released guidance on section 45Z, clarifying eligibility for credits of up to $1.75 per gallon, as well as detailing an updated methodology to calculate the carbon intensity of the fuel. To reduce the import of foreign feedstocks the US government restricted the applicability of 45Z to refineries that use domestic feedstocks. While such “carrots” have long been advocated by the industry, biofuel producers raised public concerns about whether the new guidance release would provide enough certainty to negotiate feedstocks and offtake agreements going forward. At the time of writing, however, the long-term impact of the 45Z guidance remains unclear after President Trump signed an executive order to freeze and review all new federal rules, including a 90-day postponement of the 45Z tax credit.50 Meanwhile the “Farm to Fly Act” was reintroduced in the Congress. It does not involve tax credits but focuses on clarifying SAF eligibility and taxonomy and fostering collaboration. Promisingly, a Montana Renewables project looking to deploy SAF got a loan guarantee approved by the new administration in February 2025. Policy patchwork There are two important consequences arising from the proliferation of SAF policy across regions. First, a patchy policy framework is developing, with different sustainability standards and targets, as well as different obligated parties and reporting requirements. Second, most emerging markets benefit from competitive-priced feedstocks, electricity or labour costs compared to Europe and, to some extent, the US. Meanwhile, China benefits from the world’s largest renewable energy pipeline as well as used cooking oil and raw materials for electrolysers. As a result, many of the stakeholders interviewed for this report agreed that the market for SAF and wider aviation decarbonization technology in the US and Europe could face challenges from Asia and South America. For example, there is a likelihood that producers in emerging markets will prioritize domestic supply rather than exports, due to their own mandates as well as logistics and carbon-related issues. Consequently, there are concerns that regions like Europe may not be able to develop a competitive domestic market for the sustainable fuels that represent a critical cost for their airlines, nor even be able to import these fuels if more countries move to mandate SAF usage. Expectations on aviation decarbonization policies for 2025 Building on this context, the Forum’s survey asked executives for their views on how regional and global policies on aviation decarbonization might evolve in 2025 (see Figure 9). –Oceania: the regulatory advances Australia achieved in 2024 bring optimism to 2025, although advancing domestic SAF production and feedstock availability continue to remain pragmatic challenges. For New Zealand, expectations were more pessimistic. –North America: stakeholders’ views were split on whether SAF would remain a priority for the new Trump administration in 2025. Early announcements and the reintroduction of the bi-partisan Fly to Farm Act suggest the topic still remains relevant across the political spectrum, but the temporary freeze of grants and incentives, including for clean hydrogen, pose practical challenges to progress on decarbonizing aviation. –China: while many of the C-suite stakeholders interviewed for this survey expected no substantial policy development, there was general consensus within industry that China could soon introduce substantial production incentives and targets for its domestic SAF industry. During regional Airports of Tomorrow roundtables, attendees said that Hong Kong SAR and mainland China are unlikely to introduce mandates unless there is certainty they can be met. –Europe: the extent to which policy can strengthen Europe’s competitiveness is expected to dominate the debate during 2025. In January, the UK government introduced a guaranteed strike price for SAF;51 meanwhile in February, the European Commission published its new Clean Industrial Deal. By mid-2025, an EU Sustainable Transport Investment Plan is expected, which could include SAF investment provisions among other transport decarbonization solutions.52 Alongside these developments, some executives expected a relaxation of feedstock criteria (e.g. on cover crops) to potentially increase the pool of fuels and regions from which Europe may import SAF in the future, while boosting competitiveness. Discussions will also continue on whether the EU’s Carbon Border Adjustment Mechanism (CBAM) should expand to include aviation as it currently excludes the sector. –Sub-Saharan Africa: stakeholders did not expect any significant changes in the SAF policy landscape in the region, although a number of feasibility studies currently being undertaken by ICAO’s Assistance, Capacity-building and Training for Sustainable Aviation Fuels (ICAO ACT-SAF) initiative may prompt some early policy development. With South Africa taking over the presidency of the G20 in 2025, the topic may continue to feature in international discussions. A sustainable fuels roadmap has been proposed as one of the G20’s deliverables, although, at the time of writing, the themes of SAF and aviation seem to be playing a less prominent role than during the previous G20 presidency of Brazil.53 Global Aviation Sustainability Outlook 2025 21