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Brazilian Sugarcane and Bioenergy Industry Association

UNICA

UNICA is the leading trade association for the sugarcane and bioenergy industry in Brazil, representing 90 percent of the country’s sugarcane production and processing.

Lobbying Activity

Response to European Climate Law amendment

17 Sept 2025

UNICA welcomes the European Commissions proposal to set a binding 2040 climate target of a 90% net reduction in emissions and fully supports the ambition for technological neutrality, fairness, and cost-effectiveness. Brazilian ethanol is one of the most sustainable and scalable biofuels globally, certified as Low ILUC risk and fully compliant with ICAO-CORSIA standards. It delivers up to 90% greenhouse gas savings compared to fossil fuels, supports circular production through renewable electricity generation, and is already available at scale to contribute to decarbonising road, maritime, and aviation transport. However, restrictions under the Renewable Energy Directive (RED III), particularly Annex IX, unfairly exclude sustainable crop-based biofuels, preventing ethanol from contributing to EU decarbonisation targets despite its proven credentials. We urge the European Union to revise its framework and adopt a performance-based sustainability approach that evaluates fuels based on actual greenhouse gas reductions, land-use risk, and certification standards rather than feedstock categories. Aligning EU rules with ICAO-CORSIA would unlock the potential of certified Brazilian ethanol to support Europes transport decarbonisation, sustainable aviation fuels, and carbon removal initiatives such as BECCS. By recognising ethanols sustainability and removing unnecessary restrictions, Europe can accelerate progress toward its 2040 climate goals while enhancing energy security and demonstrating global leadership in fair and effective climate policy. Please consider the attached document.
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Response to EU vision for enhancing global climate and energy transition

11 Sept 2025

The Brazilian Sugarcane and Bioenergy Industry Association (UNICA) welcomes the opportunity to contribute to the European Commissions consultation on the forthcoming EU Strategy to Boost Global Climate and Energy Transition. Both Brazil and the European Union share a strong commitment to the goals of the Paris Agreement, and Brazils long-standing experience in advancing large-scale bioenergy through sustainable sugarcane-based solutions offers important lessons for Europe. These include the design of effective environmental regulations, the promotion of a fair and just transition, and the integration of sustainable bioenergy into climate diplomacy. Brazil has pioneered integrated policies that reconcile energy security, environmental protection, and competitiveness. Initiatives such as the Forest Code, strict zoning rules, and the RenovaBio programme demonstrate how sustainability criteria and market mechanisms can deliver tangible climate benefits while preserving ecosystems. With certified ethanol achieving up to 90% reductions in lifecycle emissions compared to fossil fuels, and with co-products like renewable electricity, biogas, and bioplastics, Brazils sugarcane sector embodies circular economy principles and proves the scalability of bioenergy as a reliable decarbonisation pathway. At the same time, Brazils sugarcane industry illustrates how the clean energy transition can be socially inclusive, supporting millions of jobs in rural areas and contributing to poverty reduction and regional development. This experience shows that competitiveness, innovation, and fairness can be combined. By integrating these lessons, the EUs strategy can recognise bioenergy as a strategic pillar alongside electrification and hydrogen, while fostering regulatory cooperation and investment partnerships. Joint EUBrazil leadership, particularly in the lead-up to COP30, offers an opportunity to demonstrate how sustainable bioenergy can drive a fair, inclusive, and global energy transition. Please see the attached document.
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Response to Clean corporate vehicles

8 Sept 2025

UNICA, the Brazilian Sugarcane and Bioenergy Industry Association, welcomes the European Commissions Clean Corporate Vehicles Initiative and is committed to contributing its expertise to accelerate the decarbonisation of corporate fleets. Representing one of the worlds most efficient biofuel industries, UNICA brings decades of experience in deploying sustainable ethanol solutions at scale. We strongly support a pragmatic, complementary approach where electrification remains the long-term goal, while certified sustainable ethanol offers immediate, cost-effective, and verifiable greenhouse gas reductions. By recognising ethanols role alongside zero-emission vehicles, the Commission can ensure rapid, inclusive, and affordable progress toward climate targets, while building a resilient foundation for Europes clean transport transition.
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Response to Sustainable transport investment plan

