Like other countries, China’s civil aviation industry faces difficulties in fundamentally changing its aviation energy mix, which is primarily reliant on fossil jet fuel in the short term, and the large-scale application of deep decarbonisation technologies that balance availability and affordability. In the long term, as the most populous developing country, China has a vast potential demand for civil aviation transport, making the energy transition very challenging. However, a Five-Year Plan is underway for the green development of the industry. Against this backdrop is an insistence by China that the transition must be fair and equitable to developing countries, particularly regarding ICAO’s CORSIA scheme. Dr David Ma, an expert in Chinese civil aviation climate policy, analyses China’s current position.

As global climate issues intensify, countries around the world are formulating their own net-zero roadmaps in accordance with their national conditions. In 2020, China officially announced its climate goals of “striving to peak carbon dioxide emissions by 2030 and to achieve carbon neutrality by 2060”, incorporating climate change response as a national strategy.

In the following years, China issued guidelines and action plans at the national level, while key industries and sectors introduced implementation plans. The civil aviation industry, being a high-energy-consuming and high-emission sector, is one of the key areas that needs focused attention and improvement to achieve China’s “carbon peaking and carbon neutrality” strategic goals.

To address this, the Civil Aviation Administration of China (CAAC) released the ‘14th Five-Year Plan for Green Development of Civil Aviation’ in 2022, proposing the vision for green development by 2035, including a well-established green low-carbon circular development system, achieving carbon-neutral growth in air transport, and making green civil aviation a distinguished profile in the industry’s international exchanges, positioning China as an important leader in global civil aviation sustainable development.

Meanwhile, at the 41st Assembly Session of International Civil Aviation Organization (ICAO) held in 2022, the Chinese delegation expressed differing positions on the climate change resolution and the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) resolution of agenda item 18. They reserved their stance on the global international aviation 2020 carbon-neutral growth target, the 2050 net-zero carbon target for global international aviation, and the emission reduction mechanisms formed based on these targets, specifically on Articles 6, 7, 9, 17 of the climate change resolution, and the entire text of resolution 18/1 on CORSIA.

The delegation submitted a written reservation to the Secretariat after the meeting, stating they would decide whether and when to withdraw the reservation based on the progress of feasibility analysis of the above targets, the resolution of CORSIA fairness issues and the development of assistance mechanisms for developing countries.

Why does the stance of China’s civil aviation industry on climate change (mainly CORSIA) differ domestically and internationally?

International aviation emissions reduction is an integral part of global climate governance and should adhere to the fundamental principles of global climate governance, particularly the principles of common but differentiated responsibilities, equity and respective capabilities established by the United Nations Framework Convention on Climate Change (UNFCCC) and its Paris Agreement. It should align with the consensus on global climate governance models, allowing countries to independently choose mid-to-long-term goals and implementation pathways best suited to their national conditions.

The historical cumulative emissions of developed countries over nearly 200 years of uncontrolled industrialisation are the primary cause of current climate change. Developed countries have international obligations under the UNFCCC to significantly reduce greenhouse gas emissions ahead of developing and emerging market countries and to provide sufficient financial, technical and capacity-building assistance to developing countries.

China’s CORSIA position

In its working paper A41-WP/468 submitted to ICAO’s 41st Assembly, China explained its proposal to implement CORSIA through Nationally Determined Plans to Implement the CORSIA (NDPIC) and to establish a regular review method for CORSIA (see Figure 1 below). The document argues that to avoid any market distortions caused by CORSIA and to enhance the effectiveness of its implementation, a framework for a NPDIC should be established. This would allow each country to determine its own implementation rules and frameworks, subject to technical review by ICAO. Regarding regular reviews of CORSIA, the document proposes the establishment of a CORSIA Review Working Group, which would develop a set of evaluation metrics based on the guidelines for designing and implementing market-based measures (MBMs) provided in the appendix to resolution A40-18.

