A FREQUENT

FLYING LEVY
IN EUROPE
THE MORAL, ECONOMIC,
AND LEGAL CASE

ecologistas
en acción
A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE
A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

CONTENTS
EXECUTIVE SUMMARY 2

I. INTRODUCTION 4
BUSINESS AS USUAL IN AIR TRAFFIC MEANS DEEP INEQUALITY 4
POLICYMAKERS MUST SECURE PUBLIC BUY-IN TO THE GREEN TRANSITION 6
THIS BRIEFING 6

II. EXISTING POLICIES TO TACKLE AVIATION EMISSIONS 7

FUTURE EMISSIONS FROM EUROPEAN AVIATION AND REFUELEU 7
THE ROLE OF CARBON AND FUEL TAXES 7
THE POLICY GAP 8

III. FREQUENT FLYING LEVY 9

MODELLED LEVY DESIGN 9
RESULTS 10
NATIONAL LEVEL IMPACTS 12

IV. FEASIBILITY CONSIDERATIONS 13

GDPR (GENERAL DATA PROTECTION REGULATION) 14
IDENTIFYING INDIVIDUALS 14
PRICE TRANSPARENCY 14

V. REVENUES 15
HOW AN FFL COULD FINANCE THE EUROPEAN GREEN TRANSITION 16
HOW AN FFL COULD PROVIDE FINANCE FOR THE GLOBAL SOUTH AND SUPPORT
UN CLIMATE FINANCE INSTITUTIONS 16
HOW AN FFL COULD SUPPORT WORKERS AND HELP DELIVER A JUST TRANSITION 17

VII. CONCLUSIONS AND INITIAL RECOMMENDATIONS 18

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A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

on the lowest incomes (under £/€20,000 per year).

Meanwhile, among the lowest-income group,

EXECUTIVE almost 70% of households do not fly in any given

year, compared with just over 20% among the

SUMMARY highest-income households.

Current policy sees air traffic exempted from most

standard forms of taxation (eg fuel duty and VAT).
Not only does this reduce state revenues, it means

E uropean air traffic presents one of the continent’s that the polluter does not pay and leaves the
largest obstacles to halting climate breakdown industry with insufficient incentive to cut emissions.
and achieving the climate goals subscribed to Applying a fuel duty on kerosene, or another form
in international and European law. Before the of comprehensive carbon tax, on flights must be an
Covid-19 pandemic, the sector’s impact was rising urgent priority. In its absence, governments should
rapidly. All indications suggest this trend is now also explore implementing meaningful distance
resuming. Additional climate damage arising surcharges on ticket taxes. However, as the price
from the growth in air traffic has out-stripped effect of any such measures will create a much
modest reductions delivered through technological larger relative barrier for those on low incomes
advancements. A wide range of expert bodies has compared to those on high incomes, we advocate
advised that technological solutions and alternative supplementing fuel tax and regulatory measures
fuels are limited and a sole reliance on these will not with a frequent flying levy (FFL). Indeed, we see an
be sufficient to align the sector with internationally FFL as a key tool for ensuring the public perceives
agreed climate commitments. EU and national climate action as fair and averting a backlash
government policy to date has been inadequate against politicians and the wider green transition.
compared with the scale of the challenge and does
not guarantee emissions reductions on behalf of Under an FFL a ticket tax is applied to each single
society. flight taken by an individual. The tax rate rises
incrementally after every two single flights taken (ie
Stronger policy is needed, but Europe has already after every return flight). It can support the green
begun to experience the backlash which can transition in three key ways:
develop if climate action does not deliver fair
and feel fair. If we are to secure a rapid global 1. Help to significantly cut aviation emissions
transition to avoid climate breakdown, European in the short to medium term, delivering
policymakers must have a clear view of two key the necessary savings that technological
dimensions of the unfairness of aviation’s climate developments cannot. Our tested policy design,
damage: first, the inequity between those nations if implemented in the example year 2028, is
responsible for emissions (largely in Europe and calculated to be able to deliver a 21% drop in
North America) versus those experiencing the most European aviation carbon emissions.
acute climate-driven loss and damage (largely in
2. Protect access to flying for infrequent, lower-
the Global South); and second, the inequity within
income passengers while managing overall
nations between the minority who fly frequently
air traffic levels and making polluters pay.
(typically the wealthiest groups) and the majority
The levy results in no change to the taxes paid
who fly rarely or not at all.
by 72% of the population in western Europe.
Globally, 1% of the world’s population produces Households earning over £/€100,000 per year
50% of aviation emissions, while approximately are four times more likely to pay the levy than
80% have never set foot on a plane.1 Within households earning under £/€20,000. Instead,
western Europe, our analysis shows that the the majority (54%) of savings come from
highest-income households (over £/€100,000 individuals who would otherwise have taken
per year) are at least six times more likely to take four or more return flights per year, a group
three or more return flights per year than those representing just 4.5% of the western European
population.

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A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

3. Raise significant funds for use in accelerating widely recognised AERO MS model, as well as
Europe’s transition to a fairer, greener a New Economics Foundation (NEF) analysis of
economy. These can recompense those nations recent polling by More in Common. We also set
least responsible for the climate crisis for out a potential roadmap to the implementation
damages experienced, and support workers of such a policy, assessing the feasibility and how
and communities with jobs or local businesses legal obstacles might be overcome, grounded in
directly in, or heavily reliant on, air travel. Our a legal analysis by AdaStone Law. An FFL offers
tested policy design raises €63.6bn in additional a fair, feasible, fast route to getting emissions for
tax revenues across Europe. European aviation on track. The levy works best
if combined with other policy measures aimed at
In this report, we evidence the effectiveness of cutting emissions, including a kerosene/carbon tax
the FFL policy based on analysis grounded in on all flights departing European airports.
an economic assessment by CE Delft, using the

A QUICK GUIDE TO A
FREQUENT FLYING LEVY IN EUROPE
WHO PAYS? Reductions in flying are
secured overwhelmingly
The majority (54%) of from higher-income
the reduction in flying social groups.
will come from just
4.5% of the western
European population
that fly the most. 63%
72% of the population 15%
in western Europe, of households of households
those who fly the least, with income with income
will pay no FFL charges. < £/€20,000 > £/€100,000
pay the levy pay the levy

HOW MUCH IS RAISED? HOW MUCH IS SAVED?

