Clear Skies, Cooler Planet

A Strategic Imperative for Mitigating Aviation’s Contrail Impact in the UK and EU

Policy Landscape

The Policy Horizon: UK and EU Frameworks for Aviation Contrail Mitigation

Mitigating contrail climate effects will require supportive policy and regulatory frameworks. Historically, aviation climate policies (emissions trading systems, fuel standards, etc.) have focused almost exclusively on CO2. However, awareness is growing that non-CO2 impacts like contrails must also be addressed. In Europe, both the EU and UK have begun exploring ways to incorporate contrails into climate policy:

European Union Initiatives

The EU is taking early steps through its new non-CO2 MRV (Monitoring, Reporting, Verification) system. From January 2025, airlines must monitor and report non-CO2 emissions including NOx, soot, SOx, and contrail formation, and the system will calculate a CO2-equivalent impact using multiple time horizon Global Warming Potential (GWP) metrics. This data collection (via the NEATs tool) is intended to inform future policy. In parallel, the EU’s “ReFuelEU Aviation” SAF mandate will ramp up SAF usage from 2% in 2025 to 70% by 2050, with sub-targets for e-fuels. While primarily aimed at CO2 reduction, increasing SAF (which tends to be low-aromatic) could incidentally reduce contrail formation. The European Commission has also funded projects like CICONIA (operational contrail avoidance) and BeCoM (Better Contrails Mitigation) to advance contrail science and mitigation techniques.

United Kingdom’s Approach

The UK’s policy approach is evolving. The UK Emissions Trading Scheme (ETS) currently covers CO2 from domestic and certain international flights, with a cap aligned to net-zero and free allowances for aviation being phased out by 2026. As of now, non-CO2 effects are not included, but the UK Climate Change Committee has explicitly recommended incorporating contrail (and NOx) impacts into climate policy. The UK is mandating SAF use as well, targeting 2% SAF by 2025 up to 22% by 2040 (with sub-targets for Power-to-Liquid fuels and caps on certain pathways). Again, while framed as a CO2 measure, this could drive adoption of low-soot fuels beneficial for contrails. Notably, the UK is investing in research: e.g., the UK’s Aerospace Technology Institute (ATI) is funding studies and technology trials for contrail mitigation, and UK aerospace strategy documents now acknowledge contrails as a climate factor.

Gaps and Opportunities

Current regulations still largely ignore contrails. Neither the EU ETS nor CORSIA accounts for non-CO2 warming. This presents a policy gap but also an opportunity: there are calls to incorporate contrail impacts into emissions trading or create incentive mechanisms for contrail mitigation:contentReference. For instance, as data from the EU’s MRV accumulates, the EU could consider “contrail credits” or CO2-equivalent surcharges to internalize contrail climate costs:contentReference. Another gap is the lack of clear metrics to compare CO2 and contrails; developing a consensus on metrics like GWP* or ATR (Absolute Temperature Potential) will be crucial for fair policy. Both the EU and UK will need to grapple with how to apply the polluter-pays principle to contrails, given the difficulty of attributing specific contrail warming to individual flights and the international nature of air travel:contentReference. The likely path is a system-level approach: e.g., using revenues from a modest non-CO2 levy to fund contrail mitigation research and deployment, rather than per-flight penalties. Overall, there is momentum building in policy circles to address contrails, but concrete regulatory mechanisms are still in nascent stages.