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Asociación de la Industria del Combustible de España

AICE

La Asociación de la Industria del Combustible de España (AICE) agrupa a las principales compañías energéticas que integran la cadena de valor de los combustibles líquidos en nuestro país, al aglutinar capacidad de refino en la Unión Europea y actividad comercializadora en España.

Lobbying Activity

Response to COMMISSION DELEGATED REGULATION on extending the scope of traceability of the Union database

7 Nov 2024

AOP welcomes the opportunity to provide feedback in this public consultation on extending the scope of traceability of the EU database. As a key tool for promoting transparency, traceability, and regulatory cohesion within the EU, the UDB requires a clear and robust framework to support consistent application across Member States. We value the steps taken to engage stakeholders in shaping a well-defined regulatory foundation for the UDB, essential for fostering trust and alignment. As the association that integrates companies supplying fuels in Spain with refining capacity in the EU, we would like to take this opportunity to convey to you our comments, suggestions for amendment and requests for clarification in the attached file.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

AOP is the Spanish Oil Companies Association. Committed to an energy transition toward a lower emissions future we support the European Green Deal’s ambition for climate neutrality in 2050. We believe that the Oil & Gas sector has an important role to play in responding to this challenge being, thus, a relevant stakeholder to consider in the review process of the Energy Taxation Directive (hereinafter called ETD). AOP welcomes the opportunity given by the Commission to provide input to the Public Consultation on the Revision of the Energy Taxation Directive (ETD) AOP is convinced that this revision should consider measures aimed to encourage the investments in new technologies and the use of alternative and more sustainable energy, always with a technology neutral approach. The best way to lead a real decarbonization is to incentive all of kind of renewable sources of energy guaranteeing their performance on a level playing field. That’s why AOP supports that: 1) ETD should align the definition of second and third generation biofuels, alternative fuels, e-fuels, etc. with all the measures included in the Fit for 55 package, such as the revision of RED II. This alignment is critical to assuring consistency for the companies to both make the necessary investments and fulfill all the obligations requested. 2) Renewable hydrogen and advanced sustainable fuels should be treated in a similar way as electricity. However, the most favorable treatment included in the current proposal for the electricity, irrespective of its origin, is not in line with the general direction of Fit for 55. Arguments given by the Commission in their working papers for excluding this distinction are rebuttable based on the provisions of art. 19 of RED II (guarantees of origin for energy from renewable sources). 3) AOP welcomes that the lower tax rate for electricity is also applied to low carbon fuels such as “blue” hydrogen. But we regret that this lower rate would only be available to low-carbon fuels for a transition period until 2033, since the EU needs low-carbon fuels while it develops a market for hydrogen based on renewable power. 4) There should be mandatory exemption for second and third generation biofuels to lead to a more harmonized implementation in the EU. We notice instead that exemptions are mandatory in certain transport sectors (maritime and air transport) while in others those are left to the discretion of the member states. AOP calls the attention on the need for carefully considering the competitiveness of peripheral countries of the EU much more dependent on road transport, maritime transport and aviation. This is the reason why AOP supports the maintenance of commercial/non-commercial use differentiated rates. On this sense, we would also welcome further clarification on the application of the categorization and ranking of the minimum tax rates, in particular the inter-category rules to respect and possible intra-category taxation rules. It seems that the minimum rates assigned to each category has to be applied for each product group belonging to this category. However, AOP think that a certain flexibility with respect to the application of equal minimum tax rate for each product group should be allowed (e.g., diesel and petrol).
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Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

The IIA opens the door to support many more technologies that are vital for transport and industrial decarbonisation AOP supports the EU 2050 Climate Neutrality ambition and has published its pathway to be an essential part of reaching this goal: https://bit.ly/3nSh3mZ. We show that liquids are a critical part of the energy transition and future for hard-to-electrify transport, especially aviation and maritime; they can be climate neutral at large scale, enabling faster progress, energy resilience and industrial transformation too. Sustainable biofuels, waste-to-fuels and synthetic fuels together with climate neutral manufacturing using CCS and clean H2 utilise a wide range of feedstocks available in the EU, and corresponding process technologies. They cut GHG emissions from all vehicles in use, do not require huge public investments in logistics & infrastructures & help finance scale for further use in heavy-duty transport, maritime & aviation. Both electricity and liquid fuels are on a journey to climate neutrality. Renewables in transport typically require strong and multiple policy and fiscal signals to mature the technologies and accelerate scale-up. Road transport has a greater ability to afford the higher costs (especially in the early stages) and therefore should be recognised as the critical lead-market to build capability and volume. Many policies and fiscal instruments are available compared with other sectors. Vehicle CO2 regulations play a key role in this policy ecosystem applying a very high C price for carmaker non-compliance but also providing the reference for additional policies. In the current vehicle test “zero g CO2/km” is only possible with electricity or hydrogen. All biomass and captured-carbon based fuels are treated as if they are 100% fossil (unlike in ETS, where biomass is treated as zero CO2; ESR, RED & FQD also consider fuels coming from biomass and waste to be zero CO2 in tailpipe). This itself is a distortion of how different renewables compete, but this effect is multiplied by the raft of Member State & regional incentives which are applied only for a “zero” rated vehicle. As a result, climate-neutral fuels cannot compete despite equivalent (or potentially better) climate impact. This does not meet the technology neutrality objective, and we ask the Commission to address this competitiveness disadvantage. An appropriate regulatory framework has the potential to unlock an investment programme across Europe of up to €650 Billion in climate-neutral fuels, creating high skill jobs, new sources of regional & rural income. Also, Europe can maintain its leadership in efficient & clean ICE technology, & related jobs. Critical policy support measures are already in place or within reach to provide the necessary foundation for linking fuels and vehicles regulation: • The carbon-intensity MRV system for fuels, established by RED-T across Europe, is supported by COM-designed auditing, certification & sustainability standards. • A robust system for fuels compliance certification is in place & will prevent risk of “double counting”. • Vehicle manufacturers or fleet operators could have full control over fuel GHG contribution through long term fuel contracts & mass balancing – credit system Whilst electro-mobility may be also seen as the solution for air quality & public health, comparable results can also be achieved with the extremely low real driving emissions of the latest ICE emission control technology (Euro 6d). AOP welcomes and supports the policy option taking “...into account the potential contribution of renewable & low-carbon fuel when determining manufacturers compliance with their targets” in the IIA and the readiness of the Commission to examine new mechanisms to achieve this including a fuels crediting for new vehicles. We call on the Commission to perform the IA with an unbiased approach to all mobility decarbonisation technologies, and we offer our contribution to this work
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Meeting with Miguel Arias Cañete (Commissioner) and

10 Apr 2015 · Energy Union and refinery sector in the EU