European Biodiesel Board

EBB

The European Biodiesel Board represents biodiesel producers in the EU and promotes biodiesel use across the Union.

Lobbying Activity

Meeting with Andreas Glück (Member of the European Parliament)

8 Jan 2026 · Automotive Package

European Biodiesel Board demands green status for crop-based fuels

2 Dec 2025
Message — The board wants the EU to align biofuel rules with energy directives. They argue that food-based fuels should count as sustainable green investments. They suggest measuring vehicle emissions over their life-cycle rather than at the exhaust.123
Why — This change would allow biodiesel producers to secure easier access to sustainable finance.4
Impact — Purely electric vehicle manufacturers would lose their exclusive claim to green investment.5

Meeting with Giorgio Gori (Member of the European Parliament)

13 Nov 2025 · Upcoming review of CO2 emission standards for cars and vans regulation

Meeting with Andreas Glück (Member of the European Parliament)

13 Nov 2025 · Climate and Environment Policy

European Biodiesel Board urges inclusion of biodiesel in heating strategy

8 Oct 2025
Message — The EBB calls for "technological neutrality" to ensure biodiesel is recognized as a heating solution. They propose "blending mandates" and "harmonised technical standards" to increase market uptake.12
Why — This would open new markets for biodiesel producers and secure government financial incentives.3
Impact — Fossil fuel gas providers would lose market share as biodiesel replaces high-carbon alternatives.4

Biodiesel board demands tech neutrality in EU vehicle standards

7 Oct 2025
Message — The organization calls for a new vehicle category running exclusively on sustainable biofuels. They want these fuels recognized as zero-emission in their use phase to match electric vehicles. Additionally, they propose a Carbon Correction Factor to reflect the climate benefits of renewable fuels.123
Why — This would secure long-term demand for biofuels and provide much needed investment certainty.45
Impact — Pure electric vehicle manufacturers would lose their exclusive status as zero-emission providers.6

Meeting with Sophie Wilmès (Member of the European Parliament)

4 Sept 2025 · Biodiesel

European Biodiesel Board demands technology neutrality for corporate fleets

3 Sept 2025
Message — The organization demands a technology-neutral approach that recognizes carbon-neutral fuels as zero-emission solutions. They warn that mandatory electric vehicle purchase targets could disrupt markets and hinder greening efforts.123
Why — Including renewable fuels ensures continued demand for biodiesel products in the corporate market.4
Impact — Fleet operators would face financial harm from high prices and falling resale values.5

European Biodiesel Board urges investment strategy for all renewable fuels

3 Sept 2025
Message — EBB requests a strategy covering all renewable fuels and all modes of transport. They demand regulatory certainty beyond 2030 and alignment of funding with binding targets. The industry also seeks trade defense measures to protect against non-EU competitors.123
Why — A bigger market and long-term certainty would de-risk investments and scale up production.4
Impact — Non-EU producers would face tougher competition through trade defense instruments and increased monitoring.5

Meeting with Ilhan Kyuchyuk (Member of the European Parliament)

2 Sept 2025 · European Climate Law

Meeting with Fabrice D'Aprile (Head of Unit Trade)

27 Aug 2025 · EBB and TRADE Directorate G on DS618 Biodiesel

Meeting with Rosa Serrano Sierra (Member of the European Parliament)

14 Jul 2025 · Decarbonisation of Transport

Meeting with Denis Redonnet (Deputy Director-General Trade)

9 Jul 2025 · Meeting focused on the current anti-dumping measures on imports of biodiesel

Meeting with Elsi Katainen (Member of the European Parliament)

2 Jul 2025 · Bioeconomy strategy

Meeting with Bruno Gonçalves (Member of the European Parliament) and ALTRI, SGPS, S.A.

1 Jul 2025 · ITRE policies

European Biodiesel Board advocates for flexible biomass market rules

20 Jun 2025
Message — The European Biodiesel Board opposes rigid rules that prioritize certain biomass uses over others. They advocate for market freedom so processors can choose where to sell their products. Furthermore, they recommend using existing biofuel standards as a basis for all biomass sustainability rules.123
Why — Market flexibility and standardized criteria would protect the biodiesel sector's competitiveness.4
Impact — Food and feed producers could face lower production levels if biodiesel markets are restricted.5

Meeting with Dan-Ştefan Motreanu (Member of the European Parliament)

2 Jun 2025 · Priorities for a “Made in Europe” transition towards carbon-neutral transport

Meeting with Cristina Maestre (Member of the European Parliament)

21 May 2025 · The future of agriculture and post-2027 CAP

Meeting with Valérie Hayer (Member of the European Parliament)

15 May 2025 · Biofuels

Meeting with Barry Cowen (Member of the European Parliament, Shadow rapporteur)

