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Hungarian Biofuels Association

HBA

The aim of the Hungarian Biofuels Association (HBA) is to promote the use of fuels produced from renewable raw materials, using environmentally friendly technology and green energy sources in Hungary and Central Europe.

Lobbying Activity

Response to COMMISSION DELEGATED REGULATION on extending the scope of traceability of the Union database

6 Nov 2024

Submission by the Hungarian Biofuels Association (HBA) The Hungarian Biofuels Association (HBA) welcomes the opportunity to provide input on the European Commission's proposal to extend the Union Database (UDB) requirements. While we recognize the Commission's intent to enhance transparency within the biofuels supply chain, we believe certain aspects of the proposal lack necessary clarity. Without answers to specific questions, it remains challenging for stakeholders to fully assess and prepare for compliance. Therefore, we respectfully request clarification on the following: Would the proposed regulation require farmers, both within the EU and outside it, to register in the UDB? Would the proposal necessitate the registration of all supposed points of origin for waste materials, such as Used Cooking Oil (UCO), regardless of volume, in the UDB? If so, would this apply to both EU and non-EU sources? Clarification on this question is essential, as requirements for waste feedstocks need to balance fraud prevention with practical compliance burdens on the industry. In our view, answers to these questions would help all stakeholders better interpret the regulation and assess its feasibility. We believe that addressing these points is essential before discussing further aspects of the proposal.
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