OpenLobby.EU
Explore

European Producers Union of Renewable Ethanol

ePURE

ePURE represents European renewable ethanol producers to EU institutions and stakeholders.

Lobbying Activity

Ethanol group ePURE urges including crop-based biofuels in Taxonomy

4 Dec 2025
Topic — The European Commission is reviewing rules defining environmentally sustainable financial investments.
Message — ePURE requests the inclusion of all sustainable crop-based biofuels within the EU Taxonomy. They argue for a life-cycle approach to emissions instead of just looking at tailpipes.12
Why — This inclusion would unlock sustainable finance and boost competitiveness for ethanol producers.34
Impact — Producers of advanced biofuels lose their exclusive claim to green investment benefits.5
Read full response

Ethanol producers urge EU to include biomass in Circular Economy Act

6 Nov 2025
Topic — The Circular Economy Act promotes sustainable production, circular models, and the free movement of goods.
Message — The group wants the EU to include biomass and captured carbon in the new circularity rules. They suggest using mandatory targets and tax breaks to promote bio-based fuels and materials.12
Why — Expanding the law’s scope would secure a strategic market for European biorefineries.34
Impact — Fossil fuel suppliers would lose market share as regulations favor renewable carbon sources.56
Read full response

Meeting with François Kalfon (Member of the European Parliament) and Bioéthanol France

16 Oct 2025 · Emissions de CO2 des voitures

ePURE Urges Inclusion of Renewable Ethanol in Car CO2 Standards

7 Oct 2025
Topic — A review of European Union CO2 emission performance standards for new passenger cars and vans.
Message — ePURE calls for a technology-neutral approach that recognizes crop-based ethanol as a carbon-neutral fuel. They request that vehicle emissions be measured on a full life-cycle basis rather than just tailpipe emissions. The organization also proposes a carbon correction factor to account for renewable fuels already in use.123
Why — This would secure the long-term market for European ethanol producers and their agricultural suppliers.45
Impact — The proposal harms the exclusive regulatory push for electric vehicles and their related infrastructure.67
Read full response

Ethanol producers urge technology neutrality for EU 2040 targets

15 Sept 2025
Topic — The EU is amending the Climate Law to establish a 2040 emissions target.
Message — The industry calls for a technology-neutral framework and an end to discrimination against biofuels. They advocate for higher targets to lower carbon intensity and favorable taxation for ethanol. They propose using life-cycle analysis and a carbon correction factor for car emissions.123
Why — This would increase market demand for ethanol and reduce its tax burden.45
Impact — Electric vehicle and synthetic fuel producers would lose their exclusive zero-emission status.67
Read full response

Ethan ol p r o d u c e r s u r g e t e c h n o l o g y n e u t r a l i t y f o r c o r p o r a t e f l e e t s

8 Sept 2025
Topic — Th e C o m m i s s i o n i s p r o p o s i n g m i n i m u m z e r o -e m i s s i o n r e q u i r e m e n t s f o r c o r p o r a t e v e h i c l e f l e e t s.
Message — eP U R E r e q u e s t s t h a t t h e C o m m i s s i o n r e c o g n i z e s C O 2 -n e u t r a l f u e l s a n d r e n e w a b l e b i o f u e l s a l o n g s i d e e l e c t r i c v e h i c l e s. T h e y d e m a n d a t e c h n o l o g y -n e u t r a l f r a m e w o r k t h a t a l l o w s f l e e t o p e r a t o r s t o s e l e c t t h e m o s t s u i t a b l e t e c h n o l o g i e s.12
Why — Th i s w o u l d a l l o w e t h a n o l p r o d u c e r s t o u t i l i z e e x i s t i n g i n f r a s t r u c t u r e a n d i n t e r n a l c o m b u s t i o n e n g i n e s.34
Impact — Ma n d a t o r y e l e c t r i c t a r g e t s c o u l d c a u s e f i n a n c i a l l o s s e s f o r f l e e t o p e r a t o r s a n d r e d u c e m o b i l i t y.56
Read full response

Ethanol group ePURE urges including crop-based biofuels in transport plan

4 Sept 2025
Topic — The Commission is developing a strategic framework for investments in renewable and low-carbon transport fuels.
Message — The organization calls for the rehabilitation of crop-based biofuels in aviation and maritime regulations to ensure technological neutrality. They argue that renewable ethanol should be fully recognized as a key solution for defossilising all transport modes.12
Why — This would unlock industrial investments and protect European producers from unfair competition from abroad.3
Impact — Foreign fuel suppliers and fossil oil importers would lose market share to domestic producers.4
Read full response

ePURE opposes including renewable ethanol in CBAM scope

26 Aug 2025
Topic — The EU is considering extending the Carbon Border Adjustment Mechanism to downstream products.
Message — The association argues that renewable ethanol should be excluded as it is an agricultural product. They suggest the mechanism must first prove effective in existing sectors before any expansion occurs.12
Why — Excluding ethanol allows producers to maintain existing free carbon allowances under the Emissions Trading System.3
Impact — The EU budget loses potential revenue from carbon border taxes on ethanol imports.4
Read full response

Meeting with Valérie Hayer (Member of the European Parliament)

18 Jul 2025 · Biofuels

Ethanol producers urge EU to recognize biomass as strategic asset

23 Jun 2025
Topic — The European Commission is seeking feedback on updating its circular bioeconomy strategy.
Message — ePURE calls on the Commission to recognize renewable ethanol and agricultural biomass as strategic assets. They request market-building policies like tax incentives and binding quotas for bio-based products.12
Why — Strategic recognition would secure investments and protect domestic producers from unfair global competition.3
Impact — Fossil-based industries would lose their competitive edge as policy shifts toward biogenic carbon.4
Read full response

Meeting with Maroš Šefčovič (Commissioner) and

13 Mar 2025 · Negotiations with Ukraine under Article 29 of the Association Agreement (tariff liberalisation) – Position of European agricultural stakeholders (sugar, poultry, eggs, ethanol, maize, wheat and honey)

Response to List of net-zero technology final products and their main specific components

20 Feb 2025

ePURE the association representing European producers of renewable ethanol deplores that not all sustainable renewable RED complaint fuels and biogenic CO2 are part of the scope of the NZIA: The proposal fails to acknowledge the significant scientifically proven contribution of crop-based and advanced biofuels to the swift decarbonization of the transport sector when it should instead be promoting their use. Sustainable crop-based biofuels, such as renewable ethanol, are today the largest and cheapest decarbonization tool in the EU to immediately reduce the EUs reliance on fossil fuels. In addition, they can help to defossilise the economy also beyond fuels (e.g. as biobased chemicals). In 2023, EU renewable ethanol produced by ePURE members achieved 79.1% GHG emissions savings on average compared to fossil petrol. Crop-based biofuels delivering such a GHG emission saving must be included in the definition of net-zero technologies. In the same vein, biogenic CO2 should be taken into account in the list of NZIA technologies and components as it plays a strategic role in decarbonisation of several sectors, incl. biobased chemicals and biobased materials. The European Commissions methodology for selecting sectors and technologies that should be recognized as net-zero or strategic net-zero should be based on track record of GHG emissions savings and carbon capture and replacement, regardless of the sector and be examined as part of an in-depth impact assessment. Advanced biofuels, which are encompassed in the NZIA definition within sustainable alternative fuels should benefit from the recognition and advantages of strategic net-zero technologies as well as components. Including advanced biofuels in the list of strategic net-zero technologies as a standalone product would be a signal to investors and industry players that there is a strong commitment to support the development and deployment of these technologies. This can help attract much-needed investment and accelerate the uptake of advanced biofuels.
Read full response

Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

ePURE the association representing European producers of renewable ethanol deplores that not all sustainable renewable RED complaint fuels and biogenic CO2 are part of the scope of the NZIA: The proposal fails to acknowledge the significant scientifically proven contribution of crop-based and advanced biofuels to the swift decarbonization of the transport sector when it should instead be promoting their use. Sustainable crop-based biofuels, such as renewable ethanol, are today the largest and cheapest decarbonization tool in the EU to immediately reduce the EUs reliance on fossil fuels. In addition, they can help to defossilise the economy also beyond fuels (e.g. as biobased chemicals). In 2023, EU renewable ethanol produced by ePURE members achieved 79.1% GHG emissions savings on average compared to fossil petrol. Crop-based biofuels delivering such a GHG emission saving must be included in the definition of net-zero technologies. In the same vein, biogenic CO2 should be taken into account in the list of NZIA technologies and components as it plays a strategic role in decarbonisation of several sectors, incl. biobased chemicals and biobased materials. The European Commissions methodology for selecting sectors and technologies that should be recognized as net-zero or strategic net-zero should be based on track record of GHG emissions savings and carbon capture and replacement, regardless of the sector and be examined as part of an in-depth impact assessment. Advanced biofuels, which are encompassed in the NZIA definition within sustainable alternative fuels should benefit from the recognition and advantages of strategic net-zero technologies as well as components. Including advanced biofuels in the list of strategic net-zero technologies as a standalone product would be a signal to investors and industry players that there is a strong commitment to support the development and deployment of these technologies. This can help attract much-needed investment and accelerate the uptake of advanced biofuels.
Read full response

Meeting with Christophe Hansen (Commissioner) and

13 Feb 2025 · Review of the EU-Ukraine Deep and Comprehensive Free Trade Area (DCFTA)

Ethanol producers urge delay in EU biofuel database rules

6 Nov 2024
Topic — This consultation seeks to extend fuel traceability to include raw material production data.
Message — The association recommends a phased approach to the Union Database's expansion. They propose postponing new requirements until 2026 and removing rules that force companies to submit identical data to multiple platforms.123
Why — A delay would prevent supply chain blockages and reduce significant administrative costs for biofuel companies.45
Impact — Small companies face high personnel costs while domestic producers lose competitiveness to foreign imports.678
Read full response