4 Sept 2025

The Brazilian Sugarcane and Bioenergy Industry Association (UNICA), representing Brazils ethanol sector, welcomes the opportunity to contribute to the European Commissions Sustainable Transport Investment Plan (STIP). Drawing on over forty years of experience in developing and implementing sustainable transport solutions powered by ethanol, Brazil offers a proven model for decarbonising road, aviation, and maritime sectors. UNICA believes that Brazils expertise in renewable fuels, robust infrastructure, and effective policy frameworks can provide valuable insights and practical pathways for the EU to achieve its ambitious climate targets. By sharing lessons learned and fostering international cooperation, UNICA aims to support the EU in building a resilient, low-carbon, and sustainable transport system for the future. Please find UNICA's answer on the attached file.
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Response to Towards a Circular, Regenerative and Competitive Bioeconomy

23 Jun 2025

UNICA, representing the Brazilian sugarcane and bioenergy industry, underscores the vital role of sustainable biofuelsespecially Brazilian ethanolin advancing the EU's climate goals within its updated Bioeconomy Strategy. Ethanol, as a commercially viable and low-carbon alternative to fossil fuels, offers rapid emissions reductions using existing infrastructure. With life-cycle greenhouse gas savings reaching up to 86%, Brazilian ethanol is positioned as a key decarbonisation solution, not only for conventional road transport but also for hard-to-abate sectors like aviation and maritime. UNICA advocates for aligning the EU's Bioeconomy Strategy with the Renewable Energy Directive III (RED III), enabling broader recognition of certified ethanol within the EUs clean energy framework. The attached document emphasizes Brazils success in sustainably scaling ethanol production with minimal land-use impact and strong environmental safeguards through certifications like Bonsucro and RenovaBio. It recommends that the EU adopt a results-oriented bioeconomy policy that supports sustainable imports, infrastructure investment, and regulatory alignment. Key proposals include recognizing ethanols strategic role, easing market access for certified biofuels, and scaling up advanced biorefinery capacities. UNICA concludes that ethanol is a proven, economically competitive, scalable solution that can enhance EU energy security, rural development, and industrial competitiveness while supporting urgent climate objectives.
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Response to 2040 Climate Target Plan

23 Jun 2023

Gostaríamos de felicitar a União Europeia (UE) por esta sua iniciativa de definir medidas climáticas intermediárias antes do objectivo proposto de 2050, e pelas medidas já implantadas no bloco e exigidas aos seus parceiros económicos mundiais. Contudo, nós na UNICA - União da Indústria de Cana-de-Açúcar e Bioenergia, temos a convicção de que, se a UE quer cumprir o seu compromisso de se tornar até 2050 o primeiro continente com impacto neutro no clima, terá de aproveitar as novas rotas tecnológicas neutras e de diversificar as suas fontes de energia não-poluentes como medida de transição para a eletrificação - não só como uma medida para melhor aproveitar os recursos disponíveis na natureza, mas também para garantir a segurança energética do bloco. Urgimos a UE a se debruçar no exemplo do Brasil, onde o uso, há já várias décadas, do etanol como combustível reduz significativamente as emissões de CO2. Este biocombustível, no Brasil, é resultante de culturas certificadas e completamente sustentáveis (certificadas através do reputado programa RenovaBio, entre outras certificações reconhecidas mundialmente), que respeitam e preservam o meio-ambiente, que garantem a segurança alimentar, honram os Direitos Humanos, que estão de acordo com a legislação ambiental brasileira - uma das mais avançadas do mundo, e que cumprem as normativas e exigências europeias em matéria de clima e ambiente. A adaptação para o uso deste biocombustível na Europa não requer grandes investimentos nem por parte das empresas, nem do sector público, e muito menos grandes investimentos por parte dos agregados familiares, e o seu uso já é regulamentado em toda a UE por meio da Directiva de Energia Renovável (REDII). O uso de etanol como combustível nos transportes no Brasil evitou já a emissão de cerca de 600 milhões de toneladas de CO2 desde o lançamento dos carros Flex em 2003. Esta emissão de CO2 evitada é equivalente às emissões anuais somadas de Argentina, Venezuela, Chile, Colômbia, Uruguai e Paraguai. E, se tivermos em conta o ciclo completo de produção e uso dos veículos (e não somente as emissões pelo tubo de escape), há uma ampla vantagem na eletrificação com etanol e biometano. O etanol proporciona uma redução de até 90% na emissão de gases do efeito estufa (GEE) em relação à gasolina e o aumento da mistura do etanol na gasolina tem sido visto como um caminho para mitigar a emissão de GEE e atender as metas do Acordo de Paris, tal como o seu uso futuro em SAF (Sustainable Aviation Fuel), e o hidrogénio. É da nossa profunda convicção de que o etanol brasileiro ajudará a garantir a eficiência energética europeia, contribuirá para a descarbonização com o seu uso nos transportes (terrestres, aéreos e marítimos), e será essencial para uma transição equilibrada e sustentável para as energias limpas, e para a neutralidade climática na UE e a nível mundial, a fim de garantir tanto a segurança energética como a estabilidade económica.
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Meeting with Frans Timmermans (Executive Vice-President) and Brazilian Tree Industry and

