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Update of list of sustainable biofuel feedstocks

Energy

Sustainable biofuels and biogases are important to increase the share of renewable energy in sectors that are difficult to decarbonise such as the aviation and maritime sector. The Commission is requested to regularly review the list of feedstock set out in Parts A and B of Annex IX with a view to adding feedstock to the Annex provided they meet the criteria set out in the third subparagraph of Article 28(6). This delegated act will add those feedstocks that meet the criteria to the Annex.

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Public consultation

ID: 13484

Lobbying Activity

63 responses

T&E urges Commission to purge unsustainable biofuel feedstocks

Transport and Environment (European Federation for Transport and Environment), 22 Dec 2022

T&E demands a robust assessment to remove problematic existing feedstocks and strict limits on adding new ones. They also call for closing loopholes that allow Member States to use unlisted materials.
This would ensure environmental integrity and prevent market distortions in other industrial sectors.
Biofuel producers and Member States would lose flexibility to use diverse, unlisted raw materials.

Chemical industry opposes adding animal fats to biofuel feedstock list

European Chemical Industry Council, 29 Dec 2022

The European oleochemical industry urges legislators not to add animal fats category 3 to Annex IX. They argue this would displace these fats from traditional chemical production uses and force substitution with palm oil. They request stronger protections for continued access to EU-sourced raw materials.
This preserves their access to essential European feedstocks for chemical production.
Biofuel producers lose access to an attractive feedstock for meeting renewable energy targets.

TotalEnergies Calls for Faster Implementation of Biofuel Feedstock Rules

TotalEnergies SE, 22 Dec 2022

The company requests a regulation instead of a directive to ensure faster, unified application across Member States. They want inclusion of additional sustainable feedstocks like category 3 animal fats and technical corn oil, and support increasing the Annex IX-B cap based on new feedstock volumes.
This would give them clearer visibility on recognized feedstocks and encourage investment in biofuel facilities.

EDF Urges Stricter Rules for Biofuel Feedstock Eligibility

ELECTRICITE DE FRANCE, 2 Jan 2023

EDF calls for clearer definitions and robust methods to verify if intermediate crops meet sustainability criteria. They argue vague rules risk diverting crops from their original use in animal feed.
Strict rules ensure limited biomass is reserved for essential uses like EDF's thermal backup power.
Agricultural producers and livestock farmers lose access to nitrogen-fixing crops needed for sustainable animal feed.

FuelsEurope urges long-term certainty for sustainable biofuel feedstocks

FuelsEurope, 2 Jan 2023

FuelsEurope opposes moving feedstocks from the uncapped Part A list to the capped Part B category to protect investments. They call for increasing or removing Part B caps and clarifying land definitions at the EU level.
Maintaining stable feedstock categories prevents new regulatory limits from restricting the scale of industrial production.
The aviation sector loses if specific sustainable feedstocks are excluded from green fuel targets.

Shell urges reclassification of intermediate crops as advanced biofuels

Shell Companies, 2 Jan 2023

Shell requests that intermediate crops like catch and cover crops be classified as Annex IXA (advanced) rather than IXB. They oppose downgrading any feedstocks from IXA to IXB, arguing this creates investment uncertainty. They also want crops grown on degraded land classified as advanced feedstocks.
This would provide long-term investment certainty and avoid biofuel production caps.
Environmental groups lose stronger safeguards against biofuels competing with food production.

BirdLife Europe warns biofuel expansion risks biodiversity loss

Stichting BirdLife Europe, 22 Dec 2022

BirdLife calls for mandatory waste hierarchy and cascading principles, stricter degraded land definitions with clear soil organic matter figures, caps on animal manure from large farms, and safeguards requiring intermediate crops be grown without fertilizers, pesticides, or irrigation.
This would prevent industrial farming intensification and protect agricultural land from diversion to biofuel crops.
Industrial livestock operations lose incentives to produce manure-based biogas at scale.

