CostingEnergy mass balanceE-fuels

ReFuelEU Aviation e-SAF compliance value and penalty exposure

What a tonne of e-SAF is worth under the ReFuelEU synthetic sub-mandate: Art. 12 minimum penalty, penalty-based price ceiling and margin against the plant's levelised cost, with sub-mandate coverage and the ASTM blend check.

Open Jack

Founder · OpenJack

Add to project

CurrencyEUR 2025
Battery limitfully financed
65 documented assumptions
Updated2 Nov 2026

Mass and energy balance

What the asset draws and delivers for the case and load you choose.

Reference case

Operating hours90.4 %

Hours per year at the design rate. Sets the SAF actually supplied and spreads the capital and fixed O&M over it. 7920 h is the PNNL on-stream factor; 6132 h is Bube's 70 % utilisation.

SAF capacity

Nameplate e-SAF output at the 7920 h/a design basis, the same size input as #489. Sets the share of the synthetic sub-mandate the plant covers and, through the 0.6 scaling law, the capital part of the levelised cost.

SAF supplied: — kt/a
Sub-mandate share covered: — %
Blended jet fuel enabled: — kt/a
Plant fixed capital investment: — MEUR

CAPEX

Specific cost at this size, what backs it, and how it behaves with scale.

Specific CAPEX at this size

—

Reference size 129.1 kt/a

Printed in PNNL-30533 Eq. (3).

CAPEX source

Model value: PNNL-30533 installed cost of the fuel section, built up to FCI, escalated to 2023 euros and scaled with a 0.6 exponent, as in #489. Customized: your own figure replaces it at every size, with no scaling law; it is then no longer sourced.

Specific FCI applied by sAF capacity

Ex-factory
Installed
Fully financed· this figure

CAPEX at the battery limit0 EUR 2025

Included

Equipment and installation
Indirect and owner's costs
Contingency

Not included

Nothing

Added at project level

Nothing: project mode uses the figure as is

Project figures

Values passed to project mode when this asset is added to a project.

CAPEX to the battery limit: 0 EUR 2025
Fixed O&M: 0 EUR/year
Variable O&M, excluding feedstocks: 0 EUR/year
Asset lifetime: 20 years

Levelised cost of SAF

A standalone indicator for a quick read. Project mode recomputes it for the whole system.

—

Methanol per tonne—
Capital per tonne—
Fixed O&M per tonne—
Hydrogen and power per tonne—

Linked to the balance above

Operating hours90.4 %

Hours per year at the design rate. Sets the SAF actually supplied and spreads the capital and fixed O&M over it. 7920 h is the PNNL on-stream factor; 6132 h is Bube's 70 % utilisation.

Fossil kerosene reference price

EASA reference price of conventional aviation fuel (CAF): 640 EUR/t for 2025, 734 EUR/t for 2024.

Synthetic fuel reference price

EASA reference price of synthetic aviation fuel: 7520 EUR/t weighted average for 2025, range 6710-9525 EUR/t from industrial or biogenic CO2 to atmospheric CO2. It is a production-cost estimate, not a traded price.

e-Methanol price

Delivered renewable methanol, the dominant line of the levelised cost. 963 EUR/t is the default of #489 (Ruokonen et al. 2021). The 800-2000 EUR/t range spans IRENA's e-methanol costs from biogenic CO2 to direct-air-capture CO2.

Planned neat SAF share in the blend

Share of neat MtJ-SPK you plan in the delivered jet fuel. ASTM D7566 caps it at 50 %: above that the blend is not certifiable, a flag is raised and the 50 % cap is used for the blend volumes.

Discount rate (real WACC)

Rate of the capital recovery factor. 6 % is Bube's reference WACC, varied 4-15 %; costs are constant euros, so read it as a real rate.

Economic lifetime

Annuity period of the capital recovery factor, 15 years in Bube et al. (2025).

Levelised cost of SAF by operating hours

Benchmarks

This model's figures against published references and reference cases.

Levelised cost of SAF, EUR/t

4,900 Printed in T&E (2024).

7,520 Printed in EASA 2026 briefing, Table 2.

