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Greenhouse gas emissions savings methodology for recycled carbon fuels and renewable fuels of non-biological origin

Energy

The Commission is required to adopt by 31/12/2021, a Delegated Regulation to supplement Directive 2018/2001 on the promotion of the use of energy from renewable source, by specifying the methodology for assessing greenhouse gas emissions savings from renewable liquid and gaseous transport fuels of non-biological origin and from recycled carbon fuels.

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Public consultation

ID: 12713

Lobbying Activity

112 responses

T&E Demands Removal of Green Hydrogen Additionality Loophole

Transport and Environment (European Federation for Transport and Environment), 17 Jun 2022

T&E demands the removal of a grandfathering clause that exempts early electrolysers from proving they use additional renewable energy. They argue strict additionality is essential to ensure hydrogen production does not increase fossil fuel generation.
Ensuring strict rules prevents greenwashing of hydrogen, upholding T&E's core mission for zero-emission mobility.
Consumers and businesses would suffer from higher electricity prices caused by increased grid demand.

BEUC urges stricter hydrogen rules to protect consumer energy bills

Bureau Européen des Unions de Consommateurs, 17 Jun 2022

BEUC demands hydrogen be produced only from new renewable power plants to avoid price hikes. They call for removing transition period loopholes that exempt early producers from rules.
Stricter regulations would prevent industrial hydrogen production from driving up household electricity costs.
Hydrogen producers would lose financial advantages and face higher costs for network infrastructure.

Consultation response

Microsoft Corporation, 16 Jun 2022

Our vision for a carbon-free grid recognizes that rapid grid decarbonization is necessary both to eliminate emissions within the electric sector itself and to enable emission reductions in other sectors via widespread electrification. That’s why Microsoft’s commitment is to have 100 percent of our…

Chemical industry urges flexible rules for renewable hydrogen certification

European Chemical Industry Council, 17 Jun 2022

The industry requests changes to greenhouse gas accounting rules, avoiding economic value-based allocation for co-products and deleting the 2035 phase-out for using captured carbon from ETS installations. They emphasize the need for regulatory predictability and warn against double-counting emissions reductions.
This would provide investment certainty and facilitate scale-up of renewable hydrogen production in the chemical sector.
Weaker carbon accounting rules could undermine genuine emissions reductions and climate ambition.

EUROFER demands removal of 2035 industrial carbon capture sunset clause

The European Steel Association, 17 Jun 2022

The association calls for deleting the 2035 sunset clause and vague sustainability labels. They also want flexible electricity agreements to help meet greenhouse gas reduction targets.
This would ensure economic viability for investments and accelerate the rollout of technologies.
Producers in countries with carbon-heavy electricity grids would face unfair competition and distortion.

ArcelorMittal urges EU to scrap carbon capture sunset clause

ArcelorMittal, 17 Jun 2022

The company demands the removal of the 2035 deadline and 'non-sustainable' label. They also request flexible electricity accounting to meet strict emission reduction targets.
This would protect the company's long-term investments in converting steel waste gases into fuels.
Steel producers in countries with carbon-intensive electricity grids would face a competitive disadvantage.

Confederation of Finnish Industries EK urges technology-neutral hydrogen production

Confederation of Finnish Industries EK, 17 Jun 2022

The group advocates for technology neutrality by allowing fossil-free electricity, including nuclear, to produce hydrogen. They also suggest lowering the renewable grid threshold to 70% and easing strict matching rules.
Using low-carbon grid electricity would lower investment costs and increase domestic fuel production.
Small hydrogen producers risk being pushed out of the market by complex regulatory requirements.

Danish Industry warns complex fuel rules may block investment

Confederation of Danish Industry, 17 Jun 2022

Danish Industry requests simpler formulas and aligned regulations to ensure rules are workable. They also want permission to allocate different emission intensities to various fuel types.
Clearer regulations would provide the certainty needed for firms to finalize major investments.
Environmental advocates lose if inconsistent rules permit greenwashing of hydrogen and fuel products.

VDA calls for flexible greenhouse gas rules for synthetic fuels

Verband der Automobilindustrie, 17 Jun 2022

VDA requests including industrial CO2 sources from outside the EU ETS. They want carbon capture at unavoidable sources permitted after 2036. The association suggests using energy content to allocate greenhouse gas emissions.
This would lower administrative burdens and expand the availability of industrial carbon sources.

Eni Urges Stable Regulatory Rules for Renewable Fuel Investment

Eni S.p.A., 17 Jun 2022

Eni requests clear and consistent rules for renewable and recycled carbon fuels. They argue that stable regulations are essential to unlock large-scale investment and minimize legal uncertainty.
A stable framework would provide the confidence needed to fund innovative energy projects.

Consultation response

Hydrogen Europe, 17 Jun 2022

The Delegated Regulation on establishing a minimum threshold for greenhouse gas emissions savings of recycled carbon fuels (RCF) and specifying a methodology for assessing greenhouse gas emissions savings from renewable liquid and gaseous transport fuels of non-biological origin (RFNBO) and from…

Austrian Business Chamber Urges Extended Credits for Carbon Capture

Wirtschaftskammer Österreich, 17 Jun 2022

The organization calls for long-term investment security and a reduction in bureaucratic effort. They suggest expanding the timeframe for carbon capture credits beyond the current 2035 limit.
Extended timelines would allow industries to amortize the costs of installing carbon capture equipment.

