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FuelsEurope

FuelsEurope

FuelsEurope represents the European fuel manufacturing industry in policy debates regarding the energy transition and industrial competitiveness.

Lobbying Activity

Meeting with Florina-Andreea Pantazi (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and International Association of Oil Gas Producers Europe and Concawe

22 Jan 2026 · REACH Universal PFAS Restriction

Meeting with Nicolás González Casares (Member of the European Parliament)

21 Jan 2026 · Automotive Package

Meeting with Jana Nagyová (Member of the European Parliament)

21 Jan 2026 · alternative fuels

Meeting with Jüri Ratas (Member of the European Parliament)

20 Jan 2026 · Automotive Package, Military mobility, The future role of liquid fuels and refining infrastructure

Meeting with Zala Tomašič (Member of the European Parliament)

20 Jan 2026 · The future role of liquid fuels and refining infrastructure

Meeting with Norbert Lins (Member of the European Parliament)

20 Jan 2026 · CO2-Regulation for LDVs

Meeting with Aura Salla (Member of the European Parliament)

20 Jan 2026 · Automotive Package

Meeting with Ondřej Knotek (Member of the European Parliament)

15 Jan 2026 · Energy and Industry Policies

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

11 Dec 2025 · Physical meeting - Discussion on global fuels and products manufacturing for the industrial value chain

Meeting with Radan Kanev (Member of the European Parliament)

9 Dec 2025 · IAA and development of lead markets: Stimulating demand and competitiveness of low-carbon products PANEL

Meeting with Stefan Leiner (Head of Unit Environment) and European Chemical Industry Council and The European Steel Association

8 Dec 2025 · Exchange of views about the implementation of the Industrial Emissions Directive (IED)

FuelsEurope Urges Taxonomy Expansion to CCUS and Biofuels

5 Dec 2025
Topic — This consultation reviews the EU taxonomy to update and simplify technical screening criteria.
Message — The group requests including CCUS, synthetic fuels, and biofuel feedstocks in the framework to reflect practical investment needs. They want to simplify reporting by removing immaterial data requirements and aligning criteria with existing energy laws. Finally, they advocate for a life-cycle approach to vehicle emissions to ensure technological neutrality.123
Why — This would reduce administrative burdens while directing green finance toward the refining sector's projects.45
Impact — Environmental groups favoring electric-only transport lose as green status is extended to combustion fuels.6
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Meeting with Mechthild Woersdoerfer (Deputy Director-General Energy) and

3 Dec 2025 · Implementation of the Methane Regulation 2024/1787 (EUMR)

Meeting with Yannis Maniatis (Member of the European Parliament)

26 Nov 2025 · Presentation of FuelsEurope's Strategic Priorities

Meeting with Angelika Winzig (Member of the European Parliament)

14 Nov 2025 · Meeting with representatives of FuelsEurope

Meeting with Kurt Vandenberghe (Director-General Climate Action)

10 Nov 2025 · Energy transition

Meeting with Kitti Nyitrai (Head of Unit Energy) and International Association of Oil Gas Producers Europe and

3 Nov 2025 · EU Methane regulation import requirements

Meeting with Andreas Glück (Member of the European Parliament)

30 Oct 2025 · Climate and Environment Policy

Meeting with Pascal Canfin (Member of the European Parliament)

29 Oct 2025 · Automotive Package

Meeting with Zala Tomašič (Member of the European Parliament)

22 Oct 2025 · Future of the fuel industry

Meeting with Pilar Del Castillo Vera (Member of the European Parliament)

21 Oct 2025 · Energy policy

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

17 Oct 2025 · Energy Policy

Meeting with Sophia Kircher (Member of the European Parliament)

14 Oct 2025 · Emission targets, AFIR

Meeting with César Luena (Member of the European Parliament)

10 Oct 2025 · Chemicals, ETS, Technological neutrality

FuelsEurope urges tech-neutral state aid for refinery decarbonisation

2 Oct 2025
Topic — EU revision of rules exempting certain state aid from prior approval.
Message — The association wants recognition of renewable fuels, recycled carbon fuels and low-carbon fuels as eligible technologies. They seek higher aid intensities and thresholds for large-scale decarbonisation projects. They also request support for integrated projects combining multiple objectives.123
Why — This would unlock state funding for refinery transformation projects currently excluded from support.45
Impact — Electric vehicle advocates lose as fossil fuel infrastructure receives climate funding.6
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Meeting with Ilhan Kyuchyuk (Member of the European Parliament)

30 Sept 2025 · Omnibus 1 package & simplification efforts

Meeting with Edoardo Turano (Head of Unit Climate Action)

26 Sept 2025 · Study on the biomass supply chains for advanced biofuels

Meeting with Edoardo Turano (Head of Unit Climate Action)

19 Sept 2025 · S&P Study, commissioned by Concawe, on the “Potential evolution of Refining and Liquid Fuels production in Europe”

EU Fuel Industry Opposes Including Indirect Emissions in CBAM

18 Sept 2025
Topic — EU regulation on calculating embedded emissions for the Carbon Border Adjustment Mechanism.
Message — FuelsEurope wants carbon leakage risk from indirect emissions addressed through EU-wide compensation rather than CBAM. They argue indirect costs aren't directly related to indirect emissions, making embedded emission intensity an inaccurate metric for CBAM compliance costs.12
Why — This would avoid complex CBAM compliance requirements and secure a harmonized compensation system.34
Impact — Non-EU competitors lose CBAM protection advantages if indirect emissions remain unaddressed.5
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EU Fuel Industry Urges Commission Handle CBAM Complexity

18 Sept 2025
Topic — Rules for adjusting CBAM certificate obligations to reflect EU ETS free allowances.
Message — FuelsEurope requests that EU authorities handle the complexity of free allocation calculations rather than requiring third-country operators to perform them. They argue the obligation to calculate equivalent free allocation using production data would hinder the mechanism and impose undue burden on non-EU operators.12
Why — This would protect their members from complex compliance requirements when exporting to the EU.3
Impact — EU authorities would face increased administrative burden managing calculations for third-country operators.4
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Meeting with João Cotrim De Figueiredo (Member of the European Parliament)

16 Sept 2025 · Fuels

FuelsEurope urges flexible EU ETS framework for 2040 climate target

15 Sept 2025
Topic — Amending the European Climate Law to include the 2040 climate target.
Message — The organization requests a flexible EU ETS framework allowing all decarbonisation solutions, early integration of international credits beyond the proposed 3% cap, and equal access to compliance options across all sectors. They argue the current framework is too restrictive and delayed.123
Why — This would lower compliance costs and provide regulatory certainty for fuel industry investments.45
Impact — Environmental groups lose stronger emissions reduction commitments through expanded offsetting mechanisms.6
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Meeting with Christophe Grudler (Member of the European Parliament) and RTE Réseau de transport d'électricité

10 Sept 2025 · Politique énergétique européenne

Meeting with Stefan Köhler (Member of the European Parliament)

10 Sept 2025 · Politischer Austausch zum Klimaziel 2040

Meeting with Pascal Arimont (Member of the European Parliament)

9 Sept 2025 · 2040 Climate Target

Meeting with Roberts Zīle (Member of the European Parliament, Rapporteur)

9 Sept 2025 · Military Mobility

Meeting with François Kalfon (Member of the European Parliament, Shadow rapporteur)

9 Sept 2025 · Mobilité militaire

Meeting with Jens Gieseke (Member of the European Parliament) and Amcor

9 Sept 2025 · Austausch zu EU Politik

Fuel industry urges technology-neutral approach to corporate fleet decarbonization

8 Sept 2025
Topic — EU proposal to mandate zero-emission vehicles in corporate fleets to accelerate decarbonization.
Message — FuelsEurope requests recognition of renewable fuels as valid zero-emission options alongside battery-electric vehicles. They want vehicles running exclusively on CO2-neutral fuels treated as zero-emission vehicles. They oppose mandates favoring single technologies and recommend focusing on enabling conditions and fiscal incentives instead.123
Why — This would create demand certainty and underpin the business case for investing in renewable fuel production.45
Impact — Climate advocates lose faster transition as renewable fuels produce lower emissions reductions than full electrification.
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FuelsEurope urges EU-wide compensation for carbon costs

5 Sept 2025
Topic — State aid guidelines for compensating electricity-intensive industries for EU ETS carbon costs.
Message — The organization requests a mandatory, harmonized EU-wide compensation scheme for indirect emission costs. They argue current optional national schemes create market distortions and unequal treatment across member states.12
Why — This would protect refineries from carbon leakage and ensure equal treatment across EU jurisdictions.34
Impact — Member states lose flexibility to design their own compensation schemes or opt out.5
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Meeting with Sophie Wilmès (Member of the European Parliament)

4 Sept 2025 · Energy transition

Meeting with Lukas Mandl (Member of the European Parliament)

2 Sept 2025 · Omnibus-Package I

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra) and Neste Oyj and

1 Sept 2025 · Heavy-duty sector and the role of carbon-neutral fuels

FuelsEurope urges CBAM design fixes before refinery expansion

7 Aug 2025
Topic — Extending the carbon border adjustment mechanism to downstream products and anti-circumvention measures.
Message — FuelsEurope urges the EU to address fundamental flaws in the current CBAM design before extending it to refinery products. They want CBAM to coexist with current carbon leakage protections, which should not be reduced until CBAM effectiveness is demonstrated. An export solution must be included to prevent carbon leakage in international markets.123
Why — This would protect their free emissions allowances and enable them to compete in export markets.45
Impact — Climate advocates lose stronger carbon pricing as refineries maintain exemptions and export advantages.6
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Fuel industry calls for hydrogen grid strategy in EU package

5 Aug 2025
Topic — New EU regulation on upgrading and expanding European electricity and energy grid infrastructure.
Message — FuelsEurope wants a dedicated Hydrogen Grid Strategy embedded in the Grids Package. They seek coordinated planning of hydrogen, gas, electricity and CO2 infrastructures with streamlined permitting and enhanced financing tools.1234
Why — This would secure infrastructure for their hydrogen business and reduce investment risks through public financing.567
Impact — Taxpayers and electricity consumers who would subsidize hydrogen infrastructure for industrial users.89
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Fuel Industry Urges Regulatory Certainty for Maritime Decarbonisation

28 Jul 2025
Topic — EU strategy to strengthen competitiveness and sustainability of Europe's waterborne manufacturing sector.
Message — FuelsEurope requests regulatory certainty to unlock investments in alternative marine fuels, alignment between EU and IMO frameworks, support for cross-sector synergies in fuel production, and strengthened collaboration across the maritime value chain.1234
Why — This would enable profitable business cases for their €650 billion transition investments to 2050.56
Impact — Environmental advocates lose from delayed regulations that would slow maritime emissions reductions.7
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Meeting with Apostolos Tzitzikostas (Commissioner) and

