Groupe Avril
Groupe Avril was formed in 1983 at the initiative of the French federation of oilseed and protein crop producers.
ID: 268338515460-22
Lobbying Activity
Response to Environmental claims based on environmental footprint methods
20 Jul 2023
Veuillez trouver ci-joint la contribution écrite du Groupe Avril à la consultation publique sur la proposition de Directive relative aux allégations environnementales explicites.
Read full responseResponse to Initiative on EU taxonomy - environmental objective
3 May 2023
Veuillez trouver ci-joint la contribution écrite du Groupe Avril à la consultation publique en cours sur 'Investissements durables - Taxonomie environnementale de l'UE'.
Read full responseResponse to Initiative on EU taxonomy - environmental objective
2 May 2023
Veuillez trouver ci-joint la contribution écrite du Groupe Avril à la consultation publique en cours sur 'Investissements durables - Taxonomie environnementale de l'UE'.
Read full responseResponse to Ecodesign for Sustainable Products - Product priorities
2 May 2023
Veuillez trouver ci-joint la contribution écrite du Groupe Avril à l'appel à contributions en cours sur les 'Nouvelles priorités en matière décoconception pour des produits durables'.
Read full responseResponse to Carbon Removal Certification
17 Mar 2023
Please find attached Avril Group written contribution to the public consultation on the Proposal for a Regulation establishing a Union certification framework for carbon removals.
Read full responseResponse to Update of list of sustainable biofuel feedstocks
2 Jan 2023
Please find attached Avril Groups written contribution to the public consultation on Annex IX.
Read full responseResponse to Adaptation to the emissions type-approval of heavy duty vehicles to accommodate the use of pure biodiesel
28 Jun 2022
The Avril Group welcomes the proposal to amend the existing Euro VI Standard to include B100 as a possible reference fuel. As a pioneer in the sector of biodiesel, the Group, via its branch Saipol, has developed the Oleon100 solution, in order to provide a concrete response to the challenge of sustainable mobility. This fuel is B100 because it can be entirely substituted for diesel. Oleo100 is a new 100% vegetable, renewable and traced energy. This biofuel enhances the value of the French rapeseed industry and creates value in the regions, by diversifying the outlets of nearly 7,500 rapeseed farmers. Besides, B100 is among the most cost-effective solutions for decarbonisation of road transport, in particular in the heavy-duty transport.
B100 is not only a cost-effective solution for new vehicles, but also many existing vehicles currently running on B7 can be adapted to run on B100. Oleo100 presents no risk to engines: it is produced 100% from premium quality rapeseed. Avril’s B100 can be used on a wide range of diesel vehicles, without important engine modification. Moreover, in the Renewable Energy Directive and, in particular, in the Fuel Quality Directive, Avril is requiring that the Directive provides for the possibility of applying a higher safeguard grade than B7 after 2027, thus considering the evolution of the vehicle fleet. The directive should also reinstate the authorisation for Member States to distribute biofuels with a maximum FAME content of 10% , in order to cover the situation of certain biofuels, such as B30 or even B100.
The Avril Group hopes this amendment to the Euro VI Standard encourages other Member-States to follow the example of France in including B100 vehicles/engines complying with Euro VI as a separate category in the vehicle classification system used as basis for taxation, city centre allowances and other policy measures.
Also, the Avril Group strongly believes that the European Commission should consider the option of B100 trucks and buses as zero-emission vehicles, in a similar way as battery electric vehicles and fuel cell hydrogen vehicles, in the future amendment on CO2 emission standards for heavy duty vehicles (the future amendment to 2019/1242).
Finally, the Avril Group would like to ask the European Commission to investigate, with the truck and engine industry, whether the approach in this amendment, currently only for new vehicle/engine types, could be expanded for re-certification of vehicles and engines already in use. This might of course require a different approach from the legal point of view, e.g., by expanding the scope of the Euro VI to re-certification of existing engines/vehicles.
Read full responseMeeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)
27 Jul 2021 · Sustainable food systems
Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and YARA BELGIUM S.A. and Xynteo
15 Jul 2021 · Bioecononmy /Sustainability of biomass
Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and Shell Companies and
15 Jun 2021 · Fit for 55 package
Response to Climate change mitigation and adaptation taxonomy
14 Dec 2020
The Avril Group supports the adoption of the EU taxonomy as an important tool to promote sustainable activities. However, the draft delegated regulation fails to recognise the contribution of sustainable first-generation biofuels to climate change mitigation. Annex I excludes sustainable biofuels (“Food-and feed crops are not used in the activity for the manufacture of biofuels for use in transport”) even when they meet the EU sustainability criteria. This sentence should be deleted.