The additional taxes
paid through the
€63.6bn There is a 21% carbon
emissions reduction
21%
FFL deliver a €63.6bn (by introducing the
increase (607%) in € FFL in the example
net tax revenues. year 2028).

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A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

ready for escalating climate damage. New sources

of revenues are urgently needed to invest in

I. INTRODUCTION solutions including speeding up the deployment of

renewables and energy efficiency; expanding public
transport and rail and investing in adaptation; as
well as diversifying economies reliant on high-
carbon industries and mass air-travel-based tourism.

G lobal governments face a rapidly closing

window during which they must implement
the policy solutions which are required to limit
While some within the aviation sector place their
faith solely in the development and roll-out of
global heating to as close to 1.5°C above pre- low-carbon technologies and alternative fuels, this
industrial levels as possible. Despite the escalating confidence that technology and fuel change alone
gravity of the climate threat, currently, committed will fix the problem is not shared by a wide array
action will fall well short of creating a safe and of expert bodies. Independent assessments have
stable climate.2 New research shows climate consistently identified a need to manage levels of air
damages already outweigh the costs of mitigation traffic if climate targets are to be met.9 In particular,
efforts,3 which makes rapid and wide-reaching the International Energy Agency’s Net Zero by 2050
climate action common sense. scenario requires demand controls limiting long-
haul air traffic to 2019 levels – a challenging task
Different sectors of the European economy have given current rates of growth.10 This needs to be
made varying rates of progress in cutting their part of a wider effort to achieve substantial energy
emissions over recent years. Notably, transport, demand reductions, as meeting climate targets
agriculture, and construction have delivered no will be extremely difficult and expensive to achieve
material overall emissions reduction over the past without reducing overall energy demand.11 With the
decade.4 Air transport has been a particularly poor growth in demand for air traffic widespread, this
performer. Before the Covid-19 pandemic, carbon is likely to require much more stringent and active
emissions from EU air departures were rising public management of the air transport system.
rapidly, from 120 MtCO2 in 2015 to 150 MtCO2 in Concerns have also been raised about the viability
2019.5 Small efficiency gains made by the industry and wider social and environmental costs of some of
were immediately eaten up by further growth. Add the proposed alternative lower-carbon fuels.12
to this the non-carbon impacts of air traffic, which
have tripled the net climate damage of the industry,6 BUSINESS AS USUAL IN AIR TRAFFIC MEANS
and air traffic emerges as Europe’s biggest obstacle DEEP INEQUALITY
to cutting its climate damage.
The Intergovernmental Panel on Climate Change
European air traffic is continuing to see rapid (IPCC) has set out the remaining quantity of global
growth following the pandemic. But global society carbon (and other gases) emissions which can be
can ill-afford a return to the climate-damaging considered ‘compatible’ with limiting warming to
trend seen pre-Covid. Very significant growth is the level targeted by the Paris Climate Agreement of
projected in aviation markets outside Europe,7 in “well below 2 degrees”.13 This remaining quantity
nations with historically lower per-person carbon can be considered our ‘carbon budget’. Depending
emissions and air traffic. Europe, with its history of on how this is calculated, if non-CO2 impacts are
climate damage, has a responsibility to lead, not lag, included, and how much aviation is considered
when it comes to tackling aviation’s contribution to a luxury or essential good, aviation’s share of the
the climate crisis. budget can vary. However, it is clear that to avoid
climate breakdown, air traffic must stay within
The call to action on air traffic emissions presents ecological limits.
broader opportunities. Beyond the aviation sector,
there is a significant lack of international and CE Delft calculated in its reporti that at current rates
European public investment8 in transitioning of efficiency, without considering non-CO2 effects,
economies to zero emissions and ensuring we are and assuming the aviation sector’s remaining

i CE Delft analysis assumes a constant emissions share for the aviation sector out to 2050 and targets a 50% chance of limiting
warming to 1.5 degrees.
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A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

carbon budget is shared equally among all global This frequent flyer group comes overwhelmingly
citizens, every individual could take up to four from Europe’s highest-income households. Our
economy short-haul return flights (eg Amsterdam to analysis of More in Common polling14 shows that
Barcelona), or one economy long-haul return flight in western Europe, the highest-income households
(eg Amsterdam to Tokyo), in total over the next 26 (over £/€100,000 per year) are at least six times more
years. If the current, unequal, distribution of aviation likely to take three or more flights per year (in this
emissions between the global north and south was case for holiday purposes) than those on the lowest
accepted, the share of each European citizen would incomes (under £/€20,000 per year). Meanwhile,
rise to ten economy short-haul return flights or among the lowest income group, almost 70% of
three economy long-haul return flights. In reality, households do not fly in any given year, compared
a mix of short- and long-haul flights will likely be with just over 20% among the highest income
taken, meaning remaining allocations somewhere in households (Figure 1).
between these two examples.
If current trends continue, an over-sized share of
While the carbon efficiency of air traffic may the remaining emissions budget for air traffic will be
improve over coming years and increase this consumed by wealthier social groups who typically
allocation slightly (up to a highly unlikely theoretical fly more frequently, longer cumulative distances,
maximum of 50%, eg 15 short-haul return trips in more damaging ways (eg in a private jet or in
or 4.5 long-haul) this small remaining allocation business/first class where emissions shares per
means a new policy is urgently required. Without passenger are significantly higher). Failing to get
action, the remaining budget will be consumed to grips with aviation’s large and growing climate
within a matter of a few years, primarily by a very damage also has consequences beyond the aviation
small minority of frequent flyers. sector. The larger the share of our remaining

FIGURE 1: PROPORTION OF RESPONDENTS FLYING AT DIFFERENT FREQUENCIES (LAST 12

MONTHS) GROUPED BY HOUSEHOLD INCOME AGGREGATED ACROSS THE UNITED KINGDOM,
GERMANY, NETHERLANDS, BELGIUM, FRANCE, AND SPAIN