30 Apr 2025 · Meeting with the European Biodiesel Board (EBB)

Meeting with Lucia Granelli (Head of Unit Taxation and Customs Union) and CASSIDY LEVY KENT EUROPE

29 Apr 2025 · Tariff codes for Sustainable Aviation Fuel (SAF)

Meeting with Christine Singer (Member of the European Parliament)

15 Apr 2025 · Biodiesel

Meeting with Sander Smit (Member of the European Parliament)

4 Apr 2025 · Renewable Energy Directive; CO2-standards for Cars & Heavy Duty Vehicles

Meeting with Andreas Glück (Member of the European Parliament)

6 Mar 2025 · Climate Policy

Meeting with Stefan Köhler (Member of the European Parliament) and Specialised Nutrition Europe and Friedrich-Alexander-Universität Erlangen-Nürnberg

4 Mar 2025 · Politischer Austausch

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)

18 Feb 2025 · Exchange of views on sustainable biofuels; EBB, representing HVO and FAME producers in Europe, wishes to share their proposals for amendments to the Implementing Regulation (EU) 2022/996, pending its revision.

Meeting with Kristian Vigenin (Member of the European Parliament)

3 Dec 2024 · Priorities of the 10th legislature

Meeting with João Cotrim De Figueiredo (Member of the European Parliament)

2 Dec 2024 · Biodiesel

Meeting with Ana Vasconcelos (Member of the European Parliament)

2 Dec 2024 · Introductory meeting

Meeting with Sophia Kircher (Member of the European Parliament)

26 Nov 2024 · Vehicle Emission targets

Meeting with Gabriella Gerzsenyi (Member of the European Parliament)

19 Nov 2024 · Introductory meeting on the role of biodiesel in EU

Meeting with Grégory Allione (Member of the European Parliament)

13 Nov 2024 · Réunion European Biodiesel Board

European Biodiesel Board urges delay for fuel traceability database

7 Nov 2024
Message — The board seeks an 18-month phase-in period to resolve database technical errors. They suggest limiting reporting to certain materials and extending transaction deadlines to one month.123
Why — The industry avoids compliance burdens and operational shutdowns linked to database glitches.45
Impact — Market integrity suffers as fraudulent imports remain harder to detect during the delay.6

Meeting with Hildegard Bentele (Member of the European Parliament)

25 Sept 2024 · eFuels

Meeting with Eero Heinäluoma (Member of the European Parliament) and European Coordination of Committees and Associations for Palestine and

24 Sept 2024 · Current Affairs

Meeting with Andrea Wechsler (Member of the European Parliament) and BUSINESSEUROPE and

23 Sept 2024 · EU Energy and Industry Policy

Meeting with Kateřina Konečná (Member of the European Parliament)

10 Jul 2024 · Priorities introduction

Meeting with Jens Gieseke (Member of the European Parliament)

10 Jul 2024 · Austausch zu Umwelt- und Verkehrspolitik

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

4 Jul 2024 · Lobby Meeting

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

4 Jul 2024 · Alternative Fuels - Biodiesel

Meeting with Andreas Glück (Member of the European Parliament) and Liquid Gas Europe and Bioéthanol France

28 Jun 2023 · HDV

European Biodiesel Board urges biofuel support in 2040 target

23 Jun 2023
Message — The EBB requests a stable framework promoting all sustainable biofuels across all transport modes. They urge using Well-to-Wheel assessments to recognize renewable fuels' decarbonization benefits.12
Why — This protects biodiesel's market share and ensures investment certainty for producers.3
Impact — Electric vehicle manufacturers lose market share if heavy-duty vehicles continue using internal combustion engines.4

European Biodiesel Board Urges Higher Caps on New Feedstocks

27 Dec 2022
Message — The board demands higher usage limits for mature feedstocks. They also oppose moving materials from advanced to restricted categories.12
Why — The board would secure its existing investments and access a larger pool of raw materials.34
Impact — Advanced biofuel investors lose financial security if their feedstocks are downgraded to restricted categories.56

Meeting with Ismail Ertug (Member of the European Parliament, Rapporteur)

12 Oct 2022 · Towards climate neutral heavy-duty transport

Meeting with Michaela Šojdrová (Member of the European Parliament)

13 Sept 2022 · Ongoing work on RED III as well as the REPowerEU initiative

Meeting with Barbara Thaler (Member of the European Parliament, Rapporteur for opinion) and TotalEnergies SE and

6 Sept 2022 · RED

European Biodiesel Board demands strict auditing for co-processed fuels

14 Jul 2022
Message — The EBB insists that only biomass dedicated to transport fuels should be counted toward renewable targets. They call for harmonized accounting rules and robust auditability to prevent market distortions. Additionally, they advocate for C14 testing to verify fuel conversion factors.123
Why — Harmonized rules prevent market distortions and ensure bio-component volumes are accurately counted.4
Impact — Refineries face increased operational costs from frequent mandatory testing and independent certification audits.56

