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COMMISSION DELEGATED REGULATION on extending the scope of traceability of the Union database

Energy

To ensure that only sustainable volumes of renewable fuels, recycled carbon fuels are counted for the achievement of the EU decarbonisation targets, also avoiding any risk of double counting of the same energy units, the Commission put in place a traceability tool, “the Union database (UDB)”. To improve the traceability, the revised Renewable Energy Directive empowers the Commission to extend the scope of the data in UDB to also cover data from the point of production/ collection of the raw materials used for the fuel production.

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Public consultation

ID: 14297

Lobbying Activity

44 responses

European farmers urge suspension of biofuels database expansion

European farmers, 7 Nov 2024

European farmers call on the Commission to suspend the draft regulation due to lack of workability. They recommend a pilot phase until 2026 to assess the technical IT systems. The proposal suggests prioritizing national databases to avoid duplicate reporting requirements.
This would limit bureaucracy and prevent farmers from having to fill in two separate databases.
The Commission loses its immediate timeline for implementing comprehensive traceability across the supply chain.

European agri-cooperatives urge suspension of Union database regulation

European agri-cooperatives, 7 Nov 2024

Copa and Cogeca call for suspending the regulation to address concerns over workability and data protection. They suggest a pilot phase until 2026 and prioritizing national databases to avoid duplicate entries.
Suspending the draft would prevent new administrative burdens and duplicate reporting costs for farmers.

Fuel Industry Urges Flexibility in EU Traceability Rules

FuelsEurope, 7 Nov 2024

FuelsEurope requests clarification of stakeholder definitions, reconsideration of the three-day transaction reporting rule, and a realistic transition period synchronized with the 2025 compliance cycle. They argue the three-day deadline is operationally impossible and would impose unnecessary administrative burdens.
This would reduce compliance costs and allow existing operational practices to continue.
Fraud prevention efforts lose as weaker traceability rules create more opportunities for misreporting.

German Chamber of Commerce Urges Flexible Fuel Database Deadlines

Deutsche Industrie- und Handelskammer, 7 Nov 2024

The German Chamber of Commerce supports a delayed mandatory implementation of the database. They advocate for a longer timeframe for operators to enter transaction data.
This avoids imposing disproportionate administrative burdens and operational complexity on smaller companies.

Eni urges alignment of fuel traceability reporting timelines

Eni S.p.A., 7 Nov 2024

Eni requests aligning transaction reporting deadlines with existing industry standards to avoid disruptions. They also recommend simplifying triggering points and adding warnings before automatic suspensions.
This alignment would reduce compliance costs by matching sustainability reporting with existing fiscal balances.

Austrian Economic Chamber urges reduced bureaucracy in fuel traceability rules

Wirtschaftskammer Österreich, 7 Nov 2024

The WKO requests a 'data-once-only' principle to minimize reporting burdens for companies. They demand specific exemptions for small businesses and significantly longer data entry deadlines.
Austrian companies would benefit from significantly lower compliance costs and reduced administrative complexity.
EU regulators face reduced transparency and slower fraud detection due to delayed reporting windows.

Neste urges phased Union Database implementation to avoid market disruption

Neste Oyj, 6 Nov 2024

Neste requests extended reporting timelines from three days to 30 days, removal of automatic transaction cancellations, and phased implementation after regulation adoption. They want clarity on initial stock registration and limits on non-UDB data requirements to reduce administrative burden.
This would reduce compliance costs and prevent smaller certified suppliers from leaving EU markets.
Regulators lose stricter oversight as longer reporting windows delay verification of sustainable fuel claims.

Eurogas Urges Extension of Fuel Data Registration Timelines

EUROGAS, 7 Nov 2024

Eurogas recommends extending the transaction data entry timeline from three working days to one month. They request clarification on registration for farmers and traders to ensure compliance. They also suggest aligning the database with national schemes to avoid double reporting.
This would reduce administrative costs and lower the risk of regulatory non-compliance.

German Crafts Association Slams Expansion of EU Fuel Database

Zentralverband des Deutschen Handwerks e.V., 7 Nov 2024

The association demands a clear exclusion of wood biomass used for heating. They also request exemptions for production residues and small fuel quantities.
Exemptions would spare small businesses from costly new data reporting and compliance duties.