8,625 Printed in EASA 2026 briefing, Table 1.

9,000 Printed in T&E (2024).

Minimum penalty per tonne not supplied, EUR/t

8,100 Printed in T&E (2024).

16,300 Printed in T&E (2024).

Reference cases at this size and usage

All results

Every model output at the current settings, grouped, with the sensitivity charts.

41 outputs · 6 groups · 11 also shown above, dimmed

Compliance value

Penalty-based price ceiling: ComputingEUR/t
Minimum penalty per tonne not supplied: ComputingEUR/t
Synthetic to fossil price gap: ComputingEUR/t
Ceiling over reference price: Computingratio
Position in the EASA cost range: Computing%
Minimum penalty at EASA 2025 prices: ComputingEUR/t
Minimum penalty at EASA 2024 prices: ComputingEUR/t

Margins

Margin under the ceiling: ComputingEUR/t
Margin at the EASA reference price: ComputingEUR/t
Levelised cost vs EASA reference: Computing%
Methanol price at the ceiling: ComputingEUR/t
Methanol price at the EASA reference: ComputingEUR/t

Levelised cost

Levelised cost of SAF: ComputingEUR/t
Methanol per tonne: ComputingEUR/t
Capital per tonne: ComputingEUR/t
Fixed O&M per tonne: ComputingEUR/t
Hydrogen and power per tonne: ComputingEUR/t
Capital load penalty: Computingratio

Mandate volume

Synthetic sub-mandate: Computing%
EU27 kerosene demand: Computingkt/a
Synthetic sub-mandate volume: Computingkt/a
Sub-mandate share covered: Computing%
SAF supplied: Computingkt/a
SAF supplied (t): Computingt/a
Penalty exposure covered: ComputingMEUR/year
Value at the EASA reference price: ComputingMEUR/year

Blend and certification

MtJ-SPK certification status: Computingcode
Blend limit exceeded: Computingbool
Neat SAF share applied: Computing%
Fossil kerosene per tonne of SAF: Computingt/t
Blended jet fuel enabled: Computingkt/a
Fossil kerosene in the blend: Computingkt/a
Blend share of EU jet demand: Computing%

Plant capital and feed

Plant fixed capital investment: ComputingMEUR
Specific FCI applied: ComputingEUR/(t/a)
Scaled specific FCI (model): ComputingEUR/(t/a)
Annualised capital: ComputingMEUR/year
Fixed O&M: ComputingMEUR/year
Capital recovery factor: Computing1/year
Methanol per tonne of SAF: Computingt/t
Methanol used: Computingkt/a

Sensitivities

4 charts

Penalty, ceiling and margin vs synthetic reference price

Levelised cost components vs operating hours

Margins vs e-methanol price

Sub-mandate share and levelised cost vs capacity

Sources

65 documented assumptions · 10 sources

About

Calculator context

Market and compliance economics of e-SAF under Regulation (EU) 2023/2405 (ReFuelEU Aviation), not a process model. The synthetic sub-mandate (1.2 % of EU jet fuel in 2030-31, 2 % in 2032-34) is enforced by Art. 12: a supplier who falls short pays at least twice the gap between the synthetic and fossil reference prices that EASA publishes, per tonne missing. With the EASA 2025 prices (640 EUR/t fossil, 7520 EUR/t synthetic) that floor is 13 760 EUR/t, and fossil fuel plus penalty gives a ceiling of 14 400 EUR/t: the price at which an obligated supplier is indifferent between buying e-SAF and paying. The ceiling is conservative, because paying does not discharge the obligation (the shortfall carries over), and it is not a price forecast: the bankable reference stays the EASA synthetic price, itself a production-cost estimate since no traded index existed in 2025. Member States may set penalties above the EU floor. The plant's levelised cost is rebuilt with the constants of calculator #489 (integrated MtJ plant, methanol bought in): PNNL-30533 FCI scaled with a 0.6 exponent, Bube et al. (2025) annuity, methanol from a carbon balance (2.95 t per t of SAF), H2 and power at Bube's reference prices. At #489's defaults (100 kt/a, 7920 h, methanol 963 EUR/t, 6 % over 15 years) it gives 3 135 EUR/t, equal to #489 by construction, which is a consistency, not a validation. The margin under the ceiling is then 11 265 EUR/t, and 4 385 EUR/t at the EASA reference price. The prices are 2025 euros and the cost 2023 euros (methanol 2020), not deflated: read the margins as indicative. Against the EU27 kerosene projection for 2030 (48.9 Mt, T&E), the 2030-31 sub-mandate is 587 kt/a and a 100 kt/a plant covers about 17 % of it. The blend check applies the 50 % neat-SAF limit of ASTM D7566. Certification: MtJ-SPK is reported approved in an ASTM D7566 Annex 5 revision published 30 July 2026 (chemie.de, secondary press), while a February 2026 Argus / Methanol Institute piece still expected approval in 2026-27 and CAAFI listed it as not yet annexed. The status is shown as reported approved, primary confirmation pending. The whole value stack also requires RFNBO eligibility. Chaining: this sheet has no physical inlet and its SAF is #489's, so its meta exports no flows and no CAPEX or OPEX. Placing it next to #489 in a project adds no cost and no SAF twice; read #489's capacity and levelised cost into it.

