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The petrochemical clusters located in Dutch harbors already offer significant comparative advantages for Sustainable Aviation Fuel (SAF) production. In addition, the Dutch government is committed to positioning the Netherlands as a leading hub for SAF production and distribution. The recently published National SAF Roadmap 2025-2035 outlines a comprehensive strategy for scaling up the production and use of SAF in the Netherlands, futureproofing the Dutch aviation sector and enhancing energy independence. In this blog post, we highlight the key initiatives identified in the roadmap for each strategic objective, as well as the main challenges faced by the Dutch SAF market.
The roadmap is structured around three primary objectives, identified in consultation with the Dutch aviation sector:
Compliance with EU obligations: Meeting the binding SAF blending mandates set by the EU's ReFuelEU Aviation Regulation, as described in our earlier blog post on how the European SAF mandate impacts market dynamics.
Stimulating additional demand: Achieving the Dutch national target of 14% SAF blending by 2030, which exceeds the EU minimum.
Strengthening the Netherlands as a production hub: Enhancing the country's role as a key location for SAF production by leveraging its petrochemical infrastructure, logistics, and expertise.
Creating an Efficient Market to Meet ReFuelEU Obligations
The first objective of the Dutch aviation sector is to ensure that the Dutch market can efficiently comply with the EU's SAF blending mandates (6% by 2030, 20% by 2035, with a sub-mandate for e-SAF starting in 2030 with 1,2%). This objective is primarily challenged by complex traceability requirements. The need for precise tracking of SAF through intricate supply chains, combined with a lack of harmonized legislation and a wide variety of CAF certification programs, complicates compliance and increases administrative burdens—especially when using shared infrastructure such as the central Europe pipeline system. Monitoring SAF blending must demonstrate compliance with minimum blending requirements under REDIII, ReFuelEU, and EU-ETS, as well as adherence to the cap of 50% blending per individual aircraft under ASTM certification. Additionally, the stepwise, exponential increase in blending mandates (with a step-up every five years) does not align well with the gradual upscaling of production capacity. In an earlier blog post, we already highlighted the implications of ReFuelEU on competitive dynamics affecting SAF producers, fuel suppliers, airlines, and airports.
To create an efficient market that meets ReFuelEU obligations, the Dutch Ministry of Water and Infrastructure is advancing the following initiatives:
Streamlining the EU registration system: Developing a robust, harmonized EU-wide registration system for SAF, integrated with national systems and regulatory frameworks (e.g., EU-ETS, CSRD). This will improve transparency, prevent double counting, and facilitate compliance monitoring.
Implementing administrative solutions: Enabling traceability and mass-balancing of SAF in the Central European Pipeline System (CEPS), ensuring that SAF delivered via pipelines can be properly accounted for in national blending obligations.
Fostering cross-border cooperation: Collaborating with key partners (e.g., France, Germany, Benelux) and aligning national policies across ministries. This includes joint research, financing, and leveraging bilateral agreements to remove barriers and optimize synergies.
Aligning bio-feedstock policy: Ensuring that Dutch regulations on bio-feedstocks are not stricter than necessary and remain consistent with EU interpretations. This includes reviewing and potentially expanding the list of approved feedstocks and removing unnecessary regulatory hurdles for innovative or waste-based inputs.
Bundling input for a unified Dutch position: Preparing for the 2027 ReFuelEU evaluation by advocating for a level playing field, clear reporting obligations, and flexibility in feedstock and mass-balancing rules.
Stimulating Additional Demand Towards the 14% National Target
The second objective is to drive voluntary and policy-driven demand for SAF beyond EU minimums, aiming for 14% blending by 2030. In addition to strengthening the SAF value chain, this will also ease the transition to the 20% blending mandate under ReFuelEU in 2035. However, this objective is challenged by the high price premium: bio- and synthetic SAF is currently three to nine times more expensive than conventional kerosene, making voluntary uptake unattractive for most consumers and businesses. Achieving the additional 8% blending (from 6% to 14%) would require bridging a funding gap of approximately €450-500 million per year, which cannot be met by voluntary demand alone. A secondary challenge is low consumer awareness and trust, with limited willingness to pay for SAF, partly due to skepticism about its actual climate impact and the effectiveness of offsetting schemes.