17 Jul 2025 · Implementation Dialogue on ramping up renewable and low-carbon maritime and aviation fuels production in the EU

Meeting with Edoardo Turano (Head of Unit Climate Action)

11 Jul 2025 · Regulatory framework for transport

Meeting with Anna Panagopoulou (Cabinet of Commissioner Apostolos Tzitzikostas), Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas) and

10 Jul 2025 · Exchange of views on e-fuels and monitoring methodology.

FuelsEurope urges ETS redesign to prevent deindustrialization

7 Jul 2025
Topic — Review of EU Emissions Trading System for stationary installations, aviation and maritime.
Message — FuelsEurope requests structural ETS redesign to support industrial competitiveness, halt allowance invalidation in the Market Stability Reserve, maintain upstream carbon accounting for CCU fuels, and implement demand-side measures to create markets for low-carbon products. They argue the current framework fails to provide a viable business case for decarbonization investments and risks driving carbon and investment leakage.1234
Why — This would reduce regulatory costs and protect refineries from carbon leakage pressures.56
Impact — Climate advocates lose faster emission reductions and stronger carbon pricing signals.7
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European Fuel Industry Demands Action Plan for Decarbonisation Support

7 Jul 2025
Topic — EU regulation to accelerate industrial decarbonisation while maintaining competitiveness and productivity.
Message — FuelsEurope demands specific measures supporting fuel manufacturing transition, including reduced regulatory burdens, investment incentives, and recognition as a strategic sector. They call for streamlined permitting, carbon leakage protection, and creation of lead markets for renewable and low-carbon products.123
Why — This would reduce compliance costs and secure investment case for costly decarbonisation technology.456
Impact — Environmental groups lose stricter pollution controls through increased regulatory flexibility for refineries.78
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Meeting with Apostolos Tzitzikostas (Commissioner) and

1 Jul 2025 · Strategic Dialogue on the EU Port Strategy

Meeting with Cynthia Ní Mhurchú (Member of the European Parliament)

24 Jun 2025 · Driving Decarbonisation with Renewable Fuels

Meeting with Heiko Kunst (Head of Unit Climate Action)

18 Jun 2025 · EU-ETS refinery benchmark and update of its value for 2026-2030

Meeting with Stefan Leiner (Head of Unit Environment) and European Chemical Industry Council and The European Steel Association

5 Jun 2025 · Exchange of view about the implementation of the Industrial Emissions Directive (IED)

Meeting with Ana Maria Blass Rico (Acting Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

4 Jun 2025 · Simplification suggestions for CLP and REACH

Meeting with Astrid Van Mierlo (Head of Unit Taxation and Customs Union)

21 May 2025 · Exchange of views on the Carbon Border Adjustment Mechanism (CBAM) and ETD

Meeting with Beatrice Coda (Head of Unit Research and Innovation) and Concawe

16 May 2025 · Transition of Liquid Fuels and Products

Meeting with Tom Berendsen (Member of the European Parliament, Rapporteur)

14 May 2025 · Position of the Dutch and European fuel sector

Meeting with Stella Kaltsouni (Cabinet of Commissioner Dan Jørgensen)

12 May 2025 · Introductory meeting with FuelsEurope

Meeting with Hélder Sousa Silva (Member of the European Parliament)

7 May 2025 · Apresentação do Manifesto da FuelsEurope.

Meeting with Tomáš Zdechovský (Member of the European Parliament)

7 May 2025 · Meeting with FuelsEurope to discuss the role of the fuel industry in supporting EU energy security, decarbonisation, and long-term competitiveness.

Meeting with Aurelijus Veryga (Member of the European Parliament)

7 May 2025 · Energy security and sustainability in the EU fuel sector

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

6 May 2025 · Chemicals regulation: revision of the REACH Regulation; CLP Regulation

Meeting with András Gyürk (Member of the European Parliament)

6 May 2025 · Automotive industry

Meeting with Veronica Manfredi (Director Environment)

24 Apr 2025 · REACH revision and the link to the Commission’s simplification agenda

Meeting with Rihards Kols (Member of the European Parliament)

2 Apr 2025 · Introductory Meeting

Meeting with Anna Panagopoulou (Cabinet of Commissioner Apostolos Tzitzikostas), Helena Hinto (Cabinet of Commissioner Apostolos Tzitzikostas)

1 Apr 2025 · Sustainable Transport Investments Plan, renewable fuels

Meeting with Radan Kanev (Member of the European Parliament)

1 Apr 2025 · Regulation establishing a Commission proposal for a Regulation establishing a common data platform on chemicals

Meeting with Norbert Lins (Member of the European Parliament)

1 Apr 2025 · Austausch zu aktuellen Herausforderungen im Bereich E-Fuels

Meeting with Andrea Wechsler (Member of the European Parliament) and Eni S.p.A. and

1 Apr 2025 · EU energy and industry policy

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

28 Mar 2025 · Key Challenges Sector

Meeting with Kathleen Van Brempt (Member of the European Parliament)

20 Mar 2025 · Carbon emissions in the transport sector

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

20 Mar 2025 · Energy

Meeting with Michał Kobosko (Member of the European Parliament)

20 Mar 2025 · Carbon neutral future

Meeting with Georgiana Teodorescu (Member of the European Parliament)

20 Mar 2025 · Automotive industry

Meeting with Benoit Cassart (Member of the European Parliament)

12 Mar 2025 · E-fuels

Meeting with Olivier Chastel (Member of the European Parliament)

12 Mar 2025 · Politique environnementale de l'Union européenne

Meeting with Elena Nevado Del Campo (Member of the European Parliament)

11 Mar 2025 · Priorities

Meeting with Daniel Attard (Member of the European Parliament)

11 Mar 2025 · Introductory Meeting

Meeting with Borja Giménez Larraz (Member of the European Parliament)

11 Mar 2025 · Priorities for the new EU mandate

Meeting with Andreas Glück (Member of the European Parliament)

11 Mar 2025 · Climate and Environment Policy

Meeting with Paolo Inselvini (Member of the European Parliament)

11 Mar 2025 · Presentation of the association

Meeting with Alexandr Vondra (Member of the European Parliament)

11 Mar 2025 · Action plan for automotive industry

Fuel Industry Seeks Database Integration for Maritime Compliance

7 Mar 2025
Topic — Technical specifications for the FuelEU Maritime database tracking renewable fuel compliance.
Message — FuelsEurope requests clear integration between the Union database and FuelEU database to avoid administrative burden. They want automatic data upload between systems and specific guidance on pooling information disclosure. The organization also seeks access rights for non-company pool managers to increase market flexibility.1234
Why — This would reduce administrative burden and compliance costs for fuel suppliers.56
Impact — Regulators lose some oversight if commercially sensitive compliance data remains hidden.7
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Fuel Industry Seeks Streamlined Water Rules and Funding Support

4 Mar 2025
Topic — EU strategy to ensure water resilience and sustainable management across Europe.
Message — FuelsEurope requests EU funding for water-saving technologies and streamlined regulations to avoid overlapping requirements. They want the Strategy to prevent new rules that duplicate existing Industrial Emissions Directive provisions. They emphasize that water efficiency measures must account for plant-specific conditions and operational differences.123
Why — This would reduce regulatory compliance costs and secure public funding for water-related infrastructure investments.456
Impact — Environmental groups lose stronger water consumption controls and industry-specific efficiency standards.78
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Meeting with Olivia Gippner (Cabinet of Commissioner Wopke Hoekstra)

27 Feb 2025 · The role of fuels in the transition to net zero

Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur)

21 Feb 2025 · Soil Monitoring Law

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

20 Feb 2025

FuelsEurope welcomes the European Commissions proposal to adopt a Delegated Act to identify the sub-categories within net-zero technologies and the list of specific components used for those technologies under Regulation (EU) 2024/1735 (Net-Zero Industry Act). Given the importance of the net-zero technologies identified by the Net-Zero Industry Act to support a clean energy technology scale-up as set out by the Green Deal Industrial Plan, we believe it is important that the Delegated Regulation adopts an exhaustive list of Net-Zero Technologies, to promote both established and emerging technologies. To this end, we propose the attached amendments to the Annex of the draft Delegated Regulation.
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Meeting with Francesco Torselli (Member of the European Parliament)

18 Feb 2025 · Automotive issues

Meeting with Dario Nardella (Member of the European Parliament)

12 Feb 2025 · Priorities in the field of Industry, Research and Energy

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

11 Feb 2025 · Alternative Fuels

Meeting with Yvan Verougstraete (Member of the European Parliament)

11 Feb 2025 · Discussion on the automotive sector

Meeting with Ondřej Krutílek (Member of the European Parliament)

11 Feb 2025 · Clean Industrial Deal for liquid fuels

Meeting with Daniele Polato (Member of the European Parliament)

11 Feb 2025 · Sustainable fuels

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

10 Feb 2025 · Clean Industrial Deal Simplification

Meeting with Elisa Roller (Director Secretariat-General)

7 Feb 2025 · Action Plan for the transition of the industry

Meeting with Andrea Wechsler (Member of the European Parliament) and Verband Deutscher Maschinen- und Anlagenbau e.V. and

4 Feb 2025 · EU Energy and industry policy

Meeting with Bruno Tobback (Member of the European Parliament)

30 Jan 2025 · secure and affordable for all EU citizens and a predictable regulatory framework

Meeting with Nicola Zingaretti (Member of the European Parliament)

28 Jan 2025 · fuels

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and Concawe

28 Jan 2025 · Renewable energy, renewable fuels, biomass, climate

Meeting with Joaquim Nunes De Almeida (Director Internal Market, Industry, Entrepreneurship and SMEs)

24 Jan 2025 · Clean industrial deal and low-carbon fuels

Meeting with Ilhan Kyuchyuk (Member of the European Parliament)

22 Jan 2025 · General presentation of activities and objectives

Meeting with Raffaele Topo (Member of the European Parliament)

22 Jan 2025 · Fuels

Meeting with András Gyürk (Member of the European Parliament)

22 Jan 2025 · Industrial policy, mobility

Meeting with Herbert Dorfmann (Member of the European Parliament)

22 Jan 2025 · New Biofuels

Meeting with Elisabetta Gualmini (Member of the European Parliament) and Eni S.p.A.

