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Advanced Biofuels Coalition

LSB

The Advanced Biofuels Coalition represents leading producers and technology providers of sustainable fuels in Europe.

Lobbying Activity

Advanced Biofuels Coalition demands price guarantees for green transport

4 Sept 2025
Topic — The initiative creates a strategic framework to boost investments in renewable and low-carbon fuels.
Message — The coalition calls for advanced biofuels to be explicitly eligible for support under the investment plan. They support mechanisms like contracts-for-difference and price floors to provide revenue certainty and enable long-term agreements.12
Why — These measures would ensure predictable returns for producers and attract private capital for facilities.3
Impact — Fossil fuel suppliers lose their price advantage as subsidies make sustainable alternatives more competitive.4
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Advanced Biofuels Coalition urges policy stability for bioeconomy

19 Jun 2025
Topic — The European Commission is updating its strategy for a circular and competitive bioeconomy.
Message — The coalition requests a pragmatic bioeconomy vision that provides policy predictability and long-term strategic clarity. They urge the Commission to prioritize advanced biofuels to reduce reliance on fossil fuels.12
Why — Regulatory certainty would reduce investment risks and encourage long-term industrial growth.3
Impact — Traditional fossil fuel providers lose market share as the EU shifts to renewables.4
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Meeting with Sophia Kircher (Member of the European Parliament)

9 Jan 2025 · Vehicle emission targets

Meeting with Emma Wiesner (Member of the European Parliament)

12 Dec 2024 · Samtal om kommande initiativ som berör biodrivmedel.

Meeting with András Tivadar Kulja (Member of the European Parliament)

18 Nov 2024 · EU’s environmental and climate priorities for the new term

Meeting with Olivia Gippner (Cabinet of Commissioner Wopke Hoekstra)

13 Jun 2024 · Advanced biofuels

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

30 Apr 2024 · FuelEU Maritime, ReFuelEU, and the future of the RED

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

29 Nov 2023 · Defossilisation of the transport sector

Advanced Biofuels Coalition demands dedicated mandates for 2040 climate targets

22 Jun 2023
Topic — The European Commission is consulting on establishing a climate target for 2040.
Message — They request a separate sub-mandate for advanced biofuels and their recognition as net-zero technologies. They also propose expanding CO2 standards for cars to include carbon-neutral fuels.123
Why — These measures would provide the industry with necessary investment security and market predictability.45
Impact — Foreign energy producers would lose market share as the EU reduces fuel imports.6
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Meeting with Marian-Jean Marinescu (Member of the European Parliament, Rapporteur for opinion) and IVECO GROUP N.V.

14 Jun 2023 · Euro 7

Meeting with Tiemo Wölken (Member of the European Parliament, Rapporteur for opinion) and Transport and Environment (European Federation for Transport and Environment) and

22 May 2023 · Net-Zero Industry Act Stakeholder Hearing

Meeting with Pietro Fiocchi (Member of the European Parliament, Shadow rapporteur)

18 Apr 2023 · Amending Regulation (EU) 2019/1242 as regards strengthening the CO₂ emission performance standards for new heavy-duty vehicles and integrating reporting obligations, and repealing Regulation (EU) 2018/956

Advanced Biofuels Coalition seeks strategic status in new EU law

22 Mar 2023
Topic — The Net Zero Industry Act framework supports manufacturing of clean energy technologies.
Message — The coalition requests the inclusion of advanced biofuels as strategic net-zero technologies. They argue these fuels are essential for domestic energy security and climate goals.12
Why — Inclusion would grant the industry faster permitting and parity with global competitors.34
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Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson)

28 Feb 2023 · Green Deal Industrial Plan and upcoming Net Zero Industry Act.

Meeting with Rachel Smit (Cabinet of Commissioner Adina Vălean)

28 Feb 2023 · Aviation

Advanced Biofuels Coalition seeks higher targets for sustainable fuels

2 Jan 2023
Topic — The European Commission is updating the list of sustainable feedstocks for biofuels.
Message — 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.12
Why — Higher mandates would guarantee a larger market for advanced biofuel producers.3
Impact — Member States may face legal conflicts between national lists and EU rules.4
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Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur)

14 Oct 2022 · FuelEUMaritime, ReFuelEU Aviation

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean), Rachel Smit (Cabinet of Commissioner Adina Vălean)

15 Sept 2022 · Transport

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson)

6 Sept 2022 · To exchange views on the legislative work on REDIII in the EU Institutions.

Meeting with Søren Gade (Member of the European Parliament, Rapporteur)

