Shammi Thakur
Sustainable aviation fuel (SAF) is becoming an increasingly important consideration in aviation fuel procurement. For general aviation airports and fixed-base operators (FBOs), changing regulations, supplier partnerships and aircraft operators' sustainability requirements are beginning to influence how fuel is sourced, priced and delivered. The implications extend beyond fuel availability, reaching storage arrangements, purchasing agreements and responsibility for documenting environmental claims.
SAF Requirements Differ Across Aviation Markets
The regulatory position is not uniform across regions. The European Union has introduced binding blending requirements through its ReFuelEU Aviation Regulation, requiring aviation fuel suppliers at covered airports to progressively increase the proportion of SAF in their supplies. The minimum SAF share began at 2% in 2025 and rises to 6% by 2030, with further increases scheduled through 2050.
The regulation generally covers EU airports handling more than 800,000 passengers or 100,000 tonnes of freight annually, although smaller airports can opt into its scope. Importantly, the blending obligation falls on aviation fuel suppliers within the regulatory framework. It should not be interpreted as a requirement for every individual FBO or general aviation airport to independently blend SAF.
The European Union Aviation Safety Agency's (EASA) 2026 annual report provides an indication of the policy's initial impact. Fuel suppliers reported delivering 1.1 million tonnes of SAF out of 39.3 million tonnes of total aviation fuel supplied at EU airports in 2025, representing 2.79%. SAF was available at 121 airports across all 27 member states, exceeding the first-year mandatory target.
The United States follows a different approach. Federal policy has primarily supported domestic SAF production through incentives rather than a nationwide blending requirement for general aviation airports and FBOs. The Section 45Z Clean Fuel Production Credit provides tax incentives to qualifying registered fuel producers. For fuel produced after December 31, 2025, eligibility also requires feedstocks to originate in the United States, Mexico or Canada. The IRS credit requirements make clear that this is a producer incentive, not an automatic discount for downstream fuel purchasers.
Washington State also considered a more direct intervention through Senate Bill 6114 in 2024. The proposal sought to require certain airport operators and FBOs to provide fuel containing at least 10% SAF for private aircraft operating under Part 91. The proposed requirement was linked to the verification of alternative aviation fuel production capacity reaching 20 million gallons annually. However, the bill reached the Senate Rules Committee and was placed on its X file on February 15, 2024. It did not become law. The Washington legislative record therefore provides an example of proposed regulatory pressure, not an existing compliance obligation.
For US general aviation operators, the immediate commercial implications are more closely connected to fuel availability, supplier commitments and customer expectations than to a universal SAF blending mandate.
Fuel Distribution Determines What FBOs Can Offer
SAF does not necessarily require airports to establish an entirely separate fuel distribution network. Approved production pathways allow SAF blending components to be combined with conventional Jet A or Jet A-1 within specified limits. The permitted blending percentage depends on the production pathway and its certification requirements.
Under the ASTM fuel specifications, SAF blending components must meet the applicable requirements of ASTM D7566. Once the finished blended fuel has been certified and released as compliant with ASTM D1655, it can be handled through the same distribution system as conventional aviation turbine fuel.
This arrangement has important implications for FBO procurement. SAF can enter the existing supply chain through producers, fuel terminals and established distributors before reaching airport storage facilities. The US Department of Energy's distribution guidance explains that blending can occur at refineries or fuel terminals before the finished product is transported to airports through existing pipelines, barges or trucks.
Blending at the airport is technically possible, but it is generally less practical because it requires additional equipment, personnel and insurance. For many FBOs, the more immediate responsibility is to secure certified blended fuel from a reliable supplier and maintain the necessary delivery and quality documentation.
The distinction is particularly relevant because SAF is intended for turbine-powered aircraft using Jet A or Jet A-1. It is not an alternative drop-in fuel for conventional piston-engine aircraft using aviation gasoline. Consequently, SAF procurement decisions will primarily affect FBOs serving business jets, turbine-powered general aviation aircraft and charter operations.
FBO Partnerships Demonstrate How SAF Supply Is Developing
Physical SAF availability is already expanding through partnerships between airports, FBO operators and fuel distributors.
In July 2025, Million Air Albany and the Albany County Airport Authority announced a consistent SAF supply for business and general aviation. The FBO received its first truckload on June 18, following coordination with Avfuel and the airport authority. The Million Air Albany announcement identified the location as the first in New York to offer a consistent SAF supply specifically for business and general aviation.
Another example came from Jet Aviation, which expanded its US SAF offering through an agreement with World Fuel Services. In October 2024, the company announced the addition of five locations, taking its announced US on-site SAF network to eight FBOs at the time. Availability at the five new locations was scheduled to begin in January 2025. The Jet Aviation expansion demonstrated how established fuel-distribution partnerships could extend physical SAF availability across multiple business aviation facilities.
These developments show that FBO participation does not always require independent investment in fuel production or blending infrastructure. Supplier-backed procurement arrangements can provide access to certified fuel while allowing airports and FBOs to retain their established refuelling operations.