80

No holidays by airplane Three or more holidays by airplane

69%
70

60%
60

52% 52%
50

42%
Percentage

40
35%

30%
30

21%
19%
20
15%
11%
9% 9%
10
5%

0
0-£/€19,999 £/€20,000 £/€30,000 £/€40,000 £/€50,000 £/€100,000 Average
-£/€29,999 -£/€39,999 -£/€49,999 -£/€99,999 or more

Source: NEF analysis of More in Common polling

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A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

emissions budget consumed by air traffic, the THIS BRIEFING

smaller the share available to other essential parts
This briefing looks at the potential role of an
of the economy, such as food and domestic heating.
FFL, a proposal which sees the relative tax paid
These areas also face carbon reduction challenges
incrementally increase as more flights are taken.
but represent services more critical to societal
The policy acts across three core objectives:
welfare than commercial aviation.
1. Cutting overall traffic, and hence emissions, such
The social inequity of aviation emissions can be
that the aviation sector is on track for net zero,
seen within European countries, between income
and consuming a globally fair share of remaining
groups, and between countries. In particular, the
emissions.
Global South contributes significantly less to global
aviation emissions but is expected to experience a 2. Recognising the need for a basic minimum
disproportionate share of climate-driven loss and of international travel and encouraging its
damage. For example, one study has suggested that distribution in a fair way.
despite Africa being home to 15% of the global
population, African residents are responsible for 3. Raising funds to recompense nations, particularly
just 2% of global aviation emissions. Meanwhile, the least well-off and least-responsible, for
in 2018, Europe’s aviation emissions were almost climate-driven loss and damage they experience.
three times greater than the emissions of Africa and
Latin America combined.15 It seeks to understand the proposed FFL from the
basis of (i) its impact in the EU across areas such as
POLICYMAKERS MUST SECURE PUBLIC BUY-IN emissions, demand for flying, and different social
TO THE GREEN TRANSITION groups; and (ii) how it might be implemented and
any relevant legal considerations. Supporting this
For a successful, ethical, and rapid transition to a briefing across these two areas (i and ii) are two
zero-carbon economy, governments must deliver commissioned reports:
climate policy in a way that is fair in both design
and communication. In other words, policies must • A model-based exercise looking at the economic
be fair, and they must feel fair. To date, governments dynamics of an FFL applied to European air
across Europe have struggled to build confidence in traffic, underpinned by the widely regarded
the public, and particularly affected industries, that AERO-MS forecast model. CE Delft, 202416
the transition to a zero-carbon economy is in their referred to henceforth as analysis by CE Delft.
interests.
• A legal feasibility assessment looking at the
Controlling levels of air traffic is essential but also alignment of an FFL with existing EU legislation
entails risks. While air travel is disproportionately and any regulatory changes that might be
enjoyed by wealthier frequent flyers, policy to cut its required. AdaStone Law, 2024 referred to
climate impact may restrict access to air travel for a henceforth as the legal assessment.
larger group of less well-off, infrequent, passengers.
Indeed there is an argument that progressive
tax and spend measures are needed alongside
already-legislated EU policy measures such as
the Emissions Trading System and ReFuelEU in
order not to exclusively price out lower-income
households from flying. If the policy is regressive
or is perceived as unfair, there is a risk of losing
commitment from this group to the common goal
of decarbonisation.

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A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

ReFuelEU will likely drive up prices for air travel

but provides no guaranteed level of overall

II. EXISTING emissions reduction. Indeed, with no direct

demand management policies in the ReFuelEU

POLICIES TO package, it is conceivable (though unlikely) that

emissions could increase. Rising demand fuelling

TACKLE AVIATION more trips and longer distances travelled, alongside

the poor performance of alternative fuels in cutting

EMISSIONS net carbon emissions, could continue to out-strip

emissions reduction progress. Meanwhile, non-
carbon emissions, which are not addressed by
ReFuelEU, could continue to deliver the majority of
aviation’s climate damage.
FUTURE EMISSIONS FROM EUROPEAN
Analysis by CE Delft suggests that the best-case
AVIATION AND REFUELEU
impact of the ReFuelEU policy on emissions still
Strong regulation will be crucial to drive aviation means an insufficient reduction in climate damage.
towards climate compatibility. The centrepiece of This is particularly the case when considering
the EU’s legislation in this regard is ReFuelEU, what might represent a fair European share of the
a new law under the European Green Deal remaining global emissions budget. As shown
package which mandates that 70% of aviation in CE Delft analysis, an assumption underpins
fuel be sourced from fuel substitutes or (so-called most forecasts for European aviation carbon
sustainable aviation fuels (SAFs)) by 2050. By 2030, reduction that Europe can continue consuming a
the goal is 6%, and by 2035 it is 20%. Before the disproportionate share of the remaining carbon
adoption of ReFuelEU, modelling by the European budget. If the budget were uniformly distributed
Union Aviation Safety Agency projected minimal across global citizens, Europe’s shareii would
change in European aviation emissions all the equate to around 6.4%. This would require Europe
way out to 2050.17 Modelling by the European to deliver a rate of carbon reduction far faster
Commission for the ReFuelEU policy process than implied by ReFuelEU. Even if Europe’s share
argues that the policy could reduce the sector’s is taken as 16.4%, based on its socioeconomic
emissions by up to 60% against the pre-policy development status, ReFuelEU still does not deliver
implementation forecast.18 decarbonisation fast enough, and leaves Europe
heavily dependent on carbon removal technologies,
While ReFuelEU is likely to drive some emissions which do not yet exist at scale and are likely to be
reductions, they will not happen in the short term costly both in financial and energy terms.
(when they are most needed), and the size of the
reduction remains uncertain. The aviation sector
THE ROLE OF CARBON AND FUEL TAXES
has missed all but one of 50 climate targets set
in the 21st century.19 Progress will depend on the Carbon charges and offsetting obligations are
industry’s success in developing and scaling up also part of the climate policy mix for European
the fuels the policy seeks to promote, and proving aviation. While air traffic has been in the scope
their ability to deliver true, long-term, emissions of the Emissions Trading Scheme (ETS) for some
reduction. While the legislation includes provisions time, airlines initially received significant protection
to encourage sourcing of fossil fuel substitutes from through the allocation of free emissions allowances.
advanced biofuels and e-kerosene – variants of While those allowances are now being rolled back,
so-called SAFs – with purportedly more sustainable exposing airlines to the full market price of ETS
credentials, doubts remain regarding the net carbon emissions permits, the market price remains
environmental impact of even the most promising relatively low, with little impact on ticket prices and
variants of so-called SAF, as well as the trade-offs demand for air traffic.
these fuels create (eg the loss of land and energy
available for other uses such as food, heating, and
local transport).

