SAF Sustainability Criteria: What Lenders Check First

9 min read · Mar 20, 2026 · By Alex

SAF sustainability criteria are the tests a fuel must pass before it counts as sustainable aviation fuel under EU rules. In practice they decide which demand your fuel can serve. Moreover they are the first document in the credit file, because a fuel that cannot be certified has no regulated buyer. Therefore this guide explains what the criteria cover, which feedstocks pass, and what lenders ask you to prove.

In short

For one thing, eligible SAF must meet the sustainability and greenhouse gas criteria of the Renewable Energy Directive, and be certified under it.
Moreover the rules split feedstocks into Annex IX Part A and Part B, and each list carries its own limits.
By contrast food and feed crops fall outside the calculation, and ReFuelEU names palm and soy materials explicitly.
In addition the greenhouse gas thresholds differ by route: 65 % for most biofuels and 70 % for synthetic fuels.
For lenders the question is not whether a feedstock is green, but whether the chain is documented before FID.

What the SAF sustainability criteria cover

In essence the criteria sit in Articles 29 and 30 of Directive (EU) 2018/2001, and they cover three things. Firstly the land the feedstock came from. Secondly the greenhouse gas saving of the finished fuel. Thirdly the certification that proves both. Moreover Article 29(1) applies them irrespective of the geographical origin of the biomass, which matters for a plant in Indonesia or Malaysia.

Specifically Article 29(1) allows energy from biofuels to count toward the EU target, toward renewable obligations and toward financial support only if the fuel meets both criteria. Consequently a fuel that misses either test does not enter the regulated demand pool at all. It may still be sold, but not as SAF under ReFuelEU Aviation, and not at the price that regulated demand supports. The wording is narrow on purpose, and the tests are cumulative.

In addition the article contains an exception that a developer should know by heart. Biofuels produced from waste and residues, other than agricultural, aquaculture, fisheries and forestry residues, need only meet the greenhouse gas criteria. Therefore used cooking oil and palm oil mill effluent escape the land tests, while straw and forestry residues face them. In effect that distinction decides how much land documentation your file needs.

The greenhouse gas thresholds under the SAF sustainability criteria

Article 29(10) sets the saving by the date an installation started operation, and the threshold rises with time. Moreover separate rules apply to synthetic fuels, so an e-SAF plant does not use the biofuel ladder.

Fuel and installation start date	Minimum greenhouse gas saving
Biofuels from installations in operation on or before 5 October 2015	50 %
Biofuels from installations starting from 6 October 2015 to 31 December 2020	60 %
Biofuels from installations starting from 1 January 2021	65 %
Renewable fuels of non-biological origin	70 % from 1 January 2021
Recycled carbon fuels	70 %

Consequently a new plant faces the 65 % rung on the bio route, and the 70 % rung on the synthetic route. Moreover the comparator is a single number: 94 gCO2eq/MJ for fossil transport fuel. Delegated Regulation (EU) 2023/1185 fixes that value and the calculation method, so a lender can reproduce the result from the plant’s own mass and energy balance.

For example a used cooking oil plant with a long collection radius can lose several points of saving to transport emissions. Therefore the collection model belongs in the greenhouse gas file, not in an appendix. In my experience the number that fails an audit is rarely the conversion step. It is almost always the logistics.

SAF sustainability criteria: Annex IX Part A and Part B feedstocks

Annex IX does the sorting, and the two lists behave differently. Moreover Part A covers advanced feedstocks, whose contribution may count twice toward the transport target. Part B covers a shorter list, whose contribution is limited and also counts twice.

List	Examples	What a lender thinks
Part A (advanced)	Algae, biowaste, straw, bagasse, animal manure, palm oil mill effluent and empty fruit bunches, forestry residues	Eligible, but collection and logistics carry the risk
Part B	Used cooking oil, animal fats of categories 1 and 2	Eligible, but supply is contested and traceability is scrutinised
Synthetic routes	Green hydrogen plus captured CO2	Eligible as RFNBO, but the electricity rules apply
Food and feed crops	Excluded from the calculation	Not a basis for an EU-linked project

In practice the Part A list is where a Southeast Asian project finds its argument. Palm oil mill effluent and empty fruit bunches sit on that list by name, and so do bagasse, rice husks and straw. Consequently a residue-based plant in the region can aim at the advanced category, which carries the double counting and the strongest policy support. However the same listing means every other developer in the region has the same idea, and the residue becomes contested.

Food, feed and palm: what the criteria exclude

ReFuelEU Aviation adds its own exclusions on top of the directive. Specifically Article 4(5) removes several feedstocks from the calculation of the minimum shares: food and feed crops, intermediate crops, palm fatty acid distillate, palm and soy derived materials, and soap stock. Therefore a palm oil or PFAD route does not help a supplier meet its obligation, however low its carbon intensity.

However the same paragraph keeps a door open. The exclusion does not apply to any feedstock listed in Annex IX, under the conditions of that Annex. As a result palm oil mill effluent and empty fruit bunches remain eligible, while crude palm oil and PFAD do not. In practice that single sentence decides which palm supply chain a developer can finance, and I have seen projects fail on the distinction alone.

In addition Article 4(4) caps other aviation biofuels at 3 % of the fuel supplied for compliance. That cap covers biofuels that are neither advanced nor Part B. Consequently the middle category exists but cannot carry a project on its own, and a lender will discount a revenue case that leans on it.

