FAQ n.105661

References: Regulation (EC) No 1107/2006 is available on EUR-Lex website. Regulation (EU) No 965/2012 and the study EASA 2008.C.25 are available on EASA website.

Regulation (EC) No 1107/2006 of the European Parliament and of the Council on rights of disabled persons and persons with reduced mobility (PRMs) when travelling by air does not include the height of an individual in the definition of ‘disability or a person with reduced mobility’. Hence, the EU rules on air operations - Regulation (EU) No 965/2012 - do not include a height of an individual (i.e. a tall passenger) in the ‘special categories of passengers (SCPs)’. 

Air operators are free to order from an aircraft manufacturer an aircraft cabin/seat configuration they wish, provided that such cabin/seat configuration meets the certification safety requirements. The space between seat rows (so-called ‘seat-pitch’) is a matter of aircraft certification process*. *Questions on aircraft certification matters should be addressed to EASA Certification Directorate.  

EASA has conducted a study on Carriage by air of special categories of passengers, reference EASA 2008.C.25, which, amongst others, concludes that aircraft designers must take into account the increasing percentage of tall passengers.  https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018R1139 

There may be passengers who do not fall into the category specified by the EU regulations on PRMs and SCPs referenced above, however they may have certain individual circumstances where intervention of the air operator or the Competent Authority may be beneficial or required. Most airlines offer various forms of assistance to passengers with certain requirements. For example, persons suffering from certain specific allergies (not necessarily food-related) are not considered disabled and do not fall into the SCP category either. However, passengers with any such circumstances may contact the operator, or the Competent Authority, to seek a solution prior to their travel.