Meeting with Julie Rechagneux (Member of the European Parliament)

15 Oct 2024 · Discussion autour des biocarburants

European Ethanol Producers Oppose Extended Ukraine Import Liberalization

30 Sept 2024
Topic — Accelerating mutual elimination of customs duties under the EU-Ukraine Association Agreement.
Message — The association opposes additional prolongation of quota removal for ethanol imports from Ukraine. They argue this would make the EU renewable ethanol industry and farmers more vulnerable, especially as the EU market has shrunk while opening to third-country imports.12
Why — This would protect their market share against rising Ukrainian imports that increased 135% since tariff removal.34
Impact — Ukrainian ethanol producers lose continued duty-free access to the EU market.5
Read full response

Meeting with Bruno Gonçalves (Member of the European Parliament) and European Digital Rights and

9 Sept 2024 · ITRE policies

Response to Count your transport emissions: CountEmissions EU

10 Nov 2023

ePURE, representing the EU producers of sustainable ethanol from crops, waste, and residues and accounting for 85% of the EU renewable ethanol production appreciates the opportunity to input into the Commission consultation on the CountEmissionsEU proposal, specifically highlighting that: The European Commission should ensure that this proposal does not create overlaps or contradictions with existing legislation.We appreciate that the proposed regulation does identify the need for consistency with said legislation, particularly the existing and revised Renewable Energy Directive (RED II). However, the methodology for calculating greenhouse gas emissions from biofuels differs between ISO 14083 and RED II. In fact, the ISO standard lacks the inclusion of emission savings from carbon capture and replacement (eCCR), from carbon capture and storage (eCCS), and from soil carbon accumulation via improved agricultural management (eSCA), which puts ethanol at a disadvantage when compared to the methodology outlined in the RED II, where eCCR, eCCS and eSCA are taken into account. We are therefore concerned that the proposed methodology (the ISO Standard) appears to be in contradiction with existing European legislation (namely the RED II). The European Commission should also further clarify according to which criteria it aims to select eligible sources of default data when compiling the core EU database (Article 6 of the proposed regulation). For instance, we trust that ISO 14083 shall merely be used as a methodological reference and not as a source of default data. The default data on European greenhouse gas (GHG) emissions factors for liquid fuels shown in Table K.1 (Annex K) of ISO 14083 provide values for ethanol (46 % reduction compared to their gasoline reference) that are not consistent with the RED II, and also absolutely not representative of the current European ethanol market, which is highly diversified in terms of feedstocks and implemented technology. Annex V of the RED II differentiates between different types of ethanol based on feedstock, process fuel, and CNP plant vs conventional boiler. The secondary data indicated in the RED II is still very conservative, and European ethanol producers may often achieve much higher GHG emission reduction. In 2022, ePURE members reduced GHG emissions by more than 78% in average compared to fossil fuel, according to audited data. ePURE recommendations: The Europan Commission should clear out all potential sources of ambiguity and inconsistency with existing legislation and ensure that the Central EU database of default greenhouse gas emission factor, that is yet to be created with the assistance the European Environmental Agency, is consistent with RED II Annex V.
Read full response

Ethanol producers urge EU to prioritize biofuels for 2040 targets

23 Jun 2023
Topic — The European Commission is establishing an intermediate 2040 climate target for the EU.
Message — The industry calls for increasing transport fuel carbon intensity targets to 16% and ending multiple counting. They propose a full life-cycle emissions assessment and favorable taxation for all sustainable biofuels.123
Why — A favorable policy framework would secure long-term investments for European renewable ethanol producers.45
Impact — Fossil fuel suppliers and importers would see their dominant market share significantly reduced.6
Read full response

European ethanol producers demand inclusion in Net-Zero Industry Act

23 Jun 2023
Topic — The consultation seeks feedback on legislation to boost Europe's net-zero technology manufacturing capacity.
Message — The group wants sustainable crop-based and advanced biofuels included in the net-zero technology list. They argue the current exclusion discriminates against a cheap and effective tool for decarbonization.12
Why — Inclusion would provide a long-term policy framework that fosters growth and future investment.3
Impact — The European biofuel industry loses competitiveness against American rivals who benefit from more generous incentives.4
Read full response

ePURE demands well-to-wheel accounting for heavy-duty CO2 standards

12 May 2023
Topic — The Commission is reviewing CO2 emission standards for new heavy-duty vehicles.
Message — The organization advocates for a methodology accounting for a vehicle's full environmental footprint. They request incentives for all renewable fuels under the principle of technology openness.12
Why — This preserves the market for renewable ethanol by keeping internal combustion engines viable.3
Impact — Electric vehicle manufacturers lose the regulatory bias currently favoring battery-powered transport solutions.4
Read full response

Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

ePURE feedback to the Commission consultation on Ecodesign for sustainable products About ePURE ePURE the European renewable ethanol association represents EU producers of sustainable ethanol from crops, waste, and residues. Our members operating in 50 plants across the EU and the UK account for 85% of the EU renewable ethanol production and bring direct and indirect jobs and revenues in our economy. European renewable ethanol is produced to strict EU sustainability criteria that protect the environment and has achieved reduced GHG emissions year on year since 2011. Whats more, its ready-made, homegrown solution: renewable ethanol is the most immediate, cost-effective, sustainable and socially inclusive way to meet the EUs 2030 goals to reduce GHG emissions. End uses of renewable ethanol The EU ethanol market can be broadly split into three segments: fuel, potable and industrial. Fuel: In fuel, ethanol is used as an additive in petrol, seen as E5, E10, at the pump; or as an alternative fuel (E85, ED95). E10 is a petrol grade that contains up to 10% ethanol, making it a sustainable way to fuel most internal combustion engine (ICE) and hybrid vehicles on the road today, significantly lowering transport greenhouse gas emissions. Potable: Ethanol can also be used to produce spirit drinks, such as vodka or gin, as a food additive, for the extraction of aromas, for food preservation and the production of white vinegar. Industrial: Ethanol is also used as a renewable chemical component in various products (e.g. sanitizing products, cosmetics, pharmaceuticals, solvents, paints and de-icing fluids), as well as a renewable raw material for bio-based chemical production (e.g. bio-ethylene). Relevance of Ecodesign for sustainable products for ePURE The Commissions recent proposal on Ecodesign for Sustainable Products aims to make products sold in the EU subject to performance and information-related requirements, to ensure greater sustainability. The Commission is proposing to apply ecodesign rules on several new products of possible relevance to ePURE: End-use products: lubricants; paints and varnishes; cosmetic products and Intermediary products: chemicals; plastic and polymers. ePURE wishes to stress that any sustainability criteria on feedstocks and products should be aligned with existing EU legislation to ensure policy coherence, noting that ePURE members produce sustainable renewable products from European feedstocks with full traceability. ePURE remains available to cooperate with the European Commission in the context of preparatory work to identify priority products and horizontal measures under the ESPR.
Read full response

Ethanol Producers Oppose Feedstock Reclassification and Target Adjustments

24 Dec 2022
Topic — The European Commission is updating the list of sustainable biofuel and biogas feedstocks.
Message — ePURE argues the Commission should only add, not remove or requalify, feedstocks from the existing lists. They recommend including alcoholic distillery residues like heads and tails and ending discrimination against sugar beet vinasse. Furthermore, sub-targets for advanced biofuels should be increased to reflect any list extensions.123
Why — This ensures existing investments remain profitable and allows more products to qualify for incentives.4
Impact — The Commission's authority to refine feedstock classifications is challenged by these legal objections.5
Read full response

Response to Revision of the CO2 emission standards for cars and vans

30 Sept 2021

The European Commission’s Fit for 55 package sets important new goals for emissions reduction in transport. Giving a prominent role to renewable liquid fuels would create a solid foundation for reaching them. To that end, the EU should fully maximise the tools it has on hand for decarbonisation and de-fossilisation. Technology neutrality must be at the forefront of this ambitious package and all renewable and sustainable fuels, including electricity, must be able to contribute on the basis of an objective well-to-wheel measurement. ePURE, the association representing the European producers of renewable ethanol from sustainably grown crops, waste, and residues, calls on policy makers to incentivise better fuels in the CO2 standards for cars and vans Regulation: - ePURE opposes the Commission’s decision to increase the CO2 emissions reduction target for new vehicles in 2030 and to set a 100% reduction target by 2035, without changing its method of accounting for emissions. By focusing solely on tailpipe emissions (Tank-To-Wheel), the CO2 standards misleadingly labels battery electric and fuel cell vehicles as ‘zero emission’, distorts competition between powertrain technologies and contradicts the principle of technology neutrality. More importantly, it completely ignores the contribution of renewable fuels and their potential to lower the GHG emissions of existing and new vehicles. - Effectively banning the sales of internal combustion engine vehicles by 2035 simply denies sustainable renewable fuels’ role in road transport decarbonisation despite being already available, cost-effective, and efficient solutions. It promises to make the energy transition even more challenging in countries lacking infrastructure and jeopardises a socially acceptable transition. - The EU should instead 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. - In the meantime, an incentive for the uptake of all sustainable renewable fuels such as European ethanol should be introduced. Attached are our comprehensive views on the overall Fit for 55 package, starting with the Renewable Energy Directive and ensuring other surrounding policies are consistent with each other.
Read full response

