International DME Association
IDA
The IDA serves as the global voice for the DME industry, and works to promote the use of DME as a clean alternative fuel worldwide, to gather and communicate authoritative information about DME, and to coordinate relevant international activities and initiatives.
ID: 208875040462-28
Lobbying Activity
Response to 2040 Climate Target Plan
23 Jun 2023
The International DME Association (IDA) is the global voice of the dimethyl ether (DME) industry, promoting its use as a clean alternative fuel to contribute to the transition to more sustainable, low carbon, low GHG and low emission energy and products in applications ranging from industrial and domestic heating and cooking, mobility, power generation and hydrogen storage, to consumer products and chemicals. As the only organisation representing the DME industry worldwide, the IDAs members represent the entire product value chain, from research and development, to technology, production, distribution and use in a variety of applications. The IDA welcomes the European Commissions initiative to develop a robust impact assessment on the EU climate target for 2040. An ambitious intermediary milestone supported by a comprehensive and predictable legislative framework will ensure that the green transition remains on track, attracts investment in climate solutions, and triggers industry commitment. To ensure a successful trajectory to the target, the policy framework supporting it should take into account three key areas: 1. Circularity: Using all available resources as feedstocks for renewable fuel production, including agricultural & forest residues, sewage sludge, biogenic and non-biogenic waste, enhances resource efficiency, reduces reliance on on-renewable sources and minimizes waste generation. 2. Affordability: A just transition has been a focal point of the Fit-For-55 package, and mechanisms have already been put in place to protect vulnerable consumers from the costs associated with the green transition. Nonetheless, affordability must remain a focus, and minimizing the transition cost must remain a priority to make sure that no-one is left behind. 3. Resilience: Increasing the European Unions energy independence by investing in domestic production of all climate-friendly energy solutions will build a greener, more resilient European economy. We believe that the capacity of the EU to reach an ambitious GHG reduction target will depend on its capabilities to deploy all technologies, both available and innovative, that will help to put the EU on track for carbon and climate neutrality. This includes advanced biofuels, recycled carbon fuels and renewable fuels of non-biological origin (RFNBOs), which includes renewable and recycled carbon DME. To maximize the contribution of this innovative technology for a more climate-friendly European Union, the European policy framework should: 1. Support and stimulate all renewable and recycled production pathways which lead to the development of renewable and recycled carbon DME. As new pathways are developed it should be possible for them to be recognised in the relevant regulation, so that they can contribute to decarbonisation efforts, at the earliest opportunity. 2. Incentivise production of renewable and recycled carbon DME. Financial incentives in the form of tax rebates, capital grants and fuel subsidies should be deployed to encourage switching to all renewable technologies. Renewable liquid gases like renewable and recycled carbon DME use existing infrastructure to achieve decarbonisation objectives. Hence, they can make the energy transition more cost-efficient and affordable for end consumers. 3. Provide a clear and stable policy environment for renewable and recycled carbon DME to support project development. Establishing regulatory coherence and legal certainty is essential to attract investment in innovative and promising technologies.
Read full responseResponse to Update of list of sustainable biofuel feedstocks
22 Dec 2022
The International DME Association welcomes the recognition of additional feedstocks in the proposed delegated directive. Moreover, the list of feedstocks covers the current potential biogenic waste pathways for the production of renewable DME, offering legislative certainty for the further development of renewable DME. In our highly innovative sector, new feedstocks and production pathways are developed frequently. In order to ensure that the regulatory framework is aligned with the pace of innovation, we ask the Commission to consider taking a more agile approach in accepting new additions into the framework, for instance by revising Annex IX every year, to avoid stifling innovation related to possible future feedstocks and processes.
Read full response17 Jun 2022
In the main text of the Delegated Act, paragraph 7, it is currently stated that for both RFNBOs and RCFs “capturing of emissions from non-sustainable sources should therefore only be considered as avoiding emissions until 2035”. We strongly recommend removing or amending this clause, for several reasons:
• This clause is likely to slow down the transition from low efficiency EfW to higher efficiency advanced conversion technologies. Investors will be unwilling to invest in waste gasification plants today which from 2036 will produce a significant portion of fuel that will be considered unsustainable.
• The date of 2035 is not in line with wider European policy for net-zero. The EU has committed to cutting emissions by at least 55% by 2030 and to achieve climate neutrality by 2050. Therefore by 2035 there will still be fossil carbon in the European economy which should be used in the most efficient way possible.
