Biomass Technology Group
BTG
Consultancy, Project Development, Business Development and Research & Technology Development in the field of biobased feedstocks & materials, advanced biofuels and energy from biomass.
ID: 545067533914-21
Lobbying Activity
Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission
8 Jul 2021
Feedstock
According to Article 21 (4) of the draft Implementation Regulation, for example saw dust -as it is not listed under waste or residues in Annex IV of the Implementing Regulation-, should be (site-)determined whether it would categorize as co-product, residue or waste, following the scheme of Annex IV (page 7).
According to Article 28 (6) of the RED-II, Annex IX (A, B) feedstocks can be added, not deleted.
We understand that for example saw dust can be used for advanced biofuels, but it may need a more extensive sustainability check, depending on whether a certification body determines whether saw dust is waste, residue or (co)product.
This will lead to additional costs and complexities for economic operators. For the economic operators it will be important to make sure the feedstock is sustainable indeed, as being defined in the various documents.
Co-processing
Article 23 deals with ‘specific rules for co-processing’, referring to Article 28 (5) of the RED-II.
Article 23 (2) states:
“Economic operators shall be required to thoroughly document the amounts and types of biomass entering the process as well as the amounts of biofuel and biogas that are produced from that biomass. Claims shall be substantiated with evidence including the results of the C14 tests. Where alternative assessment methods are used by the economic operator as a main method, C14 tests shall still be used as a way of controlling the correctness of the results of the main method used. Where the C14 test, or other alternative control test, shows a deviation of more than 1% in absolute terms, compared to the results of the alternative main method used by the economic operator, the lower value of both tests shall be retained. In addition, the economic operator shall be obliged to review its testing methods in order to correct any system errors leading to such deviation. Alternative control tests other than the C14 test may be used where the bio content assessed does not contain carbon.”
As C14 is quite imprecise at low levels of co-processing of pyrolysis oil, a viable alternative will be needed. We kindly refer to the EC-funded research project on Co-Processing of Pyrolysis Oil (CPO), conducted by NEN, for the latest findings.
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