23 Jan 2023 · the EU Deforestation Regulation

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

18 Nov 2021

Transport is responsible for about one quarter of global greenhouse gas emissions worldwide. To reach our climate targets set out under the Paris Climate Accord, there is no single solution and urgent and complementary measures are needed. UNICA, the Brazilian sugarcane association, welcomes the revision of the Renewables Directive and appreciates the opportunity to contribute. In order to meet the EU’s ambition of reaching climate neutrality by 2050, enormous effort and support will be required both immediately and in the longer run. Please find in attachment our feedback to the public consultation.
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

27 Jul 2021

UNICA, the Brazilian Sugarcane Industry Association, welcomes the opportunity to provide feedback to the Commission on the rules to verify sustainability and greenhouse has emissions saving criteria and low indirect land-use change-risk criteria. We are the leading trade association for the sugarcane industry in Brazil, representing 55% of the country’s sugarcane production and processing, 60% of its ethanol and nearly 70% of the bioelectricity that feeds into the national grid. During the last 2020/2021 harvest, Brazil produced approximately 657 million tonnes of sugarcane, the raw material used to produce 41.5 million tonnes of sugar, 32.5 billion litres of ethanol and 22.6 TWh of electricity. As producers of a low-ILUC risk biofuel, UNICA’s members support measures that may provide reassurances to both European importers and authorities as to the excellence of our land management practices. Particularly, certification of biofuels’ compliance with GHG emissions-saving and sustainability criteria may support overturning disproven and obsolete arguments around ILUC, otherwise known as ‘food vs fuel’, that are inapplicable to Brazilian sugarcane production. Brazilian sugarcane ethanol is among the biofuels achieving most greenhouse gas savings while having an excellent sustainability performance. Sugarcane ethanol reduces GHG emissions by around 77% when compared to fossil fuels, performing better than any other liquid biofuel produced today on a commercial scale. Should the EU introduce certification to verify sustainability and GHG emissions saving and low ILUC risk, it is essential to ensure policy coherence across initiatives, particularly in the framework of ‘Fit for 55’ and subsequent amendments to REDII. It is our understanding that certified sustainable biofuels, complying with stringent GHG emissions saving and ILUC criteria would be made exempt from the 7% cap on crop-based biofuels to unleash their potential to decarbonise transport systems. Please find in attachment our response to this public consultation.
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Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

The Brazilian Sugarcane Industry Association, UNICA, supports the objective of reviewing CO2 emission standards for cars, particularly to accelerate the decarbonisation of the transport sector. Setting stringent CO2 emission standards and including an incentive mechanism has helped to increase investments in zero tailpipe emission technologies and increased the share of electric models in the fleets. However, until now such endeavours have not resulted in a significant reduction of CO2 emissions in  transport that still contributes around 25% of overall greenhouse gas emissions in the EU. Cutting emissions from transport must play a pivotal role in realising the ambition of net-zero emissions, as set out in the European Green Deal. In view of the urgency to reduce carbon emissions, we trust that the instrument in its current form has some shortcomings that the revision should address. First of all emission performance standards will only lead to an emission reduction once the new models hit the road while emission reduction should start immediately. That is also why the focus on zero and low emission vehicles in the incentive mechanism is largely insufficient. It will require substantial investments in infrastructure until zero-emission vehicles, mainly battery electric vehicles might become a substitute for internal combustion engines (ICE). In particular in rural areas and in Central and Eastern Europe it will take many years until road transport can be electrified.  One other important element to deliver GHG reductions is the inventory methodology. Specialists stress that a life cycle GHG emission analysis is required to fully assess transport’s contribution to climate change. For instance, a zero tailpipe emission EV can contribute as much to global warming as an ICE vehicle if it is charged with a fossil-based electricity. The increased use of sustainable biofuels could help fill this gap and lower carbon emissions with immediate effect. In Brazil the use of sugarcane ethanol has avoided emitting more than 515 million tons of carbon dioxide since 2003. In France the use of the E85 conversion box combined with lower tax rates for E85 allow to reduce CO2 emissions by 50-75% per car. Particulate matter emissions can be reduced by 90% and NOx by 30%. Having a strong biofuel supply chain guarantees sustainability of the transport matrix, offering consumers options such as the already marketed and affordable hybrid flex-fuel vehicles, that has an emission pattern of 25 gCO2eq/km when using sugarcane ethanol. In addition, new fuel cell vehicles that run on hydrogen extracted from liquid fuels will soon be on the market. These options present several advantages when compared to plug-in EVs, for example they require smaller batteries and have longer autonomy, ideal for individual or public transportation. Therefore, we highly welcome the initiative to explore new mechanisms to take into account the potential contribution of renewable and low-carbon fuels when determining manufacturers compliance with their targets. If the mechanism incentivises the use of sustainable biofuels and technologies that enable increased biofuel blends such as the E85 conversion box, road transport emissions can be reduced almost immediately.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