1. On top of legal inconsistency, this is affecting the legality of the delegated regulation:
Coherence is not only a policy necessity; it is also a legal requirement. Article 19 of the Taxonomy Regulation requires indeed to build upon “Union methodologies for assessing environmental footprint” and to “take into account any relevant existing Union legislation”. In fact, Article 10(1)(a) of the Taxonomy Regulation explicitly foresees that economic activities are to be qualified as contributing substantially to climate change mitigation where the generation of renewable energy is “in line with RED II”.
Annex I of the draft delegated regulation provides that biofuels shall further entail greenhouse gas emission savings of at least 65% compared to fossil fuels, which represents a significant effort compared to the 50% laid down in article 29(10) of RED II – and therefore already achieves the Taxonomy’s objective to raise the ambition level.
By setting different criteria from those of RED II, this exclusion is affecting the legality of the draft.
2. This would run counter the European Green Deal objectives and undermine the fulfilment of the 2030 targets on renewables:
What is at stake here is the development of new generations of biofuels on an industrial scale, and the effective phasing out of fossil fuels. Sustainable first-generation biofuels make a proven and meaningful contribution to climate change mitigation, as recognised by the RED II and the European Commission’s Renewable Energy Progress Report.
The European Commission’s Renewable Energy Progress Report published in 2020 highlights they have enabled almost 46 million tons of emissions savings in 2018 – which represents the annual emissions of the entire country of Slovakia.
They already comply with the EU sustainability criteria set out in RED II and would even comply with the 65% requirement of emissions savings further set out in that draft.
3. Including sustainable first-generation biofuels in the taxonomy would enable the Commission to keep in line with the legal mandate given by the EU co-legislators:
Article 3 of the Taxonomy Regulation provides that an economic activity qualifies as sustainable where it contributes substantially to the objective of climate change mitigation. Any sustainable biofuels produced in compliance with (i) the sustainability criteria laid down in articles 29(2) to (5) of RED II, and (ii) the substantial requirement of the greenhouse gas emissions savings of at least 65%, must necessarily qualify.
The Taxonomy Regulation foresees that an activity may qualify as contributing substantially to climate change mitigation if (i) their greenhouse gas emissions are substantially lower than the sector or industry average, (ii) they do not hamper the development and deployment of low-carbon alternatives and (iii) they do not lead to a lock-in of assets incompatible with the objective of climate-neutrality. There is strong evidence that all of requirements would be fulfilled by sustainable first-generation biofuels, as highlighted in the 2020 European Commission’s Renewable Energy Progress Report mentioned above.
Through a perverse disincentivising effect, such an exclusion would risk turning biofuel production infrastructure into stranded assets, impacting the investment and amortisation plans and giving rise to further refinancing issues.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
21 Sept 2020
The Groupe Avril fully supports the EU’s Green Deal and its ambition to become the first climate-neutral economy by 2050 and believes the revision of the RED is a key part of reducing CO2 emissions.
1.Increase of the renewable energy target in transport
As biodiesel made from European feedstocks reduce CO2 emissions, the EU should promote sustainable solutions in the transport sector, and make sure that all sustainable solutions available are duly promoted in order to unleash the potential of European sustainable biodiesel for road, maritime and air transport. The share of the renewable energy target in transport should increase from 14% to 24% and there should be a harmonisation of the calculation methods for greenhouse gas emissions, in particular for agriculture (NUTS 2).
2.Recognise the role of European sustainable biofuels in the coproduction of proteins
Rapeseed or sunflower biodiesel are a market-ready alternative to fossil fuels and respect high sustainability standards. The use of biofuels in passenger transport and freight saved 33.2 million tonnes of CO2 equivalent in 2016; which is more than the annual emissions of Latvia and Lithuania combined.
Biodiesel made from European oilseeds significantly increases to the EU protein supply: rapeseed is composed of 60% of protein meal and 40% of vegetable oil. Today, the EU imports 70% of its protein needs, while there are alternative solutions locally. The supply of protein linked to rapeseed biodiesel helps the EU reduce its imports of soybean meal – often genetically modified – from third countries.