EBA Urges Tracking Exemptions and Delayed Deadlines

European Biogas Association, 7 Nov 2024

The association calls for extending the implementation deadline for gaseous fuels to twelve months. They also request exempting producers under 2 MW capacity. They propose increasing reporting windows for transaction data to three months.
The sector would avoid technical disruptions and reduce administrative costs for small operators.

Air France-KLM warns EU database expansion threatens SAF supply

Air France-KLM, 7 Nov 2024

The airline argues the proposed tracking requirements are too complex and costly, especially for non-EU fuel sources. They want consistency with existing national registries to avoid duplicate reporting obligations.
This would reduce their compliance costs and administrative burden from duplicate reporting systems.
Environmental groups lose stronger safeguards against fraudulent sustainability claims in fuel supply chains.

Repsol urges more flexible deadlines for Union Database compliance

Repsol, S.A., 7 Nov 2024

Repsol requests clearer definitions for traders and more time to report transactions. They argue the current three-day window is an impossible administrative burden for many.
This would lower administrative costs and protect the company from unfair suspensions.

UPM warns against rushed Union Database implementation

UPM-Kymmene Oyj, 7 Nov 2024

UPM calls for a thorough system check and transition period before mandatory implementation. They propose extending the transaction reporting window to one month to reduce administrative burdens.
UPM avoids competitiveness risks and administrative burdens caused by a non-functional reporting system.
Regulators seeking real-time traceability may find it harder to mitigate fraud risks effectively.

Snam Urges Exclusion of Low-Carbon Fuels from Database Reporting

Snam S.p.A., 7 Nov 2024

Snam requests excluding low-carbon fuels from the scope of new reporting requirements. They also propose a simplified certification for raw materials delivered directly to production plants.
The company would avoid duplicate reporting requirements and reduce administrative compliance costs.

eFuel Alliance urges flexible rules for sustainable fuel traceability

eFuel Alliance, 6 Nov 2024

The alliance requests a one-year transition period for downstream processing procedures and recognition of mass balance tracking for fuels from non-EU grids. They warn that excluding imports and imposing excessive administrative burdens will undermine climate goals and disadvantage smaller companies.
This would allow their members to import sustainable fuels and reduce compliance costs.
EU-only fuel producers lose competitive advantage if imports are recognized equally.

European Biodiesel Board urges delay for fuel traceability database

European Biodiesel Board, 7 Nov 2024

The board seeks an 18-month phase-in period to resolve database technical errors. They suggest limiting reporting to certain materials and extending transaction deadlines to one month.
The industry avoids compliance burdens and operational shutdowns linked to database glitches.
Market integrity suffers as fraudulent imports remain harder to detect during the delay.

Austrian agricultural chamber demands delay for Union database

Landwirtschaftskammer Österreich, 7 Nov 2024

The chamber calls for delaying the database launch until the 2025 harvest to allow for essential testing. They request extending reporting deadlines to ten days and introducing a window for error corrections without penalties.
This delay would reduce immediate administrative costs and avoid duplicating existing national reporting systems.
Small agricultural traders and cooperatives face high stress and penalties under the current strict reporting rules.

MOL Group seeks exemptions to reduce biomethane administrative burdens

MOL Hungarian Oil and Gas Company, 7 Nov 2024

MOL proposes exempting suppliers within 50km of plants from registration to reduce bureaucracy. They also suggest long-term contracts should serve as sufficient evidence of traceability for farmers.
Reducing administrative requirements prevents shifting investments from biomethane toward the electricity sector.

COCERAL urges excluding crops from expanded biofuel traceability database

Comité du commerce des céréales, aliments du bétail, oléagineux, huile d'olive, huiles et graisses et agrofournitures de l'U.E., 6 Nov 2024

COCERAL calls for excluding crops where traceability is already sufficient and requests a transitional implementation period. They argue the current proposal imposes disproportionate requirements on upstream operators.
Traders would avoid significant human resource requirements and high associated compliance costs.
Farmers and small traders suffer from reduced market access and high administrative burdens.

Waste manager association FEAD warns of excessive reporting burdens

FEAD, 7 Nov 2024

FEAD requests integrating national reporting systems with the Union database to stop duplication. They propose extending reporting deadlines to 30 days and demand less severe penalties.
These changes would lower compliance costs and ensure businesses avoid sudden operational suspensions.