Physical SAF and Book & Claim Require Different Agreements
Physical SAF delivery is not the only way aircraft operators can participate in SAF procurement. Book & Claim arrangements allow customers to purchase verified environmental attributes associated with SAF used elsewhere in the supply chain, even when the physical fuel is not delivered to their departure airport.
For an FBO, the distinction needs to remain clear. Facilitating a Book & Claim transaction does not mean an aircraft has physically received SAF. The arrangement concerns the allocation and accounting of environmental benefits rather than a change in the fuel delivered into the aircraft.
The Roundtable on Sustainable Biomaterials published SAF accounting guidance in June 2026 addressing how fuel suppliers, airlines and corporate customers should report physical SAF use and Book & Claim-supported emissions reductions. Its guidance emphasises traceability, consistent reporting and preventing double counting.
Accordingly, procurement agreements should establish whether a customer is buying physical blended fuel, environmental attributes through Book & Claim, or both. They should also identify who owns the associated environmental claims and how supporting documentation will be maintained.
What Changes in an FBO Fuel Purchase Agreement?
SAF introduces additional considerations into fuel purchasing beyond the conventional price per gallon. Suppliers and FBO operators need to establish how the fuel will be delivered, which technical specifications apply and what happens when agreed volumes are unavailable.
Several contractual provisions deserve particular attention:
● Fuel specification: Identify the approved SAF pathway, blending percentage, applicable ASTM certification and quality documentation.
● Pricing arrangements: Specify the conventional Jet A benchmark, SAF premium, price-adjustment mechanism and responsibility for applicable transportation charges.
● Volume commitments: Define minimum purchase quantities, delivery frequency, annual commitments and procedures for adjusting volumes when aircraft demand changes.
● Environmental attributes: Establish ownership of emissions-related claims, Book & Claim arrangements, certification records and traceability responsibilities.
● Supply interruptions: Clarify delivery obligations, alternative sourcing arrangements, conventional Jet A availability and the treatment of contractual price adjustments when SAF supply is disrupted.
Pricing deserves particular attention. EASA reported an average 2025 SAF price of approximately €1,925 per tonne, compared with €640 per tonne for conventional aviation fuel in the EU. These figures are regional averages rather than direct quotations for individual FBO contracts, but they demonstrate the cost difference that can influence purchasing negotiations.
Supply availability also remains a constraint. The International Air Transport Association's 2026 supply forecast estimates global SAF production at approximately 2.4 million tonnes in 2026, equivalent to 0.8% of total annual jet fuel consumption. Limited production relative to conventional fuel demand makes minimum purchase commitments, delivery schedules and alternative supply arrangements important considerations for smaller aviation facilities.
North America's position in the developing supply chain is another relevant consideration. Vyansa Intelligence's SAF market research estimates that the region accounts for approximately 40% of the global SAF market. Its research also identifies business and general aviation as a separate application segment. The regional share reflects North America's position in the wider SAF industry, not the proportion of SAF currently consumed by general aviation airports or FBOs. For fuel purchasers, the important question is how expanding production capacity translates into accessible, certified supply at individual aviation facilities.
Smaller Airports Face Different Procurement Pressures
Large commercial airports and smaller general aviation facilities operate with different fuel purchasing requirements. A high-volume airport may have greater negotiating leverage, more predictable fuel turnover and the ability to coordinate purchases across multiple operators. A smaller FBO may serve fewer turbine-powered aircraft and face greater uncertainty about recurring SAF demand.
Committing to minimum SAF volumes can therefore create additional commercial exposure when aircraft movements fluctuate or deliveries are delayed. Maintaining separate inventory arrangements can also affect storage planning, fuel turnover and working capital.
For smaller facilities, supplier-backed availability agreements or coordinated procurement with airport authorities may provide a more practical starting point. Contracts should retain flexibility to accommodate changes in production, transportation routes and customer requirements without compromising conventional Jet A availability.
Fuel Procurement Will Need Greater Flexibility
SAF policies are changing the aviation fuel supply chain, but they do not impose identical obligations on every airport and FBO. European blending requirements, US production incentives, state-level legislative proposals and voluntary business aviation procurement arrangements represent different forms of influence.
For general aviation airports and FBOs, the practical challenge is understanding where requirements apply, which suppliers can deliver certified fuel and how pricing, volumes, traceability and environmental claims are addressed in purchasing agreements.
As SAF production and distribution expand, fuel contracts will need to accommodate changing supply conditions, customer expectations and regulatory requirements. Dependable fuel availability will remain central to FBO operations, but the quality of procurement relationships will increasingly determine how effectively SAF becomes part of general aviation refuelling.
Author Bio:
Shammi Thakur is a research director at Vyansa Intelligence, where he leads research and analysis across aviation, transportation, technology, and industrial sectors. With more than 15 years of experience in industry research and market intelligence, he focuses on translating industry developments, operational trends, and business data into practical insights for professional and technical audiences.