To stimulate additional demand towards the 14% national target, the Dutch aviation sector—through collaboration between public and private actors—is pursuing the following initiatives:
Stimulating voluntary demand: Organizing consortia of corporate and private travelers committed to sustainable flying, and encouraging the government to mandate SAF use in its own travel procurement.
Defining the scope and requirements of the 14% Target: Clarifying eligible SAF types, feedstock origins, and certification standards. This clarity is essential for market participants to plan investments and for financiers to assess risk.
Improving communication: Enhancing communication about SAF's climate benefits, monitoring the effectiveness of the EU flight emissions label, and ensuring robust public oversight of SAF claims to build consumer and investor confidence.
Assessing use of existing levies: Evaluating how proceeds from existing levies (on producers, airlines, or fuel suppliers) can be used to subsidize the SAF price premium, especially for volumes above the mandatory minimum.
Exploring government revenue support: Assessing the potential for using government revenues from CO₂-related levies, EU-ETS, and air passenger taxes to support SAF uptake, possibly through mechanisms like Contracts for Difference (CfD) or national SAF allowances for non-EU-ETS routes.
Strengthening the Netherlands as a SAF Production Location
The third objective is to build and maintain a competitive, flexible, and resilient SAF production ecosystem in the Netherlands. The petrochemical clusters in Dutch harbors already offer significant advantages for SAF production. The availability of existing infrastructure means no significant additional investments are required in this area, and synergies with existing petrochemical clusters, as well as proximity between actors in the value chain, offer the opportunity for lower production costs. However, the first challenge for SAF production in the Netherlands is feedstock availability. The supply of waste oils and fats for HEFA is limited, and advanced bio-feedstocks face competition from other sectors (chemicals, heavy transport, etc.). Additionally, the cost of renewable electricity and green hydrogen in the Netherlands is relatively high, making domestic e-SAF production less competitive compared to countries with cheaper renewables. Importing feedstock, semi-finished products, or SAF itself therefore seems a more likely route. Subsidy programs for the various production paths and value chains are currently being developed, and it is uncertain which route will become dominant. Secondly, the capital intensity and long lead times for SAF plants, combined with price volatility (which causes airlines to hesitate to commit to long-term contracts with fixed pricing), make it difficult to secure financing and reach final investment decisions. Investment uncertainty is further exacerbated by additional complications for project development in the Netherlands, such as grid congestion and permitting delays (especially related to environmental regulations).
To strengthen the Netherlands as a SAF production location, the Ministry of Climate Change and Green Growth is promoting the following initiatives:
Evaluating short-term co-processing potential: Assessing the short-term potential for co-processing bio-feedstocks in existing refineries as a transitional measure, while recognizing its limitations due to continued fossil dependency.
Supporting large-scale HEFA SAF plants: Facilitating the development of large-scale HEFA SAF plants with flexible input/output capabilities, leveraging existing projects.
Building e-SAF production capacity: Supporting the establishment of e-SAF facilities with a focus on flexibility and integration with green methanol hubs.
Developing advanced bio-SAF capacity: Promoting the development of innovative bio-SAF plants using advanced feedstocks and processes, potentially repurposing Alcohol-to-Jet facilities built for e-SAF.
Stimulating new production pathways: Providing subsidies for R&D and the scale-up of novel SAF technologies (e.g., Power-to-Liquid, Alcohol-to-Jet).
De-risking long-term contracts: Advocating for an EU-level intermediary (modeled on H2Global) to facilitate long-term offtake agreements between producers and airlines, reducing price and volume risk and enabling investment decisions.
Addressing permitting bottlenecks: Tackling issues such as nitrogen and nature permits, prioritizing grid connections, and ensuring access to infrastructure to prevent project delays.
Developing trade relationships and infrastructure: Building infrastructure for importing bio- and e-SAF feedstocks and intermediates, and maintaining favorable import tariffs to ensure supply security.
Path Forward
Streamlining the implementation of EU regulations will be the first step in creating an efficient SAF market in the Netherlands and Europe. Whether additional demand can be generated to boost the SAF value chain will depend on bridging the funding gap. To meet the 2030 requirements for e-SAF, building e-SAF production capacity will be essential. To stimulate final investment decisions for production plants in the Netherlands, the Dutch government must de-risk market price uncertainty under long-term offtake contracts with airlines and mitigate project delays caused by permitting bottlenecks or grid connection issues.