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

30 Sept 2021

The Fit for 55 package sets important new goals for emissions reduction in transport. Giving a prominent role to renewable liquid fuels would create a solid foundation for reaching them. The EU should fully maximise the tools it has on hand for decarbonisation and de-fossilisation, starting with the RED. ePURE, the association representing the European producers of renewable ethanol from sustainably grown crops, waste, and residues, calls on policy makers to consider the following key policy recommendations. Increase ambition for renewable energy use in transport - ePURE welcomes the Commission’s proposal to remove the use of multipliers, allowing reporting of progress towards renewable energy targets to be based on real uptake. - Including in the RED an obligation to decrease the carbon intensity of transport fuels is a sensible move forward. However, the suggested obligation should be gradually increased following an indicative trajectory, starting from 6% in 2021 as set in the existing FQD, to at least 11% in 2025 and 16% by 2030, to ensure continuous decarbonisation efforts. - To harness the GHG reduction and air quality benefits of ethanol blends, E10 should become the standard petrol protection grade, paving the way for the introduction of higher-octane petrol such as E20, with an octane rating aiming towards 102 and an oxygen/ethanol content of maximum 8/20% respectively. Promote sustainable crop-based biofuels - Crop-based biofuels are an immediate and the most cost-effective tool to reduce emissions of existing and future vehicles, considering their number and lifespan, and their use should not be limited to hard-to electrify transport modes. - ILUC concerns were fully addressed in 2018 in the RED II delegated act on high ILUC-risk biofuels, which singled out problematic feedstocks and confirmed that European crop-based ethanol does not drive deforestation. - Each Member State should be entitled to set its own contribution of crop-based biofuels towards the renewable energy and GHG intensity reduction targets provided the combined share of crop-based biofuels at EU level does not exceed 7% of the final consumption of energy in the transport sector. Continue the progressive deployment of advanced biofuels - The deployment of advanced biofuels should build on existing legislation and industry, to secure investor confidence. Advanced biofuels are an additional instrument to further reduce fossil fuel use and GHG emissions and must be supported through a dedicated ramping-up sub-target. - ePURE welcomes the removal of double counting, which means an effective increase of the sub-targets for years 2022 and 2030. Such targets must be based on the current Annex IX-A feedstock list on the basis of which investments decisions have been or are being made and come with associated penalties for non-compliance. Any addition of feedstock to the list must be accompanied with increased targets corresponding to the sustainable potential of these feedstocks. Sustainability Criteria - The RED must guarantee the stability of the regulatory framework under which first-move decarbonisation investments were made. Ethanol biorefineries should remain entitled to claim and allocate savings to ethanol for the carbon captured from the fermentation process that replaces fossil CO2. - Removing the possibility to use regional values for cultivation emissions does not make the LCA methodology more accurate; it makes it biased to undermine crop-based biofuels. In addition, this would eliminate any incentive to reduce emissions from cultivation at regional level and will only increase the administrative burden. - RED II provides that all wastes and residues shall be considered to have zero lifecycle GHG emissions up to their collection. This provision shall remain, irrespective of whether the feedstock is listed under Annex IX or not and could be, in theory, used in the food and feed market. Attached are our views on the package and the IA.
Read full response

Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

30 Sept 2021

The European Commission’s Fit for 55 package sets important new goals for emissions reduction in transport. Giving a prominent role to renewable liquid fuels would create a solid foundation for reaching them. To that end, the EU should fully maximise the tools it has on hand for decarbonisation and de-fossilisation. Technology neutrality must be at the forefront of this ambitious package and all renewable and sustainable fuels, including electricity, must be able to contribute on the basis of an objective well-to-wheel measurement. ePURE, the association representing the European producers of renewable ethanol from sustainably grown crops, waste, and residues, calls on policy makers to keep a parallel Emission Trading System for transport: - The main compliance instrument to reduce emissions in transport should remain the Effort Sharing Regulation, which sets national binding targets for Member States with flexibility to achieve said targets. - It is of the utmost importance to ensure the pricing of CO2 for road transport fuels does not depend on the existing emissions trading system. A dedicated, parallel system taking into account the specificities of the transport sector is a safer way to ensure an actual emission reduction occurs, provided measures are taken to limit fuel price increase and social discontent. Consistent with IPCC guidelines, ePURE supports the Commission’s decision to count biofuels and biomass as emission free. Attached are our comprehensive views on the overall Fit for 55 package, starting with the Renewable Energy Directive and ensuring other surrounding policies are consistent with each other.
Read full response

Response to Revision of the Energy Tax Directive

30 Sept 2021

ePURE, the association representing the European producers of renewable ethanol from sustainably grown crops, waste, and residues, appreciates the opportunity to provide feedback on the adoption of the proposal for a revised Energy Taxation Directive. ePURE already called for the revision of the Energy Taxation Directive (ETD) in the past, and more recently expressed support to the Commission’s intention to align the Directive with the EU revamped energy and climate ambitions in view of the 55% emissions reduction target by 2030 and climate neutrality by 2050. In its input into the Commission’s consultation of Oct. 2020, ePURE pointed out to the need to: - move away from volume-based taxation to carbon intensity, in order stop the favourable tax treatment granted to fossil fuels while promoting sustainable low-carbon fuels, and - avoid the discrimination between crop-based and advanced biofuels, as long as they meet the sustainability criteria laid under the Renewable Energy Directive (RED II). A taxation based on energy content would represent already a positive step ahead of the current system based on volume – which de facto favours fossil fuels. However, the Commission’s proposal would fail to achieve the objective of taxing fuels on the basis of their environmental performance and would pursue instead a counterproductive approach putting renewables against each other. More specifically, the Commission’s proposal perpetuates the discrimination against crop-based biofuels, by excluding them from the category of ‘sustainable (non-advanced) biofuels’ and by increasing their minimum taxation level over time as to reach the same as fossil fuels in 2033. The above does not consider that: - All the controversies surrounding European crop-based biofuels, and ethanol in particular, have been debunked, with the adoption of the 2019 delegated Regulation on high ILUC-risk biofuels and its accompanying Report on the status of production expansion of relevant food and feed crops worldwide. More recently, the Commission’s 2020 Renewable Energy Progress Report repeatedly found no correlation between food prices and biofuel demand in the EU, as well as low environmental impacts associated to the production of crop-based biofuels in the Union. - Discriminating against sustainable crop-based biofuels contradicts the current and future EU legislation on renewables. The RED II sets already clear and stringent sustainability criteria, incl. minimum GHG savings performance, for all biofuels to count towards the renewable energy targets, limiting the phase out only to high ILUC-risk biofuels. This approach was kept in the new Commission’s proposal for the revision of the RED II, which largely maintains the existing policy framework on crop-based biofuels. - Sustainable crop-based biofuels are an immediate and cost-effective tool to reduce the EU reliance on fossil fuels and emissions in the transport sector. In 2020, ePURE members’ ethanol saved on average 75.5% GHG emissions compared to fossil petrol, a number that has kept rising since 2011. ePURE therefore calls for essential amendments to the Commission’s proposed revision, which encompass: - The use of a taxation system which better reflects the different renewable fuels’ GHG savings potential compared to fossil fuel; - The inclusion of sustainable crop-based biofuels in the category of ‘sustainable biofuels’, in order to grant them a fixed favourable taxation level compared to fossil fuels, due to their enhanced environmental performance.
Read full response

Response to FuelEU Maritime

30 Sept 2021

The European Commission’s Fit for 55 package sets important new goals for emissions reduction in transport. Giving a prominent role to renewable liquid fuels would create a solid foundation for reaching them. To that end, the EU should fully maximise the tools it has on hand for decarbonisation and de-fossilisation. Technology neutrality must be at the forefront of this ambitious package and all renewable and sustainable fuels, including electricity, must be able to contribute on the basis of an objective well-to-wheel measurement. ePURE, the association representing the European producers of renewable ethanol from sustainably grown crops, waste, and residues, calls on policy makers to ensure sustainable crop-based biofuels contribute to the objectives of ReFuelEU Aviation and FuelEU Maritime - ePURE welcomes the Commission’s proposal to implement dedicated legislations for the decarbonisation of aviation and maritime through sustainable renewable fuels but strongly objects to the ill-founded decision to exclude or penalise biofuels produced from food and feed crops. - The impact assessment underpinning the RefuelEU Aviation proposal failed to assess the use of crop-based ethanol as Sustainable Aviation Fuels and only referred to crop-based biodiesel. Crop-based biofuels are already subject to stringent sustainability criteria and should be allowed to contribute to the sustainable aviation fuel mandates alongside RFNBOs and biofuels made from Annex IX feedstocks. - Both proposed Regulations will result in a strong demand pull of waste-based vegetable oils and animal fats which is already causing supply problems in the vegetable oil market. Setting a mandate for RED II Annex IX-A biofuels would create an incentive to invest in the deployment of advanced biofuels and ease the problems in the vegetable oil market. - Under the methodology set out in the FuelEU Maritime Regulation, crop-based biofuels are arbitrarily and without any scientific foundation considered to emit as much GHG emissions as the least favourable pathway for the fossil fuel they would replace, effectively privileging the use of fossil energy over sustainable renewable fuels. Consistent with the Renewable Energy Directive, the emission factors of all sustainable solutions should be calculated based on the same, technology-neutral methodology. Attached are our comprehensive views on the overall Fit for 55 package, starting with the Renewable Energy Directive and ensuring other surrounding policies are consistent with each other.
Read full response

