Policy Misalignment and Systemic Barriers to Sustainable Aviation Fuel Deployment in Europe: An MLP-Informed Stakeholder Analysis

Aviation contributes approximately 2.4% of global CO2 emissions and 3.5% of total effective radiative forcing when non-CO2 effects are included, yet Sustainable Aviation Fuel (SAF) accounts for less than 0.5% of European jet fuel consumption. This paper investigates why the gap between policy ambition and deployment persists, asking (i) how misaligned instruments across ReFuelEU Aviation, RED III, CORSIA, and the UK RTFO impede high-integrity production pathways, and (ii) what convergence mechanisms can reduce fragmentation beyond Hydroprocessed Esters and Fatty Acids (HEFA)-dominated supply. Applying the Multi-Level Perspective framework, the study triangulates comparative policy analysis with a stakeholder survey (n = 45) across SAF producers, airlines, policymakers, and investors. Results identify regulatory fragmentation, capacity constraints, and funding barriers as near-equally weighted obstacles, while disaggregation reveals actor-specific priorities: policymakers emphasise regulatory complexity, airlines emphasise funding, and producers emphasise capacity. Most producers declined to disclose volume projections, interpreted here as strategic ambiguity under regulatory uncertainty. Three convergence mechanisms are proposed: harmonised carbon-intensity registries, standardised book-and-claim accounting, and joint feedstock certification protocols. The findings align aviation decarbonisation with SDGs 7, 9, 12, and 13. Without coherent policy architecture, SAF deployment risks entrenching low-ambition compliance pathways that undermine the EU’s contribution to the 2030 Agenda.