21 Jan 2025 · ITRE Committee

Meeting with Stefan Leiner (Head of Unit Environment) and European Chemical Industry Council and The European Steel Association

16 Jan 2025 · Exchange of view about the implementation of the Industrial Emissions Directive (IED)

Fuel Industry Urges Extension of Aviation Fuel Support Mechanism

31 Dec 2024
Topic — EU rules for calculating price differences and allocating ETS allowances for sustainable aviation fuels.
Message — The organization requests extending the support mechanism beyond 2030 to enable long-term investment decisions. They argue the current 20 million allowance budget ending in 2030 cannot bridge the price gap between fossil kerosene and sustainable aviation fuels over the typical 10-15 year asset amortization period. They also seek safeguards against antitrust risks and inclusion of co-processed RFNBO fuels at 95% support levels.1234
Why — This would provide revenue certainty for 10-15 year fuel supply contracts and production facility investments.56
Impact — Taxpayers fund extended subsidies for an industry bridging to commercially viable sustainable fuel production.
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Response to Restriction updating Annex XVII REACH regarding CMRs (2023)

24 Dec 2024

FuelsEurope fully supports the Commission proposal adding a derogation for cumene in REACH Annex XVII Appendix 11 as it will solve the issue for aviation fuel used by private pilots (jetfuel and Avgas) which can contain cumene. To ensure that all types of Avgas are covered, we would like to ask that standard ASTM D6227 Standard Specification for Unleaded Aviation Gasoline Containing a Non-hydrocarbon Component (https://www.astm.org/d6227-18.html) is added to point (b): (b) gasoline used as aviation fuel conforming to DEF STAN 91-090, ASTM D910, ASTM D7547, ASTM D6227, EN 228 or equivalent recognised standards. The proposed derogation is justified as the fuels are used in closed systems and exposure is minimised: a derogation from REACH restrictions 28-29-30 exists for almost all fuels used by the general public. To avoid similar issues in the future we would like to request the addition of two missing fuel uses (aviation fuel and fuels for recreational craft at sea) to the derogation from REACH restrictions 28-29-30 for fuels used by the general public. These fuels are used under similar circumstances as motor fuels covered by Directive 98/70/EC for which there is a derogation. For recreational craft at sea, the fuels are identical to the ones used by recreational craft on inland waterways, for which there is a derogation.
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Meeting with Jens Gieseke (Member of the European Parliament) and eFuel Alliance

26 Nov 2024 · Austausch zu EU Politik

Meeting with Michał Kobosko (Member of the European Parliament)

26 Nov 2024 · EU conventional and renewable fuels

Meeting with Jüri Ratas (Member of the European Parliament)

26 Nov 2024 · European fuel manufacturing industry

Meeting with András Gyürk (Member of the European Parliament)

26 Nov 2024 · Liquid fuels

Meeting with Elena Donazzan (Member of the European Parliament)

26 Nov 2024 · Incontro su tema automotive

Meeting with Radan Kanev (Member of the European Parliament)

26 Nov 2024 · Low carbon liquid fuel and SAF

Meeting with Hildegard Bentele (Member of the European Parliament, Shadow rapporteur)

21 Nov 2024 · Surface water and groundwater pollutants

Fuel Industry Urges Flexibility in EU Traceability Rules

7 Nov 2024
Topic — Extending traceability requirements in the Union Database to raw material production points.
Message — FuelsEurope requests clarification of stakeholder definitions, reconsideration of the three-day transaction reporting rule, and a realistic transition period synchronized with the 2025 compliance cycle. They argue the three-day deadline is operationally impossible and would impose unnecessary administrative burdens.123
Why — This would reduce compliance costs and allow existing operational practices to continue.45
Impact — Fraud prevention efforts lose as weaker traceability rules create more opportunities for misreporting.6
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Meeting with Magda Kopczynska (Director-General Mobility and Transport) and European Chemical Industry Council and

7 Nov 2024 · Ambrosetti Club Europe - Transport and mobility priorities

Fuel industry urges clear rules for low-carbon fuel certification

25 Oct 2024
Topic — EU methodology for assessing greenhouse gas emissions savings from low-carbon fuels.
Message — FuelsEurope requests regulatory certainty for long-term investments, consistent rules across renewable and low-carbon fuels, and clear guidelines for co-processing multiple fuel types. They want unit-specific performance values recognized over default values and protection for first-movers from regulatory changes.1234
Why — This would maximize the load factor of manufacturing assets and reduce the energy transition bill.5
Impact — Environmental groups lose if dated carbon sources remain eligible and gas producers avoid methane reduction efforts.6
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Meeting with Miriam Lexmann (Member of the European Parliament)

23 Oct 2024 · Meeting to discuss current co2 emissons performance targets & transformation of fuel industry

Meeting with Raúl De La Hoz Quintano (Member of the European Parliament) and Vodafone Belgium SA

23 Oct 2024 · Competitiveness

Meeting with Silvia Sardone (Member of the European Parliament, Committee chair)

23 Oct 2024 · ENVI COMMITTEE

Fuel Industry Seeks Limits on Aviation Label Requirements

22 Oct 2024
Topic — EU environmental labelling scheme for estimating flight emissions under ReFuelEU Aviation.
Message — FuelsEurope requests that the scheme not impose additional data requirements on fuel suppliers beyond existing ReFuelEU obligations. They seek alignment with other EU regulations and clarification on implementation details, particularly regarding the flexibility mechanism and batch allocation.123
Why — This would avoid increased administrative burden and compliance costs for fuel suppliers.45
Impact — Consumers lose more detailed transparency on flight emissions from independent verification.
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Meeting with Elena Donazzan (Member of the European Parliament)

22 Oct 2024 · Incontro politiche automotive

Meeting with Stine Bosse (Member of the European Parliament)

22 Oct 2024 · European transportation and industrial policy

Meeting with Andrea Wechsler (Member of the European Parliament) and thyssenkrupp Steel Europe AG and Miele Cie. KG

22 Oct 2024 · EU Energy and Industry Policy

Meeting with András Gyürk (Member of the European Parliament)

19 Sept 2024 · Overview of policy priorities of the European downstream oil sector

Meeting with Ondřej Krutílek (Member of the European Parliament)

19 Sept 2024 · Expected regulatory activity on fuels after the election

Meeting with Andreas Glück (Member of the European Parliament)

18 Sept 2024 · Energy and Climate Policy

Meeting with Daniele Polato (Member of the European Parliament) and UTOPIA LAB S.R.L.

18 Sept 2024 · Meeting

Meeting with Jorge Buxadé Villalba (Member of the European Parliament)

18 Sept 2024 · Environment

Meeting with Roberto Vannacci (Member of the European Parliament)

18 Sept 2024 · Presentazione associazione e priorità del settore

Meeting with Aldo Patriciello (Member of the European Parliament) and Eli Lilly and Company and Acumen Public Affairs

18 Sept 2024 · first general meeting

Meeting with Marco Falcone (Member of the European Parliament)

18 Sept 2024 · Ruolo dell'industria dei carburanti nella transizione ecologica

Meeting with Brando Benifei (Member of the European Parliament)

18 Sept 2024 · European Industry fuels manufactory, Decarbonization, competitiveness of the sector

Fuel industry urges clearer offshore vessel emission rules

3 Sept 2024
Topic — Regulation updating greenhouse gas emission monitoring from offshore ships and sustainable fuels.
Message — FuelsEurope requests clear definitions of offshore vessels, clarified emission reporting requirements, prompt definition of offshore port calls, and consistent low-carbon fuel definitions across EU legislation. They propose implementing a negative list of vessel exemptions and treating 2025 as a transition year for obtaining facility codes.123
Why — This would reduce administrative burden and prevent double counting of emissions for their members.45
Impact — Environmental advocates lose stricter immediate compliance requirements for offshore emission monitoring.6
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Fuel industry urges alignment of low-carbon fuel definitions across EU regulations

26 Jul 2024
Topic — EU ETS regulation update on monitoring and reporting greenhouse gas emissions.
Message — FuelsEurope requests revising the definition of synthetic low-carbon fuels to align with terminology in other EU regulations. They want the MRR definition replaced with the low-carbon fuels definition from the Gas Directive. They also seek greater flexibility in reporting timelines and evidence requirements for sustainable aviation fuels.123
Why — This would simplify compliance by creating consistent definitions across multiple EU regulations.4
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Meeting with Yannis Maniatis (Member of the European Parliament) and European Community Shipowners' Associations

16 Jul 2024 · Introductory Meeting

FuelsEurope urges alignment with global aviation fuel standards

12 Jun 2024
Topic — EU rules for calculating aviation offsetting requirements under CORSIA scheme.
Message — The organization requests alignment of EU's CORSIA eligible fuels definition with ICAO's definition. They also recommend developing an EU-specific Sector's Growth Factor for aviation emissions. They argue this would ensure global consistency and reduce administrative burden.12
Why — This would reduce compliance complexity and costs for their members operating internationally.34
Impact — Environmental standards weaken as EU would adopt less stringent ICAO criteria.5
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean), Pablo Fabregas Martinez (Cabinet of Commissioner Adina Vălean)

15 May 2024 · Climate neutrality

Fuel Industry Seeks Clarity on Maritime Decarbonization Rules

24 Apr 2024
Topic — EU regulation on verification of renewable fuel use in maritime transport.
Message — FuelsEurope requests clarification on documentation requirements for fuel suppliers selling to shipping companies. They want guidance on database interactions and written confirmation that all low-carbon fuels count toward compliance, regardless of where used.123
Why — This would reduce administrative uncertainty and streamline compliance for fuel suppliers.45
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Meeting with Maroš Šefčovič (Executive Vice-President) and

8 Apr 2024 · Dialogue on Clean Mobility

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Transport and Environment (European Federation for Transport and Environment) and

8 Apr 2024 · Energy market

Fuel Industry Seeks Lighter Data Rules for Chemicals Platform

3 Apr 2024
Topic — EU regulation establishing a common data platform for chemicals information.
Message — FuelsEurope requests limiting notification requirements to hazard-relevant studies only, excluding straightforward physico-chemical property tests. They want notifications required only when studies conclude, not during research phases. The duty to notify should apply only to business operators, not contract research organizations.123
Why — This would reduce their administrative burden and compliance costs for chemical testing.45
Impact — Regulators lose earlier visibility into planned chemical safety studies and testing programs.6
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FuelsEurope demands sub-installation rules for EU emissions allocation

21 Dec 2023
Topic — New EU rules for free allocation of carbon emission allowances under ETS.
Message — FuelsEurope requests that climate neutrality plans and efficiency requirements apply at sub-installation level, not installation level. They argue the current approach creates disproportionate penalties when one sub-installation underperforms. They also want commercially sensitive climate plans kept confidential and the hydrogen benchmark definition amended to exclude refinery production.123
Why — This would prevent penalties on efficient operations and protect competitive intelligence from disclosure.45
Impact — Public transparency on refinery climate plans would be reduced, limiting scrutiny of decarbonization commitments.6
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FuelsEurope urges simplified reporting to protect industrial competitiveness

30 Nov 2023
Topic — Commission initiative to reduce corporate reporting requirements by twenty-five percent.
Message — The group requests removing complex digital formats and delaying sustainability standards. They suggest limiting disclosures to the direct supply chain.12
Why — Streamlined requirements would significantly reduce compliance costs and required workforce hours.3
Impact — Environmental groups lose transparency regarding the full impact of industrial activities on ecosystems.4
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Meeting with Maroš Šefčovič (Executive Vice-President) and

30 Nov 2023 · Clean Transition Dialogue on Energy Intensive Industries

Meeting with Mercedes Bresso (Member of the European Parliament)

24 Oct 2023 · HDV CO2

Meeting with Mercedes Bresso (Member of the European Parliament) and Eni S.p.A. and IVECO GROUP N.V.