Model

115 variables — inputs, calculations and outputs, with their dependencies.

115 variables shown of 115

Value	Unit	Depends on
100	kt/a	—
7920	h/year	—
1	—	—
640	EUR/t	—
7520	EUR/t	—
963	EUR/t	—
50	%	—
0	—	—
1300	EUR/(t/a)	—
0.06	ratio	—
15	years	—

Variable	Formula	Unit	Depends on
	`if((<=)+(<)+(>)+(<)+(>)+(<=)+(<=)+(<=)+(<=)+(>)+(<)+(>)+(>=)*((<)+(>))+(<)+(>)+(<)>,,)`	—
		h/year
	`*`	t/a
	`/max(*,)`	t/a
	`*/max(,)`	ratio
	`/max(,)`	ratio
	`**`	%
	`/max(,)/max(,)/max(,)`	kg/t
	`/max(*,)`	kWh/t
	`(+)(+)*/max(,)/max(,)`	MEUR
	`/max(,)/max(*,)`	EUR/(t/a)
	`/max(*,)`	ratio
	`/max(,)*`	%

Variable	Formula	Unit	Depends on
	`-`	EUR/t
	`*`	EUR/t
	`+`	EUR/t
	`/max(,)`	ratio
	`(-)/max(-,)*`	%
	`*(-)`	EUR/t
	`*(-)`	EUR/t
	`if(==,,)`	%
	`*`	kt/a
	`**`	kt/a
	`/max(,)*`	%
	`/max(,)`	ratio
	`*/max(,)`	t/a
	`/`	kt/a
	`/max(**,)`	t/t
	`*/`	kt/a
	`clamp(*^(-),,)`	EUR/(t/a)
	`if(>=,,)`	EUR/(t/a)
	`*/`	MEUR
	`if(<,/max(,),(*(+)^)/max((+)^-,))`	1/year
	`*`	MEUR/year
	`**`	MEUR/year
	`*/max(,)`	EUR/t
	`*/max(,)`	EUR/t
	`*`	EUR/t
	`+*`	EUR/t
	`+++`	EUR/t
	`-`	EUR/t
	`-`	EUR/t
	`/max(,)*`	%
	`(-(-))/max(,)`	EUR/t
	`(-(-))/max(,)`	EUR/t
	`*/`	MEUR/year
	`*/`	MEUR/year
	`if(>,,)`	bool
	`min(,)`	%
	`(-)/max(,)`	t/t
	`*/max(,)`	kt/a
	`*`	kt/a
	`/max(,)*`	%
		code