Response to ReFuelEU Aviation - Sustainable Aviation Fuels

30 Sept 2021

The European Commission’s Fit for 55 package sets important new goals for emissions reduction in transport. Giving a prominent role to renewable liquid fuels would create a solid foundation for reaching them. To that end, the EU should fully maximise the tools it has on hand for decarbonisation and de-fossilisation. Technology neutrality must be at the forefront of this ambitious package and all renewable and sustainable fuels, including electricity, must be able to contribute on the basis of an objective well-to-wheel measurement. ePURE, the association representing the European producers of renewable ethanol from sustainably grown crops, waste, and residues, calls on policy makers to ensure sustainable crop-based biofuels contribute to the objectives of ReFuelEU Aviation and FuelEU Maritime - ePURE welcomes the Commission’s proposal to implement dedicated legislations for the decarbonisation of aviation and maritime through sustainable renewable fuels but strongly objects to the ill-founded decision to exclude or penalise biofuels produced from food and feed crops. - The impact assessment underpinning the RefuelEU Aviation proposal failed to assess the use of crop-based ethanol as Sustainable Aviation Fuels and only referred to crop-based biodiesel. Crop-based biofuels are already subject to stringent sustainability criteria and should be allowed to contribute to the sustainable aviation fuel mandates alongside RFNBOs and biofuels made from Annex IX feedstocks. - Both proposed Regulations will result in a strong demand pull of waste-based vegetable oils and animal fats which is already causing supply problems in the vegetable oil market. Setting a mandate for RED II Annex IX-A biofuels would create an incentive to invest in the deployment of advanced biofuels and ease the problems in the vegetable oil market. - Under the methodology set out in the FuelEU Maritime Regulation, crop-based biofuels are arbitrarily and without any scientific foundation considered to emit as much GHG emissions as the least favourable pathway for the fossil fuel they would replace, effectively privileging the use of fossil energy over sustainable renewable fuels. Consistent with the Renewable Energy Directive, the emission factors of all sustainable solutions should be calculated based on the same, technology-neutral methodology. Attached are our comprehensive views on the overall Fit for 55 package, starting with the Renewable Energy Directive and ensuring other surrounding policies are consistent with each other.
Read full response

Response to Updating the EU Emissions Trading System

30 Sept 2021

The European Commission’s Fit for 55 package sets important new goals for emissions reduction in transport. Giving a prominent role to renewable liquid fuels would create a solid foundation for reaching them. To that end, the EU should fully maximise the tools it has on hand for decarbonisation and de-fossilisation. Technology neutrality must be at the forefront of this ambitious package and all renewable and sustainable fuels, including electricity, must be able to contribute on the basis of an objective well-to-wheel measurement. ePURE, the association representing the European producers of renewable ethanol from sustainably grown crops, waste, and residues, calls on policy makers to keep a parallel Emission Trading System for transport: - The main compliance instrument to reduce emissions in transport should remain the Effort Sharing Regulation, which sets national binding targets for Member States with flexibility to achieve said targets. - It is of the utmost importance to ensure the pricing of CO2 for road transport fuels does not depend on the existing emissions trading system. A dedicated, parallel system taking into account the specificities of the transport sector is a safer way to ensure an actual emission reduction occurs, provided measures are taken to limit fuel price increase and social discontent. Consistent with IPCC guidelines, ePURE supports the Commission’s decision to count biofuels and biomass as emission free. Attached are our comprehensive views on the overall Fit for 55 package, starting with the Renewable Energy Directive and ensuring other surrounding policies are consistent with each other.
Read full response

Response to Revision of Alternative Fuels Infrastructure Directive

30 Sept 2021

The European Commission’s Fit for 55 package sets important new goals for emissions reduction in transport. Giving a prominent role to renewable liquid fuels would create a solid foundation for reaching them. To that end, the EU should fully maximise the tools it has on hand for decarbonisation and de-fossilisation. Technology neutrality must be at the forefront of this ambitious package and all renewable and sustainable fuels, including electricity, must be able to contribute on the basis of an objective well-to-wheel measurement. ePURE, the association representing the European producers of renewable ethanol from sustainably grown crops, waste, and residues, calls on policy makers to ease the deployment of biofuels blends in the Alternative Fuels Infrastructure Regulation - ePURE welcomes the maintaining of renewable fuels including biofuels within the list of alternative fuels and converting the Alternative Fuels Infrastructure Directive into a Regulation setting binding targets. - However, the proposal completely overlooks the contribution of higher biofuel blends that also need dedicated infrastructure. Infrastructure should not be the privilege of new technologies when other fuels are ready to make an immediate and positive change on existing fleets. To harness the GHG reduction potential and air quality benefits of ethanol blended in petrol, Member States should foster access to high ethanol blends such as E85 for compatible engines, and ED95 for buses and trucks. Attached are our comprehensive views on the overall Fit for 55 package, starting with the Renewable Energy Directive and ensuring other surrounding policies are consistent with each other.
Read full response

Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

27 Jul 2021

ePURE, the association representing the European producers of renewable ethanol from crops, waste, and residues, appreciates the opportunity to provide feedback on the draft Implementing Regulation on rules to verify sustainability and greenhouse gas emissions saving criteria and low ILUC-risk criteria. Attached ePURE provides comments on the substance of the draft Regulation, expresses some concerns on the overall approach and lawfulness of some provisions and recommends a transition to the new sustainability framework in the absence of adequate transposition of RED II by Member States.
Read full response

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and The European Steel Association and

7 Jun 2021 · Carbon Border Adjustment Mechanism

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis) and The European Steel Association and

3 May 2021 · Carbon Borden Adjustment Mechanism

Meeting with Helena Hinto (Cabinet of Commissioner Kadri Simson), Laure Chapuis (Cabinet of Commissioner Kadri Simson) and

30 Apr 2021 · To discuss priorities in climate policy and carbon emission reduction in the mobility sector.

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and FuelsEurope and

23 Mar 2021 · Renewable fuels to climate neutrality and economic growth

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

ePURE, representing the European producers of renewable ethanol from crops, waste and residues, and at least 50,000 direct and indirect jobs, supports the final objective of the sustainable finance Regulation: to enable financial flows to support sustainable growth and transition to a carbon neutral economy. We understand and support the principle that the EU taxonomy should not contradict the European Green Deal objectives 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 stakeholders’ consultation process. 1. The draft delegated act would contradict the sustainability criteria that have been agreed in the Renewable Energy Directive II (2018/2001), hereafter ‘RED II’, currently being implemented across Member States. 2. In line with Article 290 TFEU “delegated acts are legally binding acts that enable the Commission to supplement or amend non-essential part of EU legislative acts, for example, in order to define detailed measures…”. However, the exclusion of the crop-based biofuels is a significant legislative change and would override a legislative act e.g. RED II, already adopted via ordinary legislative procedure. We regret that the elaboration process of a piece of legislation on such a crucial and complex matter has been restricted without providing real opportunity for the stakeholders from our sector to be heard and that the joint candidate put forward for the Sustainable Finance Platform by several bioenergy stakeholders was not selected. We therefore believe that it is premature for the delegated act to restrict the scope of eligible biofuels in a way that is more restrictive than RED II. Only ‘high ILUC-risk biofuels’ identified by the Delegated Regulation and its annex, should be illegible and the same sustainability criteria should apply to the eligible ones. This same logic should apply to the eligibility criteria for the manufacture of biogas and biofuels for use in transport (4.13) as well as for organic basic chemicals (3.13) and for the manufacture of plastic in primary form (3.16) in which crops (labelled as ‘food and feed crops’) should be eligible. Please find attached our position for further information.
Read full response

Response to Land use, land use change and forestry – review of EU rules

20 Nov 2020

ePURE, representing the European producers of renewable ethanol from crops, waste and residues, supports the Commission’s proposal to increase the 2030 EU GHG emissions reduction target to 55% compared to 1990, as an intermediate step to reach climate neutrality by 2050. Achieving the higher climate ambition will require actions in all sectors, including the land and bio-economy related ones, and ePURE welcomes the Commission’s intention to align the LULUCF Regulation with that ambition. Indeed, according to the Impact Assessment on Stepping up Europe’s 2030 Climate Ambition, the share of bioenergy in the EU total energy mix will grow from around 10% in 2030 to at least 20% in 2050. This expected increasing role of renewable energy from biomass in the next decades makes it even more important to rely on sustainably sourced bio-based materials, which will help to replace fossil-based ones. EU renewable ethanol falls under that category: it is produced sustainably from crops and agricultural wastes and residues in the EU and, used as a fuel, it can replace fossil petrol in transport, providing more than 72% GHG emissions savings on average. EU renewable ethanol respects the sustainability criteria set by the EU legislation Feedstock used to produce EU ethanol already meets the sustainability requirements of the RED II. In addition, the Commission Delegated Regulation on ILUC certifies EU renewable ethanol as low ILUC-risk. More specifically, crops cultivated for EU ethanol use only a small percentage of EU utilised arable land, not with high carbon stock (e.g. forests, thus not causing deforestation) or with high biodiversity value. Furthermore, EU ethanol production creates both fuel and feed, offsetting the need to import animal feed from countries where deforestation is actually happening. …and does not compete with the EU agri-food sector As highlighted in the Renewable Energy Progress Report for 2020, no correlation has been found between food prices and biofuel demand in the EU in recent years. The Commission also admitted that most Member States report limited cultivation of feedstock used in biofuel production (which, in total, accounts for 3% of EU cropland) compared to total agricultural activities and therefore consider that associated environmental impacts are low. Also, ethanol producers already engage to promote best practices. In addition to capture carbon while converting crops into renewable ethanol, additional savings can be achieved by increasing the yields per area of cultivated land and through improved fertiliser management. But its potential is untapped Biofuels have been the main contributor towards renewable incorporation in the transport sector since the RED inception and their role should be better recognised. The Renewable Energy Progress Report acknowledges that ‘[…] uncertainty about the future policy framework slowed down investments in biofuel production capacity including advanced biofuels’. Crop-based biofuels are an immediate and cost-effective tool to reduce emissions of the existing and future light vehicles, considering their number and lifespan. Their use should not be limited to transport modes that cannot be electrified. Renewable ethanol displaces fossil fuels, contribute to the supply security of animal feed and support the EU agriculture sector. ePURE therefore calls the Commission to send a strong signal and support all low carbon fuels, including biofuels and recognise their role in the decarbonisation process leading the EU to climate neutrality by mid-century.
Read full response

Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

20 Nov 2020

ePURE, representing the European producers of renewable ethanol from crops, waste and residues, supports the Commission’s proposal to increase the 2030 EU GHG emissions reduction target to 55% compared to 1990, as an intermediate step to reach climate neutrality by 2050. Achieving the higher climate ambition will require actions in all sectors, but there is no doubt that this upgraded target will be even harder to reach without a strong effort to decarbonise the transport sector. As highlighted in the European Green Deal, emissions of the transport sector need to be reduced by 90% by 2050 in order to contribute to the overall climate neutrality objective for mid-century. Today, European transport is still 94% reliant on fossil fuels and the EU transport emissions increased by over a quarter since 1990, accounting for 25% of the total GHG emissions in the EU. Road transport makes up more than 70% of that amount, representing 21% of the total EU emissions. In addition, while making up 36% of Effort Sharing emissions, transport is the second least decarbonised Effort Sharing sector, after agriculture, with only 2.5% emissions reduction between 2005 and 2018. ePURE therefore supports the bloc’s increased ambitions, but is concerned by the possible inclusion of road transport in the EU ETS and, consequently, by the policy options presented in the IIAs for the EU ETS and ESR , incl. the phasing out of the ESR or a reduced ESR. In particular, ePURE is concerned by: • The impact of including road transport in the ETS on carbon pricing. A study commissioned by the European Climate Foundation and conducted by Cambridge Econometrics shows that inclusion within the ETS would not lead to significant emissions reductions in road transport unless the carbon allowance price is increased significantly, instead damaging the competitiveness of industry sectors and hurting lower income households by increasing the price of fuels. • The impact of including road transport in the ETS on the EU bioenergy industry, especially biofuels. If carbon pricing was to be reduced, there is the concrete risk that fuel suppliers would prefer purchasing carbon allowances to cover their emissions rather than facilitating the deployment of sustainable low-carbon renewable fuels, such as European renewable ethanol that already saves more than 72% GHG emissions compared to fossil fuel on average. • The transfer of responsibility on buildings and road transport emissions from Member States to the EU. With the expansion of the ETS and LULUCF, the ESR would critically loose its strength; this would transfer the burden for reducing ESR sectors emissions from Member States to the EU, thus also reducing political and legal pressure on national governments to promote green transport policies
Read full response

Response to Updating the EU Emissions Trading System

20 Nov 2020

ePURE, representing the European producers of renewable ethanol from crops, waste and residues, supports the Commission’s proposal to increase the 2030 EU GHG emissions reduction target to 55% compared to 1990, as an intermediate step to reach climate neutrality by 2050. Achieving the higher climate ambition will require actions in all sectors, but there is no doubt that this upgraded target will be even harder to reach without a strong effort to decarbonise the transport sector. As highlighted in the European Green Deal, emissions of the transport sector need to be reduced by 90% by 2050 in order to contribute to the overall climate neutrality objective for mid-century. Today, European transport is still 94% reliant on fossil fuels and the EU transport emissions increased by over a quarter since 1990, accounting for 25% of the total GHG emissions in the EU. Road transport makes up more than 70% of that amount, representing 21% of the total EU emissions. In addition, while making up 36% of Effort Sharing emissions, transport is the second least decarbonised Effort Sharing sector, after agriculture, with only 2.5% emissions reduction between 2005 and 2018. ePURE therefore supports the bloc’s increased ambitions, but is concerned by the possible inclusion of road transport in the EU ETS and, consequently, by the policy options presented in the IIA for the EU ETS and ESR , incl. the phasing out of the ESR or a reduced ESR. In particular, ePURE is concerned by: • The impact of including road transport in the ETS on carbon pricing. A study commissioned by the European Climate Foundation and conducted by Cambridge Econometrics shows that inclusion within the ETS would not lead to significant emissions reductions in road transport unless the carbon allowance price is increased significantly, instead damaging the competitiveness of industry sectors and hurting lower income households by increasing the price of fuels. • The impact of including road transport in the ETS on the EU bioenergy industry, especially biofuels. If carbon pricing was to be reduced, there is the concrete risk that fuel suppliers would prefer purchasing carbon allowances to cover their emissions rather than facilitating the deployment of sustainable low-carbon renewable fuels, such as European renewable ethanol that already saves more than 72% GHG emissions compared to fossil fuel on average. • The transfer of responsibility on buildings and road transport emissions from Member States to the EU. With the expansion of the ETS and LULUCF, the ESR would critically loose its strength; this would transfer the burden for reducing ESR sectors emissions from Member States to the EU, thus also reducing political and legal pressure on national governments to promote green transport policies.
Read full response

Response to Revision of the CO2 emission standards for cars and vans

19 Nov 2020

ePURE would like provide recommendations to make the most out of this upcoming revision. As the process of revising climate and energies policies in line with the increased ambitions set in the Green Deal unfolds, these recommendations aim at incentivising low carbon technologies and reducing reliance on fossil energy in order to swiftly decarbonise new and existing light duty vehicles. Decarbonisation of the transport is lagging behind because of a skewed approach Decarbonising the EU transport sector requires a clear understanding of the shortcomings of existing policies and coherent and realistic policies going forward. The EU transport is currently 94% reliant on oil its emissions have increased by 19% compared to 1990, now accounting for one quarter of EU emissions. Light duty vehicles represent the main contributor in terms of emissions within the transport sector. Instead of supporting the overarching goal of reducing fossil fuel reliance and decarbonising both vehicles and fuels, the current policy focuses on specific technologies using an outdated approach and rationale. • The current CO2 standards for vehicles only consider tailpipe emissions (Tank-To-Wheel). This restrictive approach distorts competition between powertrain technologies and misleadingly labels some technology as low and zero emissions. In addition to being biased and to incorrectly represent the real environmental footprint of powertrain technologies, it contributes to the stacking of incentives for electromobility e.g. multipliers for renewable electricity in the RED, bonus on its GHG impact in the FQD, sales quotas and multipliers in the CO₂ standards. While electromobility will be key to deliver the European Green Deal ambitions, it is now time to allow all low carbon solutions to contribute. • The current CO₂ standards were not designed to deal with different energy carriers, with different renewable energy content. Only accounting for Tank-To-Wheel emissions fails to recognise and therefore incentivise better fuels with lower Well-to-Tank performance and biogenic energy content. This should be corrected, as better fuels provide benefits to new and existing vehicles. While better fuels, such as high-octane petrol, may help to reduce Tank-To-Wheels emissions, there is a significant potential for transport decarbonisation if the contribution of fuels is recognised. • ePURE welcomes that the EC is now considering a system to reward other solutions as well: - The EU should ultimately consider an approach that accounts for the nature of the energy powering vehicles distinguish between fossil and biogenic CO₂ and account for the production and end-of-life emissions of the vehicles. - In the meantime (i.e. by 2030), an incentive for the uptake of renewable/low-carbon energy should be introduced to bridge between separate policies. The concept of having a crediting system could allow fuels suppliers and car manufacturers to synergise which will boost the demand of renewable fuels and the decarbonisation of transport. Biofuels potential is untapped Biofuels have been the main contributor towards renewable incorporation in the transport sector since the RED inception and their role should be better recognised in the decarbonisation of light duty vehicles. The last Renewable Energy Progress Report acknowledges that ‘[…] uncertainty about the future policy framework slowed down investments in biofuel production capacity including advanced biofuels’. Biofuels are an immediate and cost-effective tool to reduce emissions of the existing and future light vehicles, considering their number and lifespan. Their use should not be limited to transport modes that cannot be electrified. Renewable ethanol displaces fossil fuels, contribute to the supply security of animal feed and support the EU agriculture sector. It is now time to send a strong signal and support all low carbon fuels, including biofuels and recognise their role in the decarbonisation of vehicles.
Read full response

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

9 Nov 2020 · ePURE to present key principles and policy measures, essential for an effective decarbonization of the EU transport sector.