Oxfam warns biofuel updates threaten food security and land rights

OXFAM INTERNATIONAL EU ADVOCACY OFFICE, 23 Dec 2022

Oxfam recommends removing crops grown on degraded land and intermediate crops. They argue these feedstocks lack impact assessments and risk causing market distortions.
Success would prevent land displacement and protect food security for vulnerable global populations.
Biofuel producers lose access to new feedstock categories and associated market incentives.

Austrian business chamber demands stable rules for biofuel feedstocks

Wirtschaftskammer Österreich, 2 Jan 2023

WKÖ urges the Commission to provide long-term certainty in feedstock classification to secure industry investments. They oppose moving intermediate crops to the capped Part B list. They also support increasing the Part B cap to maximize fuel production benefits.
Predictable rules would protect massive, long-term investments required for the refining industry.
Restricting feedstocks harms the transport sector by making decarbonization significantly more difficult.

ENGIE Urges EU to Reclassify Intermediate Crops for Biofuels

ENGIE, 23 Dec 2022

ENGIE requests moving intermediate crops from Part B to Part A to avoid production caps. They also suggest including additional waste feedstocks like biowaste and flotation greases.
This change allows ENGIE to scale up biomethane production without restrictive regulatory limits.
Natural gas suppliers lose market share as biomethane replaces gas in buildings and industry.

Deutsche Umwelthilfe urges rejection of expanded biofuel feedstock list

Deutsche Umwelthilfe e.V., 2 Jan 2023

The organization calls for a fundamental revision of the proposal and the deletion of several categories. They argue that expanding the list risks market distortions, fraud, and harmful additional land use.
Tightening these rules helps the NGO ensure land is used for ecosystem restoration rather than fuel.
Biodiversity and the climate suffer from increased land use pressure and associated greenhouse gas emissions.

CMA CGM urges broader list of advanced biofuel feedstocks

CMA CGM, 2 Jan 2023

CMA CGM recommends adding intermediate crops, landfill gas, and wastewater to the advanced fuels list. They argue this sends a strong signal to investors and helps carriers find enough fuel.
Wider feedstock options help the group meet mandatory maritime emissions reduction targets.
Waste incinerators would lose materials like sewage sludge to new biofuel production processes.

IATA urges EU to expand sustainable aviation fuel feedstock lists

International Air Transport Association, 1 Jan 2023

IATA requests expanding feedstock criteria to include readiness levels and avoiding restrictive lists that hamper investment. They advocate for sustainability-based eligibility rather than maturity-based classification to ensure long-term policy stability.
Broadening the feedstock base provides the necessary supply to meet aviation's net-zero goals.
Environmental groups lose strict safeguards against the use of food-competing crops for fuel.

BP Urges Expansion of Advanced Biofuel Feedstock List

BP p.l.c., 2 Jan 2023

BP requests that intermediate crops like cover crops be added to Part A rather than Part B of Annex IX, arguing they represent advanced sustainable farming practices. They also seek clearer definitions and an increased cap on Part B feedstocks.
This would provide stronger incentives for their advanced biofuel production and deployment.
Environmental groups concerned about potential land use pressures from expanded feedstock eligibility.

Repsol opposes Annex IX reclassification threatening existing biofuel investments

Repsol, S.A., 29 Dec 2022

Repsol requests that feedstocks currently recognized as Part A by Member States not be reclassified to Part B. They argue the Part B cap should be removed or proportionally increased. They want technology maturity assessments to consider supply chain and payback periods.
This would protect their existing investments and maintain long-term business case viability.

Danish Shipping Opposes Reclassifying Key Feedstocks to Protect Investments

Danish Shipping, 22 Dec 2022

The organization requests that brown grease remains listed as an advanced feedstock. They also highlight the need for transparent certification to provide certainty for fuel-producers.
Consistent rules would de-risk investments and provide certainty for the maritime energy transition.
Early investors in specific biofuel technologies would be penalized by changing feedstock categories.

FEFAC Urges Protection for Animal Feed Materials from Biofuel Competition

Fédération Européenne des Fabricants d'Aliments Composés, 2 Jan 2023

FEFAC calls for strict guarantees and verification controls to prevent the deliberate downgrading of valuable by-products. They request that energy production does not undermine the nutrient efficiency of the feed industry.
These protections would safeguard the industry's access to affordable by-products and maintain its competitiveness.
The environment suffers as replacing diverted feed requires more land and increases carbon emissions.