Neste urges EU to accept all CO2 sources for renewable fuel production

Neste Oyj, 17 Jun 2022

The company requests removal of restrictions on CO2 sources for renewable fuel production, arguing all CO2 that would otherwise be emitted should be accepted. They seek full credits for captured CO2 and annual updates to grid emission values to reflect rapid decarbonization.
This would accelerate their production capacity expansion and provide flexibility for annual GHG calculations.
Environmental groups lose stricter standards ensuring CO2 sources are genuinely additional to climate goals.

Consultation response

ENGIE, 17 Jun 2022

We would like to thank you for the possibility to provide our feedback on this important draft delegated act. Please refer to our position paper in attachment (see part 2 on the Delegated Regulation Establishing a Minimum Threshold for GHG Savings of RCFs and RFNBOs)

Fortum calls for removal of industrial CO2 phase-out dates

Fortum Oyj, 17 Jun 2022

Fortum and Uniper demand the removal of the 2036 phase-out date for industrial carbon dioxide. They also seek simpler rules and updated national electricity grid data.
Deleting the phase-out date secures future revenues for their synthetic fuel and hydrogen projects.
Environmental groups lose if fossil-based carbon remains integrated into the green fuel supply chain.

Iberdrola urges stricter additionality rules for renewable hydrogen

IBERDROLA, 17 Jun 2022

Iberdrola demands stricter rules to ensure hydrogen production uses new renewable energy sources. They want equal treatment for direct and grid connections to maintain a level playing field. Additionally, they advocate for zero-emission status for hydrogen produced from 100% renewable electricity.
These rules would protect the competitive advantage of Iberdrola’s vast renewable portfolio.
Consumers and the climate suffer through higher energy prices and increased greenhouse emissions.

Consultation response

Ørsted A/S, 17 Jun 2022

The Delegated Act (DA) assessing GHG savings from R(T)FNBOs is needed to provide the necessary standard for the renewable PtX sector to ramp-up, to deliver and contribute to climate ambitions and to security of supply. To achieve this and to take final investment decisions on first-mover projects,…

Paper Industry Urges Flexible Rules for Renewable Hydrogen Production

Confederation of European Paper Industries, 17 Jun 2022

Avoid strict conditionality rules that disrupt energy supply and market efficiency. Ensure a level playing field between hydrogen production and direct electrification.
Flexibility ensures stable energy supplies and lower costs for industrial hydrogen investments.
Electricity consumers and market participants face inefficiencies and potential pricing distortions.

German energy group BDEW seeks flexible green fuel methodology

BDEW Bundesverband der Energie- und Wasserwirtschaft e. V., 17 Jun 2022

BDEW requests the transferability of the methodology to low-carbon fuels and waste. They also suggest using established methods for biomass to avoid double work.
This would reduce administrative burdens and help projects using hydrogen in refineries.

Equinor urges removal of 2035 fossil carbon feedstock deadline

Equinor ASA, 17 Jun 2022

Equinor asks the Commission to delete or extend the 2035 deadline for fossil feedstock. They argue that capital-intensive projects require longer investment cycles and clear rules for direct air capture.
This protects their long-term capital investments in complex industrial carbon reduction projects.
Environmental efforts lose if large-scale emission reduction projects are abandoned due to uncertainty.

Eurogas pushes for flexible carbon sourcing in renewable fuel rules

EUROGAS, 17 Jun 2022

Eurogas recommends removing the 2035 time limit on using captured industrial carbon for fuel production. They propose using default values for transport emissions to avoid the technical challenge of tracking individual gas molecules. Additionally, they want the methodology to include carbon captured from waste treatment facilities.
This would reduce administrative costs and facilitate easier trading across the EU gas network.
Environmental targets may be undermined by allowing continued use of non-sustainable industrial carbon.

European cement industry fights 2035 limit on industrial CO2

CEMBUREAU - The European Cement Association, 17 Jun 2022

The association suggests removing the 2035 limit on using industrial CO2 for fuel production. They argue these proposals are premature without an impact assessment or political discussion. They also request that carbon pricing be decided by market participants rather than fixed upstream.
This would preserve the economic viability of the industry's ongoing carbon capture projects.
Transport sectors lose access to affordable synthetic fuels due to restricted carbon sources.

Danish Chamber of Commerce seeks clarity on waste-based fuels

The Danish Chamber of Commerce, 17 Jun 2022

They request that CO2 from waste-to-energy plants be classified as a sustainable source after 2035. The organization also calls for aligning definitions between different regulations to avoid market confusion.
Clearer rules would provide investment certainty for companies using municipal waste installations.
Environmental advocates lose if flexible electricity definitions undermine strict renewable energy standards.

E.ON Urges More Flexible Greenhouse Gas Calculation Rules

E.ON SE, 17 Jun 2022

E.ON requests clearer rules for calculating emissions from hydrogen transport and distribution. They want credits for capturing industrial carbon emissions extended until 2045. The company also suggests lowering default emission values for grid-sourced electricity.
This would protect the financial viability of long-term, capital-intensive investments in hydrogen.
Environmental goals are weakened as prolonging fossil-based carbon use delays full decarbonization.

