Greenergy Fuels Ltd
A midstream oil company with biodiesel production facilities to decarbonise the transport sector.
ID: 951876838302-05
Lobbying Activity
Response to Import of used cooking oils
31 May 2024
We welcome the opportunity to respond to this draft. In Regulation 1069/2009, Used Cooking Oil is defined as Catering Waste. Catering waste used in biodiesel production is excluded from the ABP regulations and this stance should be maintained to avoid the unnecessary burden on EU UCOME producers. UCO collection, aggregation and storage is a highly regulated industry which normally falls under the jurisdiction of the appropriate countrys environment agencies.
Read full responseResponse to Update of list of sustainable biofuel feedstocks
22 Dec 2022
Greenergy supports the addition of feedstocks into Annex IX. These additional volumes will support the drive to decarbonise transport as a whole. There needs to be consideration for the certification process and we encourage the Commission to liaise with voluntary schemes and certification bodies to ensure consistency which ensures feedstocks are correctly reported in Member States. The Commission must be wary of contravening Member States' determinations of feedstock classifications, such as Brown Grease. Several Member States have granted this feedstock Part A status which has led to investment in collection, pre-treatment and biofuel production. Brown Grease's physical properties are inferior to other waste oils, such as Used Cooking Oil, and does meet the advanced biofuel criteria.
Read full responseResponse to Detailed implementing rules for the voluntary schemes recognised by the European Commission
27 Jul 2021
Greenergy welcomes the opportunity to respond to this consultation and supports the Commission’s intention to harmonise rules across member states. The increased auditing and scrutiny on waste supply chains will ensure that the waste streams being used to count towards member states’ targets are genuine and can be relied upon. Waste lipids provide the highest greenhouse gas reductions and are an integral part of the decarbonisation of road transport particularly so should continue to be incentivised as Member States’ commit to supporting the Commission’s ‘Fit for 55’ package.
Article 2.16 – definition of “Product Group”
In order to avoid different approaches by certification schemes, it would be appropriate to further refine the definition of product group, which is a key element for the functioning of the proposed revised mass balance system. For this reason, we believe that the draft implementing regulation would be significantly improved if it were to contain either a positive list of product groups or a definition based on an accurate product description and feedstock type. In addition, it would also be positive to have a more detailed description of the parameters to be considered for the purposes of determining the “physical and chemical characteristics” of any given biofuel or bioliquid.
Article 13.4 (a) – 1 or more tonnes per month threshold for the sampling of points of origin supplying feedstocks listed in part B of Annex IX to Directive
While we welcome the lowering of the threshold, we understand that 1 or more tonnes per month as a reference value would be too onerous for most market operators. Given the fact that waste lipids in parts A and B have the same physical characteristics, and that part A has its own promotion sub-target within the REDII system, we believe that it makes sense establishing the same 5 tonnes threshold for the whole Annex IX.
Article 19 (Implementation of the mass balance system)
The Commission should issue clarification on what exactly can and can’t be mass balanced for finished fuels. The proposal suggests that fuels can only be mass balanced if they are physically mixed or belong to the same product group. The definition of product group is still vague and open to interpretation which could cause competitive advantages with some voluntary schemes and/or certification bodies depending on how they enforce it. All fuels that are intended to be blended into the same fossil fuel categories, such as gasoline and diesel, should allow for mass balancing to remain as it is this principle that allows fuel suppliers to supply sufficient bio inclusion in winter specification fuels.
For example, for winter spec diesel meeting EN590, UCOME molecules would have to be blended into diesel at <3% with the balance made up with crop based biodiesel molecules. If mass balancing was not allowed, we’d expect bio inclusion to be at reduced amounts compared to mass balance methodology. This means that from November to March of each year, there would be lower biofuel blended into Diesel which would impact the carbon savings for fuel supplied. Obligated parties would likely pay buy-outs to their respective governments thus recarbonising the road fuel market. If UCOME demand dropped to low levels of ~3%, there’s a strong possibility of those production plants running at reduced rates over the winter, or shutting down which will make the ‘Fit for 55’ programme harder to achieve.
With the introduction of the Union database, the Commission has full traceability of supply chains and feedstock origination. If everything is being transacted through said database anyway, the mass balance principle allows for suppliers to continue blending biofuels all year round therefore the elimination of mass balancing doesn’t add any further protection.
Annex IV 6) c) “Used vegetable ester and oil (waste stream)”
This definition is very different from the current Annex IX definition of Used Cooking Oil. The specification
Read full responseMeeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and Cargill and
8 Mar 2021 · waste-based biodiesel leaders on SAF
Response to Revision of the Renewable Energy Directive (EU) 2018/2001
21 Sept 2020
I write on behalf of Greenergy Fuels from the United Kingdom. We welcome the early revision of the REDII as an excellent opportunity to further improve certain elements of the existing regulatory framework to ensure that the EU achieves carbon neutrality by 2050.
Our main points are covered in the below and go into more detail in our attachment.
1. Upward revision of the 14% transport obligation (Article 25(1))
2. Elimination of the 1.7/3.4% soft cap on the contribution of feedstocks in Part B of Annex IX (Article 27(1)(b))
3. Maintaining double counting as the promotion mechanism for the whole Annex IX
4. Maintain unrestricted Mass Balancing
Regards,
Ben Hartland
Read full response