ii Here we refer to the Europe31 countries defined by CE Delft.

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A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

A key limitation to the effectiveness of the ETS THE POLICY GAP

is that it currently only applies to flights within
Overall, sufficient measures are not currently in
Europe, meaning long-haul traffic outside of
place to guarantee that the emissions reductions
Europe incurs no charge. In the international
required from aviation are achieved. Analysis of
arena, negotiations have established the Carbon
carbon budgets against existing policy by CE Delft
Offsetting and Reduction Scheme for International
shows that the current trajectory will lead to either
Aviation (CORSIA) mechanism. CORSIA places
an overshoot of internationally agreed global
an obligation on airlines to purchase approved
warming targets or extremely costly and disruptive
emission offsets for emissions arising above a
future emergency action to belatedly cut emissions
historic baseline. This design feature means that
using technologies that may or may not ultimately
the majority of existing air traffic is effectively
materialise.
exempt from the CORSIA mechanism. In addition,
offset obligations can currently be purchased Whether through the tightening of existing
at an extremely low price, and there is concern measures, or the introduction of new measures,
regarding the true effectiveness of the offsets in it seems inevitable that the cost of flying is going
reducing emissions. Offsetting projects also have a to rise. Without action, this increase will impact
very poor record when it comes to the protection poorer groups who fly infrequently relatively more
of human rights and ecosystem [Link] The EU than it affects wealthy frequent flyers. This poses a
has committed to reviewing the effectiveness of risk to public acceptance of the measures required,
CORSIA in 2026, and will consider expanding the and potentially also to public support for the wider
ETS to cover non-EU destinations should CORSIA climate transition at the speed and scale required.
be deemed ineffective at reducing emissions.
There is a very strong case for a new policy
A privilege of the European aviation sector is its measure which will control air traffic emissions
broad exemption from fuel taxes and VAT. In other in the short-to-medium term, and possibly also
industries such taxes are common and create an for the long term. The idea of a new aviation tax
added incentive for individuals and businesses mechanism, grounded in international solidarity, is
to switch to alternative fuels or reduce demand. not new. In 2005, nine countries, including France,
Despite long-running diplomatic efforts in the EU, implemented a solidarity tax on air tickets. Since
a fuel tax has yet to be extended to aviation. The its introduction, hundreds of millions of euro have
proposal is, however, part of the EU’s Fit for 55 been raised for Unitaid and its work diagnosing
plans. In October 2023, it was rumoured that such a and treating diseases such as malaria and HIV/
tax was still under serious consideration, but with a AIDS. While aviation umbrella groups such as the
decision deferred until after the 2024 elections.20 International Air Transport Association (IATA) have
strongly protested the tax, its ultimate impact on
Some states levy a departure tax or duty on air
the sector is suggested to have been minimal both
travel tickets. Some tax short-haul flights higher,
in terms of ticket price impacts and competition
as the journeys can easily be shifted to ground
between taxed and un-taxed countries.22 Neither is
transport; others tax long-haul higher, as they are
it a new idea to vary the relative tax rates applied
most emission intensive. The relative value of these
to air tickets according to the social merits of the
taxes is low when compared with the value of other
flight in question. For many years, governments
tax exemptions and is highly variable between
across Europe have provided tax relief on air routes
nations. For further information see Transport and
to remote locations for social as well as economic
Environment (2023) who estimate that by 2025,
objectives. The ETS operates similarly for a social
European governments will be missing out on
purpose, levying a charge aimed at supporting the
€47bn in potential revenue from aviation.21
common goal of carbon emissions reduction.

iii See for example Carbon Brief’s work mapping 61 reports of carbon offsetting failures around the globe: [Link]
[Link]/carbon-offsets-2023/[Link]
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A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

Alternatively, employers might compensate

employees for levies incurred for private journeys

III. FREQUENT because of previous professional trips.

FLYING LEVY The setting of the tariffs within the FFL can also be
conducted in a range of different ways. Our initial
position was that the tariffs should be set according
to the climate need, ie tariffs should be set at a level
high enough to deliver all of the traffic reduction
required to put aviation on a fast and fair transition.
MODELLED LEVY DESIGN
However, it became apparent from our initial tests
Our analysis is illustrative, demonstrating the that aviation’s climate problem is so great, and its
potential impacts and effectiveness of a levy. Our overshoot of a reasonable emissions trajectory so
core design replaces existing ticket taxes with a large, that this would require an extraordinarily
single common European approach but imitates high tax rate that is unlikely to be politically
many typical features of existing national ticket feasible. A suite of policy measures would be
taxes. In line with the German and French ticket required. As such, our subsequent analysis is based
taxes, the tax rises for longer-distance journeys. on our subjective judgement of what might
This feature might be removed if the EU were to represent a politically feasible tariff that also
successfully deliver an effective aviation fuel duty. delivers meaningful emissions reduction fairly. The
In line with the UK government’s ticket tax, an FFL tariff levels tested by CE Delft are shown in
additional surcharge is applied to flights made in Table 1.
business and first class. Also in line with the UK
government’s approach to ticket taxes, a double CE Delft’s analysis looks at different ways of
rate is applied to tickets for flights departing the calculating a fair remaining carbon budget for
implementing zone (in our case Europe) and no tax European aviation. Their work arrives at a range
is levied on flights entering the zone. of levels of emissions reduction required in the
immediate short term of between -25% and -82%.
In CE Delft’s modelling, no distinction was made The lower-end estimate involves aviation’s share
between those passengers flying for business of emissions in Europe increasing considerably
purposes (typically 10%–20%) and those travelling over the coming decades. Given the largely non-
for leisure (including holidays and visiting friends essential nature of most air traffic and the other
and family). However, other studies looking at the important areas of the economy also facing major
design of an FFL have suggested that corporate carbon reduction challenges, we regard a fair short-
travel could be subject to a separate levy scheme.23 term emissions reduction to be at least -45%.