Siemens Energy urges flexible CO2 rules for renewable fuels

Siemens Energy AG, 17 Jun 2022

Siemens Energy requests extending the deadline for using fossil CO2 until 2045 to protect long-term investments. They also want CO2 from waste plants recognized as a sustainable source to lower production costs. Lastly, they suggest removing carbon pricing rules that disadvantage synthetic fuels against traditional fuels.
This would improve the cost-competitiveness of their fuel technologies and support global expansion.
Environmental targets may be compromised by extending the industrial use of fossil-based carbon.

SUEZ urges clearer greenhouse gas rules for recycled fuels

SUEZ Group, 17 Jun 2022

SUEZ recommends that incineration for electricity should be the default reference for non-recyclable waste. They also propose extending the 'existing use' concept to advanced biofuels for mixed feedstocks.
This methodology allows their waste-to-fuel projects to meet the mandatory 70% emission reduction target.
Long-term waste-to-fuel projects lose viability due to the planned 2035 limit on non-sustainable carbon.

Air Liquide urges flexible rules for low-carbon hydrogen production

AIR LIQUIDE, 17 Jun 2022

Air Liquide requests that low-carbon hydrogen play a role alongside renewable hydrogen. They want clarified rules for mixing electricity sources and full life-cycle assessments.
This would allow the company to monetize existing low-carbon production assets more easily.
Carbon emitters would be forced to bear the financial burden of pollution.

EnBW urges flexible emission rules to accelerate hydrogen investments

EnBW Energie Baden-Württemberg AG, 17 Jun 2022

EnBW requests applying this methodology to the gas package and allowing annual emission factor updates. They advocate for using actual emission data and removing transport emissions from calculations.
These changes would provide regulatory certainty for investments while cutting administrative costs.
Climate monitoring accuracy could suffer if emissions from storage and distribution are excluded.

Wirtschaftsvereinigung Stahl urges special status for unavoidable carbon

Wirtschaftsvereinigung Stahl, 17 Jun 2022

WV Stahl requests rules distinguishing between carbon from unavoidable sources and other sectors. They argue these emissions should count as avoided greenhouse gases even after 2035.
The industry would avoid carbon costs while continuing to operate current blast furnace technology.
Industries with easier decarbonisation paths would face stricter limitations on using carbon capture.

Zero Waste Europe demands stricter carbon accounting for recycled fuels

Zero Waste Europe, 17 Jun 2022

ZWE requests removing "avoided emissions" from the methodology for assessing recycled carbon fuels. They argue these practices artificially reshape the real carbon footprint of plastic fuels. They also recommend using actual greenhouse gas intensity for electricity instead of national averages.
This ensures only fuels with true potential for emission reductions meet the legal requirements.
Companies making fuels from plastic waste would lose their competitive advantage from lenient accounting.

BP urges EU to allow fossil carbon until 2045

BP p.l.c., 17 Jun 2022

BP requests a grandfathering clause for plants using fossil carbon until 2045. They also want municipal solid waste included as a valid fuel feedstock. The company suggests using energy-based allocation for greenhouse gas emissions calculations.
Clearer rules and extended deadlines would reduce investment risks for expensive fuel projects.
Climate advocates lose as BP seeks to extend fossil carbon usage for another decade.

Maersk calls for fairer accounting of renewable shipping fuels

A.P. Møller - Mærsk A/S, 17 Jun 2022

Maersk urges applying mass-balance principles to preserve the value of high-performing renewable fuels. They also request clear definitions for CO2 sourcing to include sustainable biogenic inputs from biomass.
The company would retain the commercial value of high-performing fuels through virtual accounting methods.
Producers in non-nuclear countries face a competitive disadvantage under the proposed power pricing rules.

Finnish chemical industry urges flexible carbon capture rules

Chemical Industry Federation of Finland (Kemianteollisuus ry), 17 Jun 2022

CIFF demands accepting all CO2 sources otherwise emitted to the atmosphere and removing the 2035 carbon capture phase-out. They also request using Guarantees of Origin for tracing emissions reductions throughout value chains.
The proposals would provide regulatory predictability and prevent delays in developing production capacity.
Producers outside the EU currently benefit from inconsistent lifecycle emission accounting rules.

Veolia warns EU carbon reuse ban threatens fuel investments

Veolia Environnement, 17 Jun 2022

Veolia requests the removal of the 2035 time limit on reusing industrial emissions for fuel production. They seek clearer definitions for sustainable carbon and protection for existing investment projects.
Removing the deadline protects long-term investments in industrial-scale carbon capture and reuse facilities.
The energy transition loses momentum, harming progress toward EU climate goals.

Repsol Urges More Flexibility in Green Fuel Methodology

Repsol, S.A., 17 Jun 2022

Repsol requests additional efforts to simplify the methodology to ensure a swift implementation. They propose allowing industrial captured carbon sources beyond 2035 and introducing credits for landfilling.
The changes would provide a stable framework for evaluating business cases and protecting investments.
Climate goals may suffer if extended use of industrial carbon delays absolute industrial decarbonization.

Snam Urges More Flexible Rules for Renewable Hydrogen Classification

Snam S.p.A., 17 Jun 2022

Snam suggests delaying the matching of hourly electricity production and consumption until 2035. They also propose lowering the renewable electricity threshold for local market regions. Finally, they advocate for extending the transition period for new projects until 2030.
Relaxing these requirements would significantly lower production costs and enable continuous fuel supply.
Environmental advocates lose as these changes allow hydrogen to be labeled renewable despite higher emissions.

