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Aviation

How aviation harms the environment and the action we’re taking to address it.

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Why is flying bad for the environment?

It’s no secret that flying is not climate friendly, but the full extent of air travel’s impact on the planet is far greater than many realise.

In fact, taking a long-haul flight is the single most environmentally-damaging activity an individual can do. The average flight releases roughly 0.3kg of CO2 per passenger per kilometre. This is about 10 times as much as the average UK train, and 100 times as much as high-speed trains like the Eurostar.

Globally, aviation accounted for 2.5% of global CO2 emissions in 2019. That number may sound small, but it is roughly the same as the total emissions of Germany or Japan. Accounting for flying’s non-CO2 climate impacts, aviation’s total share of planetary heating to date probably reaches 4%.

Who flies the most?

Right this second, there may be as many as 1.2 million people in the air. But who are they?

Around 4% of the world’s population flew internationally in 2018, while around 80% of people have never even been on a plane. What’s more, only 1% of the global population is responsible for half of aviation emissions.

Private jets may account for only around 2-2.5% of total aviation emissions, but are the most carbon intensive form of flying – and therefore of any mode of transport (apart from space travel). Private jets are mainly flown by the richest 0.003% of the adult population with a combined wealth of $31tn. And yet private flights often face a far lower effective tax rate: for a London to Paris ticket, only 2% of the price is paid in tax on a private jet versus 43% for economy class.

How does flying damage the climate?

CO2 emissions

Flying largely accelerates global heating through the carbon dioxide emissions released when jet fuel is combusted. CO2 accounts for around 55% of aviation’s global warming contribution. It can remain in the atmosphere for over 1,000 years, and will keep warming the planet for the full extent of this time.

Non-CO2

CO2 isn’t aviation’s only climate problem. Non-CO2 impacts, from contrails and NOx emissions, are estimated to be at best equally as damaging as aviation’s CO2 impacts. At worst, they may be twice as damaging.

  • Contrails are the white streaks of cloud left behind planes. They form when water vapour and soot from plane exhausts form ice crystals that become clouds, which reflect solar radiation and trap heat in the atmosphere. Contrail formation depends on factors including aircraft engine characteristics, fuel composition, and air temperature and humidity.
  • NOx emissions cause chemical reactions in the atmosphere which lead to increased ozone production.

While we don’t have enough data to know the full magnitude of non-CO2 impacts, we do know that they must be mitigated, and how to do so effectively and cheaply.

Find out more in our guide to controlling contrails.

Are aviation emissions coming down? 

The short answer is no. Flying has become more energy efficient, meaning fewer emissions are released per passenger kilometre, but these improvements have been outpaced by the sector’s rapid and continuing growth.

International aviation is on track for well over 4ºC warming above industrial levels. This scenario would see radically disrupted global food and water systems, ecosystems and rampant extreme weather events, and the average individual up to 40% poorer.

Without transformative change, by 2050 the sector could still be releasing over 16 times more emissions than what it needs to in order to stay under 1.5ºC.

How can we reduce flying’s impact on the environment?

Changing how much we fly

Plans to expand airports have been approved across Europe and the UK, including at London’s Heathrow, Gatwick and City airports, and airports in Dublin, Amsterdam, Florence, Frankfurt, Athens, and Heraklion. This means more passengers, more flights, and more emissions.

Governments justify expansion on the basis that it grows the economy, but research shows that this is only true in certain situations.

The cleanest flight is undoubtedly the one you don’t take – but how can we reduce demand for flying? Firstly, we need governments to invest in affordable, efficient and accessible alternative transport means to flying. The Sail & Rail scheme between England and Ireland, for instance, is much less carbon intensive than flying, yet the ticketing system presents a barrier to consumers choosing this route over air travel.

Secondly, aviation should be properly taxed. Aviation has long enjoyed a privileged tax regime, paying neither standard nor climate taxes as other sectors do. Air travel levies (national taxes applied per passenger per flight) are now relatively common, but some countries still hold out, like Ireland.

Adopting alternative aviation fuels and technologies

There are a range of different alternative aviation fuels, such as biofuels, hydrogen and e-kerosene some more sustainable than others, as well as novel technologies that produce no carbon emissions during flight.

Learn more on our alternative fuels and technologies page.

Avoiding contrails

Contrails can be avoided easily and cheaply. Since contrails form in certain air temperatures and humidities, planes can be rerouted to avoid such conditions, by flying at different altitudes and times of day.