TABLE 1: THE FFL PRICING SCHEDULE TESTED BY CE DELFT, SHOWING CHARGES APPLIED
PER SINGLE FLIGHT RISING EVERY TWO FLIGHTS, AND ADDITIONAL SURCHARGES FOR
LONGER DISTANCES AND COMFORT CLASSES

Flight count Surcharge Surcharge

General FFL Surcharge long
within a medium haul per business/first
per flight haul per flight
12-month period flight class per flight

1&2 0 €50 €100 €100

3&4 €50 €50 €100 €100

5&6 €100 €50 €100 €100

7&8 €200 €50 €100 €100

9 or more €400 €50 €100 €100

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A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

TABLE 2: CORE IMPACTS OF AN FFL IMPLEMENTED IN 2028 AGAINST A BASELINE,

NO-FFL-POLICY SCENARIO

Baseline scenario 2028 FFL scenario 2028 % change

Passenger journeys 1137mn 844mn -26%

Carbon emissions 188.5 Mt 148.6 Mt -21%

Taxation revenues €10.5bn €74.1bn 607%

Targeting a short-term reduction of -45% our RESULTS

proposed tax can deliver approximately half of the
The FFL proves highly effective as an instrument
necessary emissions reduction in aviation. Further
for bringing down emissions and raising revenue.
measures would therefore be necessary. These
The tested levy design delivers a 26% reduction in
could include caps on the number of flights, such
passengers in 2028 which leads to a 21% reduction
as at Amsterdam’s Schiphol airport, slot reduction
in carbon emissions (Table 2). A similar reduction
policies, and limits on especially problematic
in non-carbon emissions impacts on the climate
flights such as routes possible to travel by train,
is likely but has not been modelled explicitly by
night flights, or private jets and limits on the more
CE Delft. The additional taxes paid through the
damaging comfort classes of travel (e.g. business
FFL deliver a €63.6bn increase (607%) in net tax
class passengers have significantly higher emissions
revenues. By using the tax revenues to invest to
per-seat). Meaningful European and international
advance emission reductions, climate adaptation
kerosene taxes would also be important, in which
and nature restoration the positive impact of the
case the FFL could be reduced to its core idea of a
FFL would be even bigger.
progressive tax, without the distance surcharges.
Any measures, including an FFL, which reduce The majority (54%) of these savings are secured
demand for flying are likely to deliver benefits also from passengers who would otherwise have flown
in reducing aviation’s non-carbon emissions and four or more return flights per year (Figure 2) – a
their climate impacts. However, as these likely group which constitutes just 4.5% of the population
make up the majority of the damage to the climate in western Europe. Individuals taking just one
caused by air traffic, further specific policies will return flight per year are minimally affected,
also be needed in this area. especially if flying short-haul. This is because, in our
modelling, the first two single flights (i.e. the first
The model developed by CE Delft tests the impact
return flight) are exempt from the FFL (although a
of the FFL in 2028 against the baseline forecast
distance/class surcharge and/or carbon tax would
without an FFL policy. CE Delft has also provided
still be paid). This also means those customers
additional sensitivity analysis exploring the impact
flying from countries with existing ticket taxes could
of some of the assumptions in the policy design.
see a reduction in price on their first flight. Using
CE Delft’s model of the FFL takes as its air traffic
polling data provided by More in Common, we
forecast input data from the Aviation Emissions and
can see that in most western European countries
evaluation of Reduction Options Modelling System
around 70% of the population would be unaffected
(AERO-MS). This model is the favoured model of
by the FFL, as they either do not fly at all, or they
the European Commission and is owned by the
take only one return flight per year.25
European Union Aviation Safety Agency (EASA).
Price elasticities are used to simulate the passenger
demand response resulting from future changes in
ticket prices due to the implementation of an FFL.
Full details on the modelling assumptions can be
found in CE Delft’s report.24

10
A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

FIGURE 2: PASSENGER DEMAND GROUPED BY THE NUMBER OF RETURN FLIGHTS TAKEN PER
YEAR IN THE WITH- AND WITHOUT-FFL SCENARIOS

600 -90

Baseline scenario 2028 FFL % change

-80
500
-70

400 -60

Percentage
Passengers (millions)

-50
300
-40

200 -30

-20
100
-10

0 0
One Two Three Four Five or more

Return flights

Source: CE Delft, 2024

Reductions in flying are secured overwhelmingly FFL (not considering distance/class surcharges)
from higher-income social groups. In western than households on the lowest incomes. Just 28%
Europe, the highest-income households (eg of households pay any charge, falling to 15%
households earning over £/€100,000) are more than among households earning under £/€20,000 per
four times more likely to pay any charge under the year (Figure 3).

