OpenLobby.EU
Explore

Methodology to determine the share of renewables in case of co-processing

Energy

The Commission is required to adopt by 31 December 2021, a Delegated Regulation to supplement Directive 2018/2001 on the promotion of the use of energy from renewable source, by specifying the methodology to determine the share of biofuel, and biogas for transport, resulting from biomass being processed with fossil fuels in a common process (co-processing).

Links

Public consultation

ID: 12711

Lobbying Activity

24 responses

ArcelorMittal urges flexible biogenic allocation in steel manufacturing

ArcelorMittal, 20 Jul 2022

ArcelorMittal requests a specific exemption for industrial processes from proposed carbon testing requirements. They propose using mass and energy assessments to allocate biogenic carbon to specific gas streams.
This avoids high investment costs for separate furnaces while supporting decarbonization technology development.
Regulators lose the physical certainty of testing if biogenic content is determined by allocation.

FuelsEurope Urges More Flexibility in Biofuel Co-Processing Rules

FuelsEurope, 20 Jul 2022

They request freedom for operators to define system boundaries and choose conversion factors. They propose increasing the allowable test deviation from one to six percent. They suggest phasing in radiocarbon testing to allow European laboratory capacity to grow.
These changes would reduce administrative burdens and lower technical barriers for fuel refineries.
Climate monitoring groups lose precision because of the increased margin for error proposed.

WKÖ seeks shorter sample storage for renewable fuel co-processing

Wirtschaftskammer Österreich, 20 Jul 2022

WKÖ proposes reducing the minimum sample retention period from two years to two months. They seek to avoid disproportionate bureaucratic effort and high costs for new equipment.
This would lower operational costs by minimizing the volume of stored physical fuel samples.

Neste urges flexibility in biofuel testing and allocation methods

Neste Oyj, 15 Jul 2022

Neste requests more flexible testing requirements, including occasional rather than per-batch radiocarbon verification and allowing stoichiometric allocation methods instead of only proportional allocation. They also propose extending permissible deviation in testing from 1% to 6% and reducing sample storage requirements from two years to three months.
This would reduce their testing costs and storage requirements while allowing methods that better align with their refinery operations.

Cement industry seeks broader scope for EU co-processing rules

CEMBUREAU - The European Cement Association, 20 Jul 2022

The association asks to expand the definition of co-processing to include waste used in cement kilns. They also want these rules to apply to other sectors.
This would help the industry reduce emissions and lower reliance on imported fuels.

BP Urges Flexibility in EU Biofuel Co-Processing Rules

BP p.l.c., 20 Jul 2022

BP requests flexibility in testing frequency, narrower system boundaries around co-processing units rather than entire refineries, and a 3% deviation threshold instead of 1% for verification testing. They argue current requirements don't account for technical limitations and would discourage investment in renewable fuels.
This would reduce compliance complexity and costs for their refinery operations.
Environmental groups lose stricter verification standards that ensure accurate renewable fuel claims.

Repsol Seeks More Flexibility in EU Biomass Co-Processing Rules

Repsol, S.A., 20 Jul 2022

Repsol requests a one-year transitional period and flexibility to define measurement zones at the unit level. They also propose increasing the allowed measurement discrepancy from one to six percent to reflect testing uncertainties.
This would reduce its compliance costs and prevent negative impacts on refinery operations.

European Biodiesel Board demands strict auditing for co-processed fuels

European Biodiesel Board, 14 Jul 2022

The EBB insists that only biomass dedicated to transport fuels should be counted toward renewable targets. They call for harmonized accounting rules and robust auditability to prevent market distortions. Additionally, they advocate for C14 testing to verify fuel conversion factors.
Harmonized rules prevent market distortions and ensure bio-component volumes are accurately counted.
Refineries face increased operational costs from frequent mandatory testing and independent certification audits.

MOL Group urges practical refinery-level renewable fuel calculation rules

MOL Hungarian Oil and Gas Company, 19 Jul 2022

MOL requests unit-level system boundaries instead of refinery-wide measurements. They also seek to eliminate the requirement for keeping physical samples of every production batch.
This approach would lower compliance costs and provide investment certainty for biofuel production.
Member State authorities would lose direct control if third-party schemes handle all verification.

Enagás urges inclusion of electrolytic hydrogen in renewable methodology

Enagás S.A., 20 Jul 2022

Enagás requests extending the methodology to include renewable hydrogen from sources like electrolysis. They also want clarification on whether synthetic fuels will be treated similarly.
This expansion would allow Enagás to market electrolytic hydrogen as a renewable fuel.
Producers of biological hydrogen lose the competitive advantage of their exclusive regulatory status.