European Biodiesel Board Urges Higher Caps on New Feedstocks

European Biodiesel Board, 27 Dec 2022

The board demands higher usage limits for mature feedstocks. They also oppose moving materials from advanced to restricted categories.
The board would secure its existing investments and access a larger pool of raw materials.
Advanced biofuel investors lose financial security if their feedstocks are downgraded to restricted categories.

MOL Group warns against adding feedstocks to capped list

MOL Hungarian Oil and Gas Company, 2 Jan 2023

MOL Group urges the Commission not to add any new feedstocks to the capped list. They argue that moving materials to this list creates significant investment risks.
This would prevent competition for existing products within the current biofuel production cap.
Renewable energy developers lose opportunities to scale up production using newly identified sustainable materials.

Liquid Gas Europe Urges Reclassification of Biofuel Feedstocks

Liquid Gas Europe, 23 Dec 2022

The group suggests including all Part B feedstocks in Part A instead. They argue the Part B cap limits investments for renewable liquid gases.
Avoiding the Part B cap would prevent investment curtailment for renewable gas production.

OMV Urges Stable Feedstock Rules to Secure Biofuel Investments

OMV Aktiengesellschaft, 30 Dec 2022

OMV opposes moving intermediate crops to the capped Part B list to protect investment certainty. They also support increasing the Part B volume cap if new feedstocks are added.
A stable, uncapped feedstock classification provides the long-term certainty needed for refining industry investments.
The transport sector loses decarbonization progress if feedstock restrictions limit the supply of biofuels.

Port of Rotterdam calls for stable biofuel policy framework

Havenbedrijf Rotterdam NV, 22 Dec 2022

The Port of Rotterdam urges a long term predictable and stable policy framework to secure new production. They highlight that the current revision causes uncertainty for pending investments in biofuel plants.
Stability would help maintain their status as the leading global biobased industrial cluster.
Industrial developers risk losing capital due to regulatory uncertainty regarding new production plants.

Moeve warns against removing feedstocks to protect biofuel investment

Moeve, 2 Jan 2023

The organization demands that the Commission only adds to the list rather than removing or reclassifying existing feedstocks. They also request that limits on specific biofuel categories be lifted to support market growth.
This would protect their existing production assets and ensure a stable regulatory environment for future projects.
Investors face significant financial risk if the rules for advanced biofuels change every two years.

Ethanol Producers Oppose Feedstock Reclassification and Target Adjustments

European Producers Union of Renewable Ethanol, 24 Dec 2022

ePURE argues the Commission should only add, not remove or requalify, feedstocks from the existing lists. They recommend including alcoholic distillery residues like heads and tails and ending discrimination against sugar beet vinasse. Furthermore, sub-targets for advanced biofuels should be increased to reflect any list extensions.
This ensures existing investments remain profitable and allows more products to qualify for incentives.
The Commission's authority to refine feedstock classifications is challenged by these legal objections.

Advanced Biofuels Coalition seeks higher targets for sustainable fuels

Advanced Biofuels Coalition, 2 Jan 2023

The coalition calls for increasing the 2.2% target for advanced biofuels if more feedstocks are added. They also urge the Commission to avoid reclassifying materials that are already considered advanced under national rules.
Higher mandates would guarantee a larger market for advanced biofuel producers.
Member States may face legal conflicts between national lists and EU rules.

JBCE Urges EU Incentives for Biofuel Food Waste Technologies

Japan Business Council in Europe, 22 Dec 2022

JBCE requests EU incentives for circular technologies or transitional measures for food waste limits. They also want clarity on whether post-industry wastes are included and specific definitions for intermediate crops.
This would prevent disruption to current internal bioenergy use and external sales.
Vague rules could cause confusion and undermine progress toward circular economy goals.