Assumptions

65 assumptions used in the calculations

Prevents division by zero in every guarded denominator.
Market range Not applicable (numerical parameter).
0
Numerical stability constant.
Unity in flags, CRF and ratios.
Market range Not applicable (numerical constant).
1
Numerical constant.
Zero in guards and flags.
Market range Not applicable (numerical constant).
0
Numerical constant.
Converts fractions to percent and bounds percentage inputs.
Market range Not applicable (unit definition).
100%
Unit definition.
Converts percent inputs to fractions.
Market range Not applicable (unit definition).
0.01
Unit definition.
Converts kilotonnes to tonnes.
Market range Not applicable (unit definition).
1000t/kt
Unit definition.
Converts the EU kerosene demand from Mt to kt.
Market range Not applicable (unit definition).
1000kt/Mt
Unit definition.
Converts EUR to MEUR.
Market range Not applicable (unit definition).
1000000
Unit definition.
Converts kWh to MWh for the electricity bill.
Market range Not applicable (unit definition).
0.001MWh/kWh
Unit definition.
Upper limit of the operating hours.
Market range Exact.
8760h/year
Calendar definition.
Converts PNNL's H2 price per pound to a quantity.
Market range Exact.
0.453592kg/lb
Exact definition.
Default fossil kerosene (CAF) reference price and lower edge of its slider. Also enters the published-price penalty reference.
Market range 640 (EASA 2025 prices) to 734 (EASA 2024 prices) EUR/t.
640EUR/t
Printed in EASA 2026 briefing, Table 2.
Upper edge of the fossil kerosene slider and fossil leg of the 2024 published-price penalty reference.
Market range
734EUR/t
Printed in EASA 2025 briefing, Table 2.
Default synthetic aviation fuel reference price, the price Member States use as reference for the Art. 12 penalty. EASA builds it from production-cost estimates: no real index price existed in 2025.
Market range Weighted-average range 6,710-9,525 EUR/t (EASA Table 1).
7520EUR/t
Printed in EASA 2026 briefing, Table 2.
Synthetic leg of the 2024 published-price penalty reference.
Market range Single published value for 2024.
7695EUR/t
Printed in EASA 2025 briefing, Table 2.
Lower edge of the synthetic price slider and of the EASA range used to place the chosen price.
Market range
6710EUR/t
Printed in EASA 2026 briefing, Table 1.
Upper edge of the synthetic price slider: the high end of the atmospheric-CO2 sub-category.
Market range
9525EUR/t
Printed in EASA 2026 briefing, Table 1.
EU-wide floor of the penalty multiplier. It is held fixed at 2: Member States may set higher penalties, which only raises the ceiling, so the result is the conservative EU minimum.
Market range At least 2 (EU floor); national levels may be higher.
2
Art. 12 as paraphrased by T&E; the regulation text itself was not machine-read in this session, hence medium.
Synthetic-fuel sub-mandate of the 2030-31 compliance period (average of Annex I).
Market range 1.2 % (2030-31), 2 % (2032-34), 5 % (2035).
1.2%
Regulation (EU) 2023/2405 Annex I, as printed by the Observatory and T&E.
Synthetic-fuel sub-mandate of the 2032-34 compliance period.
Market range 1.2 % (2030-31), 2 % (2032-34), 5 % (2035).
2%
Regulation (EU) 2023/2405 Annex I, as printed by the Observatory.
Code of the 2030-31 compliance period in the selector.
Market range Not applicable (code).
1
Selector convention.
Code of the 2032-34 compliance period in the selector.
Market range Not applicable (code).
2
Selector convention.
Fuel base the synthetic sub-mandate applies to. Held at its 2030 value for both compliance periods: a 2032-34 demand figure was not taken from the source, so the 2032-34 volume is an approximation.
Market range No independent projection cited.
48.9Mt
Printed in the T&E table (p. 15). A projection, not a statistic.
Maximum share of neat MtJ-SPK in the blend: at least 50 % vol conventional kerosene. Applied by volume in the standard and by mass here, the two being close for paraffinic and conventional jet.
Market range 50 % for annexed synthetic paraffinic kerosenes.
50%
Secondary trade press; the ASTM D7566 revision history itself was not read.
