European Oilseed Alliance
EOA
EOA (European Oilseed Alliance) brings together the oilseed organizations of the major European producing countries (Germany, France, United Kingdom, Poland, Czech Republic, Belgium, Sweden) EOA members represents 90 % of EU oilseed production - EOA works in association with the European organizations representing the oilseed supply chain, producers, processors, and seed breeders: Copa-Cogeca, Fediol, EBB, ESA.
ID: 265299815747-31
Lobbying Activity
Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission
27 Jul 2021
The European Oilseed Alliance (EOA) brings together the oilseed producing organizations from the main European countries.
We welcome this opportunity to comment on the European Commission's proposal for an implementing regulation on rules to verify sustainability and greenhouse gas emissions saving criteria and low indirect land-use change-risk criteria.
First of all, we would like to express our concerns regarding the timing of this proposal. The RED II directive came into force on 1 July and all the elements needed for its transposition are not yet known, while the harvest is in progress in the European Union and producers have already marketed all or part of this harvest. It therefore appears necessary to introduce a transitional period for the application of the new rules, particularly with regard to the need to approve all the operators concerned in accordance with the new rules. The rules in place before 1 July should be maintained for some time. If not this means that the harvest sustainable biomass may not be certified.
Our second concern is the evolution of the rules for certifying emission savings from soil carbon accumulation via improved agricultural management. The proposed methodology makes the process of certifying emission savings considerably more cumbersome (sampling protocol for 1 ha) and reduces the interest in improving producers' agroecological practices due to the cost involved. This also raises the question of continuing to value the efforts of producers who are already committed to more sustainable farming practices. We therefore request the coexistence of such a system based on soil analysis with the current methodology based on the IPCC guidelines.
In addition, we would like to point out that the methodology described in the Commission proposal leads to a commitment between the producer and his buyer over a particularly long period (10 years), which does not correspond to the usual agricultural practice of commercial relations but also to the evolution of cultivation practices on the farms. The certification elements required (sustainability, practices) must be sufficient to attest to the reality of emissions savings.
At a time when fighting climate change is becoming increasingly important and in line with the proposals of the "fit for 55" legislative package, it is important that the rules for applying RED II are homogeneous throughout the European Union and do not take away any interest for the producers and the entire renewable energy sector to evolve towards more sustainable and profitable practices.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
17 Dec 2020
EOA supports the final objective of the sustainable finance framework and supports the principle of the EU taxonomy in order to fully deliver on the increased EU climate ambition. However, we wish to point towards legislative contradictions as well as underline the shortcomings of the process leading to the adoption of the draft delegated regulation. The draft text fails to recognise the contribution of sustainable biofuels, made from European oilseeds, to climate change mitigation. Annex I of the text currently excludes sustainable biofuels by concluding that “Food-and feed crops are not used in the activity for the manufacture of biofuels for use in transport”, even when they meet the EU sustainability criteria.
Discriminating between crop-based and advanced biofuels is not justified according to RED II. The phase-out of policy support for crop-based biofuels in transport has been rejected by the co- legislators, first in the ‘ILUC Directive’ 2015/1513 and more recently in RED II. On the contrary, the co- legislators have renewed their support to all sustainable forms of biofuels:
• Sustainable biofuels, both crop-based and advanced ones, can count towards the obligation put on fuel suppliers to provide at least 14% of renewable energy in the transport sector by 2030;
• The contribution of crop-based biofuels shall be no more than one percentage point higher than their 2020 share, with a 7% maximum;
• RED II limits the phase-out of support to high indirect land-use change-risk feedstock for which significant expansion of the production into land with high-carbon stock is observed, as defined in the Commission Delegated Regulation and its annex;
Excluding crop-based biofuels would also go against the findings of the Commission’s Renewable Energy Progress Report, which underlines that these biofuels have significantly contributed to CO2 emission reduction in the transport sector in 2018. The Report, published in 2020, highlights they have enabled almost 46 million tons of emissions savings in 2018 – which represents the annual total emissions of Slovakia. The European Commission itself assumes that an even higher renewable energy share of 24% in transport is required to ensure that the transport sector contributes sufficiently to the 55% GHG saving target of the Green Deal.