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

18 Sept 2020

In response to the RED II revision roadmap, ePURE would like provide recommendations to make the most out of this upcoming revision of the main policy instrument fostering the uptake of renewable energy. This in order to significantly increase renewable energy quantity in Europe, reduce reliance on fossil energy and support the European Green Deal ambitions. As the EU is once again moving towards a new revision of the RED, it is critical that the Commission takes stock of the failures of the approach that has been taken on renewables in transport and crop-based biofuels in particular. The design of RED II puts renewables against each other, pursuing the approach initiated by the ILUC Directive, thereby hindering greater renewable energy incorporation. • It is time to do better: the EU cannot afford to dismiss what has been the nearly sole contributor to renewable energy incorporation in transport. In light of the Green Deal ambitions, it would be wise to reassess the current cap on crop-based biofuels put in place in response to ILUC concerns which have now been fully addressed in the Delegated Act on high ILUC-risk biofuels. The existence of a crop-based biofuel cap simply hinders greater renewable energy incorporation in transport by penalising some high environmentally performing biofuels such as European renewable ethanol. • RED II targets and sub-targets should only be revised upwards, without the possibility to reduce them, as is presently the case through reduced crop-based biofuels cap and the use of artificial multipliers. The target of at least 14% represents an absolute minimum, which may not be sufficient to achieve the ambitions set out in the European Green Deal and the 2030 Climate target plan. • As illustrated by the launch of this process less than 20 months after the adoption of the RED II, the EU renewable energy policy framework has been highly unstable and inconsistent, hindering the development of innovative renewable energy such as Annex IX-A biofuels. This instability has triggered investors certainty and delayed the necessary deployment of renewable energy in transport. These biofuels require a level of support not currently offered by the RED. Low carbon renewable fuels such as ethanol consistently deliver high GHG emissions savings and offset fossil fuels reliance. Keeping fossil fuels in the ground is essential to meet the climate targets for 2030 and to become climate neutral in 2050. Renewable ethanol produced by ePURE members saves more than 72% GHG emissions compared to fossil fuel on average; these savings have increased by more than 20% over the lasts 9 years. More than 99% of the feedstock used by ePURE members to produce renewable ethanol originated in Europe which contributes to sustain farmers revenue, hence preserving Europe’s food security. ePURE members are at the forefront of EU transport decarbonisation, investing to valorise European feedstock: in addition to ethanol, ePURE members are co-producing protein animal feed and capturing biogenic CO2 for further uses. In light the above, ePURE calls on the Commission to consider the attached key policy recommendations.
Read full response

Response to ReFuelEU Aviation - Sustainable Aviation Fuels

16 Apr 2020

ePURE, representing the European producers of renewable ethanol from crops, waste and residues, welcomes the publication of the Inception Impact Assessment (IIA) on the ReFuelEU Aviation initiative and the opportunity to provide feedback. ePURE supports the Commission’s intention to consider legislative options to boost the supply and the demand for Sustainable Aviation Fuels (SAF) in the EU, in order to reduce the aviation sector’s reliance on fossil fuels and enable its contribution to the EU’s climate targets. Discriminating between certified sustainable crop-based and advanced biofuels is not justified according to the EU’s Renewable Energy policy post-2020. As the IIA specifies, the sustainability of feedstock used to produce renewable fuels is already covered by the Renewable Energy Directive 2018/2001 (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. In particular: - 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 already excludes the possibility to count 1.2 times in energy content the share of crop-based biofuels supplied in the aviation sector; - The phase-out of policy support is limited to ‘high-ILUC risk’ biofuels, as defined in the Commission Delegated Regulation on high and low ILUC-risk biofuels (i.e. palm oil biofuels); - Advanced biofuels, defined as those made from Annex IX-A feedstock, are subject to a dedicated ramping-up sub-target, reaching 3.5% of the energy in transport by 2030. It would therefore be inconsistent to have RED II defining and supporting sustainable crop-based biofuels and the SAF Regulation excluding the same biofuels that are supported under RED II. When it comes to the envisaged solutions to foster the uptake of SAFs, ePURE finds the revision/possible increase of the multiplier as counterproductive from a climate perspective. Multiple counting of certain renewable energy perpetuates fossil fuel dependence and does not help reducing aviation GHG’s footprint. Such accounting trick must be eliminated.
Read full response

Response to 2030 Climate Target Plan

14 Apr 2020

ePURE, representing the European producers of renewable ethanol from crops, waste and residues, welcomes the publication of the Inception Impact Assessment (IIA) on a 2030 Climate Target Plan and the opportunity to provide feedback on the initiative. ePURE supports the Commission’s intention to increase the 2030 EU GHG emissions reduction target to 50-55% compared to 1990, as an intermediate step to reach climate neutrality by 2050. This upgraded target will be hard to reach without a strong effort to decarbonise the transport sector. European transport is still 94% reliant on fossil fuels and the EU transport emissions are 19% higher than in 1990, accounting for 25% of the total GHG emissions in the EU. Road transport makes up more than 70% of that amount, accounting for 21% of the total EU emissions. Low carbon energy, including in transport, will therefore play a central role in the transition to a carbon neutral future. In this context, sustainable low carbon fuels incl. renewable ethanol will need to play a more important role to achieve the EU envisaged more ambitious climate targets. In 2018, renewable ethanol produced by ePURE members achieved 71% GHG emissions savings on average compared to fossil petrol, while also improving air quality. ePURE calls for a more effective policy framework for transport fuels decarbonisation, which should include: - Increased ambitions for transport fuels GHG savings and renewable energy use in transport, by, for example, increasing the obligations to lower the carbon intensity of transport fuels set by Art. 7a of the Fuel Quality Directive, increasing Member States’ shares of renewable energy in transport and eliminating the multiple counting of several renewable energy sources; - Ensuring policy continuity, especially with regards to the full respect of both the 2020 and current 2030 renewables and energy efficiency targets. Any revision should not get in the way of Member States’ implementing the already agreed targets. It should not undermine but increase existing targets, incl. for advanced biofuels; - Promoting sustainable crop-based biofuels beyond the current cap, so as to take into account the already adopted delegated act on high-ILUC risk biofuels. European crops do not drive deforestation, and only high-ILUC-risk biofuels must be limited and then progressively phased out. - Continuing the progressive deployment of advanced biofuels through dedicated long-term targets and associated penalties for non-compliance; - Facilitating the deployment of biofuels blend, in particular by rolling out the E10 across the EU and paving the way for high octane petrol and other higher ethanol blends; - Incentivising better fuels by correcting the restrictive tailpipe emissions approach (Tank-To-Wheel) of the current CO2 standards for vehicles. A better way forward would account for the nature of the energy powering vehicles (Well-to-Wheel) as well as the production of end-of-life emissions. In the meantime (i.e. by 2030), an incentive for the uptake of renewable/low-carbon energy should be introduced; - Moving away from a volume-based taxation of energy products. In relation to the Commission’s consideration of extending the scope of the EU ETS to road transport, ePURE supports the introduction of a minimum CO2 pricing of transport fuels that is outside the existing EU ETS.
Read full response

Response to Revision of the Energy Tax Directive

31 Mar 2020

ePURE, representing the European producers of renewable ethanol, welcomes the publication of the Inception Impact Assessment ahead of the revision of the Energy Taxation Directive (ETD). This follows a public consultation in Spring 2018, a Roadmap in Jan. 2019, and the Evaluation in Sept. 2019 where the European Commission found the ETD unfit for purpose. Under the European Green Deal, time has now come to match ambitions with concrete actions. ePURE supports the Commission’s intention to remove harmful fossil fuel subsidies and promote low carbon renewable fuels through the alignment of the ETD with climate and renewable energy policies under the Green Deal. ePURE has already called for a revision of the ETD along the lines of the Commission’s 2011 proposal, which would have provided for a level playing field between fossil and renewable energy sources used as motor fuels. ePURE has already emphasised that the current ETD does not incentivise renewable energies but rather work against the protection of the environment by favouring fossil energy over renewable alternatives. ePURE therefore calls for the revision of the Directive to: - Remove distortions between transport fuels responsible for the EU diesel-petrol imbalance: minimum taxation rates based on energy content should be preferred. o The ETD currently provides that ‘any product […] shall be taxed at the rate for the equivalent motor fuel’. Because of the lower energy density of ethanol compared to petrol, the volume consumption increases over the same distance. Under the existing rules, ethanol used in petrol attracts the same minimum taxation level as petrol despite its numerous benefits, including lower CO2 and air pollutant emissions. On a Euro per gram of CO2 equivalent basis, every gram of CO2 emitted from ethanol is taxed almost five times more than CO2 emitted from petrol. o The current volume-based approach to energy taxation grants favourable tax treatment to diesel over petrol. Taxing energy on the basis of the energy content rather than physical volume would be a technology neutral approach to ensure that all energy sources compete on fairer grounds. Energy products with a higher energy density would continue to benefit from their inherent advantages but without the distortive effect of additional subsidy from taxation. Removing this distortion would lead to a gradual rebalancing of the diesel-petrol market, which is imperative to the EU’s energy independence. - Support Member States in meeting their non-ETS CO2 emission reduction obligation by putting a minimum price on CO2 emissions in the transport sector o Member States could more effectively use energy taxation policies to meet their non-ETS obligations without having to fear competitive disadvantages vis-à-vis other Member States. The introduction of an EU-wide fossil CO2 pricing (e.g. tax on energy, on top of minimum rates), would contribute significantly to reducing transport sector emissions, while being associated with very limited costs or even small economic and employment benefits. o To be effective, the pricing (taxation) of CO2 emissions from road transport fuels should however operate outside the ETS, as is the case for the planned CO2 taxation for transport and buildings in Germany. o To be even more effective from a CO2 saving perspective, the energy taxation of fuels could be completely transformed into a pricing system for fossil CO2 emission (i.e. including the minimum taxation on energy basis mentioned).
Read full response

Response to Enhancing Market transparency in the agri-food chain

6 Jun 2019

ePURE, representing European renewable ethanol producers irrespective of the feedstock or the end use (fuel, industrial or potable applications) welcomes the opportunity to comment on the Commission’s draft Implementing Regulation on Market Transparency. With regard to Article 12, ePURE questions the value of ‘Non-weekly pricing, production and market information notification’ for buying prices for sugar and molasses by ethanol producers (Annex II, Part b). The primary users of sugar juices for transformation into ethanol are often the sugar manufacturers themselves or companies affiliated to them, meaning that, in the first case, there is no buyers’ price for molasses since it is an internal operation, and, in the second case, an internal transfer price is used that does not reflect market prices. As a result, the notification of buyers’ prices for sugar and molasses for transformation into ethanol would not provide relevant information on market prices.
Read full response