Certification status code shown as an output: 1 = not annexed, 2 = reported approved (D7566 A5 revision, July 2026), primary-source confirmation pending, 3 = confirmed in the standard. The whole value stack is conditional on certification and on RFNBO eligibility.
Market range
2
Set from secondary press; to be moved to 3 only after reading the ASTM revision.
Design hours of the plant: the SAF capacity input is the nameplate at 7920 h/a, as in calculator #489.
Market range Bube et al. (2025) use 6132 h (70 % utilisation); PNNL uses 7920 h.
7920h/year
Printed in PNNL-30533 Table 2.
Lower edge of the operating-hours domain.
Market range
6132h/year
Printed in Bube Table 4.
Share of methanol carbon that ends in liquid fuels, reference case of #489.
Market range
85%
Printed in Bube et al. (2024).
Kerosene share of the liquid-product carbon: turns the total-product efficiency into a kerosene efficiency and the SAF capacity into a total-fuel capacity.
Market range About 90 % (Bube 2024); Ruokonen et al. (2021) run a gasoline- and diesel-rich slate.
90%
Printed in Bube et al. (2024).
Methanol carbon mass fraction (0.3749).
Market range Exact to the digits used.
32.042g/mol
NIST.
Carbon mass fractions of methanol and of the SAF proxy.
Market range Exact to the digits used.
12.011g/mol
IUPAC.
SAF is represented by paraffinic C12H26 for its carbon mass fraction (0.8461).
Market range C10-C14 n-paraffins span 0.844-0.847 carbon mass fraction.
170.34g/mol
NIST.
Carbon atoms in the SAF proxy molecule.
Market range Exact.
12
Molecular formula.
Installed cost of the MTO, oligomerisation, hydrotreating and fractionation section: anchor of the plant FCI used to rebuild the levelised cost of SAF, as in #489.
Market range Single anchor; #489 publishes its gap to Ruokonen et al. (2021).
60.1MUSD
Printed in PNNL-30533 Table 12.
Builds TIC up to total direct cost.
Market range PNNL convention for nth-plant estimates.
18.5%
Printed in PNNL-30533 Table 3.
Builds total direct cost up to fixed capital investment.
Market range PNNL convention for nth-plant estimates.
60%
Printed in PNNL-30533 Table 3.
Index PNNL uses for its 2019 dollars.
Market range Published CEPCI 2019 annual average is 607.5.
541.7
Printed in PNNL-30533.
Escalates the 2019 anchor to 2023 euros, the cost year of #489.
Market range Single published index value.
797.9
Published index.
Converts the escalated PNNL anchor and PNNL's H2 price to euros.
Market range Rate taken from the cost-method source, not a market average.
1.19USD/EUR
Printed in Bube (2025).
Reference size of the capital scaling law: liquid-fuel capacity of the PNNL anchor plant.
Market range Anchor plant only.
129.14kt/a
Derived from printed PNNL flows and on-stream factor.
Exponent of the capacity-cost law FCI = FCI_anchor x (capacity / anchor)^0.6 on the total-fuel nameplate, as in #489. 0.6 is the low end of PNNL's range.
Market range
0.6
Printed in PNNL-30533 Eq. (3).
Floor of the clamp on the scaled specific FCI and lower limit of a Customized value. It does not bind inside the slider domain (model value 513-3237 EUR/(t/a) over the slider corners).
Market range Not a market value.
100EUR/(t/a)
Guard rail.
Ceiling of the clamp on the scaled specific FCI and upper limit of a Customized value. It does not bind inside the slider domain.
Market range Not a market value.
10000EUR/(t/a)
Guard rail.
Whole-plant fixed operating costs; over the whole-plant FCI it gives 5.47 % of FCI per year.
Market range PNNL nth-plant convention; no independent range cited for the ratio.
21.9MUSD/year
Printed in PNNL Table 12; ratio derived.
Denominator of the fixed O&M ratio.
Market range Whole PNNL plant including upstream sections.
400.7MUSD
Printed in PNNL Table 12.
Annual H2 cost of the PNNL plant; divided by the H2 price and the fuel output it gives the make-up (14.8 kg/t fuel), as in #489.
Market range
4MUSD/year
Printed in PNNL Table 12; make-up derived.
Converts PNNL's H2 cost line back to a quantity.
Market range PNNL price assumption only.
0.95USD/lb
Printed in PNNL Table 11.
Net electricity per tonne of liquid fuels; no steam credit taken.
Market range Only one published plant-level figure found.
98kWh/t
