EC request for feedback on Flight Emissions Label

1 October 2024: The European Commission has launched a public consultation on the draft implementing regulation for the EU Flight Emissions Label (FEL), previously referred to as the EASA Environmental Label. The feedback period ends 22 October. Once finalised, the scheme will be available for voluntary adoption by airlines starting next year.

The below summarises the main points:

Reporting requirements:

1. Application submission:

• Airlines seeking to issue labels for their flights must apply to EASA through a digital reporting tool by 1 February each year. The application should include the intended scope of flights covered under the scheme.

2. Reporting of scheduled flights and operations:

• By 1 May of each year, operators are required to report on scheduled flights for the two upcoming periods and operations conducted in the previous year. This includes providing information on routes, aircraft types, estimated flights, and relevant operational details.

3. Data verification:

• Before submission to EASA, the data provided by airlines must be verified by an independent verifier.
• For aviation fuels life cycle emissions, certification must be done through bodies identified under Directive (EU) 2018/2001 or the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA).

Key features of the Flight Emission Label:

1. Voluntary participation:

• Participation in the scheme is voluntary but requires detailed operational data to be reported annually.

2. Scope:

• The initial focus is on passenger flights or mixed passenger-freight flights, with gradual extension to include all-cargo services from 1 January 2028.

3. Labelling of fight emissions:

• The Flight Emissions Label will provide consumers with standardised information on the carbon dioxide equivalent (CO₂eq) emissions of flights, enabling environmentally-conscious choices.
• The labels will differentiate between passenger and freight emissions, offering a transparent view of flight performance.
• Two validity periods of the labels issued:
  • Winter: from the moment of issuance of the label until the end of the winter scheduling period.
  • Summer: five months before the start of that summer scheduling period until its end.

4. Display of labels:

• Airlines will be required to display the FELs at all points of sale belonging to them within 5 days following their receipt.
• The label shall be clearly visible during the entire electronic purchase process and in all forms of visual advertising.
• Aircraft operators must ensure that the points of sale with a contractual relation also display the labels on time.

5. Compliance and monitoring:

• EASA will monitor compliance by reviewing emissions data at least semi-annually. Incorrect or outdated labels must be removed or replaced immediately.
• Airlines must ensure that labels remain up-to-date and reflect current operations.
• Failure to comply with the labelling requirements could result in the revocation of labels.

6. Flight emissions website

• A search functionality will allow customers to compare aircraft operators on the same route by their flight emissions.
• Comparisons will be displayed in ascending order from the lowest emitter to the highest emitter.
• Aircraft operators will have restricted access to the website to view their own compliance information.

ERA would like to provide consolidated feedback from members on the draft regulation. This represents your last opportunity to express any concerns, suggestions, or operational challenges related to the implementation of the scheme.

Members are also invited to send their feedback directly to the Commission through the Have your Say Portal - https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14142-Flight-Emissions-Label_en - and we kindly request you keep ERA in copy to ensure we remain informed.

The consultation will stay open until 22 October. The proposal and annex are attached for your information.

Please submit your feedback ERA no later than COB 20 October 2024 as this will allow us to consolidate all responses and submit a detailed and comprehensive position to the European Commission before the consultation closes.

Thank you in advance for your valuable input. In case of questions, please don’t hesitate to contact elena.cuencasanted@eraa.org

17 April 2024: Following the two-day stakeholder workshop held in January, DG MOVE and EASA held a follow-up meeting in Brussels on 9 April to present and discuss the ‘Environmental Label’ ahead of the Commission Implementing Regulation later this year.

With the preparation of the Commission Implementing Regulation (IR) ongoing, ERA alongside member representatives, attended a meeting organised by DG MOVE and EASA to update stakeholders as to how the Environmental Labelling Scheme as foreseen in ReFuelEU is progressing.

In opening the meeting, DG MOVE explained that the purpose of the regulation is to establish a means for a flight emissions calculator, providing information on CO2 emissions to the consumer in a simple manner to support informed decision making.

A presentation covering the key components, terminology, calculation assumptions and estimates, as well as providing some initial thoughts regarding user and public access information areas.

Several questions were raised from the floor with regards to data validation criteria, opt in/out, operational implications (ad hoc aircraft changes/new routes), reporting criteria etc.

Whilst Article 14 of the ReFuelEU Regulation (EU) 2023/2405 does address many of the questions raised, DG MOVE advised following the meeting, they are working on a more comprehensive Q&A which will be communicated in due course.

Unfortunately, there was no further clarity on how much the issue of the labels will cost, other than once again reminding those present that it will be in accordance with EASA Fees and Charges regulation.

Members should be aware that whilst the labelling scheme remains voluntary at this stage, it is becoming clear that this may change in the future, with a review/revision to the upcoming IR foreseen by 1 July 2027 as per Article 14, being the first opportunity to do so.

The presentation from the meeting (locked for members only) can be found in additional to those from the previous meeting in the downloads section in the top right corner.

In case of questions, please contact nick.rhodes@eraa.org

6 February 2024: ERA, along with several association member representatives, attended an EASA stakeholder workshop on the environmental label in Cologne on 22–23 January, ERA to discuss the latest status, methodology, data ingestion and treatment, as well as the integration of the labelling into emission communications.

As part of the ReFuelEU regulatory package, a new environmental labelling scheme aimed at providing transparency to consumers regarding the environmental impact of air travel has been adopted.  

The scheme, to be managed by the European Union Aviation Safety Agency (EASA), is voluntary and is designed to provide single source, independently verified emissions values to European passengers when booking their flights.

It aims to enable passengers to identify flights with lower emissions, ensuring that sustainable aviation fuels (SAFs) are also considered in the values shown. It is anticipated that passengers will be provided with emission values during the flight booking process.

Understandably, there have been several questions about the practical implementation of such a scheme. EASA has clarified that while the methodology is still under discussion and consultation, progress is being made. A recent stakeholder workshop held in Cologne provided a platform for discussions, with another workshop scheduled for April in Brussels.

One of the key points of discussion, particularly for regional operators, related to the methodology and metrics used to calculate the environmental impact. During the pilot phase, revenue seat kilometres (RPKs) served as the primary metric. However, at the workshop, EASA has indicated that this will be supplemented by additional metrics and data points to provide a more comprehensive assessment.

Importantly for ERA members, EASA also assured stakeholders that data will be benchmarked by range category to ensure fairness, particularly for regional travel and essential connectivity. This move seeks to prevent regional aviation from being unduly disadvantaged by the labelling scheme.

Considering these developments, ERA is likely to call upon its members to participate to the workshop in April and provide feedback on various aspects of the scheme. This meeting will also cover the financial aspects for the issuance of the labels, detail of which is currently limited, although it has been confirmed that it will sit within the current EASA fees and charges regime.

All presentations from the workshop held last month can be found in the downloads section in the top right (locked for members only). Details of the next workshop will be provided to members once available.

In case of questions, please contact nick.rhodes@eraa.org