It would be inconsistent to have the RED II legislation defining and supporting sustainable biofuels (including crop-based ones) and the sustainable finance policy excluding the same biofuels.
The draft delegated act aims at identifying consistent criteria to demonstrate a substantial contribution to the environmental objectives. The principle should evaluate the technologies in a neutral approach. As far as mobility is concerned, the focus on promoting only tailpipe zero emission vehicles excludes artificially sustainable biofuel solutions. The mobility emission criterion should be based on life cycle analysis.
Sustainability criteria for biofuels are already legally defined in RED II. Given that both RED II and the taxonomy pursue sustainability goals, coherence of the EU legal framework and equal treatment require the taxonomy to duly take into account the RED II. This coherence is both a policy necessity and a legal requirement.
The exclusion of food and feed crops is in total contradiction with the objectives of taxonomy as regards the greenhouse gas emission savings and puts at risk the livelihood of oilseed farmers across the EU.
Read full responseResponse to Revision of the Energy Tax Directive
1 Apr 2020
EOA fully supports the revision of the Energy Taxation Directive, as a key instrument of the transition to cleaner fuels and cleaner transport.
Biofuels are today the more effective way to decarbonize transport. ETD should be elaborated as an incentive to all biofuels as all of them will be needed if we would have a chance to meet the ambitious targets for 2030. In a coherent approach with other European policies, ETD should support european biofuels coproducing high value protein feed.
Read full responseResponse to Climate Law
6 Feb 2020
The ambition of the EU is to become the first climate-neutral economy by 2050. To achieve this ambition, we believe the EU agriculture has a key role to play. Not only are European agricultural products the most sustainable in the world, but they can bring sustainable solutions to reduce emissions and climate impact. The bioeconomy is indeed a major lever for decarbonization, through the development of renewable energy sources based on agricultural biomass. Unlocking the potential of the bioeconomy will enable the EU to take a significant step towards the decarbonisation of transport – the only sector which emissions are still rising today.
Deployment of sustainable biofuels
Biofuels produced from European oilseed crops, such as rapeseed and sunflower, have significant environmental benefits. They are the main renewable energy used in transport and reduce the EU’s dependence on fossil fuels in transport.
In particular, biodiesel represents today around 70-80 % of the renewable energy in transport – and rapeseed biodiesel alone 36%. In fact, the 2019 European Commission’s Renewable Energy Progress Report[1] highlights that the use of biofuels in EU transport saved 33.2 million tonnes of CO2 equivalent in 2016.
Far from a ‘food vs fuel’ debate, the EU biofuels sector contributes greatly to the security of food and feed supply in Europe. Biodiesel made from European oilseeds significantly contributes to the EU protein supply, as for example rapeseed is composed of 60% of protein meal and 40% of vegetable oil.
Today, the EU imports 70% of its protein needs, while there are alternative solutions locally, and especially European oilseeds meals. The increased supply of protein linked to rapeseed biodiesel would help the EU reduce its imports of soybean meal – often genetically modified – from third countries, hence limiting CO2 emissions from imports.
Given the key role of the biodiesel outlet for the co-production of protein, we are looking forward, as part of the Green Deal, to increased ambition in the Renewable Energy Directive. In particular, decarbonising transport should be a priority, by:
Increasing the current 14% target for renewable energy in transport;
Enable a greater contribution of EU sustainable biofuels
This would ensure ambitious environmental goals, promote investments in sustainable alternatives to fossil fuels, while positively contributing to the EU’s food and feed security.
Read full responseMeeting with Peter Wehrheim (Cabinet of Commissioner Phil Hogan), Tom Tynan (Cabinet of Commissioner Phil Hogan)
12 Jun 2018 · Opportunities and challenges of the European oilseed and protein sectors
Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development) and European farmers and European agri-cooperatives
28 Oct 2016 · Biofuels
Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan)
12 Sept 2016 · Business discussion