January 22, 2026
The scientific understanding of non-CO₂ effects from aviation is not yet sufficiently mature and science-evidenced to support regulatory and financial obligations under the EU ETS.
Implementation at this stage carries high risks, including unfair financial burdens, distortions of competition, and legal uncertainties. A4E urges that the Commission's report, as well as any potential binding mitigation obligations based on non-CO₂ MRV, be postponed until the aforementioned uncertainties are eliminated.
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January 22, 2026
A4E Position Paper on non-CO₂ MRV and Mitigation
Position paper
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