• We recognise the concerns of the Commission that production of RCFs or RFNBOs should not extend the lifetime of facilities producing non-biogenic waste. However in the case of municipal and industrial waste there is a complete disconnect between the demand for the waste for production of RCFs, and the production of waste by the individual. Therefore changes in RCF legislation are unlikely to impact the amount or biogenic content of the waste generated.
• A delegated act is not an appropriate piece of legislation in which to effectively phase out an entire category of fuels from a particular date. Such a decision, if taken, should be properly debated.
Annex A section 11, sub-section (a) currently excludes CO2 incorporated into a fuel that is taken from an energy from waste facility, because Energy from Waste is specifically excluded from Annex I of Directive 2003/87/EC. This exclusion means that no RCF or RFNBO produced from carbon sources diverted from an EfW facility will be able to meet the 70% threshold, even before 2035. This would seriously hamper the transition from low-efficiency energy from waste to high efficiency advanced conversion technologies because investments are unlikely to be made in plants for which a significant portion of the output is considered unsustainable.
The International DME Association (IDA) supports the ambition shown in imposing a GHG threshold of 70% on RCFs. We note that under the methodology proposed the 70% threshold for RCFs will be challenging to meet in all but a few Member States because of the GHG intensity of their electricity grid. We suggest two changes which would enable more Member States to benefit from the decarbonisation potential offered by RCFs:
• A stepped increase in the GHG threshold for RCFs, starting from 65%, which is the threshold currently imposed on biofuels, and increasing by the late 2020’s to 70%. This would enable producers of RCFs to build plants in countries where grid CO2 emissions are falling rapidly, therefore allowing RCFs to easily meet a 70% threshold by the late 2020’s.
• Producers should be allowed to offset the “displaced” electricity, from diversion of non-biogenic waste from power production, with purchase of renewable electricity, following the principles established in the recent delegated acts to ensure the power is renewable and additional. This would allow plants producing RCFs to be constructed in all Member States, supporting member states GHG reduction targets and supporting the scale-up in renewable power generation capacity.
We believe that in line with the Innovation Fund GHG assessment methodology, the associated emissions from inputs whose ‘existing use or fate’ is landfilling, should be assumed equal to those for incineration without energy recovery because although landfill sequesters part of the carbon, encouraging landfills is not desirable for environmental reasons.
Finally, IDA would like to request the inclusion of LPG in Annex B with standard values on GHG emission intensities of elastic fuels.
Read full responseResponse to Revision of Alternative Fuels Infrastructure Directive
18 Nov 2021
The International DME Association (IDA) is the global voice of the Dimethyl Ether (DME) industry, promoting its use as a clean alternative fuel worldwide. DME produced from renewable feedstocks (rDME) is a safe, clean, sustainable fuel that can support de-fossilisation of transport, domestic and industrial heating and cooking. rDME provides up to 85% GHG savings in comparison to diesel and heating oil and with very low emissions of air pollutants (zero soot, low NOx) . Its chemical and physical properties make it compatible with existing diesel and LPG technology, providing an excellent and inexpensive alternative for both new and existing vehicle fleets. Overall, rDME has the potential to significantly contribute to reducing greenhouse gas and air pollutant emissions from road transport and achieving the objectives of the European Green Deal.
The International DME Association calls on EU Policy makers to take the following legislative recommendations into account concerning the proposal for Alternative Fuels Infrastructure Regulation:
1. Respect the principle of technological neutrality by keeping the scope of the definition of alternative fuels
rDME has a significant role to play in delivering on the EU’s decarbonisation and air quality objectives, both from new vehicles and the existing LPG and diesel fleet. rDME can be blended up to 20% into LPG for use in existing LPG vehicles. For this reason, the International DME Association welcomes the proposal for the Alternative Fuels Infrastructure Regulation and the definition of alternative fuels, where LPG continues to be included in the scope of the definition.
Additionally, rDME can be used as a replacement for diesel in light or heavy-duty vehicles, requiring only an inexpensive retrofit to the vehicle. rDME is produced from renewable feedstocks and can reduce life-cycle GHG emissions by up to 85% compared to diesel. We, therefore, welcome that the Commission also clearly recognises renewable fuels as an alternative to conventional fossil fuels, such as diesel, by including them in the scope of the definition .
2. Ensure all viable alternative fuels are covered by the definition
The International DME Association welcomes that renewable fuels are included in the scope of the definition of alternative fuels. However, we ask for more clarity on which type of renewable fuels are included, especially in regards to different production pathways. Due to the different production pathways of rDME, it is vital that the Alternative Fuels infrastructure Regulation provides more clarity on renewable fuels that are considered under the definition of alternative fuels, in line with Renewable Energy Directive.