18 May 2022 · Refuel EU aviation

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

12 Apr 2022 · RED

Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

The Advanced Biofuels Coalition (LSB) welcomes the opportunity to provide comments ahead of the revision of the EU waste framework. In this context, LSB would like to bring the following points to the attention of the Commission: - The ambitious goals to increase the uptake of advanced biofuels available in different modes of transport (including maritime and aviation) will result in larger volumes of waste and residues being processed with existing and new technologies. - This ambition requires a careful reconsideration of the existing waste hierarchy. Waste to energy is considered ‘recovery’, and it comes just above the level of ‘disposal’ in the hierarchy. At present, it is not clear under the Directive whether a process in which biofuels are produced from waste is considered ‘recovery’ or ‘recycling’. Annex II of the Directive (Recovery operations) makes reference to ‘fuel’, as does the definition of 'material recovery’. It is unclear, however, what kinds of fuels these references allude to. Additionally, under the definition of ‘recycling’, operations that entail “energy recovery and the reprocessing into materials that are to be used as fuels or for backfilling operation” are excluded. However, the definition of ‘recycling’ describes recycling as “any recovery operation by which waste materials are reprocessed into products, materials or substances whether for the original or other purposes. It includes the reprocessing of organic material". Under these provisions it is unclear whether biofuels fall under ‘recycling’, and the situation calls for clarification. - The production of biofuels from waste and residues should be preferred over incineration for energy purposes, as there is an urgent need to replace as much fossil fuels in transport as possible. - The production of biofuels should either be mentioned explicitly as an accepted way of recycling, or alternatively a new level that covers only fuels for transport from waste and residues should be added in the hierarchy between ‘recovery’ and ‘recycling’.
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Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson)

17 Dec 2021 · To discuss the Fit for 55 package and the long-term perspective of advanced biofuels in decarbonizing EU transport.

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans) and Blic Oy

23 Nov 2021 · Fit for 55 and REDIII proposals: reactions by LSB and discussions on state of play on negotiations among co-legislators

Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

16 Jul 2021

The Advanced Biofuels Coalition (LSB) welcomes the opportunity to provide comments to the Commission implementing regulation on rules to verify sustainability and greenhouse gas emissions saving criteria and low indirect land-use change-risk criteria. LSB supports the efforts of the draft EU implementation rules with the objective to come to a single and harmonized system of demonstrating and verifying the sustainability of biofuels, bioliquids and biomass fuels. LSB values that compliance is done in a transparent, independent and reliable fashion. Minimising the risk of fraud is crucial to maintain support from society to produce and use biofuels. LSB would like to bring the following points about the proposed implementing regulation to the attention of the Commission: - LSB is very concerned about what is presented in Annex IV. In the view of LSB, the Commission is creating legal uncertainty by using a feedstock list that deviates from what is listed in Annex IX of Directive (EU) 2018/2001. LSB calls on the Commission to 1) ensure current investments are not undermined and that feedstocks clearly defined under REDII are treated equally, point (o) must be added to Annex IV; 2) add to the list all the feedstock that have received national approval for the production of advanced biofuels; 3) make clear what list has legal preference over the other. - With regard to Audit Process and Level of Assurance in Article 10, the draft implementation act classifies non-conformities in the categories of minor, major, and critical. It proposed that if a major non-conformity is given during an audit, the certificate is immediately suspended. This causes significant and unbearable risk for operators, as it would mean no supplies or deliveries could be made before the non-conformity is corrected. If the certificate is active at the time the non-conformity is detected, it should not impact the operations unless the non-conformity is not corrected by the deadline. - The draft implementation act states that the document will be in force 3 days after the final version is published leaving no time for Economic Operators to update their systems to meet the new requirements. Furthermore, there is no clarity on which rules need to be applied for agricultural crops that are cultivated (not harvested) before the implementation act comes into force. They should be allowed to be certified using the rules that were in force when cultivation started (RED). Economic Operators require a decent transition period to properly adopt the changes being implemented. Please see the attached document for complete feedback.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Blic Oy

