Subject: RefuelEU – Clarification Request on Exceptions Handling and National Implementation
From: "Catherine Rowles" <[email-masked]>
To: <[email-masked]>
Date: Mon, 10 Nov 2025 15:03:37 +0200

Dear Estonian Transport Administration

As we support aircraft operators in most EU states, we are writing to seek
clarification regarding the national implementation of the RefuelEU
Aviation Regulation, and specifically how your authority is advising
operators and verifiers to treat exceptions in the current reporting year.

As you will be aware, there remain several operational
scenarios—particularly for ad hoc, business jet, or multi-leg
operators—where RefuelEU uplift requirements cannot be met due to
infrastructure constraints, commercial re-routings, or unavailable fuel
supply. To date, there has been no formal, central guidance on how such
exceptions should be documented or verified.

We would therefore appreciate your response to the following questions:

1.	Has your authority issued specific guidance or clarification to
operators or verifiers on how to handle exceptions to uplift obligations
under RefuelEU?

*	If so, could you please share this guidance or any related
documents?

2.	Do you currently consider infrastructure or operational issues
(e.g. last-minute re-routings, unavailable fuel supply from contracted
suppliers, apron restrictions, etc.) to be grounds for valid exclusion
from the uplift requirement, assuming proper documentation?
3.	Have you formally implemented RefuelEU-specific national
legislation or regulatory amendments, and if so, could you briefly outline
what this means for operators under your jurisdiction?

Thank you for your support and we look forward to your guidance. We would
appreciate it if you could reply by the end of this week.

Kind regards

Catherine Rowles

Carbon and Sustainability Support

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