关键词: 航空, 碳关税, 欧盟, 排放权交易, 国际航空碳抵消和减排机制（CORSIA）

Abstract: Carbon allowances in Emissions Trading Systems are broadly categorized as carbon tariffs. Directive (EU) 2023/958 proposes the conditional inclusion of the entire-route carbon emissions from flights departing the European Union (EU) into the allowance management of the EU ETS, with unilateral expansion linked to the implementation scope and effectiveness of the International Civil Aviation Organization (ICAO)’s Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). It also accelerates the full auction of aviation carbon allowances and mandates the use of EU-compliant sustainable aviation fuels (SAF). On 17 July 2026, the European commission published the proposal COM (2026) 616, which would replace the full-scope extension of the EU ETS under Directive (EU) 2023/958 with a “5000 km circle plus two-year deferral plus 2032 review” arrangement, introduce an “ETS as a service” clause, and significantly scale up allowance support for SAF, triggering renewed global attention to the EU’s aviation carbon tariff. The EU’s unilateral aviation carbon tariff runs counter to the fundamental principles of the UN Framework Convention on Climate Change (UNFCCC), the convention on international civil aviation, and bilateral air transport agreements. It will substantially escalate airlines’ financial burdens and erect carbon barriers hindering the growth of aviation transport and relevant industries in developing countries. Furthermore, the relevant policy will distort the international aviation market, enable developed countries to shift their international aviation emission reduction obligations, facilitate their monopoly over aviation cleaner energies markets, and allow them to extract enormous economic gains from developing countries once again, while boosting the EU’s negotiating leverage in global aviation decarbonization. To safeguard the rights and interests of the global aviation industry and promote its sustainable development, this paper advocates adherence to the principle of common but differentiated responsibilities (CBDR), upholding multilateral governance and consultation, making full use of international rules and legal instruments to prepare reciprocal countermeasures, accelerating the integration of aviation emissions in China’s national carbon market, and strengthening the SAF industry and its standards system to enhance the response capacity of the industry and enterprises.

Key words: Aviation, Carbon tariff, European Union (EU), Emissions Trading System, Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA)