ASFE - Paraffinic Fuels for Europe
ASFE
Launched in March 2006 in Brussels, Paraffinic fuels for Europe (ASFE) is a unique European level initiative which brings together car manufacturers and fuel suppliers, who are together working towards reducing the environmental impact of road transport through improved energy efficiency and cleaner fuels.
ID: 349989434504-22
Lobbying Activity
Response to Adaptation to the emissions type-approval of heavy duty vehicles to accommodate the use of pure biodiesel
29 Jun 2022
ASFE, while supporting the objective of the proposal, stresses the need to include XTL fuels (EN15940 paraffinic diesel) a reference fuel in future legislation.
Technology neutrality is a promising regulatory starting point. But introducing exclusively B100 is promoting one solution, turning a blind eye on other widely available fuel solutions, like XTL.
XTL fuels already have interest in several member states, as they deliver benefits like cold operability and storability which allows wide usage across Europe.
The existing provisions for UFTA in section 1.1 of Annex I of Regulation (EU) 582/2011 allow a certain amount of fuel flexibility in an efficient way. Making use of this possibility should be maintained for vehicles not dedicated 100% on alternative fuels to ensure fuel flexibility.
The proposal does not clarify the requirements for CO2 declaration. According to the proposal, manufacturers can type-approve engines, but VECTO is not able to determine a CO2 figure for vehicles with such powertrains.
Including B100 together with XTL as reference fuels in Regulation (EU) 582/2011 would be the basis for applying the requirements in Regulation (EU) 2017/2400. Including B100 and XTL in VECTO would mean that there is a need for definition of these fuels' CO2 factor.
Traditionally this value has been TtW value, but in case of approving vehicles using 100% renewable fuels that value should be WtW based. Looking into the future, these additions to VECTO and CO2 legislation could have a big impact for acceptance and endorsement of new solutions, like e-fuels. It is important that legislation is keeping up with the development and starting with B100 and XTL would be a step in the right direction.
Other benefit of including XTL:
● CO2 reduction potential of XTL
● XTL can utilise already available infrastructure
● XTL can be stored longer periods of time than B100
● XTL cold operability better - can be used year around across Europe
The inclusion of all cleaner alternatives in type approval legislation will supports replacement of fossil diesel fuel. There is currently a pathway to get approval with alternative fuels via UFTA and this option should be maintained to ensure fuel flexibility of those vehicles which will not be dedicated for B100. Needed adjustments to other legislation should be considered simultaneously. For example vehicles type approved for operating solely 100% alternative fuels should have according reference fuels and values in CO2 perspective for VECTO.
We support the inclusion of B100 if XTL and other already available solutions are included at the same time.
ABOUT ASFE
ASFE is a European-level initiative which has been promoting synthetic and paraffinic fuels for more than a decade. ASFE supports low carbon and renewable, liquid and fully fungible drop-in fuels that have the potential to contribute to decarbonization of all modes of transport.
We believe that synthetic and paraffinic fuels have a strong and immediate role to play in achieving EU climate goals by targeting GHG and tailpipe emission reduction in transport, as they are available today.
Read full responseResponse to Sustainable and Smart Mobility Strategy
28 Jul 2020
ASFE, the voice of paraffinic fuels in Europe, welcomes the opportunity to contribute to the development of the EU’s new Strategy for Sustainable and Smart Mobility.
As already recognized in the 2011 White Paper for Transport, the transport and mobility sector is fundamental to Europe’s economy and society. It is however vital for the sector to play its part to achieve the EU’s decarbonisation ambitions under the Green Deal.
In order for the EU to achieve climate neutrality by 2050, the Sustainable and Smart Mobility should promote all technologies with decarbonisation potential. Specifically when it comes to transport, ASFE believes that the strategy should recognise the role that all technologies and fuels can play when looking at reduction of climate emissions and air pollutants. In this context, ASFE wishes to highlight the potential of liquid, low-carbon drop-in fuels. Due to their compatibility with existing fleets, these fuels do not require extensive infrastructure development or fleet renewal and can therefore deliver swift results when it comes to reducing carbon emissions, as well as contribute to the decarbonasation of transport in the longer term.
In addition, ASFE believes that to achieve its climate neutrality ambitions, the Strategy should take a holistic view to decarbonisation and air quality, where all stakeholders across the value chain are contributing to the climate effort.
Finally, the Strategy should recognise the importance of an ambitious yet consistent regulatory framework for transport fuels, which should guide the decarbonisation effort while promoting the competitiveness of the sector and its innovation potential. ASFE therefore calls on the strategy to ensure consistency between key regulatory developments currently on the agenda which are paramount for the sector, i.a. the revision of the Alternative Fuels Infrastructure Directive, the Energy Taxation Directive, the Fuel Quality Directive and the CO2 emissions regulations.
Read full responseResponse to Revision of Alternative Fuels Infrastructure Directive
4 May 2020
ASFE – the voice of paraffinic fuels in Europe – welcomes the initiative to revise the Directive on Alternative Fuel Infrastructure, as this piece of legislation has the potential to be the regulatory cornerstone for the deployment of alternative fuels in Europe.
