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BERTAGNI CONSULTING SRL

BC SRL

Azione di Lobbying per le associazioni di categoria: Widen: Caviro Extra spa Distillerie Douence (F) Union Nationale Distilleries Vinicoles (UNDV) (F) AND (P) FNDCV (F) Giovanni Randi (I) Hungarian Spirits Association (HU) La Alcoholera de la Rioja, Ebro y Duero (E) Villapana (I) Must/Federmosti: Caviro Bono e Ditta spa Cantine Brusa spa Naturalia Ingredients srl SUeCO spa Vallovin srl Vinorte srl

Lobbying Activity

Response to Update of list of sustainable biofuel feedstocks

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 and especially for environment since few million tons of wine leftovers (marcs and lees) so far treated, valorized and transformed into advanced biofuel would easily become waste in case of lack of market for ethanol of grape marcs and lees. Moreover, considered what historically happened with Crisis Distillations, namely in 2020, I suggest adding Unsuitable wine for human consumption as a letter (r) among advanced biofuel. This non potable wine, is traditionally distilled under the scope of Crisis Distillations rules, to produce industrial alcohol used as a fuel, as such or via ETBE. ANNEX IX Part A. Feedstocks for the production of biogas for transport and advanced biofuels, the contribution of which towards the minimum shares referred to in the first and fourth subparagraphs of Article 25(1) may be considered to be twice their energy content: (a) Algae if cultivated on land in ponds or photobioreactors; (b) Biomass fraction of mixed municipal waste, but not separated household waste subject to recycling targets under point (a) of Article 11(2) of Directive 2008/98/EC; (c) Biowaste as defined in point (4) of Article 3 of Directive 2008/98/EC from private households subject to separate collection as defined in point (11) of Article 3 of that Directive; (d) Biomass fraction of industrial waste not fit for use in the food or feed chain, including material from retail and wholesale and the agro-food and fish and aquaculture industry, and excluding feedstocks listed in part B of this Annex; (e) Straw; (f) Animal manure and sewage sludge; (g) Palm oil mill effluent and empty palm fruit bunches; (h) Tall oil pitch; (i) Crude glycerine; (j) Bagasse; (k) Grape marcs and wine lees; (l) Nut shells; (m) Husks; (n) Cobs cleaned of kernels of corn; (o) Biomass fraction of wastes and residues from forestry and forest-based industries, namely, bark, branches, pre-commercial thinnings, leaves, needles, tree tops, saw dust, cutter shavings, black liquor, brown liquor, fibre sludge, lignin and tall oil; (p) Other non-food cellulosic material; (q) Other ligno-cellulosic material except saw logs and veneer logs. (r) Unsuitable wine for human consumption
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