Biofuels which contribute to the coproduction of protein feed in Europe should be incentivised: when revising the Renewable Energy Directive, they should no longer be subject to the current cap on food and feed crops.
In addition, the current cap on first-generation biofuels in all transport modes is based on the share, in 2020, of these fuels in the final consumption of energy in road and rail transport only. The cap should be reviewed to represent the share of first-generation biofuels in the final consumption of energy in all transport modes in 2020, in a given Member State.
Finally, far from undermining biodiversity, rapeseed biodiesel and rapeseed crops are essential to bee pollination. Studies show that in arable production zones, honey production can depend up to 35-40% to oilseed flowers. Therefore, the EU needs a coherent approach between the Renewable Energy Directive and its Biodiversity strategy. Similar coherence should be applied with the review of the Fuel Quality Directive, which should replace the B7 standards by the B10 standards as a statutory requirement.
3.Maintain the progressive phase-out for the contribution of high-ILUC risk biofuels, as well as a controlled certification of low-ILUC risk biofuels
The Avril Group recognises the growing concern regarding deforestation in third countries and on the expansion of some crops into land with high-carbon stock. In fact, we support the approach taken by the co-legislators with regards to biofuels with a high-ILUC risk, their capping at 2019 consumption levels until 2023, and the progressive phase-out of their contribution to renewable targets by 2030. Within that regard, and as reminded in the impact assessment on the new 2030 climate targets, Member States should ensure proper implementation of the existing 2030 framework.
The EU should reinforce this policy by ensuring that the certification of low-ILUC risk biofuels do not become an open door to palm oil. In particular, the small producer clause, qualifying their production as low-ILUC risk, is worrying for countries such as Indonesia and Malaysia. Finally, while Avril supports the Commission’s ambition to increase the use of advanced biofuels, through its investments in the next generation, they cannot yet replace the first generation. This is why it is all the more important that sustainable first-generation biofuels be used in the transition.
Read full responseResponse to ReFuelEU Aviation - Sustainable Aviation Fuels
21 Apr 2020
Avril fully supports the Sustainable aviation fuel initiative. As CO2 emissions by commercial flights rose by 32% from 2013 to 2018 and in line with Green Deal objectives of reducing transport emissions by 90%, sustainable biofuels should be used for the decarbonisation of the aviation sector. Although 2020 will see a sharp decrease, we must make sure we plan for more sustainable air travel after the crisis.
At this stage, Avril notes the EC’s current intention of only incentivising the use of non-food and feed feedstocks to produce sustainable aviation fuels. Unfortunately, this approach is too limiting, and does not reflect the sustainability criteria currently in place at European level in the EU Renewable Energy Directive. Moreover, it would unreasonably limit the potential for all sustainable feedstocks to contribute to the decarbonisation of the aviation sector. The scope should rather include all biofuels made from feedstocks that entail the co-production of high-value protein feed in Europe. Please see the attached file for more details.
Read full responseResponse to Climate Law
6 Feb 2020
The Green Deal and the ambition to become the first climate-neutral economy by 2050 is a unique opportunity for the EU to show global leadership in the fight against climate change. To achieve this ambition, we believe the EU agriculture has a key role to play. Not only are European agricultural products the most sustainable in the world, but they can bring sustainable solutions to reduce emissions and climate impact. The bioeconomy is indeed a major lever for decarbonisation, through the development of renewable energy sources based on agricultural biomass. Unlocking the potential of the bioeconomy will enable the EU to take a significant step towards the decarbonisation of transport – the only sector which emissions are still rising today.
Given the key role of the biodiesel outlet for the co-production of protein and the development of green chemistry, we are looking forward, as part of the Green Deal, to increased ambition in the Renewable Energy Directive. In particular, decarbonising transport should be a priority, by:
- Increasing the current 14% target for renewable energy in transport;
- Enable a greater contribution of EU sustainable biofuels.
This would ensure ambitious environmental goals, promote investments in sustainable alternatives to fossil fuels, while positively contributing to the EU’s food and feed security.
Read full responseMeeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and
18 May 2017 · Biodiesel imports / anti-dumping measures
Meeting with Dominique Ristori (Director-General Energy)
26 Apr 2017 · Bioenergy
Meeting with Dominique Ristori (Director-General Energy)
9 Jul 2015 · Biofuels