Only about 14% of flights in 2019 caused climate-warming contrails at all, and 2% of flights were responsible for 80% of contrails. Rerouting these few flights that produce the majority of contrails is estimated to cost between $0.50 and $14.00 per tCO2e. By contrast, using alternative aviation fuels to reduce flying’s impact costs at best $185 per tCO2 equivalent.

Nevertheless, aircraft operators do not yet face binding obligations to reduce their contrails.

Read more in our report Contrails: A policymaker’s guide to reducing aviation emissions.

Improving energy efficiency

Improving energy efficiency is an important piece of the energy transition, but is not the whole picture. More efficient technologies reduce the emissions produced per unit of fuel burnt, but won’t eradicate pollution altogether. Indeed, air travel demand has outpaced efficiency gains: since 1990, flying has become twice as efficient but emissions have still doubled.

However, improving energy efficiency is still important. Even the most sustainable fuel has some environmental impact across its lifecycle, so reducing demand is positive. It also reduces costs, helping the uptake of more expensive sustainable fuels.

International law: who is responsible for planes’ pollution?

Aviation emissions either come from domestic flights (between two airports in the same country), or international flights (between two different countries). Regulating domestic flight emissions is clearly the responsibility of the country in question. But who reduces international aviation emissions?

The International Civil Aviation Organization (ICAO)

ICAO is the UN specialised agency for regulating international aviation. While some claim that ICAO (and not states), is responsible for international emissions, the truth is that states are legally obliged to reduce this pollution, despite ICAO.

ICAO also lacks inclusivity and transparency, with developing countries underrepresented and research pointing to corporate capture.

The body’s flagship climate measure, the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), has long been proven inadequate relative to the Paris Agreement temperature targets.

States

States are legally obliged under the Paris Agreement to take all means necessary to address climate change across their economies. This means that states are responsible for international aviation emissions regardless of ICAO, and particularly since ICAO’s policies do not align international aviation with the Paris Agreement temperature targets.

This legal interpretation has been reinforced in the Advisory Opinions released by International Tribunal for the Law of the Sea in 2024, and the International Court of Justice and Inter-American Court of Human Rights in 2025.

Policy and regulation: what is being done to reduce flying emissions?

There are many ways that policy addresses aviation’s climate impacts. Below we list the areas that Opportunity Green focuses on.

Setting targets

  • In 2022, ICAO Member States adopted the ‘long-term global aspirational goal’ (LTAG) of net-zero carbon emissions by 2050. However, the LTAG comes with no obligations on member states, does not set interim targets, and fails to account for non-CO2
  • The European Union’s aviation targets are bound up in the 2019 European Green Deal that sets a legally binding target to become climate-neutral by 2050, with interim goals of at least 50% by 2030, rising towards 55%. As part of this framework, transport emissions must be reduced by 90% by 2050 compared to 1990 levels.
  • The UK’s Jet Zero Strategy published in 2022 aims for net zero aviation by 2050 with interim targets in 2030 and 2040, although these are not legally binding.

Transitioning to alternative fuels, energy sources and technologies

Once targets are set, authorities put in place measures for achieving them, which largely involves transitioning from fossil jet fuel to alternatives.

  • ReFuelEU Aviation – the EU’s main legislative tool for driving the aviation energy transition. Adopted in 2023 as part of the Fit for 55 package, ReFuelEU Aviation sets binding mandates for minimum levels of uptake of alternative fuels for commercial air transport, including a sub-target for the most sustainable synthetic fuels. These increase yearly to a peak of 70% in 2050.
  • SAF Mandate – introduced in the UK in 2024. It is similar to ReFuelEU Aviation, but will also phase out the use of HEFA (hydroprocessed esters and fatty acids) fuels due to this alternative fuel being less sustainable.
  • ICAO’s aircraft CO2 standard – requires planes to comply with a certain efficiency level. However, the average newly-built aircraft is already above the standard’s baseline efficiency level, so the policy does not effectively incentivise efficiency gains.

Putting a fair price on emissions

The ‘polluter pays principle’ is the idea that whoever is responsible for greenhouse gas emissions should pay for them rather than the public. The aviation industry uniquely benefits from a range of free passes that means it does not pay for its pollution and is not robustly incentivised to decarbonise.