17 Oct 2023 · HDV CO2

Meeting with Kurt Vandenberghe (Director-General Climate Action)

12 Oct 2023 · Energy transition

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

3 Oct 2023 · Physical meeting - Follow-up on solidarity contribution and also the investment outlook and FuelsEurope industrial strategy in general, thoughts about taxation strategy for the FuelsEurope industry and products

Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur)

13 Sept 2023 · Verkehrs- und Umweltpolitik

Meeting with Mercedes Bresso (Member of the European Parliament)

13 Sept 2023 · HDV CO2

Meeting with Kateřina Konečná (Member of the European Parliament, Shadow rapporteur for opinion)

13 Sept 2023 · CO₂ emission performance standards for new heavy-duty vehicles

Meeting with Sylvia Limmer (Member of the European Parliament, Shadow rapporteur)

13 Sept 2023 · Euro 7

EU Fuel Industry Seeks Climate Plan Rules at Sub-Installation Level

1 Sept 2023
Topic — EU regulation on climate-neutrality plans for free emission allowance allocation under ETS.
Message — FuelsEurope requests that climate neutrality plan obligations apply at sub-installation level rather than installation level. They argue the current approach creates disproportionate treatment where entire installations face penalties if just one sub-unit performs poorly. The organization also wants targets based on measures and investments rather than absolute emission reductions.123
Why — This would limit penalties to only their worst-performing units rather than entire facilities.4
Impact — Climate goals lose as poorly-performing facilities face weaker accountability for overall emissions.5
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Fuel industry seeks simpler emissions tracking for transport fuels

15 Aug 2023
Topic — EU rules for monitoring greenhouse gas emissions under revised Emissions Trading System.
Message — FuelsEurope requests changes to how fuel use is tracked and reported, arguing current proposals don't reflect distribution chain complexity. They want transport losses excluded from reporting and more flexible methods for determining which fuels enter the ETS. They also seek clearer rules on biomethane accounting and sustainable aviation fuel evidence.123
Why — This would reduce their administrative burden and compliance complexity across supply chains.45
Impact — Environmental integrity weakens if ex-post methods allow emissions to escape proper accounting.
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Fuel industry urges broader tech scope in EU manufacturing act

20 Jun 2023
Topic — EU regulation promoting manufacturing of critical net-zero technologies and industrial competitiveness.
Message — FuelsEurope requests extending the strategic technologies list to include all renewable and low-carbon fuel production technologies, not just aviation and shipping fuels. They want carbon capture and usage (CCU) included alongside carbon capture and storage, with incentives rather than mandates to create a functioning CO2 market.1234
Why — This would unlock funding for converting existing refinery assets to low-carbon fuel production.56
Impact — Renewable electricity and battery sectors lose priority status by diluting focus across more technologies.
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Meeting with Izaskun Bilbao Barandica (Member of the European Parliament)

13 Jun 2023 · El transporte comercial por carretera

Meeting with Marco Campomenosi (Member of the European Parliament)

13 Jun 2023 · Meeting with FuelsEurope

Meeting with Marco Campomenosi (Member of the European Parliament)

24 Apr 2023 · STAFF LEVEL on the European Manufacturing Industry

Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur)

19 Apr 2023 · Verkehrspolitik

Meeting with Sylvia Limmer (Member of the European Parliament, Shadow rapporteur)

18 Apr 2023 · Euro 7

Meeting with Bergur Løkke Rasmussen (Member of the European Parliament, Shadow rapporteur)

18 Apr 2023 · Strengthening the CO2 emission performance targets for new heavy-duty vehicles

Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

30 Mar 2023

Petroleum substances are by nature complex substances with thousands to millions of hydrocarbon constituents. They are truly substances of unknown or variable composition, complex reaction products or biological materials (UVCBs). Even though it is generally acknowledged that the exact composition of a UVCB substance cannot be determined, the hazardous properties of petroleum substances can be fully assessed using suitable methods. As identifying and testing every individual constituent is not feasible and as the classical tests and assessment methods (e.g. OECD guideline tests) were written with simple mono- or multi-constituent substances in mind, we often need to adapt these classical tests and assessment methods or derive alternative methods, including non-animal methods. In the attached document, we outline some concerns and comments on the Commission proposal for the revision of the Classification, Labelling and Packaging (CLP) Regulation on the hazard assessment of complex UVCBs (including the use of New Approach Methods (NAMs) and Integrated Approaches to Testing and Assessment (IATAs)), the introduction of the new hazard classes, the grouping of proposals for harmonised classification, the derogations from classification and labelling for bulk chemicals and refill sales and requirements for refill stations and the format of the labels.
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Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion) and BUSINESSEUROPE and

16 Mar 2023 · CMRD6

Response to Review of the CO2 emission standards for heavy-duty vehicles

13 Mar 2023

Please see the attached contribution from FuelsEurope: 1. Joint statement of the EU industry: CO2 regulation for heavy-duty vehicles should recognize decarbonisation potential of sustainable and renewable fuels. 2. Letter to Vice-President Timmermans: Call for preserving essential technology options to move logistics chains.
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Marco Campomenosi (Member of the European Parliament, Shadow rapporteur) and Edison Spa

8 Feb 2023 · on fuel Eu Maritime

Meeting with Sylvia Limmer (Member of the European Parliament, Shadow rapporteur)

1 Feb 2023 · Euro 7

FuelsEurope urges long-term certainty for sustainable biofuel feedstocks

2 Jan 2023
Topic — The EU is reviewing the list of sustainable feedstocks for biofuel and biogas production.
Message — FuelsEurope opposes moving feedstocks from the uncapped Part A list to the capped Part B category to protect investments. They call for increasing or removing Part B caps and clarifying land definitions at the EU level.12
Why — Maintaining stable feedstock categories prevents new regulatory limits from restricting the scale of industrial production.3
Impact — The aviation sector loses if specific sustainable feedstocks are excluded from green fuel targets.4
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

20 Dec 2022 · ETS

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans) and European Association Automotive Suppliers and

20 Dec 2022 · CO2 standards trucks and buses

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and

7 Nov 2022 · Corporate Sustainability Due Diligence

Fuel industry urges UN approval before EU chemical hazard rules

17 Oct 2022
Topic — New EU regulation on chemical classification, labelling and packaging hazard classes.
Message — FuelsEurope demands new hazard classes be discussed at UN-GHS level before EU implementation to avoid diverging from global standards. They request longer transitional periods of 36 months for substances and 48 months for mixtures, citing insufficient guidance and experience with new classifications.12
Why — This would preserve their global competitiveness and reduce compliance burdens from divergent standards.3
Impact — Environmental and health advocates lose faster protection against persistent and toxic chemicals.4
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Meeting with Michal Wiezik (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

11 Oct 2022 · Industrial Emissions Directive

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

30 Sept 2022 · Physical meeting - Impact of the solidarity contribution on the fossil fuel industry

Meeting with Marian-Jean Marinescu (Member of the European Parliament)

13 Sept 2022 · Fit for 55

Meeting with Radan Kanev (Member of the European Parliament, Rapporteur) and European Aluminium AISBL

9 Sept 2022 · IED

Meeting with Marco Campomenosi (Member of the European Parliament)

9 Sept 2022 · STAFF LEVEL Online meeting on the European Manufacturing Industry

Fuel Industry Seeks Protection for Commercially Sensitive Chemical Data

16 Aug 2022
Topic — EU regulation on sharing and accessing chemical safety data across regulatory domains.
Message — FuelsEurope requests protection for commercially sensitive information and intellectual property rights in data sharing systems. They want industry consultation before authorities commission tests, especially for complex petroleum substances. They also seek inclusion in the Expert Working Group implementing the policy.123
Why — This would preserve their competitive position and protect research and development secrets.45
Impact — Public health advocates lose fuller transparency on chemical safety test data.
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FuelsEurope Urges More Flexibility in Biofuel Co-Processing Rules

20 Jul 2022
Topic — This consultation establishes a methodology for determining renewable shares in co-processed transport fuels.
Message — They request freedom for operators to define system boundaries and choose conversion factors. They propose increasing the allowable test deviation from one to six percent. They suggest phasing in radiocarbon testing to allow European laboratory capacity to grow.123
Why — These changes would reduce administrative burdens and lower technical barriers for fuel refineries.4
Impact — Climate monitoring groups lose precision because of the increased margin for error proposed.5
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Meeting with Henrik Hololei (Director-General Mobility and Transport) and Hydrogen Europe and

12 Jul 2022 · Working plan of the alliance

Meeting with Marco Campomenosi (Member of the European Parliament)

5 Jul 2022 · STAFF LEVEL Online meeting on the European Manufacturing Industry

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

23 May 2022 · ETS

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

2 May 2022 · Fit for 55 package ; transition pathway mobility

Meeting with Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski)

6 Apr 2022 · Meeting with the Director General of the European Association representing the refining and fuel industry and FuelsEurope Director

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and ExxonMobil Petroleum Chemical

23 Mar 2022 · Presentation of the CONCAWE study on the integrated assessment of FF55

FuelsEurope Urges Recognition of Low-Carbon Liquid Fuels in HDV Standards

14 Mar 2022
Topic — Revision of CO2 emission performance standards for new heavy-duty vehicles.
Message — FuelsEurope requests that the regulation account for CO2 benefits when renewable and low-carbon liquid fuels replace fossil fuels. They advocate for a fuel crediting system that maintains separation between vehicle and fuel manufacturers while recognizing fuel-based emissions reductions. They emphasize technology neutrality in transport decarbonization.123
Why — This would create market value for their renewable fuel products in heavy-duty transport.45
Impact — Zero-emission vehicle manufacturers face weakened incentives if liquid fuel credits offset emissions.
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Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur)

8 Mar 2022 · Austausch zur EU-Umweltpolitik

Meeting with Marian-Jean Marinescu (Member of the European Parliament)

8 Mar 2022 · Fit for 55

Fuel industry urges flexible waste oil recycling targets

21 Feb 2022
Topic — Review of EU Waste Framework Directive to improve waste management and recycling.
Message — FuelsEurope requests that any waste oil collection and regeneration targets be based on technical feasibility and economic viability. They want flexibility for Member States and assessment of unequal geographical distribution of regeneration facilities. They seek targets that enable production meeting existing ISO standards.123
Why — This would allow them to use waste oils as feedstock for low-carbon fuels without unrealistic quality constraints.45
Impact — Stricter regeneration targets could limit fuel production from waste oils favored by refiners.6
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