FIGURE 3: THE PROPORTION OF HOUSEHOLDS IMPACTED BY THE FREQUENT FLYING LEVY

CHARGES BROKEN DOWN BY INCOME GROUP AGGREGATED ACROSS THE UNITED KINGDOM,
GERMANY, NETHERLANDS, BELGIUM, FRANCE, AND SPAIN

70

63%

60

50
45%

40
Percentage

34%

30 28%
25%

21%
20
15%

10

0
0-£/€19,999 £/€20,000 £/€30,000 £/€40,000 £/€50,000 £/€100,000 Average
-£/€29,999 -£/€39,999 -£/€49,999 -£/€99,999 or more

Source: NEF analysis of More in Common polling

11
A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

NATIONAL LEVEL IMPACTS their share of transfer passengers. As transfer flights

are not charged an additional levy, countries with
The general trends at the national level are
a larger share of transfer passengers (Netherlands
consistent between European nations. Frequent
and UK) see a lower proportionate decline in air
flying activity is reduced, primarily through cuts to
traffic. As shown in Table 3, very significant new
the flights of wealthier social groups. The primary
revenues accrue to all governments.
driver of differences between nations depends on

TABLE 3: KEY DATA ON FREQUENT FLYING AND THE IMPACT OF AN FFL IN

SIX EUROPEAN COUNTRIES (WHERE DETAILED DATA WAS AVAILABLE)

Change in
Proportion of Proportion of Change in Additional
national
the population the population passenger revenue
aviation
Country flying more paying at journeys raised
emissions
than three least one FFL in the FFL in FFL
in the FFL
times per year charge scenario scenario
scenario

Belgium 5.8% 34.0% -33% -28% €1664m

France 2.7% 20.5% -33% -25% €9899m

Germany 6.4% 26.5% -20% -17% €8328m

Netherlands 5.5% 36.5% -12% -12% €3018m

Spain 4.8% 26.6% -33% -28% €8097m

United Kingdom 4.7% 25.3% -22% -17% €9108m

12
A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

Taxes are also in scope. EU-level taxes can be

implemented for environmental reasons and

IV. FEASIBILITY where necessary to strengthen the single market.

It seems likely that the FFL would qualify in both

CONSIDERATIONS categories as it is primarily an environmental tax

and harmonising air ticket taxes would strengthen
the single market. At present, national air ticket
taxes are inconsistent across Europe. Given the
international, cross-border, dynamics of air traffic,

A n FFL is legally possible at the EU level and

the national level. On the fundamental matter
of pan-European aviation taxes in general, a 2005
and the freedom of movement of passengers to
access departure airports across intra-EU borders,
there is a strong case for moving towards a
European Commission analysis26 of the voluntary consistent framework for air ticket taxation across
participation of member states in an international Europe. This would support the delivery of a level
scheme introducing a mandatory levy for passengers playing field and the integrity of the Single Market.
at the national level argued that the Commission
said: “no specific legal constraints would prohibit The example of the Solidarity Tax implemented by
the implementation of such a scheme”. Indeed, France and a selection of non-European nations
there are several national examples of airline taxes, shows that it is not essential for all nations in
including an eco-contributioniv on French flights, Europe to sign up to such a tax. Nonetheless, there
that demonstrate governments’ power and interest should be a pan-European approach, particularly
in creating novel air ticket taxes. for a tax with the features of the FFL (ie requiring a
degree of tracking of individual travel).
From a legal perspective, the Principle of
Subsidiarity (Treaty on European Union, Article A challenge in this regard will be the need
5(3)), which defines the circumstances in which it for unanimity among member states for the
is preferable for action to be taken at the EU level implementation of a new EU taxation measure.
rather than by member states, suggests that both Despite the unanimity rule, there are examples
environment and transport represent areas where where tax progress has been made. Member states
competence is shared. agreed to a Council Directive that establishes a
global minimum level of taxation for multinational
Today, the EU operates common environmental enterprise groups and large-scale domestic groups
and climate policies. The EU environment policy that was adopted under the special legislative
notably adheres to the polluter pays principle, procedure. Nevertheless, tax issues are controversial
which mandates that the emitter of pollutants and, for example, the revision of the Energy
must cover the costs associated with combating Taxation Directive continues to be stuck.29 Some
pollution.27 This approach ensures a partial politicians are arguing for institutional reforms
internalisation of costs, enabling the imposition of that could see more topics, potentially including
taxes or charges on polluters rather than burdening tax, be decided through qualified majority voting.30
the entire community. However, some argue that However, in case unanimity was needed and would
this principle is not being effectively implemented not be achieved in the relevant time frame, single
in the aviation industry due to the sector’s countries or an alliance of the willing should be the
prolonged under-taxation and over-subsidisation, first step for implementing the FFL.
leading to artificially low prices for air travel.28 Both
the EU Emissions Trading Scheme and European
Plastic Contribution are relevant examples of
coordinated regulation for environmental aims that
enshrine the polluter pays principle, and despite
neither representing taxation measures in the most
technical sense both are similar in effect.

iv An eco-contribution has been made in addition to the Solidarity Tax since 2020.
13
A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

The legal advice we have commissioned from AdaStone Law assesses the legal feasibility
of the implementation of some form of FFL in Europe. The main challenges to consider are the
following:

GDPR (GENERAL DATA PROTECTION PRICE TRANSPARENCY

REGULATION)
Another challenge is to take into account the
At the EU level, the EUDPR31 lays down rules obligation provided by Article 23 of Regulation
on how EU institutions, bodies, offices, and 1008/2008 stating that all unavoidable and
agencies should treat the personal data they hold foreseeable taxes must be included in the first
on individuals. The implementation of an FFL and final price for the ticket presented to the
will require either the tracking of an individual’s customer. This requires that ticket sellers be
flight data or at least the ability of a tax authority somehow ‘aware’ of an individual’s FFL status
to investigate an individual’s flight data to ensure (ie the number of flights previously taken in
adherence to tax rules. The main challenge will the year) at the point of presenting the ticket
be ensuring that the FFL complies with the price. Ideally, the European Commission and
subsidiarity/proportionality test, ie to justify Council would grant either an amendment to
why the imposition of a tax for environmental this legislation or a re-interpretation which
and social purposes takes precedence over the would allow additional flexibility for sellers. The
right to privacy over movement data, therefore idea that ticket sellers would contact the flight
justifying the establishment of a database tracking database before the sales process seems
of passengers. While data is, in fact, already onerous. With a small amount of flexibility, it
tracked for security purposes, such security might be possible that the individual would
objectives are protected by a stronger position voluntarily enter into the ticket search box
in the proportionality test. Our legal advice (when adding their destination, dates, etc.) their
suggests that securing a GDPR-compatible number of flights within the past tax year to
FFL design should be possible, conditional on obtain an initial quoted price inclusive of their
the EU establishing a sound legal basis that estimated FFL tax. Once the individual had
there is a public interest in individual travel selected their flight, and proceeded through the
data being tracked and that this interest passes booking confirmation process, formal contact
the proportionality test when considering an would be made with the passenger database to
individual’s right to privacy. confirm the accuracy of their self-declared data.