German biofuel industry urges safeguards for existing feedstock classifications

Verband der Deutschen Biokraftstoffindustrie, 2 Jan 2023

The VDB requests a grandfathering provision to protect existing national classifications of advanced biofuel feedstocks. They also advocate excluding intermediate crops and defining damaged crops to prevent fraud.
This would prevent the devaluation of current investments and maintain existing biofuel value chains.
Regulators and the environment lose if difficult-to-monitor feedstocks enable widespread fraudulent conduct.

German Biogas Association Urges End to Technology-Based Feedstock Caps

German Renewable Energy Federation, 22 Dec 2022

The GBA requests feedstock classification focus on environmental benefits rather than processing technology. They propose moving catch crops to Part A to bypass restrictive caps.
This would prevent sustainable feedstocks from being capped by the 1.7 percent limitation.

Consultation response

SkyNRG B.V., 1 Jan 2023

SkyNRG welcomes the European Commissions ambition to expand the list of eligible feedstocks but also identifies multiple concerns. More specifically, SkyNRG is worried that investment certainty is undermined by the decision to place certain feedstocks on the Annex IX B list, which is capped. No…

Novamont seeks reclassification of bacteria as sustainable biofuel feedstock

Novamont SpA, 30 Dec 2022

Novamont argues that bacteria such as Escherichia Coli should be reintroduced to Annex IX. This would allow spent bacteria from industrial fermentation to be used for advanced biomethane.
This would allow the company to monetize its manufacturing byproducts as advanced fuel.

EWABA urges removal of biofuel feedstock caps in EU rules

EWABA, 21 Dec 2022

The association advocates for the elimination of the 1.7% cap on certain waste-based fuels. They also want brown grease reclassified to receive higher policy incentives and recommend increasing overall renewable transport targets.
Removing these limits would allow their members to scale production far beyond current restrictive regulatory constraints.
Producers of existing sustainable fuels could be sidelined by a surge of new, high-volume feedstocks.

Consultation response

Association Générale des Producteurs de Maïs, 2 Jan 2023

L'Association Générale des Producteurs de MAïS (AGPM) souhaite faire part de ses remarques sur le projet d'acte délégué visant à ajouter des matières premières dans l'annexe IX de la directive RED 2028/2001 : Pour l'ajout des cultures intermédiaires, nous estimons que la définition proposée parait…

Equilibre des Energies pushes for uncapped biofuel feedstock lists

Equilibre des Energies, 2 Jan 2023

The organization recommends adding intermediate crops to Annex IX-A to avoid production limits. They also propose including category 3 animal fats and technical corn oil as sustainable feedstocks. They prefer a regulation over a directive to ensure uniform application across member states.
These modifications would provide investment clarity and allow companies to scale up biomethane production.

Consultation response

SHV Energy NV, 22 Dec 2022

SHV Energy Introduction SHV Energy is a leading global distributor of off-grid energy such as LPG and LNG and is active in the area of sustainable fuels (bioLPG, bioLNG, rDME) and renewable energy solutions (energy efficiency, solar). SHV Energy is a wholly owned subsidiary of SHV, a family-owned…

Consultation response

Groupe Avril, 2 Jan 2023

Please find attached Avril Groups written contribution to the public consultation on Annex IX.

Consultation response

Filiera Italia, 30 Dec 2022

La produzione di biocarburanti rappresenta unimportante opportunità per il perseguimento degli obiettivi di transizione energetica previsti dalla normativa europea e per la decarbonizzazione del settore dei trasporti con la creazione di sinergie tra settori diversificati. Le integrazioni previste…

Consultation response

Roquette, 26 Dec 2022

Roquette proposal for the ongoing Annex IX review and its importance for EU climate goals Roquette is a global leader in plant-based ingredients for food, nutrition and health market. The group addresses current and future societal challenges by unlocking the potential of nature through a broad…

Consultation response

North European Oil Trade Oy, 2 Jan 2023

North European Oil Trade Oy (NEOT) strongly supports the EU objective of net climate neutrality in 2050 and the circular economy. We warmly welcome the initiative of the Commission to update the list of sustainable biofuel feedstocks to Annex IX of RED as an important element continue transforming…

Bioenergy Association of Finland urges support for cover crops

Bioenergia ry - Bioenergy Association of Finland, 2 Jan 2023

The group wants intermediate crops in list A to improve business cases. They request simpler definitions and a higher cap for list B feedstocks.
This would increase investment predictability and expand market access for their products.
Environmental monitoring may be weakened by simplified definitions and local assessment.

