FAA guidance allows for both industry consensus specifications and independent specifications for the purpose of type certification; an ASTM specification is not required for FAA certification under the TC/STC approval pathway. An ASTM standard is however required for fuel pursuing FAA fleet authorization utilizing the PAFI testing, as per the 2018 FAA Reauthorization.
Although not required for FAA safety certification or authorization, ASTM fuel specification is the industry standard for independent peer review and understanding of a new fuel. As such, ASTM specification is widely relied upon by aircraft and engine manufacturers, fuel refiners and distributors, airports, and FBOs for risk assessment, warranty support, and market acceptance.
Fuels without an ASTM specification are not excluded from consideration as a potentially viable replacement for 100LL by FAA or government regulation; however, the developer of such a fuel will need to address additional considerations required by industry stakeholders to support business risk decisions for deployment and use.