Printed in Ruokonen Table 5.
Price of the hydrogenation make-up H2, held at Bube's reference case: a small line (about 2.6 % of the levelised cost), so it is not a slider here. Use #489 to vary it.
Market range
5EUR/kg
Printed in Bube Table 4.
Price of the plant's electricity, held at Bube's reference case (about 0.3 % of the levelised cost).
Market range
72EUR/MWh
Printed in Bube Table 4.
Repère: EASA's production-cost estimate for synthetic fuel from atmospheric CO2, the high-cost sub-category.
Market range
8625EUR/t
Printed in EASA 2026 briefing, Table 1.
Low end of T&E's expected e-kerosene selling price, a benchmark for the levelised cost.
Market range
4900EUR/t
Printed in T&E (2024).
High end of T&E's expected e-kerosene selling price.
Market range
9000EUR/t
Printed in T&E (2024).
Low end of the penalty T&E derives from its own e-kerosene price range, a benchmark for the minimum penalty. T&E's fossil price basis differs from EASA's, so the comparison is indicative.
Market range
8100EUR/t
Printed in T&E (2024).
High end of T&E's penalty range.
Market range
16300EUR/t
Printed in T&E (2024).
Biofuel SAF reference price, shown for context only: the synthetic sub-mandate cannot be met with bio-SAF, so it does not enter the synthetic penalty.
Market range Single published value.
1925EUR/t
Printed in EASA 2026 briefing, Table 2.
T&E's 2030 sub-mandate volume. It is the same product (48.9 Mt x 1.2 %) as the model's, so it is a consistency check on the arithmetic, not an independent validation.
Market range Single projection.
0.59Mt
Printed in the T&E table (p. 15).
The levelised cost here is rebuilt with #489's constants, so at #489's defaults it reproduces #489 by construction. That is an identity, not a validation.
Market range Not a market value.
3135EUR/t
Internal.
The methanol slider runs 800-2000 EUR/t: e-methanol, from biogenic CO2 at the low end to direct-air-capture CO2 at the high end, at 1.19 USD/EUR. The default is #489's, so the two calculators agree at their defaults.
Market range 800-2,000 EUR/t e-methanol (IRENA ranges converted at 1.19 USD/EUR).
—EUR/t
IRENA ranges in USD of the study year, not escalated; the slider is a domain, not a forecast.
The penalty-based ceiling is the price at which an obligated fuel supplier is indifferent between buying one tonne of e-SAF and buying fossil kerosene plus paying the minimum penalty. It is conservative, because the penalty does not discharge the obligation, and it is a ceiling, not a price forecast: the bankable reference stays the EASA synthetic price.
Market range Not applicable (statement).
—
Method statement.
The synthetic reference price, and so the penalty and the ceiling, rest on an EASA cost estimate, not on traded prices.
Market range Not applicable (statement).
—
Caveat from the source.
Each Member State sets its own penalty; the EU only fixes the twice-the-price-gap floor. The calculator uses the floor, so a higher national penalty raises the ceiling and the margin.
Market range Not applicable (statement).
—
Regulation, via T&E paraphrase.
Only the period averages (1.2 % in 2030-31, 2 % in 2032-34) are used. 2035 (5 %) is left out because the 2030 demand projection would not be a fair base for it.
Market range Not applicable (statement).
—
Scope statement.
The prices and the levelised cost are in different euro years and are not deflated to one year. The margins are therefore indicative to within the inflation between those years; no deflator is applied because none is cited here. The discount rate is read as real on constant euros, as in Bube et al. (2025).
Market range Not applicable (statement).
—
Cost-basis statement.
This is a valuation sheet, not a process: it has no physical inlet and its SAF is the SAF that #489 makes. Its meta therefore exports no flows and no CAPEX or OPEX, so chaining it next to #489 in a project cannot count the plant or its SAF twice. Link it by reading #489's SAF capacity and levelised cost; the value only exists if the SAF meets the RFNBO threshold (upstream calculator) and MtJ-SPK is certified.
Market range Not applicable (statement).
—
Chaining rule of this asset.