Figure 1: Framework of the Nationally Determined Plans To Implement The CORSIA (NDPIC) proposed by China

In working paper A41-WP/469, China elaborated on its stance and suggestions regarding the targets and measures for international aviation carbon emissions reduction. The document contends that the current CORSIA implementation plan and standards, which are based on ICAO’s goal of carbon-neutral growth starting from 2020 (CNG2020), do not conform to international law and the basic principles of global climate governance. It argues that if developed countries do not fulfil their international obligations under the United Nations Framework Convention on Climate Change (UNFCCC) through ICAO, developing countries will be deprived of fair development opportunities. The specific points are as follows:

In contrast to its stance at ICAO, China is cautiously advancing the implementation of market mechanisms domestically. The Civil Aviation Administration of China (CAAC) proposed in its Five-Year Plan in 2022 to “coordinate the construction of domestic and international carbon markets, and promote the establishment of a market-based carbon reduction mechanism for aviation activities.”

China actively promoting SAF

In contrast to CORSIA, China actively promotes SAF. In working paper A41-WP/468, China proposed that “countries refer to relevant ICAO standards or guidelines to determine sustainable aviation fuels and/or low-carbon aviation fuels recognised by their governments.” The Five-Year Plan aims to “promote breakthroughs in the commercial application of sustainable aviation fuels, striving to achieve an annual consumption of more than 20,000 tonnes of sustainable aviation fuels by 2025,” and targets a cumulative SAF consumption of 50,000 tonnes from 2020 to 2025.

It defines SAF as “aviation fuels that meet aviation airworthiness standards and sustainability evaluation standards for aviation fuels.” At the project level, it proposes to accelerate the establishment of a sustainable aviation fuel certification system and fully promote the construction of an airworthiness certification system for sustainable aviation fuels. It aims to conduct regular application demonstrations of sustainable aviation fuels, pilot blended supply models of sustainable aviation fuels at airports with an annual passenger throughput of more than 5 million in regions such as Beijing-Tianjin-Hebei, Yangtze River Delta, Guangdong-Hong Kong-Macao Greater Bay Area, Chengdu, Chongqing and Hainan, and support related airports in accelerating the construction of supporting infrastructure.

The latest news is that the CAAC has identified SAF, the carbon market and efficiency improvements as the three main directions for the green transition of civil aviation in the next five years (2025-2030).

The inconsistency between China’s domestic actions and international commitments on civil aviation’s climate change stance can be found in the Five-Year Plan. It pledges to: “Adhere to independent emission reduction actions, undertake emission reduction responsibilities commensurate with China’s national conditions, the development stage of civil aviation and its capabilities. Fully participate in the global governance process for sustainable development of international civil aviation, uphold the correct view of justice and interests, follow the principles of equity, common but differentiated responsibilities and respective capabilities, strengthen the application of international law, advocate for the establishment of a new international civil aviation emission reduction order with wide participation, independent contributions, mutual learning and benefit sharing, propose more Chinese solutions, promote a balance of obligations and rights, and demonstrate China’s image as a responsible major country.”

From this, several key points can be summarised:

■ Independent emission reductions and independent contributions.
■ The principle of equity and the extension to the principle of common but differentiated responsibilities and respective capabilities.
■ The ‘Chinese solution’.

Accelerating the energy transition

To achieve the goals of “carbon peaking and carbon neutrality”, China’s energy industry is steadfastly accelerating the energy transition, shifting the primary energy source from fossil fuels to non-fossil fuels. As a hard-to-abate sector, the civil aviation industry must make significant adjustments based on China’s macro situation to overcome resource and environmental constraints.

According to roadmaps by IATA, carbon emissions need to be reduced by 1.8 billion tonnes by 2050, with 65% of the emissions reduced through SAF, 13% through new engine propulsion technologies (such as hydrogen), 3% through efficiency improvements and the remainder through carbon capture and storage (11%) and offsets (8%). These measures are reflected in the Five-Year Plan.