Uniper calls for simpler methodology for renewable hydrogen emissions

Uniper, 17 Jun 2022

Uniper calls for simpler rules and removing the 2036 phase-out for industrial carbon dioxide. They also recommend using up-to-date data for national grid electricity intensity.
These changes would lower compliance costs and protect the viability of their hydrogen projects.
Environmentalists lose as extending industrial carbon dioxide use delays the transition to cleaner technologies.

eFuel Alliance urges flexible rules for renewable hydrogen production

eFuel Alliance, 17 Jun 2022

The Alliance requests grandfathering for industrial CO2 sources beyond 2036 and elimination of restrictions limiting these sources to EU ETS activities. They argue the 10-year lifespan is insufficient to amortize carbon capture costs and prevents eFuel production at cement, steel, and glass facilities.
This would protect their investments in industrial carbon capture from becoming stranded assets.
Climate advocates lose stricter requirements ensuring faster transition to direct air capture technology.

Nucleareurope pushes for lower emission factors for nuclear hydrogen

Forum Atomique Européen, 16 Jun 2022

The group suggests using hourly grid emission data and lower nuclear emission factors. They also advocate for a full life cycle assessment to ensure technological neutrality.
Lowering these factors makes nuclear-derived hydrogen viable under EU emission thresholds.
Foreign renewable equipment manufacturers may face disadvantages from full lifecycle emission checks.

CIP urges EU to accept waste-to-energy emissions for green fuels

Copenhagen Infrastructure Partners P/S, 17 Jun 2022

The groups demand that CO2 from waste-to-energy plants remain eligible for fuel production after 2035. They argue fossil plastic emissions are unavoidable and should qualify for sustainable status. They also request clarity on investment grandfathering and input definitions.
This would allow the company to monetize carbon captured from their waste incineration plants.
Environmental groups lose if burning fossil plastic is classified as a sustainable source of carbon.

Bellona Europa demands stricter carbon accounting for renewable fuels

Bellona Europa, 17 Jun 2022

Bellona Europa requests the methodology reflect the fuels' entire carbon intensity and prevent double counting. They demand fossil carbon be differentiated from atmospheric sources to ensure real emission reductions.
This ensures that renewable fuel production supports genuine climate targets and additional green energy.
Early-stage hydrogen projects would lose their permanent exemption from requirements to add renewable capacity.

Liquid Gas Europe urges fair greenhouse gas calculation rules

Liquid Gas Europe, 17 Jun 2022

The association requests including hydrogen compression emissions and using economic value for allocation. They also call for LPG to be added to the standard values table.
These changes would ensure a level playing field between hydrogen and liquid gases.
Hydrogen producers would face higher carbon ratings if compression and distribution emissions are included.

MOL Group urges flexible GHG rules for synthetic fuels

MOL Hungarian Oil and Gas Company, 17 Jun 2022

MOL requests renewable energy definitions use heating values instead of molecular structures. They advocate for indefinite industrial carbon dioxide use and mass-balance allocation for emissions.
This would stabilize investment and prevent volatile carbon intensity ratings for their fuels.
Environmental advocates lose the opportunity to mandate cleaner direct air capture technology.

Heidelberg Materials urges removal of 2035 industrial CO2 limit

Heidelberg Materials AG, 17 Jun 2022

The group requests removing the 2035 deadline for using captured industrial emissions in fuel production. They argue unavoidable process emissions should be classified as sustainable. They also suggest grandfathering rules for existing projects.
This allows the company to monetize process emissions and prevents future investment losses.

Enagás advocates for carbon circularity in new EU fuel methodology

Enagás S.A., 17 Jun 2022

Enagás suggests sharing emission responsibility between fuel users and capture facilities. They want to exempt gas grid operations from strict emission tracing requirements. The group also supports using yearly correlation to reduce production costs.
This would reduce administrative burdens and lower capital costs for synthetic fuel production.
The EU Emissions Trading System loses revenue if carbon capture facilities are granted exemptions.

Consultation response

Environmental Defense Fund Europe, 17 Jun 2022

Environmental Defense Fund Europe welcomes the publication of the Delegated Act setting out a methodology for assessing greenhouse gas emission savings for RFNBOs and recycled carbon fuels. We believe that renewable hydrogen can play an important role in the EU economy and these rules will be…

EDP calls for fairer methodology for renewable hydrogen savings

EDP - Energias de Portugal, SA, 17 Jun 2022

EDP requests that hydrogen produced from pure renewable electricity be attributed zero emissions. They argue current rules create an unfair field by ignoring the fuel's origin. They also propose adjusting emission benchmarks for different sectors like heating and cooling.
EDP would secure a competitive advantage for its high-quality renewable hydrogen production.
Climate targets are undermined by weak emission standards for hydrogen in non-transport sectors.

Port of Rotterdam Urges Realistic Rules for Renewable Hydrogen

Havenbedrijf Rotterdam NV, 17 Jun 2022

The Port requests realistic production conditions and a dedicated impact assessment to ensure investment certainty. They seek clarity on rules for non-EU imports and lower thresholds for bidding zones.
Realistic regulations would secure investment cases and facilitate the Port's massive hydrogen import ambitions.
Future hydrogen producers face higher costs and restricted capacity due to strict energy matching rules.