18 Feb 2022 · Fit for 55 package; transition pathway energy intensive industry

Meeting with Salvatore De Meo (Member of the European Parliament)

8 Dec 2021 · Biomasse

FuelsEurope demands export protections in EU carbon border mechanism

18 Nov 2021
Topic — EU proposal to place carbon price on imported products to manage carbon leakage risks.
Message — FuelsEurope requests that refining products be included in CBAM only with export protections and without phasing out free emission allowances before thorough impact assessment. They want the mechanism to cover both direct and indirect emissions costs.1234
Why — This would preserve their international competitiveness during industrial transformation and maintain free emission allowances.56
Impact — Climate action loses as delayed phase-out of free allowances weakens carbon pricing incentives.7
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EU Fuel Industry Warns ETS Reform Threatens Competitiveness

8 Nov 2021
Topic — Revision of EU Emissions Trading System to achieve 55% emissions reduction by 2030.
Message — FuelsEurope requests avoiding a cross-sectorial correction factor that would dramatically reduce free allowances by 60% in 2026-2030. They want sustained carbon leakage protection and realistic benchmarks that don't modify existing refining product definitions. They also seek mandatory EU-wide compensation for indirect emission costs.1234
Why — This would prevent refineries from carrying large uncompetitive cost burdens versus non-EU producers.56
Impact — Climate advocates lose stronger carbon pricing pressure on fossil fuel industries.
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Fuel industry urges recognition of liquid fuels in CO2 standards

4 Nov 2021
Topic — EU regulation strengthening CO2 emission standards for new cars and vans.
Message — FuelsEurope wants the regulation to recognize low-carbon liquid fuels as a complementary solution to electrification. They propose a fuel crediting system that would allow car manufacturers to meet CO2 targets by using renewable fuels. They argue the current proposal creates a de facto ban on internal combustion engines regardless of fuel type.123
Why — This would support production at scale of their fuels and create a lead market for technologies they are developing.456
Impact — Climate advocates lose faster fleet decarbonization by extending the life of combustion engines.7
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

11 Oct 2021 · Fit for 55

Meeting with Marian-Jean Marinescu (Member of the European Parliament)

24 Sept 2021 · Decarbonisation of transport

Meeting with Thierry Breton (Commissioner) and

7 Jun 2021 · Pact for skills: re/upskilling needs for a successful green and digital transition in the energy intensive industries ecosystem

Fuel Industry Urges Workability Over New REACH Requirements

1 Jun 2021
Topic — Revision of EU chemical registration and safety rules under REACH Regulation.
Message — The organization requests improved workability rather than additional requirements, particularly for complex petroleum substances. They seek greater regulatory acceptance of alternatives to animal testing and flexible assessment methods for hydrocarbon mixtures. They oppose uniform mixture assessment factors and essential use concepts.123
Why — This would reduce testing costs and preserve flexibility for petroleum product registration.456
Impact — Environmental and health groups lose stronger protections against chemical mixture exposure.7
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Fuel Industry Urges Limited Changes to Chemical Classification Rules

1 Jun 2021
Topic — Revision of EU regulation on classification, labelling and packaging of chemicals.
Message — FuelsEurope requests a targeted revision avoiding far-reaching modifications that diverge from global standards. They seek workable approaches for petroleum substance UVCBs and increased regulatory acceptance of alternatives to animal tests.123
Why — This would avoid costly new testing requirements for complex petroleum products.45
Impact — Health and environmental groups lose more comprehensive hazard information on complex chemicals.6
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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 Thierry Breton (Commissioner) and

24 Mar 2021 · Commissioner Breton meeting with CEOs from Energy Intensive Industries on Industrial strategy & fit for 55.

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and European Association Automotive Suppliers and

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

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and European Association Automotive Suppliers and

1 Mar 2021 · European Green Deal

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

27 Jan 2021 · Renewable and Low-Carbon fuels value chain alliance

Meeting with Eszter Batta (Cabinet of Commissioner Thierry Breton), Joan Canton (Cabinet of Commissioner Thierry Breton) and

14 Dec 2020 · Energy, Industrial strategy, Alliances

Meeting with Adina-Ioana Vălean (Commissioner) and

30 Nov 2020 · The Pathway for the European Refining Industry to Climate Neutrality

Meeting with Kadri Simson (Commissioner) and

27 Nov 2020 · Green deal, FuelsEurope strategy for the transformation of the sector

Fuel industry urges carbon leakage protection before ETS expansion

26 Nov 2020
Topic — Revision of EU Emissions Trading System to achieve 55% emissions reduction by 2030.
Message — FuelsEurope requests stronger carbon leakage protections before any ETS expansion. They support increasing the linear reduction factor but want a separate ETS scheme for road transport. They oppose overlapping regulations that could distort markets.123
Why — This would protect EU refiners from losing market share to non-EU competitors.45
Impact — Climate advocates lose stronger carbon pricing across all sectors simultaneously.6
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FuelsEurope calls for recognition of climate-neutral fuels in regulations

25 Nov 2020
Topic — Revision of CO2 emission performance standards for cars and vans to reach climate goals.
Message — The organization requests that the Commission adopt a technology-neutral approach by allowing renewable fuels to count toward vehicle emission targets. They propose a fuels crediting system for new vehicles to address the current competitive disadvantage against electric mobility.123
Why — This would allow the refining industry to remain relevant and unlock massive investments in liquid fuels.45
Impact — Electric vehicle manufacturers may face increased competition as internal combustion engines remain a viable regulatory option.67
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Response to Protection of workers from risks related to carcinogens

20 Nov 2020

FuelsEurope is the voice of the European petroleum refining industry and represents the interest of 40 companies operating refineries in the EU. Members account for almost 100% of EU petroleum refining capacity; more than 75% of EU motor fuel retail sales and is an essential actor in the chemicals’ supply chain. FuelsEurope supports the Proposal for the fourth amendment to the Carcinogens or Mutagens at Work Directive (CMD, 2004/37/EC) as adopted by the European Commission on 22nd September 2020 . This amendment introduces the revised Occupation Exposure Level (OEL) for benzene aiming at protecting citizens - particularly the workers – exposed to carcinogens. Welcoming the Commission efforts to beat cancer, underlined also by the Commission’s political guidelines , we acknowledge the continuous and long-lasting EU efforts to reduce cancer incidence and the objective of adapting the Occupational Health legislation according to the latest scientific findings. The refining industry supports the revised OEL value of 0.2 ppm for benzene as it is a safe level of exposure that avoids any negative health effects. This level is in line with the conclusions of the research that scrutinised more than 100 publications and studies on workers’ exposure to benzene and health effects and toxicity of benzene. It concluded that 0.25 ppm is the safe level of exposure for both cancer and non-cancer health effects. This has been also confirmed in other research, which proves that no additional effect on genotoxicity and hematologic toxicity is identified if the OEL is set at 0.25 ppm. For the refining industry sector, lowering the benzene OEL from the current level of 1 ppm to the revised value of 0.2 ppm will have a substantial positive impact on worker protection, aligning it with the most ambitious limits already in force in some EU Members States. At the same time, it will require substantial technical modifications and important investments to adapt installations to these highest standards. We welcome the attention for the feasibility in terms of time required for the implementation of the new OEL through the inclusion of a transitional period of 4 years after entry into force of this Directive to allow for the necessary adaptations the installations. To help realising this, the involved sectors are preparing the industry guideline with recommendations for sharing best practices to achieve the revised OEL for benzene. Considering the importance of the health effect, we strongly believe that keeping an approach based on scientific evidence, with a thorough assessment of the technical feasibility and a socio-economic impact assessment is key. To achieve results that are beneficial for both workers and employers, discussions must include all relevant stakeholders. Therefore, we welcome that the Commission retained the tri-partite Advisory Committee on Safety and Health at Work (ACSH) priorities for new or revised scientific evaluations of OELs. Long-standing collaboration in the preparation of the revision of the OELs has been fundamental to achieve an acceptable OEL for both workers and employers. We strongly believe that this approach must perpetuated with involvement of Occupational Safety and Health experts, timely consultation of industry and other stakeholders, and through the existing procedures involving the ACSH, including the WPC. To conclude, we are of the opinion that a predictable and stable regulatory framework is needed to unlock the resources necessary to amongst others implement the revised OEL for benzene, to secure strategic autonomy in the EU for essential chemicals, to reinforce continued innovation, all with as aim to protect EU workers. Please find in the PDF enclosed the reference to the scientific studies published in peer-reviewed journals that were used to support FuelsEurope views.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

FuelsEurope supports the EU Green Deal’s ambition of climate neutrality by 2050 and will work with the EU institutions, Member States, and stakeholders, to help create the essential enabling policy framework. Specifically, the refining industry’s Clean Fuels for All vision indicates how by 2050, liquid fuels for transport could be climate neutral, enabling the decarbonisation of aviation, maritime and road transport. The full deployment of technologies for the production of these low-carbon fuels requires policies providing clear, predictable and strong regulatory signals to investors. With this in mind, FuelsEurope welcomes the possibility to provide input to the IIA on the possible revision of the EED. In performing its impact assessment, FuelsEurope invites the EU Commission (EC) to consider the following points: • A number of technologies that can facilitate important Green Deal objectives and are vital for the COVID-19 recovery- such as battery production, green/blue H2,CCUS, or the production of low- and carbon neutral synthetic fuels - have high energy requirements. In case of a revision of the EED, the EC should endeavour to improve efficient energy use rather than absolute energy reduction, without therein disadvantaging technologies that will be vital for achieving the decarbonisation and greater circularity of the EU economy • We believe it imperative that policy is designed in such a manner that it addresses climate change globally, safeguard the global competiveness of EU industrial sectors, and maintain affordability for consumers • The significant uncertainty associated with the current COVID-19 crisis and its effect on governments, industries, and citizens • FuelsEurope welcomes the fact that the EC commits to taking into account the possible revision of existing policy schemes, such as the RED II, the EU ETS, and ESR in its IIA, which are interlinked with the EED. Beyond this, we also invite the EC to take into account the possible introduction of new policy regimes, such as a carbon border adjustment mechanism, as well as the review of the ETD, which are likely to have knock-on effects throughout the regulatory environment, and hence on the EED itself • If the IIA finds it necessary to revise the EED, we invite the EC to consider the importance of exemptions under Art. 7 of the existing directive so as to avoid regulatory overlap, ease implementation, and provide regulatory certainty to investors. The latter point in particular is important because of the long life-cycle of industrial investments o This extends in particular to the flexibility of Member States to exclude from their calculations energy used in industrial activities listed in Annex I to Directive 2003/87/EC o Similarly, for transport, vehicle efficiency standards, labelling, taxation of road fuels, and measures to improve infrastructure are all used extensively and are more effective means of tackling this complex area compared to the Energy Efficiency Obligation Schemes (EEOS) under the EED Efficient use of energy is vital for EU industry and for the EU refining sector in particular, as on average energy costs make up about 60% of the overall costs to EU refiners. Despite greater product and emissions requirements that necessitate more intensive processing, EU refiners have improved their efficiency by 10% over the past 22 years. Because of this expertise, we believe it essential that the up-coming EED Expert Group includes sufficient representation from industrial stakeholders. FuelsEurope - together with Concawe - is fully available to provide its expertise to the EED Expert Group, as well as collaborate with the consultants conducting the dedicated technical assistance study in support of the IIA. For clarification: Low-carbon fuels are able to reduce CO2 emissions during their production and use (also referred to as “well-to-wake”) compared to conventional, fossil-based fuels.
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Fuel industry seeks exemptions for waste biomass in emissions rules