3. Ensure means of transport remain affordable and accessible to all
Defossilising the legacy fleet of existing vehicles is critical to achieve climate targets as they will dominate the CO2 emissions of European traffic in the upcoming years. Here, retrofitting of existing LPG and diesel vehicles with rDME and blending with fossil LPG could contribute to CO2 reduction on a Well-to-Wheel and Tank-to-Wheel basis significantly in order to achieve the climate targets.
There are over 8 million vehicles running on LPG in the EU. rDME can be easily blended into LPG, demonstrating the ability of such renewable fuels to decarbonise the existing vehicles fleet and ensure “no-one is left behind”. Moreover, diesel engines can be modified to run up to 100% on rDME. Given that 41% of passenger vehicle cars, 88% of light commercial vehicles and 95% of busses and trucks run on diesel in the EU , there is an immense opportunity for such vehicles to be retrofitted to run on rDME. Moreover, several companies have been exploring models that can run on rDME, for example, Ford with a DME passenger car , and Volvo with heavy-duty models . This illustrates the viability of rDME as a diesel replacement fuel even for heavy applications.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
18 Nov 2021
The IDA is the global voice of the Dimethyl Ether (DME) industry, promoting its use as a clean alternative fuel worldwide. The IDA has a global membership of more than 50 companies, institutions and individuals involved in the research, development, production, distribution and use of DME.
Renewable DME (rDME) is a renewable gaseous fuel that can make a significant contribution to reducing GHG and air pollutant emissions from transport, off-grid residential heating and industry. rDME provides up to 85% GHG savings in comparison to diesel and heating oil and with very low emissions of air pollutants (zero soot, low NOx). Its chemical and physical properties make it compatible with existing diesel technology. rDME can also be blended up to 20% by weight with (bio)LPG and used in existing domestic heating and cooking appliances, making it a solution to reduce the GHG emissions areas of the gas grid. In industry rDME can decarbonise industrial processes requiring high-temperature heating that are hard to electrify. Additionally, rDME is an effective hydrogen carrier.
The IDA fully supports the EU Green Deal and welcomes the proposal to amend the Renewable Energy Directive, including the increased renewable energy targets. We call on EU policy-makers to take the following recommendations into account:
1) Recognise all relevant rDME production pathways
Some of the rDME production routes are listed in Annex V of REDII as biofuel pathways, recognising their use in transport. rDME’s potential contribution in the decarbonisation of other sectors such as domestic and industrial heating and cooking should also be recognised. Therefore it is key that the list of rDME production routes are updated and extended. 0See attachment for an overview of existing pathways.
2) Create a stimulating regulatory framework for renewable fuels of non-biological origin (RFNBOs) and recycled carbon fuels (RCFs)
RCFs and RFNBOs have an important role to fulfil in the energy transition - the former primarily in the transitional phase and the latter after 2030. We welcome the amendment of the definition of RFNBOs and the new sub-target in transport for RFNBO, which will stimulate their early uptake.
We also welcome the introduction of GHG emissions savings criteria in Article 1 (19). At the same time, we call on the European Commission to shortly specify the methodology for assessing GHG emissions savings from RFNBOs and RCFs in a delegated act.
For RCFs, the current REDII gives Member States the option to decide on whether they can contribute to the targets. Divergent Member State acceptance of RCFs when implementing REDII will create a fragmented EU market, unnecessary barriers to deployment and delay their market access and uptake in the EU. As the EU and its Member States should be able to rely on all sustainable solutions available decarbonising the energy system, the IDA calls to include RCFs in the calculation of the overarching target as well as the sectoral targets and benchmarks by default.
3) Create more flexibility for the certification and verification renewable gases
The IDA considers that the revision of the directive should facilitate cross-border trade of rDME and its recognition under different policy instruments. This could be done by ensuring that sustainability certificates and certificates issued using book and claim such as Guarantees of Origin are compatible, rendering it possible to use them together in a complementary manner. For gaseous fuels, sustainability certificates could be issued using the mass balancing system defined by REDII until the product enters downstream distribution value chain. Once the renewable gas enters the distribution infrastructure, GOs should become the main instrument to carry information. GOs compatible with sustainability certificates would enable smooth flow of information till it reaches the end consumer.
Read full responseResponse to Revision of the CO2 emission standards for cars and vans
26 Nov 2020
The International DME Association (IDA) welcomes the opportunity to provide comments on the inception impact assessment on the Amendment of the Regulation setting CO2 emission standards for cars and vans. Please find the IDA's feedback in the document attached.
Read full response