IDENTIFYING INDIVIDUALS
As regards intra-EU flights, EU nationals have
the right to fly with either a valid passport or an
identity card. This adds a layer of complexity to
tracking the flight behaviour of an individual.
Given this limitation, and the GDPR concerns,
our analysis suggests that the most efficient
implementation approach would be through the
creation of a unique passenger identifier number.
This number would be the link to a centrally
managed database tracking flight numbers
which would be accessed by the ticket seller
during the final stages of the sales process. The
use of such traveller numbers is increasingly
common. In the USA, some 27 million
individuals have a Known Traveller Number. This
government-managed identifier is principally
designed to speed up the processing of traveller
security information.

14
A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

Second, governments need to increase progressive

taxation. There is a need to increase both taxes

V. REVENUES on polluting activities, such as frequent flying, as

well as taxation of the wealthiest to ensure they
contribute their fair share towards necessary public
investments.

T he global transition demands a substantial The FFL will be an important component of a

increase in capital investment, estimated at strategy to finance both European and Global
around $3.5tn annually until 2050. While a portion South mitigation and adaptation efforts. Our
of this investment will be reduced by decreased analysis shows that an FFL could generate €74.1bn
spending on fossil fuels, the net investment gap annually for the 31 European countries analysed
still equates to $3tn annually, equivalent to 1.3% and €56.4bn for the EU27. This would be a €63.6bn
of the anticipated average annual global GDP over increase in tax revenue for 31 European countries
the next three decades. The biggest challenge lies and a €50.9bn increase for the EU27 relative to
in directing investments toward middle- and low- existing ticket taxes. For context, this budget is
income countries. It is estimated that a fourfold similar to the EU’s spending on the Common
increase from current levels to approximately Agricultural Policy (CAP) which cost €55.7bn in
$900bn per year by 2030 is required.32 Moreover, the 2021.41 These additional tax revenues could pay
UN says there is an annual financing shortfall for for expanding our public transport systems, bike
adaptation of $194bn to $366bn.33 Loss and damage infrastructure, renewable energy production, and
in the Global South are estimated at $425bn in 2020 energy efficiency and contribute to the EU paying
and $671bn in 2030.34 Some of the investment to its fair share of global climate finance and loss and
cover these costs will come from private investors, damage.
but a significant increase in public investment will
be needed to transition our economies, protect Our proposal for generating tax revenue from
people and livelihoods from the growing climate an aviation levy originates from a long-lasting
impacts, and rebuild following loss and damage. call from Least Developing Countries in 2008
to introduce an International Air Passenger
In Europe, governments will need to boost public Adaptation Levy (IAPAL) to raise revenue from
investments by at least €260bn per year35 to fulfil aviation to provide more adequate funding for
their climate commitments, while an additional adaptation activities.42 Also in COP28, using an
€192bn36 is needed to meet social (eg schools, aviation tax has again been discussed for the
hospitals, and housing) investment gaps. A recent grossly underfunded Loss & Damage Fund.43
analysis by NEF and the European Trade Union
Confederation37 found that under new EU fiscal Another proposal was made by the ICCT in its
rules – rules governing national borrowing and 2022 report, stating that raising $121bn in revenue
spending – only three member states would have in 2019 would have been possible with an FFL
sufficient public spending capacity to meet these starting at $9 for a person’s second flight to $177
investment gaps. Additional financing will be for their twentieth flight within the same year.44
needed to invest in protecting the EU from rapidly They propose that the revenues would be given to
growing climate risks.38 the industry for decarbonisation, in other words,
for technological development. We argue for not
To overcome the global and EU investment gaps, using the revenues collected from frequent flying
governments will need, first, to allow more safe for direct support to the industry, as they are profit-
borrowing to invest in quality public services oriented rather than public interest organisations,
and the green transition. Such investments will have waited decades to proceed with the needed
pay for themselves as they have high multiplier technological advancements, have received billions
effects,39 reduce future costs to public coffers from in bailout money during Covid, and continue to
preventable environmental damage (including be further subsidised. Revenues raised should
health),40 build more resilient economies and therefore be directly used for building alternatives
societies, as well as contribute to debt sustainability. to aviation and taking on responsibility for the
historic and current climate debt.