24 Jul 2020
Topic — Updates to EU ETS greenhouse gas monitoring and reporting rules before 2021.
Message — The industry wants biomass waste fuels to have zero emission factors without meeting full sustainability criteria. They also request recognition of ships, trains, and trucks for CO2 transport, not just pipelines.12
Why — This would allow continued waste fuel use without proving sustainability credentials for each source.3
Impact — Environmental groups lose verification that biomass waste fuels meet sustainability standards.
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Refining Industry Urges Risk-Based Chemical Regulation Over Hazard Focus

19 Jun 2020
Topic — EU strategy to create toxic-free environment and promote safe chemical alternatives.
Message — FuelsEurope wants the strategy to prioritize risk-based rather than hazard-based assessment of chemicals. They call for regulatory stability, reduced administrative burden, and adapted testing methods for complex petroleum substances. They emphasize that regulatory decisions should consider economic trade-offs and competitiveness impacts.1234
Why — This would reduce regulatory restrictions on petroleum products and lower compliance costs.56
Impact — Citizens lose stronger protections from hazardous chemicals in widespread production and use.7
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FuelsEurope welcomes sector-specific poison centre notification rules

9 Jun 2020
Topic — EU regulation on harmonised information requirements for emergency health response and poison centres.
Message — The organization requests the fuel sector solution be made permanent, not temporary. They want technical amendments to broaden fuel definitions and clarify toxicological profile requirements. They express concern about the tight implementation timeline.1234
Why — This allows fuel manufacturers to use simpler safety data sheet information instead of detailed component notifications.56
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EU Refining Industry Urges Recognition of Low-Carbon Liquid Fuels

8 Jun 2020
Topic — EU strategy on linking energy sectors to achieve climate neutrality by 2050.
Message — FuelsEurope requests that low-carbon liquid fuels be recognized as central solutions for decarbonizing hard-to-electrify transport sectors. They advocate for technology-neutral policies and market signals that support investment in alternative fuels and industrial hubs.123
Why — This would preserve their role in transport fuels and position refineries as energy hubs.45
Impact — Battery electric vehicle advocates lose policy focus on direct electrification as primary solution.6
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Fuel industry urges technology-neutral hydrogen strategy including carbon capture

8 Jun 2020
Topic — EU strategy to promote clean hydrogen for decarbonizing the economy by 2050.
Message — FuelsEurope requests that all hydrogen production technologies be considered equally, including Steam Methane Reforming with carbon capture alongside renewable electrolysis. They advocate for refineries as energy hubs within industrial clusters and recognition of low-carbon liquid fuels as decarbonization solutions.123
Why — This would allow them to continue using existing infrastructure and fossil fuel production methods.45
Impact — Climate advocates lose faster transition to truly renewable hydrogen production methods.6
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

5 May 2020 · Decarbonisation of liquid fuels in the context of climate neutrality goals and the European Green Deal

Response to Climate Law

1 May 2020

FuelsEurope supports the Green Deal’s ambition for climate neutrality in 2050 and will work with the EU institutions, Member States, and stakeholders, to help create the essential enabling policy framework. The European refining industry recognises that there is no business as usual and is ready to play a full role by developing alternative fuels with low or zero climate impact (1) , as well as other products, services, and processes needed to achieve the climate neutrality objective. Low-carbon liquids in particular have an unrivalled energy density and are easy to handle, making them an ideal means to carry and store energy, whilst driving the decarbonisation of the transport sector. With the EU Climate Law setting the overall EU ambition level, it is paramount that the associated legislative framework enables the development and deployment at scale of innovative technologies for the mitigation of greenhouse gas (GHG) emissions in all sectors of the economy. To this end, the EU Climate Law takes important steps in the right direction, and we welcome in particular: • its stated aim to provide “predictability and confidence” for investors and other economic operators; • the inclusion of competiveness of the economy, cost-effectiveness and technology neutrality amongst the guiding principles of the regulatory activity; • the pledge that all revised and new regulations are to be based on comprehensive impact assessments. The Green Deal states that “a new pact is needed […]” with “[…] industry working closely with the EU’s institutions […].” Seeing its future in the transformation of its manufacturing processes, products, and services that would create European leadership in low-carbon technologies, FuelsEurope’s members are uniquely positioned to share their expertise, and embrace the opportunity to provide input to the Commission for evaluations, impact assessments, and legislative proposals. Naturally, these impact assessments should follow the better regulation guidelines, and be sufficiently inclusive to allow all relevant stakeholders to participate in the policy dialogue, just as they should consider all available technology pathways, so as to allow the most cost-efficient solution to succeed. Regulatory stability is an important pre-condition for mobilising investment, and minimising the risk profile of low-carbon projects. Hence, we welcome the regulatory predictability that the Climate Law provides. Similarly, we fully recognise the need for the regulatory framework to be inclusive of the latest available science, while also emphasising the importance of carefully impact assessing any change made to the Union’s decarbonisation trajectory, so as to maintain the regulatory predictability of the climate law, which is crucial for mobilising investments at scale. In addition to individual impact assessments, evaluating the cumulative cost and benefit impacts of the Green Deal and ensuring consistency of the legislative framework, will be key. Furthermore, whilst fully supportive of the target of climate neutrality by 2050 as such, we also point towards the discrepancies between national ambition levels. In the absence of globally coherent climate policy, sufficient carbon leakage protection, commensurate with the respective level of climate ambition, will be absolutely vital to ensure the success of the climate law. Similarly, regulatory discrepancies between member states, be that in energy markets or transport, should be avoided to improve market functioning and facilitate the decarbonisation of the EU economy coherently. (1): these are sustainable liquid fuels able to reduce CO2 emissions during their production and use compared to conventional fossil-based fuels
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Fuel industry urges air quality focus over strict emission limits

28 Apr 2020
Topic — New EU emission standards (Euro 7) for cars, vans, lorries and buses.
Message — FuelsEurope wants the Commission to shift from 'zero emissions' to 'zero impact emissions' approach, focusing on actual air quality improvements rather than stricter tailpipe limits. They argue current vehicle turnover already improves air quality without additional standards.12
Why — This would avoid costly new emission controls while maintaining market for liquid fuels.34
Impact — Urban residents lose stronger protections against vehicle pollution in non-compliant cities.
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Response to FuelEU Maritime

24 Apr 2020

FuelsEurope supports the Green Deal’s ambition for climate neutrality in 2050 and will work with the EU institutions, Member States, and stakeholders, to help create the essential enabling policy framework. The European refining industry recognises that there is no business as usual and is ready to play an essential role in supporting this ambition by developing alternative fuels, products and services needed to achieve this demanding objective. Mindful that a supportive policy framework will be indispensable in achieving climate neutrality, and the decarbonisation of shipping, we particularly welcome the opportunity to provide feedback on the IIA of the FuelEU Maritime Initiative. We view the following points raised in the IIA as encouraging first steps in the effort to drive down GHG emissions from shipping: • its stated aim to enhance predictability and facilitate the planning of investments • its stated aim of reducing the price gap between existing technologies and low-carbon alternatives; • the awareness that avoiding carbon leakage (CL) will be critical in designing successful climate policy in the shipping sector Expanding on these aims, FuelsEurope recommends following a holistic approach to the decarbonisation of shipping that is both appreciative of the strong interdependencies between supply infrastructure and fuel production, and considers the full basket of available technologies from energy efficiency measures and innovations in ship design, to the development of alternative and low-carbon fuels (ranging from liquids such as bio- and e-fuels, to LNG, and renewable gases). Allowing for multiple pathways to decarbonisation under the objective of limiting overall societal costs will be essential to enable the most competitive solutions to succeed. As part of this holistic approach, the impact assessment should consider the supply and demand of low carbon technologies across all transport modes. Fostering the use of low-carbon liquids in road transport, for example, given its regulatory environment, price structure and scale, will be critical for providing a business case to mobilise investments and innovation in low-carbon fuels, just as aviation will be an important market. FuelsEurope is convinced that EU leadership in R&D will be indispensable in expanding the range of available technologies, and is strongly supportive of the EU’s stated aim to create a nurturing investment environment that is mindful of the long life-cycle of industrial projects and the aim to de-risk the capital raised by early movers. As is laid out in our Vision 2050, the European refining industry is engaged in a number of pilot projects that can, under the right regulatory conditions, be scaled up to deliver low-carbon liquid fuels, making a critical contribution to the EU’s 2050 climate neutrality objective. Given the nature of the maritime sector, it will particularly vulnerable to CL as Europe develops its decarbonisation agenda. FuelsEurope therefore recommends that solutions are sought at IMO level as much as possible and that maintaining a global competitive playing field, as well as integrating any European solution into a global system, is a central consideration in the policy design framework going forward. Any such framework will need to navigate the complexity of the industry structure of shipping, which will add to the governance challenge when policies are to be enforced. It will be important that inconsistencies or overlaps, be it between IMO and EU, or between different EU regulations, be avoided so as to maintain regulatory certainty and investment stability. FuelsEurope, representing key stakeholders in the marine fuel supply chain, is very much looking forward to contributing to the upcoming public consultation on the decarbonisation of shipping. We remain ready for a more technical consultation with a view to provide any useful inputs and robust data that are needed to conduct the upcoming IIA.
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Fuel Industry Warns Against Climate Rules in Emissions Directive

21 Apr 2020
Topic — Revision of EU directive regulating industrial emissions from factories and plants.
Message — FuelsEurope opposes including greenhouse gas emissions limits in the Industrial Emissions Directive, arguing this would create double regulation alongside the EU emissions trading system. They want the directive to maintain its focus on local pollutants while supporting testing of low-carbon technologies through adapted permitting processes.123
Why — This would prevent additional regulatory compliance costs beyond existing carbon trading obligations.45
Impact — Environmental advocates lose stronger climate protections for industrial greenhouse gas emissions.6
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