Consultation response

Nature Energy, 23 Dec 2022

Please see the document attached

German Fuel Industry Urges Expanded Biofuel Feedstock Categories

Wirtschaftsverband Fuels und Energie e. V., 22 Dec 2022

The organization requests that intermediate crops be categorized under Annex IX Part A rather than Part B, and that member states maintain current feedstock classifications until 2030. They advocate for long-term planning security with clear targets for at least 10 years and an increase in Part B caps.
This would allow members to increase production capacity and reduce market uncertainty.
Environmental groups lose stricter controls on which feedstocks count as truly advanced.

Consultation response

Republiková únia zamestnávateľov, 2 Jan 2023

We appreciate the proposal to expand Annex IX. We believe that in order to achieve ambitious targets set by the European legislation more eligible and sustainable feedstock is required. At the same time expansion of the available feedstock pool may lower Europe's dependency on already imported…

Consultation response

European Former Foodstuff Processors Association, 2 Jan 2023

Please find attached the feedback of the European Former Foodstuff Processors Association

Consultation response

Envien group, 2 Jan 2023

Envien Group welcomes the step of European Commission to finally launch public consultation on the draft Delegated Directive amending Annex IX of Directive (EU) 2018/2001 on the addition of feedstocks for the production of biofuels and biogas. In our attached position we would like to adress…

Consultation response

Preem AB, 2 Jan 2023

Feedback concerning Commission delegated directive (EU) amending Annex IX to Directive (EU) 2018/2001 of the European Parliament and of the Council, as regards adding feedstocks for the production of biofuels and biogas Preem AB (publ.) Summary Preem welcomes the initiative to amend Annex IX with…

Consultation response

TEREOS, 30 Dec 2022

In general terms, Tereos welcomes the revision of Annex IX as the EU needs to accelerate the decarbonization of the transport sector to achieve its Green Deal objectives. Since liquid biofuels will play an indispensable role in relishing this challenge and given that conventional biofuels are…

Consultation response

iEthanol, the European Industrial and Beverage Ethanol Association, 21 Dec 2022

We hereby submit some highlights regarding the proposed update for Annex IX. In Part A (advanced double counting raw materials ) of Annex IX, the following raw materials are added: (r) Alcoholic distillery residues and wastes (fusel oils) not fit for use in the food or feed chain; It is important…

Consultation response

Nutreco, 2 Jan 2023

Nutreco acknowledges the EU's ambitions in the area of renewable energy as one of the ways to achieve carbon neutrality in 2050. We appreciate at the same time that, as a matter of principle, the food waste hierarchy is being followed. According to this approach, use as food has the highest…

Consultation response

Fachagentur Nachwachsende Rohstoffe e.V., 2 Jan 2023

The Agency for Renewable Resources (FNR) welcomes the initiative of the European Commission to update Annex IX of the Renewable Energy Directive 2018/2001 (RED2). Broadening the feedstock basis is crucial if the EU wants to meet its climate and energy targets in the transport sector. However, with…

Consultation response

Argent Energy, 2 Jan 2023

Changes to Annex IX Part B The considerable changes to Annex IX Part B in the proposal would lead to a far greater supply availability of feedstocks from this category. That in itself is a welcome result as it opens up much greater decarbonisation potential from renewable fuels based on genuine…

Consultation response

Münzer Bioindustrie GmbH, 2 Jan 2023

Die Münzer Bioindustrie GmbH fordert seit langem die Aufhebung der 1,7 %-Beschränkung für die Rohstoffverwendung laut Anhang IX Part B. Die Einschränkung sollte potenziellen Rückverfolgbarkeits- und Nachhaltigkeitsbedenken in den Lieferketten von Teil-B-Biokraftstoffen Rechnung tragen. Für uns ist…

Consultation response

Mittelstandsverband abfallbasierter Kraftstoffe e.V. (Waste-based Fuels Association), 2 Jan 2023

The MVaK welcomes the opportunity to provide feedback to the European Commission's proposal to extend the Annex IX (RED II). Please find the MVaK feedback in the attached document.