EU Vegetable Oil Industry Urges Pilot Testing Before Biofuel Database Expansion

The EU Vegetable Oil and Proteinmeal Industry, 5 Nov 2024

The industry requests pilot testing with operators before implementing new requirements, and a sufficient phase-in period with step-by-step integration. They argue current timelines for data entry are unrealistic and the database has technical problems that must be fixed first.
This would reduce their administrative burden and allow time to adapt systems.
Transparency advocates lose stronger real-time oversight of biofuel supply chain sustainability claims.

Assarmatori urges more flexible deadlines for fuel traceability reporting

Assarmatori, 7 Nov 2024

The association calls for extending the three-day reporting window to reflect complex supply chains. They suggest better integration with national databases to reduce administrative burdens. Finally, they demand single accounts for operators to ensure consistency.
Relaxing timelines prevents reporting errors and reduces the heavy administrative burden on shipowners.
Rigid rules could create barriers that destabilize the supply of renewable energy.

Ethanol producers urge delay in EU biofuel database rules

European Producers Union of Renewable Ethanol, 6 Nov 2024

The association recommends a phased approach to the Union Database's expansion. They propose postponing new requirements until 2026 and removing rules that force companies to submit identical data to multiple platforms.
A delay would prevent supply chain blockages and reduce significant administrative costs for biofuel companies.
Small companies face high personnel costs while domestic producers lose competitiveness to foreign imports.

German waste industry urges Commission to reduce biofuel reporting burdens

BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V., 7 Nov 2024

The BDE requests that reporting apply only to first collection points instead of individual origins. They propose extending reporting deadlines to 30 days and implementing a transition period until 2025. The group also demands stricter controls to prevent auditors from accessing sensitive supplier data.
This would minimize administrative overhead and protect proprietary customer and supplier data from unauthorized access.
European regulators would lose granular data intended to ensure biofuel sustainability and prevent fraud.

GRDF urges biomethane exemptions and longer fuel traceability deadlines

Gaz Réseau Distribution France, 7 Nov 2024

The group seeks to extend transaction recording deadlines from three days to one month. They also request exempting small producers and excluding local deliveries from registration.
Small operators avoid high administrative costs and technical burdens of database compliance.
The Commission's push for total transparency is weakened by these requested exemptions.

EWABA urges one-year delay for biofuels database implementation

EWABA, 7 Nov 2024

EWABA requests a one-year postponement for the database to become operational. They also propose extending the fuel transaction reporting window to three weeks.
A delay would prevent potential industry losses caused by technical implementation failures.
Sustainability efforts are hindered as the tool to prevent fuel fraud is postponed.

Consultation response

Methanol Institute, 7 Nov 2024

The Methanol Institute (MI) is the global trade association for the entire supply chain of the methanol industry, representing the worlds leading methanol producers, consumers, distributors, and technology companies. MI represents its members from offices in Singapore, Washington D.C., Brussels,…

Finnish bioenergy group demands delay in fuel traceability rules

Bioenergia ry - Bioenergy Association of Finland, 7 Nov 2024

The association demands postponing the regulation's application until January 2026. They also seek exemptions for small biogas and biomethane producers.
A delay would prevent excessive administrative costs for smaller energy producers.
Regulators and environmental groups lose tools for credible verification of fuel sustainability.

Consultation response

GasNet, s.r.o., 7 Nov 2024

GasNet welcomes the Commissions proposal to support the correct accounting of liquid and gaseous renewable fuels and recycled carbon fuels to achieve the Renewable Energy Directive (RED) targets based on the functional and operational Union database. Our concern, nevertheless, is and for the near…

Consultation response

Bioéthanol France, 7 Nov 2024

Statement on the draft of COMMISSION DELEGATED REGULATION (EU) /... of XXX on supplementing Directive (EU) 2018/2001 of the European Parliament and of the Council, by further extending the scope of the data to be included in the Union database to cover relevant data from the point of production or…

Consultation response

Preem AB, 7 Nov 2024

We thank the EC for the opportunity to provide feed-back on the DRAFT delegated act on the Union Database. The UDB has significant impacts on the European biofuel business and the further guidance on the implementation of the UDB is much needed. Responsibilities of Certification Bodies (CB) The CB…