20 Apr 2020

FuelsEurope supports the Green Deal’s ambition for climate neutrality in 2050 and will work with the EU institutions, Member States, and stakeholders, to help create the essential enabling policy framework. The Green Deal is clearly work in progress and will require careful societal consultation and impact assessment. FuelsEurope welcomes the opportunity given by the Commission to provide input to the publication of the inception impact assessment on the ReFuel EU aviation sustainable aviation fuels of March 24th, 2020. FuelsEurope’s Vision 2050 shows that several key technologies could potentially be deployed across Europe to deliver low-carbon liquid fuels (including net-zero carbon liquid fuels) bringing benefits both to the climate and to the economy, whilst also making a critical contribution to the EU’s 2050 climate neutrality objective. Key regulatory measures are needed to help the development and deployment of these low-carbon liquid fuels, including sustainable aviation fuels. FuelsEurope is of the opinion that if the EU wants to implement a sustainable aviation fuels policy that, as indicated in the inception impact assessment, this should be based on: - A harmonised implementation by a common policy mechanism to avoid possible market distortions that could be caused by a patchwork of national policies. - A policy mechanism for the uptake of sustainable aviation fuels that is common across all the Member States to allow market players to operate based on equal conditions. We would like to recommend that the evaluation of the EU sustainable aviation fuel policies include consideration of how investors’ risks could be mitigated through robust, stable, sustainability criteria maximising the availability of eligible feedstocks and pathways, and of capital and operating risks. Special attention should be paid to sustainability criteria applied to sustainable aviation fuels. Those should be harmonized with other sectors and legislations like for example the renewable energy directive or the Fuel Quality Directive. The sustainability criteria should be easily applicable to sustainable aviation fuels produced in Europe as well as those imported. We would furthermore highlight the benefit of considering a policy that is able to equalise the cost deferential between fossil and sustainable aviation fuels through any combination of carbon pricing, regulation or taxation. The impact assessment should consider - the supply and demand of low-carbon technologies across transport sectors. Allowing low-carbon liquids to be used in road transport, which has the largest scale, is critical for the business case to make investments in low-carbon liquids, including sustainable aviation fuels, in 2020s-2030s; - ensure predictability for industry and investors to allow them to realize their investments and developments; - the significant uncertainty associated with the current COVID-19 crisis and its expected effect on governments, industries, and citizens alike FuelsEurope, representing some of the main stakeholders in the aviation fuel supply chain, is willing to actively participate in further steps taken in the development of the legislative proposal on the uptake of sustainable aviation fuels under the ReFuel EU aviation initiative.
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Meeting with Thierry Breton (Commissioner) and

20 Apr 2020 · COVID 19 economic impact on Energy intensive industries

Fuel Industry Urges Recognition of Low-Carbon Liquid Fuels

15 Apr 2020
Topic — EU plan to increase 2030 greenhouse gas emission reduction targets.
Message — FuelsEurope requests recognition of low-carbon liquid fuels in transport sector CO2 standards using a well-to-wheel approach. They call for carbon leakage measures commensurate with increased climate ambition and grandfathering to protect existing investments.1234
Why — This would create demand for their low-carbon fuel products and protect refineries from stricter emission requirements.5
Impact — Electric vehicle adoption slows as fuel-based solutions receive regulatory support and funding.
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FuelsEurope urges CBAM to protect EU investment and export competitiveness

1 Apr 2020
Topic — EU initiative to place a carbon price on imported products to prevent carbon leakage.
Message — FuelsEurope demands the mechanism prevents investment transfers and addresses indirect carbon costs. They insist that a levy on imports cannot fully replace existing carbon leakage protections. The association also seeks specific impact assessments for the highly exposed refining sector.123
Why — These demands help manufacturers maintain global market share while receiving continued financial protections.45
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Response to Revision of the Energy Tax Directive

31 Mar 2020

FuelsEurope supports the Green Deal’s ambition for climate neutrality in 2050 and will work with the EU institutions, Member States, and stakeholders, to help create the essential enabling policy framework. The Green Deal is clearly work in progress and will require careful societal consultation and impact assessment. FuelsEurope welcomes the opportunity given by the Commission to provide input to the publication of the inception impact assessment on the review of the Energy Taxation Directive of March 4th, 2020. FuelsEurope’s Vision 2050 shows that several key technologies could potentially be deployed across Europe to deliver low-carbon liquid fuels (including net-zero carbon liquid fuels) bringing benefits both to the climate and to the economy, and making a critical contribution to the EU’s 2050 climate neutrality objective. Key regulatory measures are needed to help the development and deployment of these low-carbon liquid fuels, one of which relates to the taxation of fuels and energies. FuelsEurope supports a reform of fuel and energy taxation which should enable very low or zero taxation for low-carbon fuels. Taxation can be an important tool to provide strong market signals for the development of low-carbon fuels. Currently all liquid fuels are taxed at a similar level regardless of carbon intensity. Zero or very low tax for low-carbon liquid fuels would facilitate fuel pricing that is both socially acceptable, and able to contribute to a business case for investments. FuelsEurope welcomes that the energy taxation directive review will evaluate on how to adequately promote greenhouse gas emission reduction via several routes, including via alternative fuels. Within the list of indicated alternative fuels, FuelsEurope would like to see that all sustainable biofuels are considered in the energy taxation directive review and not as indicated in the inception impact assessment only the advanced biofuels. FuelsEurope is willing to actively participate into the further steps taken in the review process of the Energy Taxation Directive.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

18 Feb 2020 · Energy and climate transition

Response to Climate Law

6 Feb 2020

1. On the Green Deal Reflecting on the Green Deal as a potential enabler of low-carbon technologies and accelerator of industrial solutions for the decarbonisation of mobility and the industrial value chain, FuelsEurope welcomes in particular the EC’s emphasis on the following: - The development of lead markets for climate neutral and circular products (s. footnote); - The recognition of the need to maintain security of supply and competitiveness of the EU economy, including avoiding carbon leakage; - The recognition that energy-intensive industries are indispensable to Europe’s economy (referencing the recommendations of the High Level Group on Energy-Intensive Industries); - The development of legislative options to boost the production and uptake of sustainable alternative fuels for the different transport modes 2. FuelsEurope’s vision 2050 Climate neutrality will require disruptive changes in the energy mix, especially for transport. Throughout these changes, the Commission’s studies clearly envisage an enduring role for low-carbon liquid fuels, particularly for more energy intensive transport modes less suited for electrification. The European Refining Industry sees its future in a transformation of its manufacturing process that would create European leadership in critical technologies for these low-carbon liquid fuels, provided the right enabling policy framework is in place. As emphasised in the Vision 2050 (attached), the European refining industry is already developing various low-carbon solutions, from low-carbon fuels to sustainably improving industrial processes, all the while providing affordable solutions to mobility, EU citizens, and the industrial value chain, making a critical contribution to the EU’s 2050 climate-neutrality objective. 3. On the Climate Law roadmap a) Climate-neutrality by 2050: With the legislative roadmap published, it is now paramount that the associated legislative framework be established in a way that ensures the Green Deal’s long-term success by firmly rooting it in comprehensive, transparent, and regularly updated impact assessments, transparent law making reflective of the best available science, and technology neutrality that will allow the most cost-efficient solutions to succeed. The Green Deal states that “a new pact is needed […]” with “[…] industry working closely with the EU’s institutions […].” Drawing from our own expertise as an actor of the low-carbon transition, FuelsEurope embraces the opportunity to provide input to the Commission for evaluations, impact assessments, and legislative proposals. In addition to individual impact assessments, evaluating the cumulative cost-impact of the Deal and ensuring consistency of the legislative framework, will be key. We firmly believe that it is only by rooting policy in sound science and carefully proofing the effects of legislation on competitiveness that the EU can fully seize the opportunities of the Green Deal, and enhance its global leadership in low-carbon technologies. b) Setting intermediate targets: FuelsEurope welcome the EC’s commitment to present an impact-assessed plan before increasing the EU’s GHG emission reductions target for 2030. The recently adopted climate and energy legislative package will have to be implemented while being reviewed and eventually updated where relevant. In performing this thorough assessment, it is therefore imperative that the EU: - ensure stability and predictability for industry and investors to allow them to realise their planned investments and development; - examine carefully the consequences on EU’s industry competitiveness, the technical/economic achievability, the societal cost and the employment/social implications of any increased target *Note: Given its regulatory and market structure, we identify road-transport as the most promising lead market to deploy low-carbon liquids at scale
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Response to Registrants’ obligations concerning dossier updates (REACH)

15 Jan 2020

FuelsEurope welcomes the new version of the proposal for the Implementing Regulation on the duties placed on registrants to update their registrations. We welcome in particular the fact that the text takes into account that the co-registrants’ submission cannot be submitted before ECHA accepts the submission of the updated Lead Registrant dossier and the fact that updates which require an update of the CSA/CSR need a considerable amount of time for the practical work and getting agreement from all co-registrants. The current practices of the yearly update cycle of the jointly submitted registration dossiers for petroleum substances is to a large extend in line with the proposal. We have the following concerns regarding the draft proposal: • According to Art 8, a registrant has 6 months (or 12 months in case of an integrated testing strategy) to submit testing proposals, this will be the case of an increase in tonnage band to 100-1000 t/y or to the tonnage band >1000t/y. Under Art 3, the registrant has 3 months to submit an update for an increase in tonnage band. We propose that Art 3.1 applies only to increases in tonnage bands requiring only Annex VII and Annex VIII tests. • It should not be mandatory to submit updates for "cease of import or manufacture" within three months. The registrant can e.g. choose to not update his dossier for "cease import or manufacture" because it is expected that this is a temporary situation only. In this situation, the registrant should however be aware that this has consequences e.g. in the case of dossier or substance evaluation (Art 3.2). • If the CSR is not part of the joint submission, and in cases where the individual CSR needs updating, the co-registrant will only have 3 months for the update. We propose to include also Art 10 in Art 7, i.e. in case an update of the individual CSR is needed, the co-registrant has one year to submit the update. • Furthermore, for the updates of the co-registrant’s dossiers, even if the members of the joint submission receive notice through REACH-IT that the dossier has been updated, they do not know what was updated in the dossier. Also, if the updated Lead Dossier does not immediately pass the validation checks, the LR will need to resubmit and the members of the joint submission could receive multiple notifications for the same substance. It is therefore difficult to rely on the REACH-IT notification system as it currently stands, for the start of the three month’s period to update the member dossiers. The co-registrants should therefore be informed by ECHA when the lead Dossier passed all the validation checks (Art 10). • Some companies rely on external service providers to update their registration dossiers. For these companies, the three and six month’s deadlines to update certain aspects of the dossiers will fall outside the current practice within the petroleum industry where dossiers are updated once per year. We thank the Commission to consider these concerns and remain available to provide further information as needed. FuelsEurope, the voice of the European petroleum refining industry FuelsEurope represents with the EU institutions the interest of 40 companies operating refineries in the EU. Members account for almost 100% of EU petroleum refining capacity and more than 75% of EU motor fuel retail sales. FuelsEurope aims to promote economically and environmentally sustainable refining, supply and use of petroleum products in the EU, by providing input and expert advice to the EU institutions, Member State Governments and the wider community and thus contributing in a constructive and pro-active way to the development and implementation of EU policies and regulations.
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Response to Amendment of REACH Annex II (Safety Data Sheets)