European Biodiesel Board seeks zero-emission status for biodiesel trucks

28 Jun 2022
Message — The EBB requests that B100 trucks be classified as zero-emission vehicles. They also suggest expanding regulations to allow re-certification for existing engines to use biodiesel.12
Why — This classification would improve the cost-effectiveness and market adoption of biodiesel fuels.3

Meeting with Nils Torvalds (Member of the European Parliament)

10 May 2022 · Biodiesel

Response to Streamlining EU scientific and technical work on chemicals through the EU agencies

12 Apr 2022

The European Biodiesel Board (EBB) is pleased to have the chance to contribute to the call for evidence and supports the principle of making more efficient use of expertise and resources by proposing a “one substance, one assessment” approach to chemical safety assessments. We, therefore, support the principle of reattributing technical and scientific information on chemicals gathered under legislation relevant to a specific European agency (ECHA, EFSA, EMA), including the work of the Scientific Committees on Health, Environmental and Emerging Risks (SCHEER) and Consumer Safety (SCCS), to streamline assessment procedures and harmonise data used throughout the EU. To achieve this, it is clear that the “basic evaluation of substances properties (hazard assessment)” should be carried out in a consistent manner, grounded in a single set of agreed scientific principles, and independent of the area of application. However, reattribution of work must not result in a single agency being responsible for the risk evaluations of all chemicals. Such an occurrence risks the agency responsible for the assessment becoming overwhelmed. At best, this would result in the quality of the work and results deteriorating. At worst, it risks scientifically unsound approaches being used and flawed decisions being made by overworked staff trying overwhelming workload. Similarly, care should be taken to ensure that work duplication does not occur, with parallel evaluations of one chemical happening simultaneously in two agencies. To prevent this, risk management measures should not begin when there is an ongoing substance evaluation. Should an Agency believe risk management measures to be necessary, the substance should be flagged, so the measures begin after the evaluation. This would prevent duplication of work and give those performing the evaluation the opportunity to implement risk management measures on top of those requested, should the evaluation find them warranted. In a similar vein, the implementation of the initiative should also avoid duplication of risk management measures. When such measures are introduced for a chemical, there should be a system to make all agencies aware they have been implemented, so separate measures are not introduced independently by two or more agencies. The agency responsible for evaluating the risk of a specific chemical have the expertise needed to assess the risk of the chemical when used in different domains. For example, if a chemical has a primary use is in medicine, the EMA should be responsible for the risk evaluation, but if it also has use as say an industrial lubricant, ECHA should provide technical support if the EMA lacks the staff, expertise, or resources, to evaluate the risk of its use in this domain. Therefore, it is vital that the implementation of the “one substance, one assessment” approach contains provisions for supporting greater interagency cooperation. It is also essential to maintain the current logical and well-understood approach, going from hazard evaluation to risk assessment, to risk management. Furthermore, the initiative’s implementation should only streamline existing procedures and not introduce new restrictions. For example, as a result of this initiative, substances under a REACH Substance Evaluation should not face new limits under other regulatory initiatives, such as the Restriction of Hazardous Substances Directive. Finally, it is vital that implementing this initiative does create additional administrative burdens, result in multiple processes that run in parallel, or create legal uncertainty.
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Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur) and Liquid Gas Europe and NGVA Europe

9 Feb 2022 · Austausch zur EU-Verkehrspolitik

Response to Revision of the Energy Tax Directive

18 Nov 2021

- Consistent with IPCC guidelines, CO2 pricing should not apply to biofuels and biomass. - Derogation for fuels used in agriculture, horticulture and forestry must be maintained. - The ETD should differentiate between sustainable biofuels and fossil fuels. Therefore, the proposal to attribute the same tax rate to fossil fuels (petrol and diesel) and sustainable crop-based biofuels in 2033 should not be accepted. - Alongside waste & advanced biofuels, which deliver significant GHG emissions savings, sustainable crop-based biofuels should continue to benefit from a lower tax rate.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