UNICA, the Brazilian sugarcane association, welcomes the opportunity to contribute to the review of EU renewable energy rules. In order to meet the EU’s ambition of reaching climate neutrality by 2050, enormous effort and support will be required both immediately and in the long term. Please find our full input in annex.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

21 Apr 2020

The Brazilian Sugarcane Industry Association, UNICA, welcomes the publication of the Inception Impact Assessment on ReFuel EU Aviation and the opportunity to comment on decarbonisation pathways for the aviation sector.

 The global aviation industry has set a goal of carbon-neutral growth and aims to reduce net aviation carbon emissions by 50% by 2050. Whilst it remains uncertain what impact COVID-19 will have on future commercial aviation, and subsequent CO2 emissions, sustainable aviation fuels will remain a key pathway towards the decarbonisation of the sector.

 To tackle this global challenge, the International Civil Aviation Organisation (ICAO) Parties introduced a global market based measure, the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). The European Union is committed to CORSIA through the adoption of the Bratislava Declaration, and has endorsed the CORSIA Eligible Fuels Life Cycle Assessment. 

 The Commission should remain committed to the sustainability and technology-neutral criteria adopted in the multilateral arena, particular as they relate to non-discrimination between crop-based and advanced biofuels provided they can offer scalable sustainable low carbon solutions. In this sense, we agree with the EU Joint Research Centre’s recommendation that “alternative fuel technologies should compete under a common policy framework, which focuses on the need for emission reductions”, as recently proposed in the 'State of the Art on Alternative Fuels Transport Systems in the European Union’.

 Amongst the eligible CORSIA sustainable fuels is farnesane, obtained from sugarcane ethanol (ASTM 7566). Farnesane is obtained biologically through sugar fermentation using biochemical conversion technology, namely the synthesised iso-paraffins (SIP) pathway. The decarbonisation value of this crop-based biofuel for sustainable aviation fuels has been endorsed by EU within the framework of CORSIA (24.1 gCO2e/MJ). This value is also recognised in the aforementioned JRC study in which researchers conclude that “sugar cane ethanol can also exhibit relatively low emissions (of about 25 g CO2eq/MJ), and this biofuel is made successfully in large volumes most notably in Brazil”. 

It is essential that the SAF legislative initiative retain policy coherence with the Renewable Energy Directive (REDII) that already outlines sustainability criteria for biofuels, including on indirect land use change (iLUC). Brazilian sugarcane ethanol is among the biofuels achieving most greenhouse gas savings, even when comparing to second generation options, with an excellent sustainability performance. In its recent study “Assessing the impacts of the EU bioeconomy on third countries”, EU’s JRC concludes that expansion of sugarcane into high carbon stock lands or into other cropland (including food crops) is marginal, and would remain negligible in the case of increased demand.
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Response to High and low Indirect Land-Use Change (ILUC) - risks biofuels, bioliquids and biomass fuels

5 Mar 2019

We would like to thank the European Commission for the opportunity to provide comments on the draft delegated act supplementing Directive (EU) 2018/2001 as regards the determination of high indirect land-use change-risk feedstock for which a significant expansion of the production area into land with high carbon stock is observed and the certification of low indirect land use change-risk biofuels, bioliquids and biomass fuels. Our comments will concentrate on sugarcane exclusively. We suggest the European Commission to be more transparent and to clearly indicate the share of each crop expansion into land with high-carbon stock according to the formula indicated in Art 3 (b) of the delegated act, instead of the share of expansion into land referred to in Article 29 (4) (a) (b) (c). In addition, we would like to question the fact that the Commission did not use, for sugarcane, the well documented information that was submitted by UNICA and Agroicone. According to the Brazilian sources, sugarcane expansion on land covered with forest and native vegetation is less than 1%, and not 2.1% as implied in the delegated act. More detailed comments are included in the document in attachment.
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