Chinese civil aviation has positioned the energy transition, led by SAF, as a crucial node in fostering “new quality productivity” in the latest round of technological and industrial transformation, to achieve a new phase of high-quality development in civil aviation. This also demonstrates the significant role of Chinese civil aviation in building a community with a shared future for mankind. Therefore, China is very proactive and efficient in promoting SAF and other emission reduction measures, recognising that the issue is no longer whether to do it, but how to do it and how to do it well.

In terms of specific actions, due to the differences in national conditions and development stages compared to developed countries in advanced countries and the significant growth needed in the civil aviation transport market in the future, along with the two binding carbon targets of 2030 and 2060 set by the state, China has chosen more pragmatic independent actions, including emission reduction targets and measures. Chinese civil aviation’s vision is that every country should actively contribute to combating climate change but should make independent decisions based on their circumstances, rather than a one-size-fits-all approach.

Principle of equity

In its submitted position papers, China does not oppose the market mechanism of CORSIA, as it has already initiated a national emissions trading system, with civil aviation soon to be included. What Chinese civil aviation disputes is the lack of the principle of equity in CORSIA’s resolution and mechanism design. They often use this metaphor: requiring a growing teenager to diet along with an overweight adult is unfair.

The principle of ‘equity’ emphasises that the responsibilities and measures for emission reductions should consider the historical emissions, economic development levels and emission reduction capabilities of different countries. Developed countries that have competed industrialisation, having accumulated significant historical emissions during their industrialisation process, should bear greater emission reduction responsibilities and provide more financial and technological support. Meanwhile, developing countries need to gradually increase their emission reduction efforts based on their capabilities, promoting sustainable development.

Only on the basis of equity can countries achieve common but differentiated responsibilities and jointly address the severe challenge of global warming. An equitable emission reduction scheme not only promotes international cooperation but also ensures the well-being and environmental sustainability of people worldwide. This climate change principle contrasts with the ‘non-discrimination’ principle of commercial operations in international aviation. However, many developing countries, represented by China, unanimously demand that ICAO reflects the principle of equity in its emission reduction mechanisms.

Unfortunately, only textual confirmation is provided, and it is not reflected in the CORSIA mechanism design. If the climate change principle and aviation operation principle cannot be balanced within the ICAO framework, discrepancies in any emission reduction negotiations and discussions will persist.

China’s anticipated stance at ICAO’s next Assembly

At the ICAO 42nd Assembly in September 2025, China is expected to maintain its established stance, reiterating concerns regarding CORSIA, the implementation paths and standards associated with it, and the 2050 global international aviation carbon-neutrality goal. China believes these targets and pathways are inherently unfair and disadvantageous to developing countries.

Furthermore, because there is currently no intersection between ICAO’s work path and China’s, and with China effectively and confidently taking independent climate actions and involving its national ETS, China will persist with its established stance. The Chinese civil aviation sector will align with the national targets of “achieving carbon peaking by 2030 and carbon neutrality by 2060”, and will not prematurely declare that the aviation industry will achieve carbon neutrality ahead of schedule. Consequently, China will, to a large extent, not join CORSIA’s mandatory implementation phase in 2027.

The ‘Chinese solution’

Chinese civil aviation has made significant progress in responding to climate change and promoting sustainable development. Through the promotion of advanced fuel technologies, optimised route designs and enhanced air traffic management efficiency, China has significantly reduced carbon emissions. Additionally, Chinese civil aviation actively participates in international emission reduction initiatives, sharing experiences with global aviation organisations and counterparts to jointly address global climate challenges. With this series of emission reduction plans, Chinese civil aviation not only demonstrates a firm commitment to reducing carbon dioxide emissions but also strives to achieve significant results through practical actions. These efforts have enabled Chinese civil aviation to confidently push the ‘Chinese solution’, contributing wisdom and strength to the sustainable development of the global aviation industry.

China’s confidence in promoting the ‘Chinese solution’ includes not only technological innovation and operational efficiency improvement but also policy support and international cooperation. Through solid emission reduction actions and comprehensive emission reduction plans, China aims to establish a good international image and demonstrate its responsibility as a major country.