18 May 2021 · Biofuels /follow-up meeting on the Commission’s upcoming Fit for 55 package

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and Blic Oy

17 May 2021 · Fit for 55 and RED II review

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and Blic Oy

16 Feb 2021 · Fit for 55 package

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

12 Jan 2021 · Role of advanced biofuels in decarbonizing the EU’s transport sector

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Advanced Biofuels Coalition LSB appreciates this opportunity to comment the proposed screening criteria related to EU’s taxonomy. LSB supports EU’s climate neutrality goals and its members are investing in biorefineries that will enable decrease of transport emissions. LSB is a coalition of leading advanced biofuel technology developers and producers committed to making a significant contribution to meeting the EU ambitions of making the transport sector carbon neutral. Sustainable advanced biofuels are a fast track solution for achieving that objective. Advanced biofuels bring multiple benefits in terms of CO2 reduction, technology innovation, investments, revenues for farmers and forestry, improved waste management practices, circularity, job creation and an increase in energy security. Transport remains a principal emitter and requires immediate attention: EU transport currently accounts for one quarter of EU emissions and is 94% reliant on oil. The EU’s transport emissions are also 19% higher today than in 1990. Even if the electrification of transport is accelerated significantly, this sector will remain dependent on internal combustion engines until at least halfway through this century. Advanced biofuels have a critical role to play in making transport fossil free today and in contributing towards a net-zero emission society by 2050. In addition, there will be a need to deploy other low carbon liquid and gaseous fuels to bridge the remaining gap to reach full climate neutrality in transport. With the European Union’s adoption of REDII and subsequent binding mandate for advanced biofuels (Annex IX part A), the EU is moving in the right direction. Since the adoption in 2018, considerable investments in advanced biofuels have been made and progress in the build-up of production capacity is under way. This momentum must not be jeopardized. LSB therefore regrets that the Commission proposal defines the production of biofuels as a transitional activity. In order to reach the targets defined in the Renewable Energy Directive II, significant investments are still needed in the EU. Furthermore, it is likely that the revision of REDII will lead to a substantial increase of the advanced biofuels mandate. By classifying the sector as transitional, the Commission is sending a wrong signal to the investor community planning investments. We therefore call upon the Commission to delete this wording from the proposed DA. LSB furthermore states that sustainability criteria overall should be strictly aligned with the criteria set out in the REDII. Finally, LSB would like to state that the classification of vehicles as zero-emission vehicles, where the current proposal favors electric vehicles only should be modified to take into consideration the fact that by using advanced biofuels, the emissions of internal combustion engines can be lowered by up to close to 100% and at any case by over 80% in average.
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Meeting with Laure Chapuis (Cabinet of Commissioner Kadri Simson)

7 Dec 2020 · Fit for 55 package Revision of the RED 2 Directive Transport and biofuels

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Blic Oy

16 Sept 2020 · Bioeconomy and bioenergy under EU’s regulatory framework

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Aug 2020

In addition to the REDII as an innovation framework, LSB calls upon the Commission to implement the following policy measures to enable advanced biofuels and synthetic fuels to be deployed at their fullest potential: 1) The advanced biofuels in the Annex IX part A target must be implemented across the EU regardless of any revision of 2030 ambitions. Advanced biofuels must remain supported through a dedicated sub-target of at least 3.5% by 2030 based on the current Annex IX part A feedstock list. 2) Any revision of the existing feedstock list as described in Annex IX part A must be undertaken with stringent due diligence as described in Article 28 of the directive and be coupled with an increase of the overall mandate, corresponding to the market potential of the newly added feedstocks. If not, the existing and planned investments will be devalued. 3) Reaching the goal of carbon neutrality by 2050 is challenging. In order to fully decarbonize transport all solutions are needed including options such as Renewable Fuels of Non-Biological Origin in REDII. Their large-scale deployment should be supported with a consistent policy approach with a specific dedicated target. 4) The FQD should be the tool to drive additional GHG emission savings in the fuels sector. Therefore, the FQD should be amended and be brought in line with both the REDII and the new Climate Action Targets to be set for 2030. The FQD should set an ambitious target for GHG emission reduction in article 7a. The Annex to the FQD should also be amended to allow for higher biofuels blends. 5) The Energy Taxation Directive (ETD) should be revised in order to support the RES-targets in transport and the overall climate ambitions of the EU: Minimum taxation rates should be based on energy content (switch from volume basis) in order to create a level playing field between fossil fuels and biofuels (with lower energy content). Furthermore, the revised ETD should include a CO2 tax element into the ETD from which biofuels are exempt. 6) Road transport should not be included in the existing Emission Trading Scheme (ETS). A dedicated GHG emission reduction goal for transport would be the best incentive for achieving tangible emission reductions. The ETS pricing system is too volatile to achieve predictable CO2-savings in the road transport sector. This price volatility will also reduce investor certainty, undermining advanced biofuel production capacity. 7) Building new production facilities that use state-of-the-art technology are highly capital intensive from both an investment and operating standpoint. Those investments will only happen under a reliable policy framework addressing the above-mentioned elements. 8) The EU Biodiversity Strategy for 2030 calls for new sustainability criteria to be developed especially for forest biomass for energy. Adding new sustainability criteria for advanced biofuels is not needed as they are already subject to the most stringent criteria globally with regards to choice of feedstock, land-use, certification requirements and the level of GHG emission reductions to be achieved. 9) The Farm to Fork Strategy should recognize the important role of agriculture and forestry as a supplier of sustainable feedstock for advanced biofuels production. Wastes and residues from farming and forestry provide the feedstock for the production of biofuels without any adverse effects on land-use or biodiversity. This reality should be considered in the future EU Carbon Farming Initiative and in the F2F-Strategy enabling the agricultural sector to valorize residual streams and maximize economic yield per hectare.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