Consultation response

Envien group, 6 Nov 2024

In general Envien Group welcomes and supports introduction of the Union Database for biofuels (UDB) as a tool to bring more transparency and traceability to the EU biofuels markets and to increase fraud prevention. However, we would like to emphasize that we are strongly concerned with the whole…

Consultation response

European Compost Network ECN e.V., 7 Nov 2024

The European Compost Network welcomes the Commissions draft delegated regulation implementing the Renewable Energy Directive (EU) 2018/2001 aiming to increase the use of renewable energy from renewable sources, including biogas and biomethane produced from bio-waste. However, we would like to…

Consultation response

U.S. Grains Council, 6 Nov 2024

Please see the attached file for comments submitted on behalf of the U.S. Grains Council (USGC) in response to the draft delegated regulation extending the scope of traceability of the EU database (UDB). Thank you. Kind regards, Stephanie Larson Regional Ethanol Manager for the EU, UK and Canada…

Consultation response

INERATEC, 7 Nov 2024

INERATEC appreciates the opportunity to provide feedback on the Draft of the Delegated Act, which extending the scope of the data to be included in the Union database to cover relevant data from the point of production or collection of the raw material used for the fuel production. This Act is…

Consultation response

Asociación de la Industria del Combustible de España, 7 Nov 2024

AOP welcomes the opportunity to provide feedback in this public consultation on extending the scope of traceability of the EU database. As a key tool for promoting transparency, traceability, and regulatory cohesion within the EU, the UDB requires a clear and robust framework to support consistent…

Consultation response

Mittelstandsverband abfallbasierter Kraftstoffe e.V. (Waste-based Fuels Association), 6 Nov 2024

The Mittelstandsverband abfallbasierter Kraftstoffe e.V. (MVaK) represents twenty-nine members who collect, prepare and convert suitable waste lipids, mainly used cooking oils and waste fatty acids, into waste-based and advanced biodiesel or trade the feedstocks and finished products. Our members…

Consultation response

Bioledger Ltd, 7 Nov 2024

Bioledger, an EU UDB Service Provider and Access Point, provides software enabling biofuel and feedstock companies across all supply chains and certification schemes to meet EU RED and UDB reporting requirements. With our attached feedback considered, Bioledger supports the efforts of the Draft…

Consultation response

European Bulk Oil Traders' Association, 7 Nov 2024

EBOTA is grateful for the opportunity to provide feedback on the draft Delegated Regulation. Please find attached feedback which is provided by the members of the EBOTA RED Working Group (Chevron, Gunvor, Hartree, Litasco, Mercuria, P66, Targray, TOTSA, Trafigura and Vitol).

Consultation response

APPA Biocarburantes, 7 Nov 2024

1.- APPA Biocarburantes regards positively the Commission's proposal to extend the scope of the UDB to the raw materials used to produce renewable fuels and recycled carbon fuels, although we deem that it should be evaluated to limit this extension, at least initially, to the raw materials with a…

Consultation response

Hungarian Biofuels Association, 6 Nov 2024

Submission by the Hungarian Biofuels Association (HBA) The Hungarian Biofuels Association (HBA) welcomes the opportunity to provide input on the European Commission's proposal to extend the Union Database (UDB) requirements. While we recognize the Commission's intent to enhance transparency within…

Consultation response

European Fat Processors Renderers Association, 6 Nov 2024

EFPRA represents the European Rendering industry, producing i.e. animal fats of Category 1, 2 and 3. EFPRA fully supports any initiative to avoid biofuel fraud risks within or from outside the European Union, as long as it means the same working conditions, requirements and opportunities for…

Consultation response

Alcogroup SA, 5 Nov 2024

Please find Alcogroup's feedback in the attached Word file. Many thanks and best regards Yves Annoye

Consultation response

DER AGRARHANDEL - Bundesverband Agrarhandel und Verein der Getreidehändler der Hamburger Börse e.V., 24 Oct 2024

Wir warnen dringend davor, die UDB in der jetzigen Form übereilt und mit heißer Nadel gestrickt verpflichtend einführen zu wollen. Schon beim Thema entwaldungsfreie Lieferketten hat sich gezeigt, dass der Schaden sehr viel größer ist, wenn eine solches System mit großer Eile und ohne…