The introduction of the ‘Chinese solution’ will provide valuable experience and a model for the green transition of the global aviation industry, contributing to achieving global carbon neutrality targets. The solution will not only consider ICAO’s resolutions but also reflect its domestic climate change initiative actions, especially as the civil aviation industry is about to be included in the national ETS, which will significantly advance the deployment of CORSIA and SAF, a prospect worth looking forward to.

Photo (H. Goussé, Airbus): Air China A350-900

About the author

David Ma

Dr Xiangshan (David) Ma, who has long worked in China’s civil aviation industry, has been involved in tackling climate change and has experienced the historical transition of China’s civil aviation from energy conservation and emission reduction to carbon neutrality. After leaving the civil aviation industry, he has worked with the Global CCS Institute, Energy Foundation China, GIZ, and FutureCoal (formerly World Coal Association) on CCU/S and energy transition. Currently, he serves as an independent consultant on energy transition and climate change. He can be contacted at maxiangshan.2010@tsinghua.org.cn.

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Views expressed in Commentary op-ed articles do not necessarily represent those of GreenAir.

Production of sustainable aviation fuel in the Asia-Pacific region has been boosted by three new projects in which major airlines Qantas, Cathay Pacific and All Nippon Airways (ANA) are key partners. In Australia, Qantas, Airbus and the Queensland state government will invest in a new alcohol-to-jet production facility planned by bioenergy company Jet Zero Australia and US-based fuel technology group LanzaJet, using locally sourced agricultural feedstock including sugar cane. Hong Kong-based Cathay Pacific has signed a Memorandum of Understanding to partner with mainland China’s State Power Investment Corporation (SPIC) in the development of four new SAF plants using a pathway similar to power-to-liquids. And in Japan, ANA, the country’s largest airline, has agreed to introduce SAF blended locally by ITOCHU Corporation to help power domestic and international flights from Tokyo’s two major airports, Haneda and Narita. The initiatives support commitments by all three airlines that SAF will comprise 10% of their total jet fuel consumption by 2030.

The Australian collaboration centres on the construction by Jet Zero Australia of a new SAF plant in North Queensland using LanzaJet’s alcohol-to-jet technology to produce up to 100 million litres of sustainable fuel per year. The Qantas Group, Australia’s largest airline operator, together with Airbus, will jointly invest A$2 million ($1.34m) of an initial A$6 million ($4m) capital raising, to which the Queensland government will contribute a further A$760,000 ($500,700), with the balance to be provided by Australian and international institutional funds. Collectively, this capital will be used to undertake a detailed feasibility study, and early-stage development of the project, with construction expected to start in 2024.

Andrew Parker, Qantas Group’s Chief Sustainability Officer, said the project was part of a A$200 million joint commitment with Airbus to progress the development of a SAF production industry in Australia, and one of several projects the airline is looking to fund this year.

“Sustainable aviation fuel is critical to the decarbonisation of the aviation industry,” he said. “This investment will help kickstart an innovative project to turn agricultural by-products into sustainable aviation fuel and create a significant domestic biofuels refinery.”

Qantas is currently using SAF sourced overseas to power commercial flights from London and expects to add San Francisco and Los Angeles in 2025.

Airbus’ Executive VP Corporate Affairs and Sustainability, Julie Kitcher, said there was “a growing positive momentum around SAF, and now is the time to move from commitments to concrete actions. The selection of the first investment under our joint partnership with Qantas is an example of such action, with the potential to deliver SAF locally in Australia and to be a model for other locations around the world.”  

Queensland’s Deputy Premier, Steven Miles, said a rich supply of feedstock meant the state was well-positioned to become a key player in SAF development. “It’s exciting to think that Queensland could be producing the millions of litres of SAF needed to power flights across Australia and around the globe, creating more regional jobs in the process,” he said. 

In addition to deploying its alcohol-to-jet technology in the project, said LanzaJet CEO Jimmy Samartzis, “it is equally gratifying to know its impact in developing the domestic agricultural industry, providing a path for energy security, and enhancing the country’s national security posture and greater fuel independence.” LanzaJet said Australia was the second-biggest emitter of carbon per capita on domestic flights.

