OpenLobby.EU
Explore

Carbon Recycling International - CRI hf.

CRI

CRI develops technology and builds and operates production facilities making renewable fuel from CO2 and hydrogen.

Lobbying Activity

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

18 Nov 2021

Carbon Recycling International is the globally recognised leader in CO2-to-methanol technology, which has been operating e-fuel (RFBNO) plants at industrial scale and selling certified e-fuel to obligated parties in the EU since 2012. As practitioners of producing and selling certified RFNBO in several EU member states, we would like to offer several comments, found int the attached document. The main points are: - We welcome a sub-target for RFNBOs, but urge the Commission to implement a higher target of 5% - The Directive should set binding national targets instead of voluntary targets for member states - Same rules for additionality and temporal correlation should apply to all forms of energy in transport (gas, electricity, BEV, renewable fuels) - We support a system of guarantees of origin based on common principles for both biogas and electricity used in transport
Read full response

Response to FuelEU Maritime

8 Nov 2021

Carbon Recycling International is the globally recognised leader in CO2-to-methanol technology, which has been operating e-fuel (RFNBO) plants at industrial scale and selling certified e-fuel to obligated parties in the EU since 2012. We enable our partners to produce renewable e-methanol (RFNBO) from carbon dioxide and electrolytic hydrogen, as well as low-carbon intensity recycled carbon fuels (RCF) and thus promote low carbon intensity transport as well as production of diverse green chemicals. In addition to the first e-fuel plants in Europe we now have three commercial scale plants in construction and under engineering, which will be the largest CCU projects in the world, each with the capacity to recycle at least 150,000 tonnes per year of carbon dioxide. 1. Extending the scope to fishing vessels or smaller commercial ships The obligation should be extended to commercial (freight and utility) ships below 5000 gross tonnage as well as fishing vessels. There is also no obvious reason why government non-commercial vessels are exempt from the obligation, in fact government procurement contracts can play a driving role for the adoption of new technologies. The arbitrary 5000-ton cut-off could encourage owners to build ships which fall just below the gross-tonnage limit. Fisheries is an important economic sector which competes with land-based food industry and should be incentivized to contribute to CO2 reduction targets accordingly. Both in the fisheries sector as well as for smaller vessels, adjustments could be made to reduce paperwork. This would involve developing monitoring which impose lower administrative burden on small operators. 2. Reduction targets The modest reduction targets set by the directive could encourage the shipping industry to continue using fossil-based fuels. Investment in both distribution and utilization of fossil fuels over the next decade will cause further carbon lock-in. CRI proposes that the 2030 target be increased from 6% to 15% and that subsequent 5-year targets be increased by at least 10 pct. points each to promote investment in vessels with the ability to run on renewable fuels and thus accelerate the necessary transition to low carbon intensity fuels. 3. Well-to-wake system We welcome the well-to-wake approach to GHG accounting but would like to emphasize the importance of a system which considers each step of the pathway of production and use, consistently. Note for example in Annex II that the WTT value for e-methanol is supposed to be defined by a pending delegated act under directive 2018/2001, while e-ammonia and e-hydrogen are given a value of 0, which is inconsistent. These three values are ultimately related to the carbon footprint of production of a given MJ of hydrogen by electrolysis. In fact, the contingency between the ETS directive, FuelEUMaritime and RED II+, with a few pending delegated acts based on both existing and revised versions of the directives impacts the fledgling RFNBO fuels industry in particular, as well as investment decisions by both producers and consumers (vessel operators in this case).
Read full response