UFE urges lower carbon intensity values for French electricity

UNION FRANCAISE DE L'ELECTRICITE - UFE, 17 Jun 2022

UFE requests using more accurate national data to reflect France's low-carbon mix. They also propose an hourly methodology and grandfathering for industrial carbon capture.
Lowering carbon intensity values would improve the competitiveness of French hydrogen producers under EU rules.
Direct air capture firms would lose their regulatory advantage over cheaper industrial carbon capture sources.

Moeve urges removal of 2035 restriction on industrial CO2 capture

Moeve, 17 Jun 2022

Moeve suggests removing the 2035 deadline for industrial carbon capture to support synthetic fuel development. They also argue for treating unavoidable fossil carbon outputs as rigid production inputs.
These changes would protect their business case for developing synthetic fuels at existing industrial refineries.
Climate targets might be undermined if capturing emissions encourages the continued use of non-sustainable fuels.

Covestro AG seeks flexible green hydrogen production rules

Covestro AG, 17 Jun 2022

Covestro requests a flexible methodology that recognizes hydrogen produced as a co-product. They propose basing carbon calculations on energy content instead of economic value.
The company could market its existing chemical byproducts as high-value renewable fuel.
Industrial sectors lose because rigid rules force continued dependency on fossil fuels.

CEA demands immediate hourly tracking for renewable hydrogen production

Commissariat à l'Energie atomique et aux énergies alternatives, 13 Jun 2022

CEA urges the Commission to implement hourly time correlation for hydrogen production immediately. Carbon intensity calculations must include hydrogen transport, distribution, storage, and compression. The Commission should provide a grandfathering clause for industrial carbon capture projects.
A grandfathering clause would protect long-term investments in industrial carbon capture projects.
Fossil fuel interests lose the ability to mislabel non-renewable energy as green.

Negative Emissions Platform backs targets for sustainable carbon fuels

Negative Emissions Platform, 17 Jun 2022

NEP supports transitioning to sustainable CO2 by 2036 and carbon pricing for fuel imports. They also call for clear targets and support mechanisms for new synthetic fuel facilities.
This policy would lower costs for capture technologies and create a secure investment environment.
Industrial emitters will lose a revenue stream as their carbon becomes ineligible after 2036.

ICCT supports rigorous GHG accounting for alternative transport fuels

International Council on Clean Transportation, 17 Jun 2022

ICCT supports the methodology but requests strict accounting for electricity greenhouse gas intensity. They recommend defining recycled carbon fuels specifically as non-renewable waste streams.
Rigorous standards ensure that policy support targets fuels with significant climate mitigation benefits.
Fuel producers with modest climate benefits lose the opportunity to receive regulatory investment.

Business & Science Poland demands fairer alternative fuel rules

Związek Pracodawców Business & Science Poland, 17 Jun 2022

BSP requests calculating emissions using energy content instead of fluctuating economic values. They also suggest extending deadlines for non-sustainable carbon and accounting for hydrogen transport costs.
Polish firms would avoid unfair competition from cheaper hydrogen imports that ignore transport emissions.
Non-EU hydrogen producers lose their price advantage if transport-related carbon costs are added.

Tree Energy Solutions wants rules to recognize closed-loop carbon use

Tree Energy Solutions BV, 17 Jun 2022

The organization requests including carbon capture and utilization in the emission calculation formula. They also propose an evaluation of carbon availability before the 2035 cutoff for non-sustainable sources.
These clarifications would secure the regulatory framework for their multi-billion euro methane project.
Biodiversity and the land-use sector suffer if inflexible deadlines force excessive biomass burning.

Air Products urges clear rules for imported renewable hydrogen

Air Products, 16 Jun 2022

The organization requests clarification to avoid administrative complexities when converting hydrogen carriers like ammonia. They advocate for a level playing field between liquid and gaseous forms of hydrogen. Finally, they propose biomethane used for conversion be considered low carbon.
Clearer rules would protect their investments in imported ammonia and liquid hydrogen distribution.
Gaseous hydrogen suppliers might lose the regulatory advantage they currently hold over liquid forms.

Westenergy calls for waste incineration inclusion in fuel rules

Westenergy Oy, 17 Jun 2022

Westenergy requests that CO2 captured from waste incineration be explicitly recognized in the methodology. They also advocate removing the 2035 deadline to protect long-term capital investments.
The company would gain regulatory certainty and a viable payback period for its investments.
The waste-to-energy sector faces significant investment risks due to restrictive and unclear rules.

Holcim warns EU carbon rules threaten industrial decarbonisation investments

Holcim Ltd, 17 Jun 2022

Holcim requests that captured industrial emissions be classified as avoided rather than released. They demand removing the 2035 deadline for using industrial carbon, extending support until 2050.
Recognising captured carbon as avoided ensures the economic viability of Holcim's investments.
Inland cement facilities lose because they lack storage infrastructure and require carbon recycling routes.

CEWEP demands inclusion of waste incineration in fuel carbon rules

Confederation of European Waste-to-Energy Plants, 17 Jun 2022

Include CO2 from waste incineration in emission reduction calculations. Remove the restrictive 2035 deadline for fossil carbon point sources. Account for carbon savings achieved by diverting non-recyclable waste from landfills.
Operators would secure long-term investment viability for hydrogen and fuel production.
Communities lose access to local low-carbon fuel if waste is landfilled.

German waste association urges inclusion of waste-to-energy in fuel rules

BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V., 17 Jun 2022

The BDE recommends including thermal treatment of non-recyclable waste as an accountable carbon source. They also propose removing the 2035 deadline to provide enough time for investment returns.
This would allow waste management firms to commercialize captured carbon and secure long-term investment.
Future fuel project developers lose because current rules prevent long-term financial viability.