Certification under the SAF sustainability criteria

Certification turns a claim into evidence, and the Commission recognises the schemes that provide it. In reality 18 voluntary and national schemes hold formal recognition, and a recognition usually runs for five years. Moreover the Commission lists the conditions a scheme must meet: traceability of the sustainability characteristics back to the feedstock origin, documented information, audits before a company joins, and regular retroactive audits.

For example ISCC EU and RSB EU RED both hold recognition, and both cover agricultural biomass and waste residues. Furthermore the IATA SAF Handbook lists the entities that need certification along the chain: feedstock producers and providers, transporters, traders, SAF producers, blenders and suppliers. Therefore certification is a chain obligation, not a plant obligation. A gap at a collector two steps upstream can break the batch.

In addition the documentation has names a lender will look for. A Proof of Sustainability records the sustainability characteristics of a delivery. A Proof of Compliance plays the same role where the first document goes to a regulator. A Product Transfer Document proves the transfer of ownership. Consequently a contract that does not allocate these documents leaves the buyer unable to claim the fuel.

How the SAF sustainability criteria reach the Union Database

Article 30 of the directive requires a Union database for liquid and gaseous transport fuels. Moreover economic operators must enter their transactions and the sustainability characteristics of each batch, including lifecycle emissions. The record starts at the point of production. Therefore an Asian producer feeds a European registry from the first delivery, and a missing entry becomes an audit finding.

ReFuelEU adds a reporting duty on top. Specifically Article 9(2) requires an aviation fuel supplier to give aircraft operators accurate information on the SAF it supplied, free of charge, by 14 February of each reporting year. In addition Article 11(6) makes misleading information on the characteristics or origin of SAF a finable offence. The fine is at least twice the price gap multiplied by the volume concerned. As a result a false sustainability declaration carries a price, and lenders price that risk into the sponsor’s covenants.

Feedstock chains in Southeast Asia

Residues from palm oil mills, used cooking oil and agricultural residues are the feedstocks I see most in the region. However each has a different collection model and a different traceability risk. Generally palm oil mill effluent arrives with the mill’s own wastewater flow, which makes provenance easy to prove and volume easy to cap. Used cooking oil arrives through thousands of small collectors, which makes provenance hard and fraud easy.

Moreover agricultural residues follow the harvest calendar, so a plant that depends on one crop runs at part load for part of the year. By contrast a mill-linked effluent plant runs whenever the mill runs. Consequently a developer who treats all three as one “waste” category will lose the lender’s confidence quickly. For the supply picture, read SAF Feedstock in Southeast Asia and see feedstock supply.

Mistakes I see in feedstock files

Assuming a feedstock is eligible because it is a waste.
Showing volumes without supply contracts or collection agreements.
Starting certification after the offtake talks rather than before.
Ignoring competition from other plants for the same residue.
Using a default greenhouse gas value where an actual value would fail.
Treating palm oil and palm oil mill effluent as the same feedstock.

In practice the last mistake is the most expensive, because it surfaces late. Moreover it surfaces in front of the buyer, not in front of the internal team. Therefore I test the feedstock classification before I test the model, every time.

Sources

Sources

Directive (EU) 2018/2001 (RED II), Article 2(40), Article 25(2), Article 29, Article 30 and Annex IX, EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj/eng
Regulation (EU) 2023/2405 (ReFuelEU Aviation), Article 3(8), Article 3(9), Article 4(4), Article 4(5), Article 9(2) and Article 11(6), EUR-Lex: https://eur-lex.europa.eu/eli/reg/2023/2405/oj/eng
Commission Delegated Regulation (EU) 2023/1185 of 10 February 2023 (greenhouse gas methodology, 70 % threshold, 94 gCO2eq/MJ comparator), Articles 1 to 3 and Annex, EUR-Lex: https://eur-lex.europa.eu/eli/reg_del/2023/1185/oj/eng
European Commission, “Voluntary schemes” (18 recognised schemes, recognition criteria, five-year validity): https://energy.ec.europa.eu/topics/renewable-energy/bioenergy/voluntary-schemes_en
IATA, SAF Handbook, May 2024 (ISCC and RSB schemes, entities requiring certification, Proof of Sustainability, Proof of Compliance, Product Transfer Document): https://www.iata.org/contentassets/d13875e9ed784f75bac90f000760e998/saf-handbook.pdf
European Parliamentary Research Service, “ReFuelEU Aviation initiative”, PE 698.900, November 2023 (Annex IX Part A and Part B, exclusion of food and feed crops): https://www.europarl.europa.eu/thinktank/en/document/EPRS_BRI(2022)698900

FAQ

What are SAF sustainability criteria?

In short they are the sustainability and greenhouse gas tests in the Renewable Energy Directive that a fuel must pass to count as SAF in the EU.

Does used cooking oil qualify?

It sits on Annex IX Part B, so it can be eligible if it meets the greenhouse gas threshold and the chain is certified.

Do palm-based fuels qualify?

Partly. Palm oil and palm fatty acid distillate are excluded from the minimum share calculation, while palm oil mill effluent and empty fruit bunches sit on Annex IX Part A.

Who certifies the fuel?

A recognised certification scheme, with an external auditor checking the whole chain from feedstock origin to supplier.

When should certification start?

Before offtake talks close. For that reason buyers and lenders ask for the scheme scope at the first meeting.

Does the origin of the biomass matter?

No for the criteria themselves, because Article 29(1) applies them irrespective of geographical origin. Yes for the logistics, which change the greenhouse gas result.