On June 14, 2023, the International Sustainability & Carbon Certification (ISCC) and the Roundtable on Sustainable Biomaterials (RSB), certified nine batches of sustainable aviation fuel (SAF) under the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). This event marked for the first time certification of sustainable aviation fuel as CORSIA-eligible fuel.

The International Civil Aviation Organization (ICAO) is a United Nations agency supporting the development of international aviation. ICAO set an aspirational goal of carbon neutral growth. CORSIA is a global market-based emissions reduction program meant to harmonize the current patchwork of national/regional regulatory initiatives that exist amongst the 121 member states under one global initiative. Currently, CORSIA is in a voluntary pilot stage. Companies in member states involved in international aviation will be required to participate in CORSIA beginning in 2027 through 2035.

The use of CORSIA-certified sustainable aviation fuel is only one component of complying with the requirements imposed by CORSIA, which also involve a market-based offsetting mechanism utilizing emission units from voluntary carbon market programs. Companies complying with CORSIA will need to navigate the provisions that apply to emissions monitoring and reporting, as well as the use of CORSIA-eligible fuels and emissions unit offsetting. Companies should understand that not all sustainable aviation fuel is CORSIA-eligible fuel. Some limitations on claiming CORSIA-eligible fuel include, but are not limited to, whether an approved Sustainability Certification Scheme certified the fuel, whether the company claimed use of the fuel under another greenhouse gas emissions scheme, and whether the fuel was blended during the applicable compliance period. Failure to comply with the CORSIA-eligible fuel requirements could affect compliance with the offsetting requirements under CORSIA. Currently, the enforcement provisions for CORSIA are unclear. Member states must implement CORSIA by adopting the program into their laws, along with applicable enforcement provisions.

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The nine batches, totalling 1,542 tonnes, were certified by ISCC and RSB and produced in China, the Netherlands, and the United States, by ECOCHEM, Neste, and WorldEnergy, respectively.

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This article is presented for informational purposes only and is not intended to constitute legal advice.