18 Nov 2021

- Biofuels comply today with strict single EU-wide sustainability criteria. This allows all sustainable biofuels to have a role in the decarbonization of European transport. The approach to feedstocks and GHG savings calculations in the Aviation and Maritime proposals unduly deviate from the RED II (and RED III) sustainability criteria. - Instead, we propose to put in place a propose an harmonized approach across the FF55 proposals addressing the decarbonization of the different transport modes, focused on technology and feedstock neutrality. - This approach should be centred around the use of sustainable biofuels abiding by a single sustainability regime for all transport modes (road, aviation, maritime, etc.), set by the EU Renewable Energy Directive and its subsequent revisions. - The RefuelEU Aviation proposed regulation contradicts the RED II, and should be adjusted accordingly. Namely, the exclusion of crop-based biofuels from the definition of Sustainable Aviation Fuels (SAF) should be removed to ensure that the RED sustainability requirements are applied consistently. - Moreover, to ensure a broad supply of Sustainable Aviation Fuels (SAF), it is critical to ensure the expansion of the pool of suitable feedstock types for aviation (e.g. sustainable crop-based, as governed already in transport), as well as and other novel feedstocks, is key. - Additional support for hard to decarbonize sectors, such as maritime and aviation transport, should not lead to an unintended displacement of existing decarbonization in road transport.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

See PDF attached for the EBB submission to this consultation. Please note that the document submitted is a high-level submission to this consultation, but does not constitute a complete EBB position paper addressing all the multiple elements in that proposal (still under preparation).
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Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

- The current EU CO2 standards for vehicles only account for tailpipe emissions (Tank-To-Wheel). This restrictive approach distorts competition between powertrain technologies and misleadingly labels electromobility as emissions free. It fails to incentivise biofuels and biogas with a lower GHG footprint and renewable content by not recognising their biogenic energy content. - The EU should consider an approach that accounts for the nature of the energy powering vehicles (Well-to-Wheel), distinguish between fossil and biogenic CO2 and account for the production and end-of-life emissions of the vehicles.
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Response to FuelEU Maritime

8 Nov 2021

- A successful EU decarbonisation transport policy should build on the achievements of the RED II and other EU policies, not reverse them. - European sustainable biofuels today account for over 89% of renewables in the European transport. They are the most widely available alternative to fossil fuels and deliver significant GHG emissions savings, and should continue to decarbonise all transport modes. - Biofuels comply today with strict single EU-wide sustainability criteria. These criteria allow for all sustainable biofuels to have a role in the decarbonisation of European transport. - The approach to feedstocks and GHG savings calculations in the Aviation and Maritime proposals unfortunately deviate from the RED II (and future RED III) sustainability criteria. - The use of sustainable biofuels should abide by a single sustainability regime for all transport modes (road, aviation, maritime, etc.), set by the EU Renewable Energy Directive and its subsequent revisions. - The FuelEU Maritime proposed regulation contradicts the RED II and should be adjusted accordingly. Namely, biases against crop-based biofuels (which deliver at least 55% savings when compared with fossil fuels), to should be removed, ensuring that RED sustainability requirements are applied consistently. - The differentiated support regimes for hard to decarbonize sectors, such as maritime and aviation, should help grow the feedstock supply, and not just divert it. Road transport is and will be the main driver for demand for renewable fuels up to 2030; its decarbonisation must not be undermined by support regimes introduced for other transport modes.
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

27 Jul 2021

The EBB welcomes the opportunity to respond to this EC consultation, which we hope will serve to improve the draft implementing act, and bring clarity to the proposed rules for the voluntary schemes. Attached you can find our contribution on the draft implementing regulation itself, with comments as well as specific proposals (identified in green) to improve the proposed draft. We have also included some requests for clarification on points of the draft that we do not fully understand (those are identified in yellow). In addition to the specific comments on the draft text (attached here), we would like to bring to your attention serious concerns related to the application of the updated sustainability criteria laid down in Directive 2018/2001 (RED II). These were already expressed in a letter sent to the EC on 30 June 2021 by the EU Biofuels Chain. While we are conscious that the RED II transposition deadline for Member States was set at 30 June 2021, most of the EU Member States are severely delayed in the transposition of the updated RED II rules, and to our knowledge the sustainability provisions do not have direct effect on economic operators. Therefore, we expect economic operators to abide by the legislation in force, that is of the Member States where they operate, that is where they produce and/or trade the certified raw material and biofuels. They also have signed contracts under the rules in force, sometimes long-term contracts. As a result, the lack of clear information regarding the application and corresponding certification of the new sustainability requirements is putting economic operators in a condition of legal uncertainty and risks significantly disrupting the smooth functioning of the entire biofuels chain and markets in the EU. Moreover, and especially considering that: 1. None of the updated voluntary schemes applying for recognition under RED II rules has been so far approved by the EC; 2. Both economic operators and voluntary schemes need adequate time to adapt themselves to the new rules and methodology, upon the clarifications that are needed; 3. Feedstock harvested and biofuels manufactured before 1 July 2021 will still represent the biggest share of the market after the RED II transposition deadline. We would also like to receive a clarification issued by the EC regarding the applicability of the updated rules in the absence of transposition by Member States, and of the published guidance by the Commission. Moreover, we would like to propose a transition period during which RED I certified biofuels, producing units and operators can be considered sustainable under RED II rules, for instance up to 1 January 2022.
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