The EU emissions trading system (ETS) is a market-based ‘cap-and-trade’ mechanism that requires companies to purchase allowances to cover their emissions. A certain number of allowances are released each year, and companies with more emissions than allowances pay a penalty on excess emissions. Every year, the number of allowances sold reduces, incentivising polluters to reduce their emissions to avoid penalties. Revenues are distributed to EU Member States to reinvest into climate action domestically. The UK has its own similar ETS.

Despite being largely effective, the ETS has gaps when it comes to aviation. Most significantly, the ETS covers emissions from flights between European countries, but not those between European and non-European countries. The ETS was meant to be extended to international flights in 2012, but heavy industry and state pressure led to the European Commission exempting these flights from paying for their pollution. The inclusion of international flights in the ETS will be reviewed in 2026.

On paper, the exemption was to allow ICAO to develop a global system, CORSIA, which has since, proved ineffectual.

CORSIA has been active since 2021. Despite its global scope, the system is not effectively designed to reduce emissions. CORSIA only aims to achieve carbon neutral growth, rather than zero or net-zero emission flying. This means that it only applies to emissions above an already high baseline – and the emissions it does apply to need only be offset using carbon credits. Even if implemented in full, CORSIA would still see international aviation on track for over 4ºC warming.

CORSIA is voluntary until 2027 and then only mandatory for the 34 States with the highest shares of global aviation. It also has no enforceability mechanism, is set to end in 2035 with no plans afterwards, and ignores non-CO2 impacts.

Aviation also enjoys a free pass on standard fuel tax. It is often claimed that taxing kerosene is prohibited under international law, but there is in fact no such prohibition. Indeed, exempting aviation fuels of tax in the EU may even come into conflict with State Aid obligations and the Trade and Cooperation Agreement between the EU and UK.

Tax rates paid on road transport and aviation fuel in 2025

 

EU car petrol

UK car petrol

Aviation kerosene

Fuel duty (per litre)

35.9¢ (minimum)

52.95p

0

VAT

21.8% (average)

20%

0%

Effective tax rate

53.6% (average)

54-57%

0%

 

Learn about our approach to tackling aviation’s climate impact.

What is Opportunity Green’s approach to decarbonising aviation?

Far from reducing at the pace our planet urgently needs, aviation emissions are only increasing. That’s why we strategically use our team’s legal, policy and economic expertise to reset the aviation industry’s emissions in line with Paris Agreement temperature targets, using a few different approaches.

Holding states to account for international flying

While governments work on cutting emissions from domestic flights, they ignore those from international flights. Yet, neglecting this major source of pollution is not in line with their international legal obligations.

One way we hold states to their legal responsibility is by contributing to international legal proceedings. In 2024 and 2025 we put forward supporting submissions to inform the advisory opinions issued by the International Court of Justice, and the International Tribunal for the law of The Sea (ITLOS). These submissions urged the courts to consider international aviation and maritime shipping emissions in their clarifications of countries’ legal obligations with regards to climate change.

We have also directly alerted states as to their responsibility to reduce international aviation emissions. In 2025 we urged states to account for international aviation in their second nationally determined contributions to achieving the Paris Agreement goals. In 2024 we submitted evidence to the Aotearoa New Zealand Climate Change Commission explaining why international aviation and shipping should be included in the country’s 2050 climate target.

Challenging greenwashing

The technologies we need to decarbonise flying exist, but greenwashing can muddy the water around what is and isn’t sustainable, and can at worst see money flow to unsustainable non-solutions and fossil fuels.

That’s why in January 2024 we launched a legal challenge against the European Commission on account of its inclusion of polluting planes and ships in the EU Taxonomy, along with NGOs Dryade, Fossielvrij NL, Protect our Winters Austria, and CLAW. Including fossil-powered planes in the Taxonomy makes them eligible for finances earmarked for sustainable activities, effectively paying polluters with euros meant for those leading on sustainability.

In our report Fuelling misconceptions: the legal risks of advertising ‘sustainable aviation fuel’, we turned our attention to the private sector. Here, we demonstrated that airlines, financiers and fuel producers that use the misleading term ‘sustainable aviation fuel’ (SAF) may risk facing legal action due to its vagueness.

Advocating for a just and equitable transition

The climate crisis is defined by a fundamental injustice, that the countries least responsible for the problem are already bearing the brunt of the damage it’s causing. In aviation this inequity is starker than ever.