21 Apr 2020

The Advanced Biofuels Coalition (LSB) welcomes the opportunity to provide comments to the inception impact assessment on ReFuelEU Aviation and the promotion of sustainable aviation fuels (SAF) in the EU. LSB recognizes the need to reduce CO2 emissions in all transport modes and therefore supports the intention to promote the use of sustainable aviation fuels. LSB is a coalition of leading advanced biofuel technology developers and producers committed to making a significant contribution to meeting the EU ambitions of decarbonizing the transport sector. Sustainable advanced biofuels are a fast track solution for decarbonizing transport. Advanced biofuels bring multiple benefits in terms of CO2 reduction, investments, revenues for farmers and forestry, improved waste management practices, job creation and an increase in energy security. We understand the importance of obtaining a common approach on reducing emissions of air traffic at international level (ICAO). The EU should nevertheless set an example by promoting the use of SAF, which other jurisdictions could follow suit. From our industry’s experience with the Renewable Energy Directive (RED) we learnt that binding mandates for the use of alternative fuels are effective. A similar mandate for sustainable fuel used in air traffic seems promising. The measures chosen have to be easy to implement at Member State level. Building upon existing practice and experience in the REDII is strongly recommended. LSB urges the Commission to set any support measures for SAF in addition to the existing REDII obligations for transport. The SAF volumes that will be required will only be produced if there is a stable policy in place for at least a decade. Building new production facilities that use state-of-the-art technology are highly capital intensive from both an investment and operating standpoint. Those investments will only happen under a reliable policy framework. Therefore, LSB underlines that quick and stringent implementation of the REDII in the member states is needed to enable both sustainable feedstock supply and technology development. Europe must lay the foundations now on which also future production of SAF volumes will build upon. Many of the plants currently under construction or under consideration to produce advanced biofuels for the road transport sector will be crucial in the coming decade to supply also fuels to the aviation sector. LSB will provide further input to the Commission public consultation in due course.
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Response to 2030 Climate Target Plan

15 Apr 2020

The Advanced Biofuels Coalition (LSB) welcomes the opportunity to provide feedback on the Inception Impact Assessment on a 2030 Climate Target Plan. LSB welcomes EU’s increased commitment to combatting climate change. LSB especially welcomes an increased dedication to reduce transport emissions. LSB is a coalition of leading advanced biofuel technology developers and producers committed to making a significant contribution to meeting the EU ambitions of decarbonizing the transport sector. Sustainable advanced biofuels are a fast track solution for decarbonizing transport. Advanced biofuels bring multiple benefits in terms of CO2 reduction, investments, revenues for farmers and forestry, improved waste management practices, job creation and an increase in energy security. Advanced biofuels development in the EU was lagging behind from 2012 until 2018 due to a lack of policy certainty due to negotiations on revisions of the Renewable Energy Directive (ILUC and RED II). Finally, in December 2018 the REDII was adopted. Since then considerable investments in advanced biofuels manufacturing have been made and progress in building-up of production capacity is under way. The REDII with its binding mandate sets the right direction enabling advanced biofuels to contribute to the decarbonization of EU transport. This direction must not be endangered. Considering both the urgent need to act on climate change and the economic challenges stemming from the current COVID-19 situation, regulatory certainty for investments in climate technologies is of immense importance. The potential proposal of regulatory changes would have wide-ranging impacts. Therefore, measures must be taken with a transparent process as not to jeopardize on-going or future investments. LSB also calls for a swift implementation of existing directives. EU member states must not deviate from the agreed targets, such as for advanced biofuels as defined by REDII Annex IX part A, while a potential revision of the target levels is undertaken. LSB underlines that a binding mandate is the most effective measure to bring advanced biofuels to the market. Introducing road transport into the ETS could be counterproductive. LSB will provide further input to the Commission public consultation in due course.
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