5 May 2021 · RefuelEU Aviation SAF initiative

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

13 Jan 2021 · Presentation of the Board’s view on Fit for 55

Response to Climate change mitigation and adaptation taxonomy

11 Dec 2020

1. Sustainability criteria for the manufacturing of biofuels Annex 1, 4.13 Sustainable biodiesel (both crop and waste-based) is the most widely used biofuel in Europe today, delivering significant greenhouse gas (GHG) emissions savings, and constituting an essential tool for the decarbonisation of the European road transport sector. As illustrated by the EC’s 2020 Renewable Energy Progress Report ( ), the use of biofuel, such as biodiesel, has contributed significantly to CO2 emission reduction in the transport sector. The sustainability criteria laid down in the post-2020 EU Renewable Energy Directive – RED II ( ) guarantees that the raw materials for biodiesel production (either food and feed crops or wastes and residues) are used in a sustainable manner. The compromise agreed in the RED II reaffirmed the co-legislators support for all sustainable forms of biofuels, including crop-based, which can be counted towards the EU renewables targets. These raw materials are considered sustainable if they meet the RED II sustainability and GHG emission savings criteria. Moreover, the RED II determined that only those biofuels, bioliquids or biomass fuels produced from food and feed crops for which a significant expansion of the production area into land with high-carbon stock is observed – the so called “high ILUC-risk biofuels” – should be phased-out. The absolute exclusion food and feed crops for biofuels manufacturing is not founded. As it is written now, the restriction on food or feed crop use is contradicting the RED II which, while capping crop-based biofuels, still gives them an important role in the decarbonization of the European transport sector. Only a coherent alignment between the EU Taxonomy Regulation and the RED II would provide investment security and a consistent framework for the EU decarbonization targets. Moreover, the proposed increase of the benchmark for GHG emissions savings to 65% without a proper impact assessment is not compatible with the existing RED II criteria, and could further fragment the existing biofuels market, and unduly harm existing companies producing sustainable biofuels. In addition, under certain climatic and soil conditions, food and feed crops are used as intermediate crop before and after the main crop as indicated in RED II (42) or in seamless crop rotation to increase overall yield (82) hence bearing a low ILUC-risk and not competing with the main crop. Furthermore, there are also crops that are not suited for food and feed usage (e.g., from contaminated land).
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

With more than 11 million tonnes of biodiesel produced per year, the EU is the world leader in the production and use of biodiesel for transport. Biodiesel constitutes a significant European renewable energy source, and the main European solution to reduce emissions from transport and dependence on imported oil. The European Biodiesel Board (EBB) represents 65 members across 21 Member-States, constituting around 80% of the European biodiesel output. The EBB supports the declared goal of increasing the EU 2030 GHG emissions reduction target to 55% compared to 1990, as an intermediate step to achieve climate neutrality by 2050. This effort should be shared between all sectors, including the decarbonisation of land/road transport. The transport sector remains the only EU sector where GHG emissions keep increasing every year and could reach close to 45% of all EU economy emissions in 2040-50, contrary to all other EU economy sectors which have experienced falling GHG emissions. Transport decarbonisation is driven multiple EU instruments, including the post-2020 Renewable Energy Directive (RED II), the Effort Sharing Regulation (ESR), the Fuel Quality Directive (FQD) article 7a, and taxation policies. They have proven to be somewhat successful in decarbonising transport, although they could step-up their level of ambition. In particular, the RED II has the intention to drive the adoption of emerging new feedstocks and advanced biofuels. A cross-sectoral EU ETS approach would eliminate the incentive to invest in first-of-their-kind production units, as ETS allowance price levels are very unlikely to provide the economic attractiveness needed to operate these units profitably. Therefore, given present and future levels of ETS allowance prices, enlarging the scope of the ETS – and consequently diminishing the scope of the ESR – would unlikely trigger the important efforts that need to be done to decarbonise the EU transport sector. This would also mean that, under the same emission cap, other ETS sectors would have to reduce more their emissions as well as pay more for the necessary emissions allowances. Transport sector would continue to use fossil fuels instead of reducing their emissions more than there is a possibility to have electrification in place. For these reasons, the EBB does not support proposals to reduce the scope of the ESR. These would mean including EU road transport sector in the existing EU ETS, and therefore likely be translated into less effective decarbonisation of that sector.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