German biofuel industry demands higher targets and strict fuel accounting

Verband der Deutschen Biokraftstoffindustrie, 17 Jun 2022

VDB requests dedicated renewable electricity for production and significantly higher climate targets. They also oppose overrating the climate benefits of grid electricity.
These rules would protect the market position of biofuels against competing energy sources.
Producers using standard grid power would see their reported emissions increase dramatically.

IFIEC Europe urges EU to relax renewable hydrogen rules

IFIEC Europe, 17 Jun 2022

IFIEC argues for a technology neutral approach including low carbon hydrogen to avoid hampering market development. They request adjustments to allow continuous production and more flexible links to the power grid.
Relaxed rules would lower production costs and ensure stable hydrogen supplies for industry.

Consultation response

CEMEX, S.A.B. de C.V., 17 Jun 2022

Please find attached our paper.

German cement association demands removal of 2035 carbon reuse deadline

Verein Deutscher Zementwerke e.V., 17 Jun 2022

VDZ requests removing the 2035 end date for synthetic fuels using captured industrial carbon. They want the Commission to differentiate between avoidable and unavoidable industrial emissions sources.
This would provide the long-term legal certainty needed for expensive carbon capture investments.
Environmental interests are harmed as blocking carbon reuse leads to higher atmospheric emissions.

Carbon Industry Urges EU to End Industrial Emission Reuse Ban

CO2 Value Europe AISBL, 17 Jun 2022

The association calls for a grandfathering clause allowing projects started before 2040 to continue using industrial carbon emissions. They argue the proposed 2035 ban on reused emissions is incompatible with industrial investment cycles. Furthermore, they request clearer definitions for sustainable carbon sources to avoid disrupting the emerging sector.
This protection would secure long-term industrial investments and prevent project cancellations.
European climate targets become unattainable if industrial carbon reuse is prematurely restricted.

Consultation response

SkyNRG B.V., 17 Jun 2022

SkyNRG welcomes this proposal outlining the calculation methodology for RFNBOs and RCFs, which sets the scene for project developers to align with the minimum 70% GHG reduction thresholds. However we believe the draft can be significantly improved by clarifying various elements and thereby enabling…

Consultation response

The Regulatory Assistance Project, 17 Jun 2022

The Regulatory Assistance Project (RAP) appreciates the opportunity to comment on the European Commission’s draft delegated acts on the “Production of renewable transport fuels – share of renewable electricity (requirements)” [hereinafter “RFNBO Production DA”] and “Renewable energy – method for…

Sandbag targets double-counting flaws in EU hydrogen methodology

Sandbag Climate Campaign, 17 Jun 2022

Sandbag proposes an amendment to exclude additional renewable electricity from grid intensity calculations. They argue the current method systematically under-estimates carbon intensity by establishing double-counting as a rule.
This would prevent the production of high-emission fuels that falsely claim a renewable origin.
Producers using carbon-intensive grid electricity would lose the ability to claim high savings.

Consultation response

SHV Energy NV, 17 Jun 2022

In the main text of the Delegated Act, paragraph 7, it is currently stated that for both RFNBOs and RCFs “capturing of emissions from non-sustainable sources should therefore only be considered as avoiding emissions until 2035”. We strongly recommend removing or amending this clause, for several…

Consultation response

Infinium Operations, LLC, 15 Jun 2022

Infinium Operations, LLC (“Infinium”) is a leading innovator in the clean fuels space with a mission to decarbonize the transportation sector and help mitigate the catastrophic effects of climate change. Infinium proprietary technology converts carbon dioxide and green hydrogen into ultra-low…

European lime industry urges removal of 2035 carbon capture limit

European Lime Association, 17 Jun 2022

The European Lime Association requests removing the 2035 industrial carbon capture deadline. They argue lime manufacturing produces unavoidable emissions requiring long-term reuse options. The group suggests distinguishing between process emissions and burning fossil fuels.
This would provide regulatory certainty and protect investments in essential carbon capture technologies.

Consultation response

European Roundtable on Climate Change and Sustainable Transition, 17 Jun 2022

ERCST welcomes the opportunity to provide our views on the proposed Delegated Act. The European Commission is envisaging a hydrogen economy where regulation rather than markets is playing the key role in the development of the Hydrogen market. The amount of renewable electricity required to…

Consultation response

Fortescue, 17 Jun 2022

FFI appreciates the opportunity to provide feedback to the Delegated Act and intends to take account of the Commission's kind offer made during the stakeholder event on the Delegated Act on renewable hydrogen for participants to make pertinent submissions bilaterally at a later date, as we are…

Consultation response

Methanol Institute, 17 Jun 2022

The Methanol Institute welcomes the introduction of the implementing act, recognizing the importance of setting uniform rules to lay the foundation for the increased integration of sustainable fuels sourced from captured carbon to address the challenges of decarbonization of mobility. While a…

Consultation response

LanzaTech EU B.V, 10 Jun 2022

LanzaTech, is a global company with a registered business in the Netherlands and offices EU-wide. Its gas fermentation technology uses biology to recycle waste carbon into ethanol; this is converted into sustainable aviation fuel (SAF) using the LanzaJet™ Alcohol to Jet process. By capturing and…

Consultation response

France Hydrogène, 17 Jun 2022

France Hydrogène welcomes the Delegated Act defining a method for assessing GHG emission savings for renewable hydrogen and its derivatives (RFNBO). The DA has been long awaited to complete the legal definition of renewable hydrogen, provide a clear and certain framework to investors and…

Consultation response

Associação Técnica da Indústria de Cimento, 17 Jun 2022

Documento em anexo.

