Iogen Corporation
IO
Iogen Corporation ("Iogen") is a leader in cellulosic biofuel and renewable hydrogen technologies, developing and deploying advanced technology for making net zero fuels from Renewable Natural Gas ("RNG").
ID: 247353643708-97
Lobbying Activity
Response to Sustainable transport investment plan
4 Sept 2025
IOGEN Corporation, Canada. We appreciate the opportunity to contribute to the consultation on the Sustainable Transport Investment Plan. The STIP is a vital chance for Europe to strengthen its leadership in clean transport. Success depends not only on ambitious targets but also on stable, predictable policies that mobilise private capital at scale. A technology-neutral, GHG-based framework, market stability through tools like contracts-for-difference (CfDs), and coherence across EU instruments are essential. Below, we set out key points in response to the consultation, offering constructive insights aligned with the Commissions objectives. Barriers: The biggest barrier is investor fear of policy change after projects are built. Frequent revisions of the Renewable Energy Directive, shifting eligibility rules, altered CO standards, and uneven infrastructure rollout create financial risk. For projects costing hundreds of millions, even small policy shifts can wipe out a business case. Investors need assurance that rules will remain stable. Precedents such as renewable power contracts show that long-term certainty can unlock capital. Reducing risk: Binding commitments are more effective than shifting promises. CfDs can guarantee stable revenues aligned with financing terms, giving investors confidence to proceed despite policy turbulence. Auctions and competitive mechanisms can help, but only if rules are consistent and transparent. Predictability not design details is what matters most. Consistency: The EUs goal to create a global clean fuels market is right, but fragmentation across EU instruments undermines confidence. Shipping is assessed on emissions, aviation on blending volumes, and overlaps send conflicting signals. Adopting emissions reductions as the common benchmark across all modes would give clarity, prevent double-counting, and align EU rules with ICAO and IMO. Technology priorities: E-fuels are critical for aviation, but scaling requires reliable biogenic CO supply and cost reductions. A framework rewarding all sustainable fuels by emissions savings can help create these conditions. Advanced biofuels both reduce emissions now and provide the CO needed for future e-fuels. Supporting the lowest-cost reductions across modes will lower compliance costs, build resilient supply chains, and make e-fuel ambitions more credible. Competitiveness & security: A technology-neutral, carbon-weighted approach reduces emissions today, diversifies supply, and lessens reliance on volatile fossil markets. Clear signals ensure the most efficient fuels are rewarded once viable, securing long-term investment in climate-critical technologies. A consistent EU framework will lower costs, avoid subsidy races, and position Europe as a global leader. Funding tools: The EU already has strong funding instruments, but their effectiveness depends on reducing uncertainty. CfDs provide stable revenues, while auctions can complement them under clear, harmonised rules. Public tools should share risk in ways that give private capital confidence to commit. With stable eligibility, predictable timelines, and aligned standards, existing funds can mobilise billions more, with new mechanisms filling remaining gaps. We thank the Commission for this consultation. Strong, coherent policygrounded in stability, transparency, and a technology-neutral, GHG-based approachis essential to mobilise the investment needed to meet Europes climate ambitions. IOGEN remains committed to supporting the STIP and looks forward to further engagement.
Read full responseMeeting with Jens Gieseke (Member of the European Parliament)
31 Aug 2022 · Austausch zur Verkehrspolitik
Response to Methodology to determine the share of renewables in case of co-processing
20 Jul 2022
Thank you for the opportunity to respond to this consultation. We welcome the opportunity to stress the importance of EU policy in catalyzing the production of carbon-negative fuels for our net zero future.
Iogen Corporation (“Iogen”) is one of the world’s leading firms in the field of second-generation biofuels with low and negative carbon emissions. Iogen has been in the biofuel business for over 35 years, with €500 million invested in new technology development around the world.
Iogen supports the Renewable Energy Directive and the transformational changes that are required to achieve the EU’s 2030 decarbonisation goals and climate-neutrality by 2050. Indeed, we are fully dedicated to using our world-leading advanced biofuels technologies to develop deep carbon-negative fuels based on green biohydrogen, a process we have successfully commercialised. As such, Iogen welcomes the proposed Delegated Act and its goal of ensuring that, when biofuels and biogas are produced in a common process in a refinery by mixing bio-based and fossil-based raw materials, their proportion when mixed with fossil fuels can be accurately determined.
