Japan's SAF Mandate Begins at 1%, Not 10%, in FY2030

On 23 July 2026, Japan’s energy agency proposed a SAF supply obligation of 1% for FY2030. The proposal applies to jet-fuel suppliers at seven airports. The 10% figure often quoted for 2030 belongs to an earlier airline target.

Where the 10% came from

The 10% figure comes from the GX Basic Policy adopted in February 2023. The Agency for Natural Resources and Energy described the target in its November 2024 SAF policy explainer: replace 10% of the fuel used by Japanese airlines with SAF as of 2030.

The 10% target applies to fuel used by Japanese airlines. It comes from a Cabinet policy document and sets no sales volume for a refiner. It also specifies no penalty for a shortfall.

The same ANRE page, published in November 2024, says the government then planned to set a 2030 supply figure under the Act on Sophistication of Energy Supply Structures at “5% or more of the greenhouse gas emissions of jet fuel produced and supplied in Japan in FY2019.” The July 2026 draft replaces that emissions-based proposal with a volume requirement.

What is actually being written

On 23 July 2026 the Ministry of Land, Infrastructure, Transport and Tourism and ANRE held the ninth meeting of the public-private council on SAF adoption (MLIT). ANRE tabled a draft design for a supply obligation under the same act (ANRE material, 23 July 2026).

The obligation would fall on anyone selling jet fuel at a covered Japanese airport above 3,000 kL a year, importers included, with jet fuel supply brought inside the act as a “specified energy supply business.” The required share is 1% or more in FY2030, 3% in FY2031, and 5% in each of FY2032, FY2033 and FY2034.

It is measured against international uplift, passenger and freighter, at the seven airports that take the most international fuel: Narita, Haneda, Kansai, Chubu, New Chitose, Fukuoka and Naha. Domestic uplift is excluded for the whole first notification period, FY2030 to FY2034. Only SAF certified as a CORSIA Eligible Fuel counts, domestic or imported, and lower-carbon aviation fuel sits outside the scheme for now.

One line in the material closes off the obvious workaround. The obligation is a volume, not an emissions cut: suppliers must sell that percentage as SAF, rather than reduce greenhouse gases by that percentage. Penalties run through the act, the administering ministry is METI, and suppliers report achievement annually, airport by airport.

So the operative figure for 2030 is 1% of international uplift at seven airports, not 10% of national airline fuel use. Those two sentences describe different regimes, and only one of them has a penalty attached.

The domestic-production requirement

Buried in the annex is the provision that matters most to anyone financing a plant. A large jet fuel supplier, defined as a domestic producer supplying 100,000 kL or more of jet fuel a year, must source at least 50% of its SAF supply from domestic production or from an overseas consolidated subsidiary (ANRE).

Without that clause, a refiner could meet the obligation entirely by buying certified SAF on the world market. Under the draft, half the compliance volume of the largest suppliers has to come from production owned by the supplier or its group. That requirement creates demand for investment in production capacity.

The required volume

In FY2024, international uplift in Japan was 8.17 million kL, of which the seven named airports took about 99% (MLIT). Narita alone accounted for 3.14 million kL and Haneda 2.95 million kL.

One per cent of that base is roughly 81,000 kL. Five per cent is roughly 405,000 kL.

Japan’s first commercial-scale domestic SAF plant, built by SAFFAIRE SKY ENERGY inside Cosmo Oil’s Sakai refinery and completed in December 2024, is designed for about 30,000 kL a year from domestic used cooking oil (Cosmo Energy). Its entire annual output covers around a third of the FY2030 requirement.

The pipeline is larger. MLIT lists four supported projects still in design: Idemitsu in Yamaguchi and Chiba, ENEOS in Wakayama, Taiyo Oil in Okinawa, Cosmo Oil in Kagawa. Their stated capacities add to about 1.1 million kL a year, well above the 5% step (MLIT).

The same material says final investment decisions have to be taken in 2026 for meaningful domestic supply to exist by 2030. Suppliers have delayed capital commitments while sales contracts remain uncertain. Airlines have resisted contracts at prices above conventional fuel. The proposed obligation supplies a fixed volume around which they can negotiate.

Note also what the four projects are made of. Three of the five listed lines use alcohol-to-jet rather than the used-cooking-oil route that the Sakai plant runs. Read alongside the ministries’ explicit workstream on securing feedstock, including expanded domestic collection and overseas sourcing, the mix suggests the planners do not expect Japanese waste oil to carry a 5% obligation.

The excuses that will not work

The draft sets out what does and does not release a supplier from its number, and the exclusions are unusually direct.

Group companies may balance between themselves, and disasters or comparable unavoidable events allow a downward revision. The draft rejects equipment failure and an unsuccessful airline negotiation as grounds for relief. It also rejects a plant delay caused by higher construction costs.

A shortfall may instead be banked into the following year, available through FY2033, and several categories of SAF delivered outside the obligation can be applied against it: fuel sold to non-CORSIA carriers and private jets, to government aircraft including the Self-Defense Forces and the Coast Guard, to foreign government aircraft in Japan, exported for uplift abroad, or sold to another obligated supplier.

A supplier may bank a shortfall into the next year, but must still supply the missing volume.

Who pays for it

The second half of the July meeting was about money moving the other way. An expert panel convened in April 2026 under Hitotsubashi emeritus professor Hiroyuki Yamauchi is designing a support mechanism, and the annex sets out its direction (MLIT annex).

From FY2030, in step with the obligation, airlines uplifting SAF for international services at the hub airports would receive a payment per unit of SAF, covering voluntary volumes as well as mandated ones. The money would come from a charge on international departing passengers and cargo at those airports, scaled by flight distance. Extension to domestic flights and other airports is flagged for review around FY2035.

For scale, MLIT’s own comparison puts a European carrier’s SAF surcharge on a Tokyo–Europe economy ticket at about ¥1,464, against a fuel surcharge of about ¥65,000 on the same route (MLIT). The environmental line is roughly two per cent of the fuel line. The political difficulty of adding it is not proportional to its size.

Draft status and next decisions

None of the above is law yet. What exists is a draft design presented to a council on 23 July 2026. The instrument that will bind is a ministerial notification under the act, and it does not exist until it is issued. Anyone citing 1% as current law is making the same category error as everyone citing 10%.

Refiners still need to make final investment decisions, while the ministerial notification may change the proposed 50% domestic-production clause. Separately, airlines and the travel industry must be consulted on the passenger charge. Without that payment, carriers would bear the cost.

The GX-ETS became mandatory on 1 April 2026 after years as a voluntary scheme. The hydrogen and ammonia strategy also moved from a target to contract-for-difference mechanics. For SAF, the ministerial notification that would create the obligation has not yet been issued.

Tech for Impact Summit 2027 is in Tokyo on 18–19 May 2027, co-hosted with the United Nations University. Fuel producers, airlines, policymakers and the investors backing the plants spend two days on exactly this kind of question. It is invitation-only, and if this is your work we would like to invite you. Join the waitlist at tech4impactsummit.com/apply.