Consultation response

Enerkem Incorporated, 16 Jun 2022

Please see the attached letter.

Bioenergy Association of Finland urges broader CO2 source rules

Bioenergia ry - Bioenergy Association of Finland, 17 Jun 2022

The association demands including carbon from waste incineration and annual updates for electricity grid emissions. They seek a full lifecycle approach to prevent market distortions for hydrogen production.
Including waste-derived carbon would facilitate timely investments and ensure accurate emission accounting.
European member states could lose investment capital to external hydrogen producers under current rules.

Belgian Chemical Industry Urges Technology-Neutral Hydrogen Framework

Fédération belge des industries chimiques et des sciences de la vie, 17 Jun 2022

Essenscia urges a technology-neutral approach including low-carbon hydrogen. They request limiting the Renewable Energy Directive to energy use. Additionally, accounting rules for avoided emissions should not include a 2036 time restriction.
This ensures the chemical sector can access necessary hydrogen volumes at competitive prices.
Renewable electricity producers lose market exclusivity if other low-carbon methods are recognized.

German Fuel Industry Urges Green Hydrogen Refinement Rules

Wirtschaftsverband Fuels und Energie e. V., 16 Jun 2022

The industry requests inclusion of green hydrogen used in refineries for fuel hydro treatment, recognition of municipal waste as eligible feedstock, indefinite use of unavoidable industrial CO2 sources, and energy-based rather than economic allocation methods.
This would enable refineries to count green hydrogen toward renewable targets while reducing administrative burden.
Climate advocates lose stricter carbon accounting that would discourage continued fossil fuel production.

Consultation response

Carbon Engineering ULC, 17 Jun 2022

Please find attached the feedback from Carbon Engineering. Kind regards, Helen

Consultation response

Eneco, 17 Jun 2022

Eneco is an energy service company with customers in the Netherlands, Belgium, Germany and the United Kingdom. We develop and operate on- and offshore wind assets, solar farms, heat networks, gas-fired plants, renewable heat sources, electric boilers, batteries, energy management systems and…

Waste-to-energy suppliers urge EU to include waste in fuel rules

European Suppliers of Waste-to-Energy Technology, 17 Jun 2022

ESWET requests that waste incineration be explicitly included as an emission reduction source. They also seek the removal of the 2035 limit on fossil carbon capture.
This would provide investment security for plants converting non-recyclable waste into hydrogen.
The EU's decarbonization efforts lose access to immediate and local low-carbon fuels.

Consultation response

France gaz, 17 Jun 2022

AFG welcomes the recent draft delegated act from the European Commission (EC) “establishing a minimum threshold for greenhouse gas emissions savings of recycled carbon fuels and by specifying a methodology for assessing greenhouse gas emissions savings from renewable liquid and gaseous transport…

Consultation response

Sasol, 17 Jun 2022

Please refer to the attached document.

Consultation response

Deutscher Wasserstoff-Verband, 16 Jun 2022

Stellungnahme zum Entwurf der EU-Kommission zum DELEGIERTEN RECHTSAKT zur Ergänzung der Richtlinie (EU) 2018/2001 des Europäischen Parlaments und des Rates durch die Festlegung eines Mindestschwellenwerts für die Treibhausgasemissionseinsparungen durch rezyklierte kohlenstoffhaltige Kraftstoffe und…

Consultation response

Hydrogenious LOHC Technologies GmbH, 15 Jun 2022

Hydrogenious LOHC Technologies supports the objectives of the REPowerEU plan and welcomes the opportunity to provide feedback to the Delegated Act on Article 25 (2) and Article 28 (5) of the Renewable Energy Directive. Adoption of the Delegated Act with a methodology for assessing greenhouse gas…

Consultation response

Portuguese Renewable Energy Association, 14 Jun 2022

APREN's response is attached as a pdf file named "APRENs response to the Draft DA Emission savings RFNBOs".

Consultation response

FEBELCEM - The Belgian Cement Association, 17 Jun 2022

Dear Sir, Dear Madam, Please find attached the feedback from FEBELCEM, the Belgian Cement Association, related to this consultation. Best regards

Consultation response

New Energies Coalition, 17 Jun 2022

The Coalition for the energies of tomorrow in Transport and Supply Chain welcomes the recent draft delegated act from the European Commission (EC) “establishing a minimum threshold for greenhouse gas emissions savings of recycled carbon fuels and by specifying a methodology for assessing greenhouse…

Consultation response

Elengy, 17 Jun 2022

Please find herewith attached Elengy's contribution.

Consultation response

NextChem - Maire Tecnimont Group, 17 Jun 2022

Nextchem provides the following comments: 1. Foreword n. 7 The provision seems to allow sustainable fuels to play a transitional role until complete electrification of transportation begins in 2035. This scenario, however, concerns only light road transport, while it is not possible for maritime,…

Consultation response

Krajowa Izba Biopaliw, 15 Jun 2022

w załączeniu przesyłamy stanowisko Krajowej Izby Biopaliw.