With more than 11 million tonnes of biodiesel produced per year, the EU is the world leader in the production and use of biodiesel for transport. Biodiesel constitutes a significant European renewable energy source, and the main European solution to reduce emissions from transport and dependence on imported oil. The European Biodiesel Board (EBB) represents 65 members across 21 Member-States, constituting around 80% of the European biodiesel output. The EBB supports the declared goal of increasing the EU 2030 GHG emissions reduction target to 55% compared to 1990, as an intermediate step to achieve climate neutrality by 2050. This effort should be shared between all sectors, including transport. Decarbonisation of the European land/road transport is driven by several EU rules, incl. the post-2020 EU Renewable Energy Directive (RED II), Effort Sharing Regulation (ESR), Fuel Quality Directive (FQD) article 7a, and taxation policies. They have proven to be somewhat successful in decarbonising transport, although they could step-up their level of ambition. The RED II has the intention to drive the adoption of emerging new feedstocks and advanced biofuels based on raw materials listed on RED II Annex IX, part A. A cross-sectoral ETS approach would eliminate the incentive to invest in first-of-their-kind production units, as ETS allowance price levels are very unlikely to provide the economic attractiveness needed to operate these units profitably. Whereas this inception impact assessment states that “covering road transport emissions by the emissions trading would provide a more level playing field in terms of carbon pricing of fossil-fuelled road transport”. Such inclusion, given present and future levels of ETS allowance prices, would be very unlikely to trigger the necessary efforts that should be made to decarbonise the EU transport sector. This would also mean that, under the same emission cap, other ETS sectors would have to reduce more their emissions as well as pay more for emissions allowances that they would need. Transport sector would continue to use fossil fuels instead of further reducing their emissions with existing tools such as biofuels. Therefore, a proposal for including EU road transport sector in the existing EU ETS should be rejected.
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Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

With more than 11 million tonnes of biodiesel produced per year, the EU is the world leader in the production and use of biodiesel for transport. Biodiesel constitutes a significant European renewable energy source, and the main European solution to reduce emissions from transport and dependence on imported oil. The European Biodiesel Board (EBB) represents 65 members across 21 Member-States, constituting around 80% of the European biodiesel output. Sustainable biodiesel (both crop and waste-based) is delivering today significant GHG emissions savings and constitutes an essential tool for the decarbonisation of the European road transport sector. To ensure that this decarbonisation continues, the EBB considers essential for the upcoming amendment of the Regulation setting CO2 emission standards to consider the following policy measures: • Develop separate targets for biofuels and CO2 emission standards for Heavy and Light Duty Vehicles (vans, long-haul buses, and trucks – all keeping full diesel mobility in the next decade at least). • The EU should recognise the GHG emission savings of biofuels in the existing EU CO2 emission standards regulations for passenger cars as well as HDVs. • Whereas this inception impact assessment states that “the increased market uptake of vehicles with zero tailpipe emissions can have a positive impact on air pollutant levels”. It should be taken into account that the tailpipe approach (Tank-To-Wheel) is too restrictive and distorts competition between powertrain technologies and misleadingly labels electromobility as emissions-free. Therefore, the EU should consider an approach that accounts for the nature of the energy powering vehicles (Well-to-Wheel), distinguishes between fossil and biogenic CO2 and accounts for the production and end-of-life emissions of the vehicles, while ensuring a level-playing field across all technologies. At this stage, the EBB notes the EC’s current intention of only incentivizing the use of electric vehicles. Unfortunately, this approach is too limiting and does not reflect the reality of the European transport sector. Consumer embrace of electric cars on a wide-scale is likely to take time and delay a broader roll-out and use of these vehicles. On the contrary, biofuels are a readily available alternative to immediately decarbonise the transport sector.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

With more than 11 million tonnes of biodiesel produced per year, the EU is the world leader in the production and use of biodiesel for transport. Sustainable biodiesel (both crop and waste-based) is delivering today significant GHG emissions savings and constitutes an essential tool for the decarbonization of the European road transport sector, not only in passenger cars but specially in light and heavy-duty vehicles where there are less available alternatives. To ensure that this decarbonization continues, the EBB considers essential for the upcoming RED II revision to include the following policy measures: • Setting a minimum effective incorporation of renewables in transport of at least 20% by 2030 (up from the existing 14% currently included in the RED II); • Develop separate targets for biofuels and CO2 emission standards for Heavy and Light Duty Vehicles (vans, long-haul buses, and trucks); • Set specific targets for bio-kerosene in aviation, and for renewable fuels in the maritime sector; • Recognize by an LCA approach the GHG emission savings of biofuels to incentivize vehicle manufacturers to put on the market vehicles that accept higher blends of biofuels; • Reassess upwards the existing cap on sustainable crop-base biofuels, essential to meet the Paris Agreement goals and a climate neutral EU; • Develop without delay the certification criteria for low ILUC-risk biofuels; • Quickly implement single EU transparency and traceability database for all biofuels to ensure that only sustainable biofuels are counted towards the EU targets. On the other hand, the EBB would like to stress that including the European road transport sector into the EU ETS, given present and future levels of ETS allowance prices, would not trigger the important efforts that need to be done to decarbonise the EU transport sector. It would also mean that, under the same emission cap, other ETS sectors would have to reduce more their emissions as well as pay more for emissions allowances they would need. Transport sector would continue to use fossil fuels instead of reducing their emissions more than there is a possibility to have electrification in place. These proposals are further explained in the attached EBB position paper, which justifies in detail why they are crucial for an effective decarbonization of the EU transport sector.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