15
A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

There is also a need to recognise that there will ensure repayment. First, the EU can introduce
be some communities, in Europe and globally, additional ‘own resources’, the EU’s term for tax
that are dependent on tourism that will be incomes. Second, the EU budget could see cuts
negatively affected by an FFL. Also, the Covid-19 in spending. Third, member states could increase
pandemic drastically showed what happens to their contributions to the EU budget – which is the
regions solely dependent on tourism. Some of default option. The preferable option would be to
the funds generated should therefore be used to implement new EU-level taxes or own resources to
support communities that have grown dependent finance debt repayments.
on mass tourism and related services to build
links through more sustainable transport modes, A pilot programme in several member states could
particularly ground-based public transport, and to also be envisioned with participating member
diversify their economies in a self-determined and states using the revenues to advance the domestic
sustainable way. transition, as well as increasing their contributions
to global loss and damage and climate mitigation.
HOW AN FFL COULD FINANCE THE EUROPEAN
GREEN TRANSITION HOW AN FFL COULD PROVIDE FINANCE
FOR THE GLOBAL SOUTH AND SUPPORT UN
New EU fiscal rules limit the scope for additional
CLIMATE FINANCE INSTITUTIONS
national public investments to achieve climate
and energy targets, as they require debt and deficit On the global level, how to finance the green
reductions, meaning 16 member states will have transition is emerging as the single most important
to make budget cuts,45 rather than incentivise issue.46 Current financing falls far short of what is
green public investment. This means the EU required. Global North governments must urgently
will need to raise taxes nationally or at the EU increase their contributions to loss and damage and
level and create new common European debt to global climate mitigation and adaptation. While
secure the necessary public investments in climate upwards of $1tn in financing for adaptation and
mitigation and adaptation in the EU. This increase mitigation is estimated to be needed by 2030,47
in public spending could go towards expanding there is also the matter of compensation for loss
and upgrading Europe’s rail system, expanding and damage, which should take the form of a direct
public transport in cities and rural communities transfer rather than a financing arrangement. While
and making them more accessible and affordable, estimates vary, one study has suggested loss and
expanding renewable energy production, damage worth $580bn could be incurred in 2030.48
retrofitting homes, and delivering a targeted and
conditional industrial policy. Such investments Implementing an FFL in Europe would generate
not only reduce emissions but also are essential to sufficient financial resources to allocate a share to
ensure a socially fair transition as well as improve Global South adaptation and mitigation financing
the productive capacity of Europe’s economy. and/or loss and damage compensation. To have
a real impact, on top of pledges already made by
New EU-level taxes could also make the creation some national governments, consistent and long-
of an EU investment vehicle more likely. An EU term revenues are needed that are truly additional
investment vehicle, which means EU borrowing above existing foreign aid spending. There is
on capital markets to create a public investment growing international acceptance that new taxes
fund, could allow the EU to frontload crucial green are required to support mitigation and adaptation
and social investments allowing cost-sharing efforts in the Global South. This is reflected, for
between generations, meaning the cost of public example, in the 2023 launch of a new taskforce,
investment is spread over time. The EU’s Recovery initiated by France and Kenya, to push for new
and Resilience Facility, which was implemented as taxes and levies that raise funds for the transition.49
a response to economic and social repercussions of New kinds of taxes are also covered within United
the Covid-19 pandemic and the Russian invasion Nations Framework Convention on Climate
of Ukraine, serves as a model for such a European Change (UNFCCC) documents under the heading
investment drive. There are several options to “innovative sources of finance”.50

16
A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

Allocating a share of the FFL revenues to HOW AN FFL COULD SUPPORT WORKERS
international development funds has precedent. AND HELP DELIVER A JUST TRANSITION
Since 2006, several countries have adopted a
CE Delft’s modelling, presented in this briefing,
solidarity levy on airline tickets, following the 2005
analyses the full implementation of an FFL in the
UN Declaration on Innovative Sources of Financing
example year of 2028. As urgent action is required,
for Development. This could provide a blueprint
an earlier implementation is preferred but could be
of repeating using revenues from taxing aviation,
approached as a phased roll-out to give workers
largely enjoyed by wealthier people in the Global
and the industry time to adapt to the demand
North, to support the Global South.
reduction. It is key to protect the livelihoods of
workers in a well-planned just transition, where
A significant portion of the revenues from an FFL
social dialogue with workers, communities, and
should be earmarked to finance both mitigation
unions is fundamental at all stages and all levels.
efforts and support loss and damage. One way to
achieve this would be for FFL revenues to feed into
Previous discussions and papers produced in
an international public investment fund, to finance
collaboration with aviation sector unions have
mitigation efforts worldwide and create an ongoing
identified several important measures,52,53 such
stream of proceeds for climate grants in the Global
as (i) promoting the creation of alternative
South, and potentially for cash dividends for
employment, particularly in the most affected
people facing climate risk. Some ‘cap and share’
regions, preferably decent secure jobs in sectors
proposals offer structures of this kind and have
that build climate resilience; (ii) Investing in
the potential to unify income streams from various
skills development and re-training as needed;
sources such as an FFL and other taxes including
(iii) union-negotiated limits on redundancy;
an international fossil fuel extraction charge.51 This
(iv) salary replacement for a fixed period during
way global climate mitigation and loss and damage
which workers are supported to upskill and
funds can have a consistent and long-term revenue
reskill for new green industries; and (v) using
stream.
the natural workforce turnover to smooth the
transition.

17
A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

B. Distribution of the significant revenues

generated by the levy to the following

VI. CONCLUSIONS destinations:

AND INITIAL • EU own resources for investment into green

infrastructure and supporting low-income

RECOMMENDATIONS groups with access to renewable energy,

energy efficiency, public transport and trains.

• Resources supporting EU or national

government policy to deliver a just transition
Aviation emissions represent a major threat for any workers affected by the policy and its
to our ability to deliver a global transition to a impact on demand.
stable climate. Policy to date has been insufficient
in scope to address this impact; it is overly • Resources for investment specifically in the
reliant on technologies that are not proven at local economies in parts of Europe with a high
scale and are not truly sustainable. Furthermore, dependency on inbound air travel (including
approaches currently in the political frame do rail and other sustainable travel to such
not do enough to address the issues of inequality destinations).
and social acceptability inherent in the aviation
climate problem. Most of the world’s population • Resources are transferred either to climate-
does not fly at all. A tiny minority of frequent vulnerable countries and regions dependent
flyers are consuming the lion’s share of the on aviation-related tourism, or to an
remaining carbon budget. A fairer, bolder, and international Global-South-led fund to
faster policy is urgently required. compensate for loss and damage and support
climate mitigation and just transition efforts.

RECOMMENDATIONS
A. Implementation of a Frequent Flying Levy
(FFL) at the pan-European level with tariffs
priced to materially cut air traffic emissions
in the short to medium term. Key design
features could include the following:

• In the absence of an effective kerosene/

carbon tax, the FFL should include distance-
linked price bands akin to those seen in some
national ticket taxes.

• The FFL could replace national ticket taxes,

but recycle equivalent revenues to all national
governments such that no government loses
out from lost ticket tax revenues.

• The FFL should greatly increase the price of

the most climate-damaging classes (premium,
business, first) of travel.

18
A FREQUENT FLYING LEVY IN EUROPE
THE MORAL, ECONOMIC, AND LEGAL CASE

ENDNOTES
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[Link] WRITTEN BY:
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October 2024
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