Consultation response

Polska Izba Przemysłu Chemicznego, 15 Jun 2022

Stanowisko Polskiej Izby Przemysłu Chemicznego znajduje się w załączonym pliku.

Consultation response

, 17 Jun 2022

VDMA welcomes the fact that the EU Commission wants to provide clarity on the rulebook of eligible CO2 sources and the calculation of GHG savings from RFNBOs. To achieve climateneutrality by 2050, the switch to climate neutral gases and fuels (eFuels) is of central importance. CO2 is an important…

Consultation response

Drivkraft Danmark, 17 Jun 2022

Please see attached document for detailed comments

Consultation response

Johanssen+Kretschmer Strategische Kommunikation GmbH, 17 Jun 2022

The European Commission has published a draft delegated act to establish a methodology to assess greenhouse gas (GHG) emission savings from RFNBOs and recycled carbon fuels (RCFs). The Power to X Alliance welcomes the largely technology-open design of the delegated act but sees a need for…

Consultation response

Syndicat Français des Industries Cimentières, 17 Jun 2022

Le projet d’acte délégué soumis à la consultation fixe des règles de comptabilisation du carbone évité qui interrogent la profession et qui pourraient compromettre la viabilité des projets de décarbonation basés sur le captage et la valorisation du carbone. Nous formulons un certain nombre…

Consultation response

ENERTRAG, 17 Jun 2022

General remarks: As a European renewable energy company and green hydrogen producer with sites in Germany, France and Poland as well as in Africa, Asia and Latin America, ENERTRAG supports the ambitious European CO2 reduction targets and the transformation of the energy sector. The recast Renewable…

Consultation response

Global Alliance Powerfuels, 17 Jun 2022

The Global Alliance Powerfuels welcomes the opportunity to comment on the European Commission’s proposal for the methodology to assess the greenhouse gas (GHG) emissions savings from renewable fuels of non-biological origin (RFNBOs) and recycled carbon fuels, which can provide much-needed…

Consultation response

Scottish Hydrogen and Fuel Cell Association, 17 Jun 2022

The Scottish Hydrogen and Fuel Cell Association (www.shfca.org.uk) welcomes this consultation on two draft EU delegated acts and the Annex which will define the requirements and methodology for certifying green hydrogen. Establishing suitable standards will encourage development and investment in…

Consultation response

, 17 Jun 2022

unem – unione energie per la mobilità, the Italian Association representing the refining industry and all energies for mobility, strongly supports the EU objective of net climate neutrality in 2050 and the circular economy, and stands ready to support policy makers RFNBOs and RCFs as centrepieces…

Consultation response

Aviation Initiative for Renewable Energy in Germany, 17 Jun 2022

aireg e.V. begrüßt die Veröffentlichung des Entwurfes eines delegierten Rechtsaktes zur Festlegung eines Treibhausgas- (THG-) Emissionsgrenzwertes für Recycled Carbon Fuels (RCF) und einer Methodik zur Bestimmung der THG-Minderungen durch Renewable Fuels of Non-Biological Origin (RFNBO) und RCF.…

Consultation response

bse Methanol GmbH, 17 Jun 2022

Im Sinne einer umsetzbaren Transformation empfehlen der Kommission nicht unterschiedslos "effective carbon pricing" von den Produktionsländern zu fordern. Wichtige Lieferländern würden dadurch wegfallen und Ressourcen an erneuerbarer Energie und ungenutzten Kohlenstoffemissionen würden…

Consultation response

International DME Association, 17 Jun 2022

In the main text of the Delegated Act, paragraph 7, it is currently stated that for both RFNBOs and RCFs “capturing of emissions from non-sustainable sources should therefore only be considered as avoiding emissions until 2035”. We strongly recommend removing or amending this clause, for several…

Consultation response

France Gaz Maritime, 17 Jun 2022

FRANCE GAZ MARITIME contribution to consultation on RFNBO-RCF GHG methodology France Gaz Maritime welcomes the recent draft delegated act from the European Commission (EC) “establishing a minimum threshold for greenhouse gas emissions savings of recycled carbon fuels and by specifying a…

Consultation response

LHYFE, 17 Jun 2022

Lhyfe welcome the draft Delegated Acts (DA) on the production of RFNBOs and on the GHG emission calculation for RFNBOs and RCF issued by the European Commission and recognize the significant efforts made to better reflect the reality of project developers in this early phase: long and complex…

Consultation response

H2V, 16 Jun 2022

As a developer, constructor, and operator of large-scale renewable hydrogen production plants (100 MW or more), H2V welcomes the opportunity to provide feedback on the effects that this Delegated Act will have on the hydrogen industry and on the EU meeting its decarbonization objectives. H2V has…

Consultation response

Federbeton, 16 Jun 2022

Federbeton welcomes the opportunity to provide feedback on the draft delegated act on GHG savings of RCF and RFNBO. Federbeton represents the Italian cement and concrete industries and has developed its decarbonisation strategy with 2030 and 2050 targets that sets out the technological and…

Consultation response

APPA Biocarburantes, 16 Jun 2022

Se exponen en el documento adjunto la valoración y propuestas que realiza APPA Biocarburantes sobre el Proyecto de Reglamento presentado por la Comisión Europea para establecer, por un lado, la reducción mínima de emisiones de gases de efecto invernadero (GEI) exigible a los combustibles de carbono…