Ed Mason, CEO of JetZero Australia, which was established in 2021, welcomed the strong investment support for the new SAF plant, which will use surplus ethanol from agricultural and sugar cane by-products to create the new fuel, and acknowledged LanzaJet’s industry leadership in developing alcohol-to-jet fuel technology, with the mechanical completion of its Freedom Pines facility in the US state of Georgia expected later this year. “We are excited to work with them,” said Mason, “to help Australian businesses and government drive real reductions in aviation emissions.”   

In Hong Kong, Cathay Pacific signed an MoU to partner with State Power Investment Corporation (SPIC), which plans to commission four SAF plants in mainland China between 2024 and 2026, each facility capable of producing 50,000 to 100,000 tonnes of SAF per year. SPIC is one of China’s biggest state-owned energy companies and claims the world’s largest solar power installed capacity. The new SAF plants will use a process similar to power-to-liquids’ (PtL) in which renewable electricity is converted into liquid fuels.

“The signing of our cooperation pact is an important milestone in SPIC’s sustainable development pursuits and a significant contribution by a Chinese enterprise towards supporting sustainable development in the global aviation sector,” said the corporation’s chairman Qian Zhimin. “We hope both parties can build on our collaboration in the certification and purchase of SAF to further cooperate in areas pertaining to the industry supply chain, project development and securing the necessary policy support.”

Cathay Pacific Group CEO Ronald Lam said the partnership combined the corporation’s clean energy strengths and the airline’s expertise as an end user of SAF. “Under the MoU, Cathay Pacific will share international experience, and also feedback on the SAF certification process, value chain and overall market know-how to facilitate SPIC in the successful establishment of four plants in the Chinese mainland,” he reported.

In Japan, ANA will procure its first supplies of locally blended SAF for use on domestic and international flights from Tokyo’s Haneda and Narita airports. The SAF solution to be blended will be provided by renewable fuel producer Neste, and blended in Japan by ITOCHU Corporation, as part of a public-private partnership led by the Civil Aviation Bureau of the Ministry of Land, Infrastructure, Transport and Tourism. 

Photo: Cathay Pacific

A new report produced by a Chinese independent energy think tank has highlighted the lack of government support as a major barrier to the production and use of sustainable aviation fuel in China, the world’s second largest aviation market. In a 64-page paper titled ‘The Present and Future of Sustainable Aviation Fuels in China’, the Institute of Energy (IOE), a research and development body affiliated with Peking University in Beijing, says Chinese fuel producers, distributors and airlines, which are mainly state-owned, were reluctant to commit to SAF without explicit policy signals from central government. “Globally, SAF consumption increased from 6,000 tons in 2016 to 80,000 tons in 2021, but most of such consumption happened in the West,” it adds. “To date there has been no meaningful demand for SAF in China.” The Institute has urged a package of measures including clear plans and favourable policies for SAF development, establishment of a SAF research and development system, and pilot programmes for the use of SAF produced from various feedstocks.

The report was produced in line with the Institute’s Climate Change and Energy Transition Program, launched in March 2021 to provide policy recommendations and support to the Chinese government by setting science-based goals, identifying necessary steps and developing action plans for energy evolution. “Carbon emissions from aviation only account for about 1% of China’s total carbon emissions,” says the SAF report. “But given the fact that China has already reached the late stage of industrialisation, the carbon emissions caused by the development scale of traditional heavy industries will gradually reach a plateau. It is estimated that carbon emissions from these industries will go down in the next 10 years. By contrast, carbon emissions from the ever-growing aviation industry will be something to be reckoned with. The absence of top-down designs at the central government level will create a high level of uncertainty for the industry’s development.”

Because of their state ownership, the report says entities across the aviation sector “will remain hesitant, waiting for explicit policy signals from the government” on SAF initiatives. Under China’s 14th Five-Year Plan for Green Civil Aviation Development, the country is aiming to build SAF consumption to 50,000 tons by 2025, but, comments the IOE: “This is not a mandatory target and pales in comparison with conventional aviation fuel consumption that amounts to 30 to 40 million tons per year (2018-2019). It can hardly bolster the confidence of airlines and producers in making more SAF commitments.”

