Subject: Request for clarification : ReFuelEU Aviation
From: "Rayanveer Singh" <[email-masked]>
To: <[email-masked]>
Cc: "Azhar Ahmed Sayeed" <[email-masked]>, "Kaustubh Deshpande" <[email-masked]>, "Lizeth Claudio" <[email-masked]>, "Mathias Grossmann" <[email-masked]>,Nicolas Duchêne <[email-masked]>, "Sasi Kumar" <[email-masked]>, "Satish Kumar" <[email-masked]>, "Chamandeep Bhalla" <[email-masked]>, "Valentijn Ronde" <[email-masked]>, "Anshul Dubey" <[email-masked]>
Date: Thu, 29 May 2025 08:50:08 +0300

Dear Sir/Madam,

I hope this email finds you well.

My name is Rayanveer Katoch, and I am an Aviation Auditor with Normec 
Verifavia, an ISO 14065:2020 and ISO 17029:2019 accredited verification 
body. We are currently engaged in verification activities related to the 
ReFuelEU Aviation Regulation (EU) 2023/2405.

As the first reporting cycle under the ReFuelEU Aviation Regulation 
concludes, we would like to seek clarification on a few points regarding the 
interpretation and reporting requirements of the regulation:

*

	We would appreciate clarification to gain a deeper understanding of the 
data gaps, specifically which flights are considered data gaps and how the 
percentage is calculated. Since the arriving flight is only relevant in case 
of 'yearly tanked quantity for fuel safety rules' (column H) having values, 
will the arriving flight still be a data gap in case the requirements in 
Article 5(1) of the ReFuelEU Aviation Regulation are met, or if an operator 
does not wish to justify any non-tanked quantities.

*

	We would appreciate further clarification regarding the treatment of data 
gaps, particularly in cases where the missing data relates to planned fuels, 
block fuels, or fuel uplift. Could you kindly clarify whether the Estonian 
Transport Administration intends to request aircraft operators to use a 
specific methodology to fill in data gaps, and if so, which one(s)?

*

	We would also appreciate your clarification on the treatment of justified 
fuel quantities in cases where one or more flights departing from or 
arriving at a Union airport are classified as data gaps. Specifically, if an 
operator justifies a 'yearly non-tanked quantity' for a Union airport, but 
one or more flights from that airport are classified as data gaps, should 
all justified fuel from that airport be disregarded? Or should the justified 
fuel still be taken into account based on flights for which complete and 
valid data is available?

*

	If the primary data source (operational flight plans) is unavailable, could 
you please clarify which secondary data sources you consider acceptable to 
obtain the planned and safety fuel values (trip, taxi, contingency, extra, 
destination alternate, final reserve, discretionary, etc.)?

*

	Article 4.3 of the COMMUNICATION FROM THE COMMISSION  C/2024/5997 states 
that "Aircraft operators should ideally keep the justifying documents for a 
minimum of 4 years (i.e., reporting year + 3 years of data retention). This 
period may vary between Member States as national rules on enforcement 
applicable to the sector may prescribe different timelines". Could you 
kindly let us know whether the Estonian Transport Administration intends to 
have any specific requirements related to data retention?

*

	We would also appreciate it if you could inform us whether national 
legislation related to the implementation of the ReFuelEU Aviation 
Regulation 2023/2405 (EU) will have any specificities which are different 
from the ReFuelEU Aviation Regulation.

*

	Has the Estonian Transport Administration decided on the penalty for 
non-compliance with Article 5(1) of the ReFuelEU Aviation Regulation, 
additionally, does the authority intend to penalise non-compliance with 
Article 8(1) of the ReFuelEU Aviation Regulation, that is, in case the 
operators fail to meet the deadline of 31st March of the reporting year?

Please let us know if there will be any specific forms, portals, or national 
guidance documents to be released by the Estonian Transport Administration 
in the coming months.

Thank you for your time and support. We look forward to your response.

Best regards,

Rayanveer Singh
Verifier

Aviation & SAF
		T. +91 7657 889 134

		normecverifavia.com <https://normecverifavia.com/>

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