Since its adoption in 2014, ASFE has supported the Directive as the first piece of legislation that specifically defined alternative fuels as environmentally beneficial and contributing to efforts to address Europe’s dependence on oil. This set a valuable precedent that went on to inspire a number of policies in their promotion of alternative energy sources as part of the EU and Member States drive towards a more sustainable mobility sector.
The 2014 Directive recognises the potential of synthetic and paraffinic fuels (EN 15940), amongst others, to “serve, at least partly, as a substitute for fossil oil sources in the energy supply to transport and which have the potential to contribute to its decarbonisation and enhance the environmental performance of the transport sector”.
Besides providing regulatory clarity on the value of paraffinic fuels as a technology delivering environmental benefits, the Directive acknowledges the value and role that “drop-in fuels” have in making transport cleaner. From ASFE’s perspective, the maintenance of synthetic and paraffinic fuels in such scope – accompanied by explanatory recitals – further confirmed the value that these fuels bring to making transport more sustainable.
The current Directive is a fundamental stepping-stone for the uptake of alternative fuels across Europe. ASFE believes that the Commission has now the chance to address some of the shortcomings of the current framework, while expanding and building on its successes.
Any future review of the Directive should, while keeping the principle of technological neutrality at its core, recognise the value that some alternative fuels have in reducing the climate and environmental impact of transport in a cost-effective manner. Since a potential review of the Directive should seek to provide coherence and alignment of legislation with EU decarbonisation endeavours and ambitions, the Directive should acknowledge all fuels that have a proven environmental record, including all alternative liquid, low-carbon drop-in fuels.
To maximise its impact on decarbonisation, the scope of the Directive should not be limited to those fuels that require major fleet renewals or deployment of new infrastructure. The new Directive should recognise the value that liquid, low-carbon drop-in fuels will play in facilitating a greater and faster adoption of low-carbon alternatives, given their compatibility with existing fleets. Moreover, the Directive should note that these fuels would not require the development of any new infrastructure as such, since they could potentially use similar infrastructure.
Based on a comprehensive and diverse scope of fuels, the new Directive should encourage Member States to adopt measures in support of all fuels with a decarbonisation and environmental potential covered by the Directive, avoiding supporting only one technology over the other and making the most of all options with a decarbonisation potential.
Lastly, the future Directive should also take into account the progress in alternative fuels that has taken place since 2013, and encourage the removal of existing regulatory barriers that, as at today, hinder the uptake of cleaner and more sustainable fuels. The new Directive should therefore be developed in full consistency with other relevant ongoing regulatory procedures, such as the review of the Energy Taxation Directive, the Fuel Quality Directive or the Heavy Duty Emission Regulation and respective reference fuel.
Read full responseResponse to Revision of the Energy Tax Directive
1 Apr 2020
ASFE's input to Energy Taxation Directive’s Revision roadmap
ASFE (the voice of Paraffinic Fuels in Europe) welcomes the Commission’s intention to review the Energy Taxation Directive, as a more harmonised European taxation framework will support the uptake of cleaner, sustainable fuels across Europe.
While the current Directive from 2003 (2003/96/EC) already contributes to this objective, its content is now obsolete and requires a thorough review. As it currently stands, the Directive does not optimise its potential to further support the uptake of cleaner alternative energy products, such as paraffinic fuels.
The Directive should be brought in line with the EU legislation adopted over the last years – such as the 2009 Fuel Quality Directive, the 2015 Alternative Fuels Infrastructure Directive or the most recent 2018 Renewable Energy Directive – in order to fully optimise its contribution to these objectives.
ASFE calls on the Commission to propose a new Directive that includes taxation criteria beyond the energy content of products, and encourages taxation based on the reduction of CO2 and pollutant emissions, i.e. to include also a CO2 component like there already are in some EU Member States.
While taxation of energy products should be approached in a technology-neutral manner in order to give new technologies the opportunity to develop, it should also serve to promote cleaner alternatives especially in the transport sector.
Differentiated national rates linked to product quality (Article 5) can serve as a very positive incentive for the deployment of high-quality alternative fuels, such as paraffinic fuels.
Therefore, the possibility for Member States to impose lower taxation levels to products with high-quality – especially those with an EN specification such as paraffinic fuels – should be maintained.
Moreover, Member States should be encouraged to promote, through taxation means, those fuels that according to Directive 2014/94/EU “serve, at least partly, as a substitute for fossil oil sources in the energy supply to transport and which have the potential to contribute to its decarbonisation and enhance the environmental performance of the transport sector”. These include, amongst others, synthetic and paraffinic fuels.
The categorisation from the 2003 Directive should be reviewed to integrate a greater emphasis on environmental protection.
The Directive should be revised with the aim to deliver a common taxation framework incentivising better performance in energy products, encouraging taxation regimes that look beyond energy content and take into account CO2. The Commission should examine whether this approach could be applied to Community legislation.
This would not only support the uptake of cleaner energy products, but would also help to deliver on the commitments assumed under the Paris Agreement as well as under other pieces of EU legislation.
In case sectoral taxes are planned - e.g. for aviation and maritime - we strongly support them to follow a similar low-carbon incentive model as for the other transport fuels.
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