With the exception of Hong Kong-based Cathay Pacific, which the report acknowledges has been active in promoting, using and acquiring SAF since 2016, the IOE says large airlines based on the Chinese mainland “have not specified any plan, goal or pathway regarding SAF use”, instead continuously planning until they are required to use the fuel.

“In terms of market demand, without a mandatory SAF target, airlines will not take it as an urgent priority to promote SAF use and therefore have not introduced any further plans in this field except for the few test flights between 2011 and 2017. In terms of investment, large fuel suppliers such as SINOPEC and China National Petroleum Corporation will find it difficult to establish medium and long-term strategies for SAF production due to the tiny SAF market and the lack of clear policy signals,” says the report.

“SAF remains a nascent market in China. On the demand side, airlines in mainland China have only conducted four tests of aircraft flying on SAF since 2011, including commercial test flights. On the supply side, only two companies are truly capable of producing SAF, but remain at the trial production stage, with a designed annual capacity of approximately 150,000 tons. China still lags behind western countries which have been constantly experimenting with SAF over the past 10-plus years, with a momentum increasingly built up over the past several years.”  

China has abundant feedstocks from which to produce SAF, from Hydroprocessed Esters and Fatty Acids (HEFA) such as waste cooking oils, which currently comprise the most common base for the fuels, to other sources including agricultural and forestry wastes, municipal organic solid wastes, industrial gases, energy crops and green hydrogen, of which much greater supplies are available, and which will progressively increase in use as a fuel ingredient.

While dedicated SAF production facilities were limited in China, the report observes that conversion of existing fuel plants could accelerate supplies. “Practically, in China it would usually take two to three years to build a new SAF production facility with an annual capacity of 100,000 tons. The time can be shortened to months or approximately one year if an existing Hydrogenated Vegetable Oil (HVO) facility or a refining facility with hydrogenation or hydrogen production systems is transformed.”

If no additional SAF or HVO production capacity was built, and existing facilities were expanded or repurposed to maximise SAF output, the report estimates that China’s total SAF production could reach 2.05 million tons in 2025, accounting for 4.5% of China’s total aviation fuel consumption. 

It also draws attention to China’s significant support for biodiesel fuel production and electric vehicle development, to contrast the lack of support for SAF development and to highlight possibilities if the low-carbon aviation fuel were to receive similar support. “China exempts biodiesel that conforms to national standards from consumption taxes, and grants a refund of 70% of value-added tax,” says the IOE. ”By contrast, no targeted support measures have been instituted in the SAF industry.”

The report recommends the Chinese government to develop “explicit plans and favourable policies” to help advance the development of a SAF industry, and “to leverage fiscal funding to channel private sector capital into SAF-related industries.” It also recommends:

• the formation of a cross-ministerial coordination mechanism to help progress SAF development;
• better collection and collation of information on feedstocks and development pathways to help facilitate better allocation of resources to the industry;
• innovative collaboration between SAF industry partners;
• the establishment of a SAF research and development system to promote diversified development of the fuels; and
• China pilot the use of SAF variants produced from different feedstocks and through a range of technology pathways.

“If China moves early to industrialise SAF production and releases explicit policy signals, it will not only help complete its SAF supply chain and accelerate the post-Covid green recovery of its aviation industry, but will also help itself gain more initiative when participating in the development and improvement of rules on carbon emissions reduction by the global aviation sector,” concludes the report.

“Generally, the SAF industry faces both challenges and opportunities in China. If internal and external favourable conditions are fully leveraged to unleash the potential of SAF in reducing carbon emissions, the industry will be a strong boost to China’s endeavour to reduce carbon emissions from aviation, peak carbon emissions, achieve carbon neutrality and strengthen energy security.”

Photo (Airbus): A delivery flight from Toulouse of a China Southern A320neo in 2019 was partly fuelled by SAF