Response to Towards the future Generalised Scheme of Preferences legal framework granting trade advantages to developing countries

6 Jun 2019

ePURE, representing the European renewable ethanol industry, irrespective of the feedstock or the end use (fuel, industrial or beverages applications) welcomes the opportunity to comment on the Commission’s Inception Impact Assessment ‘Towards the future Generalised Scheme of Preferences Regulation granting trade advantages to developing countries’. ePURE supports the objective of the GSP of fostering the sustainable economic, social and environmental development of developing countries, with the primary aim of eradicating poverty. However, trade preferences granted through GSP must be conditioned on strict eligibility criteria and these must be carefully checked and stringently applied. Lack of consistent application of GSP eligibility criteria in the case of Pakistan: - ePURE is particularly concerned about the GSP+ status of Pakistan, granting duty free, quota free access to the EU market for ethanol (heading 2207). The European Commission Midterm Evaluation of the EU GSP recognised Pakistan accounted for a significant share of EU ethanol imports, 21% in 2018. - Unfortunately, the lack of consistent application of GSP eligibility criteria means that Pakistan has had little incentive to date to improve the environmental aspects and working conditions in its agricultural sector and in particular of sugarcane growers, the primary feedstock for ethanol production in Pakistan. The European Commission Midterm Evaluation of the EU GSP has already highlighted strong social and environmental concerns with regards to Pakistan’s sugarcane industry in relation to labour rights and working conditions, deforestation, effluent and air emissions, soil quality and greenhouse gas emissions (see enclosed for further details). However, the Commission’s Midterm evaluation has erroneously assumed that Pakistan’s ethanol exports to the EU are for biofuel use. It should be noted that ethanol has many applications other than for biofuels. Renewable ethanol used as biofuel in the EU must adhere to strict sustainability criteria that apply through the entire value chain, from the cultivation of the feedstock to the production and transport of ethanol. The application and enforcement of sustainability criteria contained in the Renewable Energy Directive would prevent the loss of biodiversity and high carbon stock area such as forests resulting from sugarcane cultivation. However, Pakistan’s ethanol producers do not comply with RED sustainability criteria and are not required to do so, since their ethanol exports the EU under the GSP regime are almost exclusively for non-fuel applications. A future GSP should ensure the strict enforcement of GSP eligibility criteria: - Environmental and social concerns are not specific or limited to sugarcane cultivation in Pakistan, but they are a clear indication of a general lack of governance which has to be addressed by additional obligations for GSP beneficiary countries and stricter enforcement of conditionality. - The EU GSP should not result in social and environmental problems in other parts of the world. The agricultural sector in the EU is complying with strict environmental regulations resulting in higher production costs. In order to establish a level playing field and to effectively promote more socially and environmentally sustainable practices in beneficiary countries, a future GSP must ensure that preferential access to the EU market can be effectively withdrawn when there is evidence that beneficiary countries clearly and consistently fail to comply with GSP eligibility requirements.
Read full response

Response to Evaluation of the Alternative Fuels Infrastructure Directive

20 Mar 2019

The AFID was meant to foster the deployment of alternative fuels and reduce the European fossil fuels dependency. Unfortunately, the role of biofuels is overlooked in the Directive, although they represent the vast majority of the renewable and alternative fuels in the European transport. In 2014, at the time of the AFID adoption, biofuels represented 89% of the renewables in the European transport energy mix. According to the latest SHARES figures, their share was still 89% in 2017. The AFID remains mostly dedicated to certain fuels (electricity, natural gas and hydrogen) and fails to fully consider both their GHG footprint and their renewable energy content. Biofuel are listed among the alternative fuels in the Directive but are kept out of its application scope, with the exception of Article 7 concerning the information to consumers on the compatibility of their cars with alternative fuels, which gave light to labelling of biofuels blends, and has been the most successful deliverable to date of the AFID. It is in areas prioritised within its scope, namely the infrastructure for electricity, natural gas and hydrogen, where the AFID has underperformed the most. The AFID impact has so far been limited. As per the Nov. 2017 Communication ‘Towards the broadest use of alternative fuels’, the quality and completeness of Members States NPFs vary greatly, and as a whole, the EU 28 is lagging behind what was and still is projected for 2020-2030. As of 2018, the number of public charging points for EVs was less 150,000 in the EU (including normal and fast charging points). Notwithstanding their uneven geographical distribution, this number can supply less than 1.4 million EVs according to the Commission assumptions included in this Communication. This figure remains far from the conservative benchmark of the AFID Impact Assessment (i.e. 4 million EVs), and marginal compared to the total number of vehicles in the European Union (nearly 300 million motor vehicles in 2017). Based on these figures, the 2025/2030 sales quotas defined in the post-2020 CO2 targets for light and heavy-duty vehicles are extremely ambitious. The Commission should not select the alternatives which should be promoted: apart from lacking technology neutrality, it can be a dangerous bet if they underperform or do not deliver. In principle, the AFID should supports all alternatives fuels, in particular the ones listed under Article 2. Low carbon renewable sources of energy should be adequately promoted in a technology neutral way, in order to support the shift toward a carbon neutral economy, in line with the recently adopted 2050 Strategy, ‘A Clean Planet for All’. The European Union has to move toward more efficient transport vehicles, with lower lifecycle GHG footprint. Combined with the objective of reducing GHG emissions from non-ETS sectors (including transport), it is clear that sustainable biofuels are the most important alternative to fossil fuels and will have an increasingly important role to play. Consequently, they should be properly considered and promoted by the AFID. More specifically for renewable ethanol, the move toward increased vehicles efficiency may foster the need for higher blends in petrol (i.e. E20/25). Additionally, high blends of ethanol are already playing an important role in Europe (ex. with the development of E85 and ED95 in France or Sweden). The future methodological shift toward a full lifecycle approach will reward sustainable biofuels and especially European renewable ethanol (which is on average certified under the Renewable Energy Directive with more than 70% GHG savings vs fossil petrol). The AFID should therefore be amended to better promote biofuels as a credible alternative to fossil fuels.
Read full response

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

7 Mar 2019 · Use of fuel ethanol in Europe

ePURE calls for removal of palm oil smallholder loophole

22 Feb 2019
Topic — EU criteria for biofuels that cause deforestation and high indirect land-use change risk.
Message — The organization demands removing the smallholder exemption and ensuring low-risk certification requires improved practices. They also recommend a more stringent traceability system for all feedstock.12
Why — Removing this loophole protects the reputation and market share of European ethanol producers.3
Impact — Palm oil producers in Indonesia and large crushers would lose access to EU targets.4
Read full response

Response to More efficient law-making in taxation: a move to QMV

14 Jan 2019

Feedback on the Commissions’ roadmap ‘towards a not legislative Communication on more efficient law-making in the field of taxation: identification of areas for a move to qualified majority voting’ ePURE, the association representing European producers of renewable ethanol from conventional and advanced feedstock welcomes the Commission initiative that explores possibilities to make EU law-making in taxation policy more efficient by using qualified majority voting as it would remove the main obstacle in modernising the energy taxation directive. Calculating minimum taxation rates for all energy sources used in transport, including electricity based on a General Energy Consumption tax in combination with a CO2 tax would remove imbalances and distortions that currently hinder the EU from achieving its wider environmental and energy goals. It would: • Remove distortions between transport fuels responsible for the EU diesel-petrol imbalance: The current volume-based approach to energy taxation grants favourable tax treatment to diesel over petrol. Taxing energy on the basis energy content rather than physical volume would be a technology neutral approach to ensure that all energy sources compete on fairer grounds. Energy products with a higher energy density would continue to benefit from their inherent advantages but without the distortive effect of additional subsidy from taxation. Removing this distortion would lead to a gradual rebalancing of the diesel-petrol market, which is imperative for the EU’s energy independence and security. • Remove harmful subsidies favouring fossil energy over low-carbon renewable energy: Ethanol is by far the most taxed source of transport energy despite the numerous benefits associated with blending renewable ethanol in petrol, including lower CO2 emissions and reduced non-CO2 tailpipe emissions. Because of the lower energy density of ethanol compared to petrol, the volume consumption increases over the same distance. A switch from pure hydrocarbon-based petrol E10 could lead to increased fuel consumed in terms of volume up to 3.8%. As a result, the tax burden is higher for clean renewable transport energy than for fossil energy. On a Euro per gram of CO2 equivalent basis, every gram of CO2 emitted from ethanol is taxed almost five times more than CO2 emitted from petrol. At the same time renewable ethanol emits significantly less CO2 per unit of energy than petrol. • Support Member States in meeting their non-ETS CO2 emission reduction obligation: by putting a minimum price on CO2 emissions which are not covered by the EU ETS system, Member States could more effectively use energy taxation policies to meet their non-ETS obligations without having to fear competitive disadvantages vis-à-vis other Member States. Introduction of an EU-wide CO2 tax on energy on top of minimum rates would contribute significantly to reducing non-ETS sector emissions, while being associated with very limited costs or even small economic and employment benefits. • Contribute to improve air quality in cities: An energy content-based approach to taxation, in particular for transport fuels could lead to general environment improvements beyond CO2 reductions. A tax based on energy content coupled with a CO2 element would also be a technology neutral approach to improve air quality by promoting higher blends of renewable ethanol. Ethanol improves efficiency, especially in today’s downsized petrol engines. This boost of efficiency also helps reduce harmful emissions-meaning the more ethanol that is blended with petrol, the greater the benefits. Moreover, ethanol can be used in high-performance fuels, to further reduce emissions and fuel consumption in optimized engines.
Read full response