21 Apr 2020

The EBB welcomes the opportunity to respond to the EC’s consultation, and to be part of the preparatory process of the ReFuelEU Aviation - Sustainable Aviation Fuels (SAF) initiative, as well as upcoming EC activities designed to gather further stakeholder input. The EBB recognizes the importance and particular difficulties for decarbonisation of the aviation sector. The deployment of SAF across the EU has a key role to play in the long-term efforts towards a climate neutral Europe, and should be supported. Therefore, the EBB supports the development of a single EU-wide policy to design incentive measures for increasing SAF uptake in the EU. At this stage, and while there is no concrete EC proposal to analyse, this EBB response is focused on principles and main elements for the EC to consider while designing its upcoming proposal. Once the EC issues its detailed proposal, the EBB expects to have the opportunity to consider every element carefully, issue a more detailed position and engage in a constructive stakeholder debate. An EU-wide measure for aviation decarbonisation must be effective and complement other existing EU decarbonisation measures in other transport sectors such as road transport, and in particular the reduction of GHG emissions of the Heavy-Duty Vehicles (HDV) sector, which has limited decarbonisation options and should continue being decarbonized. Therefore, when developing a stimulus for SAF, the market impact on feedstock availability should be taken into consideration to ensure there is sufficient feedstock for the aviation sector’s requirements while at the same time ensuring current uses are not drawn away leading to a reversal of decarbonisation in road transport. Considerations in this regard include measures such as: a) The expansion of the pool of feedstock types for aviation (e.g. crop-based, as governed already in transport) and other novel feedstocks); b) The use of other measures that incentivize technological innovation and use of novel high GHG-reducing feedstocks; c) The consideration of a specific obligation for the aviation sector (for example by having a separate blending mandate for aviation). If measures are implemented in the right way, the EBB believes it would trigger companies to invest in SAF technology development and generate additional SAF production volumes. At this stage, the EBB notes the EC’s current intention of only incentivizing the use of non-food and feed feedstocks for the production of SAFs. Unfortunately, this approach is too limiting, and does not reflect the sustainability criteria currently in place at European level in the EU Renewable Energy Directive (RED II). Moreover, it would unreasonably limit the potential for all sustainable feedstocks to contribute to the decarbonization of the aviation sector. In addition, we believe that there is potential for using other wastes & residues available besides those mentioned in the Annex IX of the RED II, which could expand the availability of materials for the production of non-food and feed biofuels. In its roadmap, the EC states that “the availability of waste-based feedstock is currently limited by suboptimal supply chains.” To help in the SAF deployment, it is critical to expand the pool of feedstocks allowed to be accounted for the EU aviation targets, and not restrict it to those included in Annex IX part A. The EBB is fully available to work with the EC to ensure a successful framework for the deployment of SAF in the context of the new baseline scenario of the European Green Deal, and its higher ambition for 2030, and is looking forward to contributing to this debate.
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Response to Revision of the Energy Tax Directive

31 Mar 2020

The EBB welcomes the opportunity to respond to the EC’s consultation, and to be part of the preparatory process leading to the necessary revision of the EU ETD. At this stage, and without having more elements to understand what are the EC’s intentions in this revision, the EBB can already say that it fully supports a revision of the ETD that bring this directive in line with EU climate & energy policy objectives stated in, among others, the Renewables Directive (RED II) and the EU Effort Sharing Regulation (ESR). In particular, a revision of the ETD should adequately promote greenhouse gas (GHG) emission reductions and an increase in the use of all alternative fuels that comply with the sustainability criteria stated in the RED II. Therefore, in the impact assessment currently being prepared, incentives for the use of all sustainable biofuels, such as crop-based biodiesel, biodiesel from wastes and residues and advanced biodiesel ( ), should be taken into consideration. These biofuels are readily available solutions to decarbonize the transport sector, already delivering significant GHG savings, and this revision should consider a fiscal structure that rewards biofuels environmental benefits. Moreover, the possibility for Member States to apply multi-annual detaxation schemes in favour of biofuels production should remain in place. This is an important element to assist the EU in the transition to a low-carbon economy and deliver on the goals of the European Green Deal. The revised ETD should avoid incentivising biofuels only via mandatory targets, which would result in redirecting most of the tax burden to final consumers and not contribute to wider public acceptance of biofuels. The EBB is fully available to work with the EC to ensure a successful revised ETD in the context of the new baseline scenario of the European Green Deal, and its higher ambition for 2030, and is looking forward to contributing to this revision.
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Response to Climate Law

