the widening gap between policy ambitions and production reality, however.
The association expects global SAF output to reach about 1.9 million tonnes in 2025 – double the 2024 level – but to grow only modestly to 2.4 million tonnes in 2026, equal to roughly 0.6% of global jet fuel consumption for 2025 and 0.8% for 2026.
IATA estimates that the SAF premium added around $3.6 billion to airline fuel costs in 2025, noting that production growth fell short of earlier expectations due to insufficient policy support.
“If the goal of SAF mandates was to slow progress and increase prices, policymakers knocked it out of the park,” IATA director general Willie Walsh said. He warned that mandates in their current form risk increasing costs without guaranteeing supplies.
IATA’s senior sustainability official Marie Owens Thomsen expressed similar concerns and said the regulators must adjust course to ensure long-term SAF viability and scale.
Owens said that, without stronger production incentives, costs will remain high, supply will lag and many of the same problems could emerge under the upcoming e-SAF mandates.
A spokesperson for the European Commission told Fastmarkets that the trade bloc remains on track for the 2030 target, but stressed that delivery of announced projects, faster permitting and feedstock diversification would be essential to meeting rising demand.
Europe’s first mandated year has demonstrated that policy can create demand. But as the market moves into 2026, the central questions remain: whether supply can scale in time, whether feedstock concentration will ease and whether policy frameworks can evolve to support investment without perpetuating volatility.
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