Response to Stepping up EU Action against Deforestation and Forest Degradation

14 Jan 2019

Feedback on the Commission’s roadmap ‘on stepping up EU Action against Deforestation and Forest Degradation’ ePURE, the association representing European producers of renewable ethanol from conventional and advanced feedstock, welcomes the European Commission’s initiative to step up EU Action against Deforestation and Forest Degradation. European ethanol is produced from European crops, waste and residues, and reduces GHG emissions by 70% on average against fossil fuel. It strengthens food security, with the co-production of high-protein animal feed and provides valuable revenue for European farmers. Within the European biofuels policy debate, ePURE has supported a policy that incentivises greenhouse gas emissions savings and reduces the risk of indirect land use change (ILUC). European renewable ethanol is produced from crops sustainability cultivated in Europe. It is not responsible for displacing traditional production of crops for food and feed on land with high carbon stock. We therefore welcome the EU’s initiative to tackle deforestation and forest degradation at its source. In particular, ePURE would welcome action against peatland drainage, which has been at the root of the controversy surrounding the biofuels policy since it was enacted in 2009 and led to its revision in 2015. The compulsory sustainability criteria attached to biofuels to count towards renewables targets or to be eligible for financial support have been ineffective in halting peatland drainage so far. The co-legislators have therefore agreed in the recast of the Renewable Energy Directive for the period post-2020 to phase out those biofuels with high risk of indirect land use change, via the adoption of a delegated act. To complement this action, we acknowledge the need to introduce a mandatory labelling scheme for palm oil products outside the scope of EU biofuels policy. We support the provisions of the European Parliament’s INI report on palm oil and deforestation and its call to introduce minimum sustainability criteria for all palm oil that enters the EU market. We believe that existing voluntary certification schemes do not effectively prohibit converting rainforests or peatland into palm plantations. Therefore, the sustainability requirements should be used widely across sectors to foster more sustainable supply chains to limit the global deforestation. The importance of traceability of commodities and transparency through all stages of the supply chain will help to ensure protection of peatlands and lands of high carbon stock.
Read full response

Response to Implementing act on a common methodology for alternative fuels unit price comparison

30 Mar 2018

We ask the European Commission to reconsider the proposal for a methodology for alternative fuels unit price comparison: • A consistent fuel price comparison methodology should not rely on the powertrain efficiency of different vehicles. As stated in the German Energy Agency (Dena) final report itself, values from the selected methodology “are derived from the vehicle type approval. Their comparability can be considered extremely problematic as they stem from different vehicles”. Additionally, a comparison of prices per 100 km is misleading as different car brands with different ages have different costs/consumptions per 100 km; • The vehicles sample of Members States would inevitably be biased depending on the vehicles available on their market, creating additional issues in term of the reliability of the comparison; • The reference fuel for type approval of petrol vehicles is E10; consequently, the prices per 100 km of ethanol blends (E5/E10) will be calculated using one fuel consumption figure, making any comparison invalid; • Taxes represent the main component of the retail prices of fuels. Therefore, without information on the level of taxes for each fuel, it is impossible to carry out a proper comparison without misleading the consumers, which is contrary to the objective of the Article 7(3) of the Directive on the deployment of Alternative Fuels Recharging and Refuelling Infrastructure; • In order to carry out a realistic comparison, it would have been preferable to use an unit such as the price per kWh (or another energy unit), completed with information about the energy content of the fuels.
Read full response

Response to Update of the 2012 Bioeconomy Strategy

15 Mar 2018

ePURE welcomes the European Commission’s initiative to update the 2012 Bioeconomy Strategy and opportunity to provide comments. ePURE members process biomass almost exclusively from Europe, including arable crops and residues, in about 50 integrated biorefineries located predominantly in rural areas across 16 EU Member States, into a range of high-value, low-carbon products, including approximately equal volumes of ethanol, animal feed, biogenic CO2 and a smaller volume of other high-value co-products. - Ethanol is used as a renewable low-carbon transport fuel; as a renewable raw material for the bio-based chemical industry; as a direct chemical ingredient in a wide range of consumer products; and as a key ingredient for the food and drinks industry. - Animal feed, including protein meal and gluten meal, reduces the EU’s feed protein deficit and increases the economic and nutritional value of processed feed cereals. - Biogenic CO2, from CO2 captured from the environment during plant growth, released during fermentation and captured through carbon capture at the biorefinery, is commercialised to replace non-renewable CO2 from fossil materials. - Other valuable co-products (e.g. corn oil, vinasse, beet pulp, pulp pellets, fermentation sludge (fertiliser), biomethane, green surplus electricity, etc.) ensure that the entire value of the processed biomass is utilised. Both the Commission Roadmap and Staff Working Document (SWD (2017) 374) rightfully address the twin objective of food security and the sustainable production of biomass for the bioeconomy. ePURE fully supports the overarching objective of the EU Bioeconomy Strategy to ensure that the substitution of non-renewable resources with biological and natural resources is accompanied by a long-term balance of social, environmental and economic gains. European renewable ethanol production, including from arable crops, is a perfect example of a well-functioning, sustainably operating integrated biorefinery concept and a major driver for the transition towards a low-carbon, climate resilient, resource efficient and circular economy. It is a cost-effective, commercially and technologically proven as well as readily available technology that already contributes to the five objectives of the Bioeconomy strategy, (1) by strengthening food security, (2) managing natural resources sustainably, (3) reducing dependence on non-renewable resources, (4) mitigating and adapting to climate change, and (5) creating jobs and maintaining EU competitiveness. There is consequently no justifiable reason to restrict the concept of integrated biorefineries to those exclusively using waste and residues to produce renewable ethanol.
Read full response

Response to Evaluation Energy Taxation Directive

26 Sept 2017

Rebalancing the diesel-petrol market is vital – preferential support for diesel must end: In many ways Europe’s diesel emissions problem is a self-inflicted one. In all EU Member States, except the UK, diesel fuel is taxed less than petrol because of national tax policies guided by Europe’s Energy Taxation Directive. In 33 out of 34 OECD countries diesel is taxed lower than petrol and biodiesel is taxed lower than ethanol (The Diesel Differential: Differences in the Tax Treatment of Gasoline and Diesel for Road Use, OECD (2014)). This preferential tax treatment is also true for diesel vehicles, where in many EU Member States road and car taxes are linked to CO2 emissions. An OECD report concluded that the high environmental and human costs of diesel emissions mean that “there is no public policy case for applying preferential tax treatment to diesel” (The Cost of Air Pollution: Health Impacts of Road Transport, OECD (2014)), a call supported by the WHO (Diesel Engine Exhaust Carcinogenic, WHO (2012)). Rebalancing the diesel-petrol market is imperative if the EU is to achieve its objective of improving urban air quality and climate change mitigation. In light of the COP21, the Commission and Member States must align energy and taxation policy with decarbonisation and air quality goals. It would also fit with the ambitions to remove environmental harmful subsidies. Taxation must support climate friendly fuels, not hinder them: Going forward, transport fuels should be taxed on their energy content and carbon footprint and all preferences for diesel cars and fuel should be removed. A fairer energy taxation system is needed because, based on volume, ethanol is the most taxed transport fuel in Europe despite its GHG saving benefits. With Europe’s dependence on imported diesel increasing – in particular from Russia – a fairer taxation regime would enable Europe to readdress its fuel balance, allowing for further petrol-ethanol penetration and to properly address issues such as air quality, energy security and long-term cost. The current volume-based taxation of motor fuels should be replaced by a combination of a tax based on energy content and on carbon footprint – as proposed by the European Commission in 2012: Such a system would result in an equal treatment of all motor fuels, while promoting those fuels with the lowest carbon footprint. It would put an end to the paradox of clean renewable fuels being taxed at a higher rate than polluting non-renewable fossil fuels. A general energy consumption (GEC) tax, resulting in the same minimum rate per GJ of energy regardless of the energy density of the fuel would have two major beneficial effects on energy security and climate change. It would end incentives driving the dieselisation of personal transportation in the EU. Moreover, it would take into account the lower energy content of renewable fuels and thus end the preferential treatment of more polluting fossil fuels. In combination with a tax based on carbon footprint, such a taxation system would ensure the promotion of carbon neutral fuels in line with the overall climate objectives of the EU. It is the consequent translation of the polluter pays principle that has been so long lacking in the fuel taxation system.
Read full response

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

21 Sept 2017 · Biofuels

Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström)

21 Sept 2017 · FTA negotiations with Mercosur

Meeting with Dominique Ristori (Director-General Energy)

29 May 2017 · European renewable ethanol

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

27 Jun 2016 · role of biofuels in the context of the 2030 energy and climate policy framework

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

14 Jun 2016 · Biofuel

Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström) and Clonbio Group Ltd

27 Apr 2016 · International trade on ethanol

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc), Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

15 Mar 2016 · renewable fuels

Meeting with Dagmara Koska (Cabinet of Vice-President Maroš Šefčovič)

26 Feb 2016 · post-2020 energy and climate framework

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

25 Jan 2016 · Post-2020 energy & climate framework

Meeting with Maria Elena Scoppio (Cabinet of Commissioner Pierre Moscovici)

9 Nov 2015 · classification of ethanol mixtures

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

19 Mar 2015 · Exchange views on ILUC file

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

18 Mar 2015 · The role of biofuels in the decarbonisation of transport

Meeting with Carlos Moedas (Commissioner) and European farmers and

2 Feb 2015 · Meeting with the European Bioeconomy Alliance on the Bioeconomy Strategy