We work with climate vulnerable countries, small island developing states, and least developed countries to increase participation at ICAO and achieve a just and equitable transition for the aviation sector that leaves nobody behind.

Ahead of ICAO’s 2025 Assembly, Opportunity Green published briefings on the relevance of recent international legal advisory opinions to obligations on aviation, and one with the Commission of Small Island States on Climate Change (COSIS) encouraging ambition to be raised at ICAO. These recommendations included:

  1. Creating a scheme to support developing countries to attend all ICAO meetings related to climate change.
  2. Implementing a universal levy on all aviation emissions, with a portion of the revenues distributed to supporting the most climate vulnerable.
  3. States joining the Global Solidarities Levies Task Force (GSLTF)’s premium flyers solidarity coalition, and the Coalition on Phasing Out Fossil Fuel Incentives Including Subsidies (COFFIS).
  4. Promoting the expansion of the EU ETS to international flights.

Our research also showed how the huge benefits of a levy on international aviation fuel would dramatically outweigh any negative impacts experienced by small island states.

Driving ambition in domestic and regional policy

We advocate for national and EU policymakers to strengthen regulation to decarbonise aviation at the pace the climate crisis demands.

A major objective is urging states to put a fair price on aviation emissions. In lieu of a robust and ambitious international framework, both the UK and EU ETS must be extended to emissions from international aviation.

Our Policy guide to the EU ETS for aviation breaks down the legal, economic and political dimensions of international aviation’s ETS exemption, and shows why the 2026 revision of the EU ETS should end this undue free pass for a polluting industry. Our CEO Aoife O’Leary also made this argument in a letter to the EU President Ursula von der Leyen.

Another area in which aviation enjoys unwarranted exceptions is taxation, both standard taxes and climate levies. Our briefing Clearing the air on how we tax aviation fuels debunks the myth that jet fuel cannot be taxed under international law, and demonstrates that states can tax this fuel just as they do other fuels.

We have also encouraged the Irish government to introduce an air travel levy like the UK’s Air Passenger Duty, and to advocate for the expansion of the EU ETS during its Presidency of the Council of the European Union.

Uplifting the voices of the industry leaders carrying aviation towards a greener future, the SASHA Coalition, facilitated by Opportunity Green, is an alliance of companies developing the most sustainable aviation and shipping technologies. We amplify these under-represented industry voices and work with policymakers to create ambitious regulation to accelerate the deployment of clean aviation technologies.

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Our experts

Dedicated professionals committed to environmental transformation

Aoife O’Leary (she/her)

Founder & CEO

Aoife founded OG in 2021 with a vision to drive bold, innovative climate action and to create an exceptional workplace.

Carly Hicks (she/her)

Chief Strategy and Impact Officer

Carly heads our legal, diplomacy and advocacy teams, ensuring we think about the impact our work is having.

Em Fenton (they/them)

Senior Director, Climate Diplomacy

Em supports climate vulnerable countries in multilateral negotiations, centring justice and equity in the transition to net zero.

David Kay (he/him)

Legal Director

David leads OG’s legal team and has overall responsibility for our strategic legal work, targeting systemic change in high-polluting sectors.

Sophie Prinz (she/her)

Senior Legal Manager

Sophie develops and implements Opportunity Green’s legal strategy on aviation and shipping finance.

Sorcha Tunney (she/her)

Senior Manager, Ireland

Sorcha leads Opportunity Green’s policy, advocacy, and engagement work in Ireland.

Kirsty Mitchell (she/her)

Legal Manager

Kirsty leads OG’s legal work in the shipping and steel sectors, advocating for climate action and systemic change.

Nuala Doyle

Nuala Doyle (she/her)

Advocacy Manager

Nuala plays a key role in driving forward the SASHA Coalition, with a focus on UK engagement.

James Kershaw (he/him)

Scientific Officer

James carries out scientific research to ensure we’re at the cutting edge of efforts to clean up polluting industries. 

Sabrina Khan-Dighe (she/her)

Membership & Advocacy Officer

Sabrina manages the SASHA Coalition membership, and actively searches for new members.

Olivia Moyle (she/her)

Legal Officer

Olivia develops and executes strategic legal interventions in the aviation sector and public international law.

James Meadway

Director of Analytics

James was OG's Senior Director of Analytics between September 2024 and December 2025.

Isabela Keuschnigg

Legal Officer

Isabela no longer works at Opportunity Green. For any enquiries related to our legal work in the shipping sector, please contact...

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