Vietnam proposes first SAF blending mandate under new aviation environmental Circular
Vietnam's Ministry of Construction (formerly the Ministry of Transport) is consulting on a draft Circular that would consolidate the country's environmental rules for civil aviation into a single framework, and for the first time set binding minimum blending targets for sustainable aviation fuel.
The draft responds to two pressures at once: Vietnam's commitment, as an ICAO member and party to the UNFCCC and the Paris Agreement, to reach Net Zero by 2050, and the practical strain of managing aviation emissions, noise and green transition requirements across two separate regulations that have not kept pace with ICAO's evolving CORSIA standards.
Consolidating two Circulars into one
The current legal basis for aviation environmental management in Vietnam rests on Circular 22/2020/TT-BGTVT, covering fuel consumption and CO2 management, and Circular 52/2022/TT-BGTVT, covering broader environmental protection in civil aviation. The new draft merges both into a single, unified instrument, with clearer allocation of responsibility across the Civil Aviation Authority of Vietnam, airport authorities, aircraft operators, fuel suppliers, air navigation service providers and ground handlers.
The Ministry's rationale is straightforward: maintaining two separate Circulars as the scope of environmental regulation expands risks fragmentation and inconsistent enforcement. A single framework is intended to make compliance more manageable for industry as SAF, CORSIA and climate obligations grow more detailed.
SAF: from voluntary uptake to a mandatory trajectory
The most consequential element of the draft is Vietnam's first proposed SAF blending mandate. Under the version currently out for consultation, international flights departing Vietnamese airports would face a minimum SAF share starting at 1% in 2030, rising in stages: 2% in 2031, 3% in 2032, 4% across 2033 to 2034, 5% across 2035 to 2037, 7% across 2038 to 2039, and 10% from 2040 onward.
Domestic flights follow a separate, later-starting trajectory: 1% across 2032 to 2034, 2% across 2035 to 2037, 3% across 2038 to 2039, and 5% from 2040. Airlines that use SAF earlier or above the mandated minimum are explicitly encouraged, though no incentive mechanism is detailed in the current draft.
If adopted, this shifts SAF in Vietnam from an encouraged or pilot fuel to a compliance obligation with a defined ramp. The draft also sets out how SAF's origin, volume, quality and sustainability are to be monitored, how trading, supply and blending are to be managed, and the methodology for calculating emissions reductions, the detail that will ultimately determine how SAF counts against CORSIA obligations.
A fuller CORSIA framework
Alongside the SAF mandate, the draft builds out a complete CORSIA monitoring, reporting and verification (MRV) regime: monitoring plan development and approval, data collection and calculation methods, verification procedures, and the process for determining and discharging offsetting obligations. This extends beyond Circular 22/2020's original focus on fuel and CO2 reporting to match ICAO's current CORSIA requirements, including offsetting obligations that did not exist when the earlier Circular was drafted. The draft also extends monitoring to domestic aviation emissions, not just the international flights that fall under CORSIA's scope.
Airports take on carbon accounting and climate risk
Airport operators gain a more defined role. Under the draft, they must build carbon management and emissions reduction into their environmental or green transition plans, and take responsibility for emissions sources under their own ownership or control. For emissions from airlines and other parties operating on-site, airports take a coordinating role, rather than being held liable in the operator's place. This is intended to prevent airport operators absorbing responsibility that belongs to airlines or other emissions sources.
A newer addition is climate adaptation. The draft requires assessment of climate change impacts, vulnerability and risk to aviation operations, with airport operators and air navigation service providers required to supply data on extreme weather effects and help build resilience plans. For new or upgraded airport infrastructure, climate risk assessment must factor into site selection, design and construction from the outset, a requirement absent from both prior Circulars.
Noise management gets dedicated provisions
The draft adds several new articles addressing aircraft noise specifically, covering noise identification and assessment, noise-reducing operating procedures, coordination on land use planning around airports, a balanced approach to noise management consistent with ICAO practice, and formal channels for receiving and responding to community noise complaints. The Ministry has stated the intent is to avoid duplicating existing technical noise and emissions standards, focusing instead on the operational and environmental management side.
Transition
Plans, reports and environmental records approved before the new Circular takes effect remain valid under their original terms, and industry will be given a phase-in period to update processes and documentation to the new requirements. Vietnam becomes one of the first Southeast Asian states to move from voluntary SAF encouragement to a defined mandatory blending schedule with dates and percentages attached. How the final Circular defines SAF eligibility criteria, the CI methodology used to calculate emissions reductions, and whether any support mechanism accompanies the mandate will determine how workable the trajectory proves for airlines and fuel suppliers operating in Vietnam.
Sources: VTV, 16 September 2026; Tạp chí Hàng không, 16 September 2026