Consultation response

Greenergy Fuels Ltd, 22 Dec 2022

Greenergy supports the addition of feedstocks into Annex IX. These additional volumes will support the drive to decarbonise transport as a whole. There needs to be consideration for the certification process and we encourage the Commission to liaise with voluntary schemes and certification bodies…

Consultation response

Suomen Biokierto ja Biokaasu ry, 22 Dec 2022

The European Commission's proposal to amend Annex 9 of the renewable directive as a delegated act is problematic in many ways. According to Article 28, the Commission is empowered to adopt delegated acts in accordance with Article 35 to amend the list of raw materials set out in Parts A and B of…

Consultation response

Associazione Nazionale tra i Produttori di Alimenti Zootecnici, 2 Jan 2023

E' fondamentale evitare la possibilità di utilizzare per la produzione di bioenergie prodotti che sono di consolidato utilizzo nel settore mangimistico. Evitare l'introduzione di prodotti riportati nel Catalogo delle materie prime (Reg. CE n. 68/2013 da ultimo modificato dal Reg. UE 2002/1104), o…

Consultation response

Cerulogy, 2 Jan 2023

Our attached feedback includes suggestions to clarify and strengthen the language related to the two crop categories that have been proposed for addition to Annex IX as item (t) in Part A and item (p) in Part B.

Consultation response

, 2 Jan 2023

unem feedback on COMMISSION DELEGATED DIRECTIVE of amending Annex IX to Directive (EU) 2018/2001 of the European Parliament and of the Council, as regards adding feedstocks for the production of biofuels and biogas unem thanks the European Commission for the opportunity offered to provide its…

Consultation response

, 30 Dec 2022

ABA Advanced Bioenergy Association, is a non-profit association whose main objective is to promote advanced bioenergy in fuels as a sustainable and viable means of reducing greenhouse gas and carbon emissions. We believe that the proposed revision of Annex IX of the RED II and the extension of the…

Consultation response

APPA Biocarburantes, 27 Dec 2022

We welcome the initiative of the European Commission to include new feedstocks in annex IX of the Renewable Energy Directive (RED II) through this Delegated Directive. We would like to make the following detailed comments on its specific content: 1.- We deem appropriate the proposal of the draft to…

Consultation response

International DME Association, 22 Dec 2022

The International DME Association welcomes the recognition of additional feedstocks in the proposed delegated directive. Moreover, the list of feedstocks covers the current potential biogenic waste pathways for the production of renewable DME, offering legislative certainty for the further…

Consultation response

FEDIAF EuropeanPetFood aisbl, 20 Dec 2022

FEDIAF, the European Pet Food Association, representing 15 National Associations and 5 direct companies, acknowledges the positive development that Category 3 animal fats were not added to the approved list of sustainable biofuel feedstocks ( Annex IX). FEDIAF has been campaigning for the…

Consultation response

BERTAGNI CONSULTING SRL, 20 Dec 2022

I would like ANNEX IX Part A to remain unchanged, above all when it recognizes that advanced bio-fuels may be considered to be twice their energy content. This clause has allowed these advanced bio-fuels to be regularly traded so far and any change could lead to major problems for producers, users…

Consultation response

Union zur Förderung von Oel- und Proteinpflanzen, 14 Dec 2022

Stellungnahme der Union zur Förderung von Oel- und Proteinpflanzen e. V. (UFOP zum Entwurf Delegierter Rechtsakt zur Erweiterung der genehmigten Rohstoffe im Anhang IX Teil A und B der Richtlinie 2018/2001(EU) Vorbemerkung: Die verbindliche Vorgabe bestimmter zugelassener Rohstoffe gemäß Anhang IX…