10 Oct 2019

Given that the adoption of this amendment to REACH Annex II is not expected before December 2019 and given the important changes throughout the whole SDS this amendment contains, the companies will need longer implementation and transitional periods than foreseen in the proposal to implement the modifications in their management systems for SDS. We therefore propose the following timeline: • The modified format of the SDS will apply as of 18 months after the entry into force of the amendment • The SDS provided to a recipient before the application date may continue to be used and need not to comply with the modified format given in the amendment for a 12 month transitional period after the application date
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Response to Amending Regulation (EC) No 1272/2008 relating to emergency health response

9 Aug 2019

FuelsEurope represents with the EU institutions the interest of 40 Companies operating refineries in the EU. Members account for almost 100% of EU petroleum refining capacity and more than 75% of EU motor fuel retail sales. FuelsEurope aims to promote economically and environmentally sustainable refining, supply and use of petroleum products in the EU, by providing input and expert advice to the EU Institutions, Member State Governments and the wider community, thus contributing in a constructive and pro-active way to the development and implementation of EU policies and regulations. FuelsEurope welcomes the postponement of the deadline for the application for the harmonised reporting to Poison Centres (Annex VIII, reg. 1272/2008) to 1st January 2021. Having been involved in the Commission DG GROW’s “Study on workability issues of Annex VIII CLP” during which we helped identifying some serious issues with the implementation of the new provisions of the Annex, we are pleased that our concerns have been taken into account and our comments inserted in the report. Even with the postponement of one year of the deadline to apply the Annex VIII provisions, there is still a significant amount of work ahead. Some challenges remain, as for instance dealing with the composition of petroleum products and the IT systems. We support that the key findings of the Commission’s workability study should be transposed in Annex VIII. Therefore, the European Refining Industry would support the further development of Annex VIII in collaboration with authorities and stakeholders, to arrive at workable solutions for the identified challenges.
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FuelsEurope demands absolute thresholds for industrial carbon allowance adjustments

9 Jul 2019
Topic — This consultation concerns rules for adjusting free emission allowances within the EU ETS.
Message — FuelsEurope requests an absolute threshold for adjustments to prevent discrimination against large, complex installations. They also argue that activity level reductions resulting from energy efficiency improvements should be excluded.12
Why — Large-scale operators would secure more stable free allocations regardless of their total installation size.3
Impact — The EU's effort to create a symmetrical and non-discriminatory adjustment system is undermined.4
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

7 Jun 2019 · aviation

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

4 Apr 2019 · EU climate action and policies

FuelsEurope urges compensation for electricity costs under ETS

17 Jan 2019
Topic — Revision of EU rules on compensating electro-intensive industries for emissions trading costs.
Message — The refining sector should be eligible for compensation for indirect emission costs because it is exposed to carbon leakage risk and uses significant electricity. They want the same 0.2 threshold used for direct emissions applied to indirect costs, ensuring level playing field with other compensated sectors.123
Why — This would reduce disincentives to adopt electricity-based low carbon technologies like renewable hydrogen.4
Impact — EU taxpayers fund subsidies that may enable refineries to avoid higher climate costs.5
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Response to Evaluation of the Industrial Emissions Directive

4 Dec 2018

FuelsEurope welcomes the Commission’s commitment to ensuring the efficacy of its directives through thorough, transparent, and self-critical reviews. It is only through these evaluations, rooted firmly in the best available data, that directives such as the Industrial Emissions Directive (IED) can be designed fit-for-purpose and deliver on the vital objectives of protecting, human health, the environment and consumers. But all legislation requires time for its effects to take shape. And while timely evaluations are an integral part of the legislative process, premature, or hasty, evaluations may not only paint a distorted picture of the status quo, but crucially undermine investor trust by drawing into questioning the regulatory stability and predictability of the EU, hurting its global competitiveness in the process. With this in mind, FuelsEurope was surprised to learn that the European Commission plans to bring forward its evaluation of the IED, which is to be completed by Q1 of 2020. This timeline is concerning because it appears to directly contradict a 2017 Commission report that unequivocally concluded that more time would be needed before any conclusions could be drawn from the BREF implementation (adopted BAT conclusions covered only 50% of IED installations at this point). The proposed evaluation also builds upon the assumption that sufficient data will be available to allow for an accurate analysis of the IED implementation in the first place. However, as can be derived from the article 21(3) of the IED, data for over half of the IED installations can only be expected four years after the publication of the last of the related BAT conclusions at the latest plus one or two years to measure any significant improvements, severely weakening the conclusiveness of any premature analysis. Regarding the process of elaborating BREFs, it is worth noting that some significant improvements in the most recent years have been implemented (frontloading, workshops, data collection). However we are just beginning to see the fruits of these improvement in a number of BREF review processes. Some essential questions however, like the derivation of BAT AELs methodology, are not answered yet (put on hold as long as the court case on the LCP BREF is pending) where they were to be discussed at the IED article 13 forum. Most worrying, a sudden, and premature evaluation of a relatively young directive, providing possible grounds for a revision that may be based on incomplete data, draws into questions the much needed regulatory stability that enables large private investments in the first place. All this leads FuelsEurope to question the timeliness of the evaluation of the IED and suggest a timeline that does right to this important and complex regulation. Doing so, the full benefits of the IED implementation can be effectively evaluated.
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Meeting with Dominique Ristori (Director-General Energy) and EUROMETAUX and

23 Nov 2018 · clean energy transition and decarbonisation

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis) and International Association of Oil Gas Producers Europe

12 Nov 2018 · Sustainable Finance and Taxonomy

Meeting with Elżbieta Bieńkowska (Commissioner) and

4 Sept 2018 · Alliance of Energy Intensive Industries - 2050 strategy

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and European Chemical Industry Council and

31 Aug 2018 · Energy Strategy

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

9 Jul 2018 · EU Climate policies and preparation of the EU’s strategy for long-term greenhouse gas emissions reduction

Meeting with Dominique Ristori (Director-General Energy) and European Chemical Industry Council and

8 Jun 2018 · clean energy transition

Meeting with Elżbieta Bieńkowska (Commissioner) and

24 Jan 2018 · Exchange of views on Industrial Policy

Response to Evaluation Energy Taxation Directive

26 Sept 2017

FuelsEurope’s preliminary and non-exhaustive views on the roadmap of the Energy Taxation Directive are summarized below. They are intended to contribute to a balanced discussion on the principles that should be considered when deciding how to evaluate the implementation of the different provisions of the Directive. FuelsEurope believes that, among others, the following action points should be taken into consideration: 1. To clarify how electricity for vehicles should be taxed. The principle of a technology neutral taxation of different transport fuels should be adopted. 2. To avoid a potential double taxation. The treatment of shortages at destination are not currently satisfactorily addressed. Tax treatment can be different by Member States tax authorities; e.g. taxation in Benelux at the destination and taxation in France at the expedition should a shortage occur. 3. With reference to Article 20: a. To improve the transparency of the process to include new fuels in the duty suspension regime by Member States. Decisions should be taken in full transparency with consultation of impacted industries. (Par. 2) b. To evaluate the need to consider the aromatic constituents as classification parameter for CN products 27 and 29 and to assess the impact of the lack of aromatics constituents’ content measurement test over the entire range of CN 27 and 29 products. c. To include aromatic residues of CN 2707 9999 in the duty suspension regime. EU Nomenclature decision in March 2013 confirmed that the aromatic content of petroleum oils produced from the distillation of crude oil needs to be considered when classifying such oils under the Combined Nomenclature (“CN”). This means that certain medium and heavy oils produced from the distillation of crude oil whose aromatic content exceeds their non-aromatic content, previously classified in CN 2710, are now classifiable in CN 2707 9999. Products of CN 2707 9999 are currently not covered by Article 20 and thus can’t neither be stored in at tax warehouse nor be moved under duty suspension between EU Member States anymore. UK customs already advised the Commission that these products should be made subject to the duty suspension provisions (Article 20 Par 2). 4. To examine the existence of non-uniform gasoil-classification criteria between international marine fuel quality standards (ISO 8217) and EU customs classification. Distillation criteria are used as customs classification requirements but are not an ISO 8217 specification parameter. 5. With reference to the EMCS-system: a. Change of destination issues: Some suppliers do not want to discharge the product, if a change in destination has not yet been registered in the EMCS-system b. Change of mode of transport: No change of mode of transport takes place during the movement in the current EMCS Paragraphs (B.1), (C.1) and (C.2) of the Evaluation and Fitness Check Roadmap are the focus of FuelsEurope attention. Therefore, we recommend the evaluation and upcoming revision of the ETD to cover the aspects as explained under the aforementioned bullet points. To sum up, FuelsEurope would be keen to be included among other selected relevant sectors as described in paragraph (D.5) under the commissioned studies to independent contractors section.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

23 May 2017 · low-carbon economy

Meeting with Dominique Ristori (Director-General Energy)

21 Apr 2017 · Energy policy

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

22 Mar 2017 · Energy efficiency

Meeting with Henrik Hololei (Director-General Mobility and Transport)

12 Sept 2016 · European Strategy for low-emission mobility

Meeting with Jos Delbeke (Director-General Climate Action)

29 Aug 2016 · EU policy on the greenhouse gas intensity of transport fuels post-2020

Meeting with Dominique Ristori (Director-General Energy)

10 Jun 2016 · Energy policy

Meeting with Lowri Evans (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

28 Oct 2015 · Presentation of the sector (transport, marketing, refining of fuels), regulatory costs, fitness check, energy prices

Meeting with Gonzalo De Mendoza Asensi (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete), Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

1 Oct 2015 · 1. Energy Union/Security of Supply/Refining; 2. ETS; 3. Decarbonisation of Transport

Meeting with Elżbieta Bieńkowska (Commissioner) and

28 Jul 2015 · Energy Union, ETS revision

Meeting with Jos Delbeke (Director-General Climate Action)

17 Jul 2015 · FQD

Meeting with Dominique Ristori (Director-General Energy)

13 Jul 2015 · European Petroleum Refining and Distribution

Meeting with Daniel Calleja Crespo (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

9 Jun 2015 · Presentation of FuelsEurope

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

26 May 2015 · ETS & Reach

Meeting with Juergen Mueller (Cabinet of Vice-President Karmenu Vella)

25 Mar 2015 · Effects on fuel industry of EU environmental / climate policies

Meeting with Miguel Arias Cañete (Commissioner) and

19 Feb 2015 · Competitiviness, Energy Union and ETS review