Moeve urges flexible verification for renewable fuel co-processing

Moeve, 20 Jul 2022

Moeve asks for the liberty to choose verification methods and define system boundaries for their facilities. They suggest that carbon testing should be performed on a yearly basis rather than for every batch. Furthermore, they argue that national systems with fixed conversion factors should continue to apply.
Moeve would reduce compliance costs by using existing monitoring frameworks and avoiding difficult gaseous stream testing.
Environmental advocates lose assurance of precise biocontent if fixed historical factors replace frequent, real-time testing.

ICCT supports strict verification for co-processed renewable fuels

International Council on Clean Transportation, 19 Jul 2022

The ICCT recommends that GHG calculations include natural gas inputs used to replace exported bio-propane. They also suggest explicitly listing radiocarbon testing as a primary method for determining bio-content in fuels.
These rules would protect the integrity of climate targets by ensuring bio-content claims are technically accurate.
Economic operators may see reduced carbon benefits if they must account for fossil fuels used to replace diverted biogas.

JBCE urges flexible biofuel testing to maintain price competitiveness

Japan Business Council in Europe, 20 Jul 2022

JBCE requests financial incentives for radiocarbon testing and more realistic error margins. They also propose relying on existing mass balance methods to verify bio-content.
Lowering testing standards would reduce compliance costs and prevent significant capital investments.
Biofuel operators lose competitive advantage if expensive testing requirements remain in place.

German biofuel lobby warns against strengthening oil refinery oligopoly

Verband der Deutschen Biokraftstoffindustrie, 19 Jul 2022

The association demands precise scientific testing and strict accounting to ensure only transport-specific biogenic content counts. They also call for biogenic shares to be verified before entering the market.
These regulations would safeguard the market position and investments of biodiesel producers.
Large oil companies lose the ability to easily strengthen their market oligopoly.

EWABA calls for stricter carbon testing in co-processing rules

EWABA, 18 Jul 2022

EWABA supports mandatory C14 testing but requests the mass balance method ensure accurate biogenic allocation. They also urge the Commission to establish clear requirements for the periodicity of testing.
Accurate reporting prevents competitors from claiming excessive renewable content for high-value fuels like diesel.
Economic operators lose the ability to over-report renewable content in high-value fuel products.

Consultation response

Wirtschaftsverband Fuels und Energie e. V., 19 Jul 2022

en2x is pleased for the opportunity to give feedback on the draft Delegated Act on bio-co-processing. Please find our detailed comments attached. We would very much welcome a stakeholder meeting for this delegated act in the near future. The meeting held on 15 June 2022 on the delegated act on…

ESWET Urges Inclusion of Waste-to-Energy in New Biofuel Rules

European Suppliers of Waste-to-Energy Technology, 20 Jul 2022

ESWET requests that the rules explicitly include waste-to-energy and waste-to-fuel activities. They also want the Commission to consider the high costs and delays of radiocarbon testing.
This expansion would provide the waste-to-energy sector with needed clarity for producing renewable fuels.

Consultation response

Preem AB, 12 Jul 2022

Preem welcomes the delegated regulation on the methodology to determine the share of biofuel and biogas for transport, produced from biomass being processed with fossil fuels in a common process. The flexibility of different methods suggested in the regulation is a welcome approach and provides a…

Consultation response

Iogen Corporation, 20 Jul 2022

Thank you for the opportunity to respond to this consultation. We welcome the opportunity to stress the importance of EU policy in catalyzing the production of carbon-negative fuels for our net zero future. Iogen Corporation (“Iogen”) is one of the world’s leading firms in the field of…

Consultation response

Sasol, 20 Jul 2022

We attach Sasol’s submission in response to the call for comments on the proposed Delegated Act to Article 28(5) of Directive (EU) 2018/2001 (DA 28). It is critical that the proposed DA 28(5) provides a supportive regulatory environment for a just transition in Non-Union countries by recognising…

Consultation response

Mittelstandsverband abfallbasierter Kraftstoffe e.V. (Waste-based Fuels Association), 19 Jul 2022

The Mittelstandsverband abfallbasierter Kraftstoffe e.V. (MVaK) represents 24 members which prepare suitable vegetable waste oils and residues, mainly used cooking oil and waste fatty acids, process them into waste-based biodiesel or trade feedstocks and finished products. The MVaK welcomes the…

Consultation response

, 20 Jul 2022

• unem invite the European Commission to draft the text in such a way that avoids ambiguity and multiple interpretation and aligns with other delegated acts proposed by the Commission (e.g. the Methodology for determining GHG emission savings from RFNBO/RC). • Establishing the share of hydrogen of…

Consultation response

APPA Biocarburantes, 15 Jul 2022

The comments of APPA Biocarburantes regarding the Draft Regulation on the methodology to determine the share of biofuel and biogas for transport in the case of co-processing, which is currently under public consultation, are as follows: 1) We agree with the general approach of the draft Regulation…

Consultation response

Drivkraft Danmark, 12 Jul 2022

Please see enclosed document for detailed feedback/comments