6 Feb 2020

The EBB welcomes the opportunity to respond to this consultation and to take part in this important debate. We have always been a strong advocate of the goals set in the Paris Climate Agreement (COP21), and have been constantly working towards providing the EU with practical solutions to accelerate the decarbonization of the European transport sector. Therefore, the EBB fully supports the goal of a climate neutral EU as early as possible. Achieving this objective is essential to reduce GHG emissions from all sectors of the European economy, keeping a global temperature rise this century well below 2.º C above pre-industrial levels and pursuing efforts to limit the temperature increase even further to 1.5.º C. To facilitate the achievement of the 2050 climate-neutrality objective, the EBB supports the principle of having intermediate targets, as well as having the possibility to amend the Climate Law at a later stage if necessary. These targets should be set (and updated) only after a detailed impact assessment is carried out by the EC. The quality and completeness of this impact assessment will be crucial to the EU to be able to prepare, alongside ambitious and long-term plans for the EU decarbonization and climate neutrality by 2050, a credible plan with concrete actions to translate these ambitions into reality. These abovementioned actions should tackle all sectors of the European economy, in particular the transport sector, the only EU sector where GHG emissions continue to increase every year and could reach close to 45% of all EU economy emissions in 2040-50 ( ). Once the EU sets into law its objective of achieving climate neutrality by 2050 (the latest), any actions taken by the EU should ensure that the transport sector is not left behind and accelerates its decarbonization pace to match the efforts of other economic sectors. With more than 11 million tons of biodiesel produced every year, the EU is the world leader in the production and use of biodiesel and renewable diesel for transport. Conventional biodiesel, as well as waste-based and advanced biodiesel, are the most widely used biofuel in Europe today, and should continue to be part of Europe’s decarbonisation path towards carbon neutrality. Accordingly to the International Energy Agency (IEA), the production of transport biofuels grew by just 4% in 2017 ( ). Therefore, the IEA considers that, to achieve its Sustainable Development Scenario (SDS) 2030 target, use of biofuels needs to triple, driven by cost reductions of advanced biofuels, widespread sustainability governance and more adoption in aviation and marine transport. This reinforce the EBB’s main message that all sustainable biofuels are essential to meet the Paris Agreement goals and a climate neutral EU. Therefore, it is essential that any EU measures targeting transport decarbonization foresee an increase in the biofuel share in the transport energy mix. The European biodiesel industry was born from a political ambition that is still ready to serve: develop an EU-made green fuel to help decarbonizing the European transport sector, improve energy security, protect European jobs ( ), and strengthen the independence and revenue of European farmers. Our industry continues committed to these values, and to continuously improve its performance and to contribute for the EU’s long-term vision to decarbonize the transport sector and achieve carbon neutral Europe by mid-century. The EBB is looking forward to engaging in a productive debate with the European institutions, as well as all relevant stakeholders, to translate the EU’s ambitious climate change goals into constructive and feasible actions that effectively decarbonize the European economy and utilize all available decarbonization tools.
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Response to Import of used cooking oils

23 Jul 2019

Response of the EBB - European Biodiesel Board to the consultation: After analysing the draft text, we are pleased to notice that the Commission has taken on board some of the suggestions previously put forward by the EBB, while nevertheless rejecting others. In particular, we welcome the 2-year transition period proposed by the Commission, which can be a useful tool to give time to the sector to adapt to the revised regulation. Nevertheless, we are concerned with the difficulty that some UCO collectors might have in 3rd countries in adapting to the new rules. In fact, even public authorities in many 3rd countries are missing and/or not able to give the registration numbers needed. This would hinder, not facilitate UCO import from these 3rd countries. To further improve the proposed revised regulation, we would like to put forward some proposals to amend it before its final adoption. See our proposals in the document attached.
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Response to High and low Indirect Land-Use Change (ILUC) - risks biofuels, bioliquids and biomass fuels

28 Feb 2019

Attached you can find the feedback provided by the EBB-European Biodiesel Board. It should be noted that several elements proposed in the draft delegated act are not sufficiently justified due to the lack of a proper impact assessment. A proper impact assessment is needed from the Commission together with the delegated act, since this element is a crucial one to understand what quantities of low ILUC-risk biofuels may be certified in the future. Considering the lack of an impact assessment, at this stage, the EBB cannot provide a fully detailed position. Instead, our position stresses the main principles on which the delegated act should be based on.
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Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and

18 May 2017 · Biodiesel imports / anti-dumping measures

Meeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker)

18 May 2017 · Anti-dumping

Meeting with Miguel Arias Cañete (Commissioner)

21 Oct 2016 · Biofuels