We are very active in the deployment of biogas-based biofuels, which include fuels made via co-processing in oil refineries where biomethane and biohydrogen are biomass feedstocks and where the biohydrogen is incorporated in finished fuels. We believe this technology is a natural step along the path to net zero, where fuel production facilities, including refineries, will increasingly use sustainable feedstocks, and where biomass feedstocks like biomethane and biohydrogen will capture an ever-increasing share of carbon reductions, including for the production of low carbon renewable hydrogen. We believe that renewable hydrogen (both biohydrogen and electrolysis hydrogen) will play an important role in the energy transition, and that all renewable hydrogen should be treated equally based upon its respective sustainability characteristics.
Our detailed comments (in the attached document) address the following five points:
1. We strongly support the inclusion of Article 5 (Establishing the share of hydrogen of biological origin) as written.
2. We strongly support Article 7(3) as written, which makes it clear that the mass balance system is permissible within a refinery, in accordance with Article 30 of RED II
3. “Co-processing” should include any facilities that use biomass processed with fossil fuels in a common process, not just refineries.
4. It is not appropriate to require the system boundaries for co-processing to be an entire refinery – the system boundaries should be defined by each situation, and administered under the voluntary schemes.
5. For carbon-based fuel made from pipeline transferred biomethane (which does not have a (14C) signature), methods other than (14C) testing should be permitted.
Read full responseMeeting with Markus Pieper (Member of the European Parliament, Rapporteur)
9 Mar 2022 · RED III
Response to Revision of the Energy Tax Directive
8 Nov 2021
Iogen Corporation supports “Fit for 55”, the transformational changes that are required to achieve the EU’s 2030 decarbonisation goals and climate-neutrality by 2050. Indeed, we as a company are fully dedicated to using our world-leading advanced biofuels technologies to develop deep carbon-negative fuels based on green biohydrogen, a process we have successfully commercialised. Many of the specific proposals in the Fit for 55 package could affect the use of this important contribution to reducing greenhouse gas emissions, both positively and negatively, as set out below. We hope the measures as ultimately adopted by the EU legislator will reflect our constructive suggestions, set out in our attached submission.
Read full responseResponse to ReFuelEU Aviation - Sustainable Aviation Fuels
8 Nov 2021
Iogen Corporation supports “Fit for 55”, the transformational changes that are required to achieve the EU’s 2030 decarbonisation goals and climate-neutrality by 2050. Indeed, we as a company are fully dedicated to using our world-leading advanced biofuels technologies to develop deep carbon-negative fuels based on green biohydrogen, a process we have successfully commercialised. Many of the specific proposals in the Fit for 55 package could affect the use of this important contribution to reducing greenhouse gas emissions, both positively and negatively, as set out below. We hope the measures as ultimately adopted by the EU legislator will reflect our constructive suggestions, set out in our attached submission.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
8 Nov 2021
Iogen Corporation supports “Fit for 55”, the transformational changes that are required to achieve the EU’s 2030 decarbonisation goals and climate-neutrality by 2050. Indeed, we as a company are fully dedicated to using our world-leading advanced biofuels technologies to develop deep carbon-negative fuels based on green biohydrogen, a process we have successfully commercialised. Many of the specific proposals in the Fit for 55 package could affect the use of this important contribution to reducing greenhouse gas emissions, both positively and negatively, as set out below. We hope the measures as ultimately adopted by the EU legislator will reflect our constructive suggestions, set out in our attached submission.
Read full responseResponse to Revision of the CO2 emission standards for cars and vans
8 Nov 2021
Iogen Corporation supports “Fit for 55”, the transformational changes that are required to achieve the EU’s 2030 decarbonisation goals and climate-neutrality by 2050. Indeed, we as a company are fully dedicated to using our world-leading advanced biofuels technologies to develop deep carbon-negative fuels based on green biohydrogen, a process we have successfully commercialised. Many of the specific proposals in the Fit for 55 package could affect the use of this important contribution to reducing greenhouse gas emissions, both positively and negatively, as set out below. We hope the measures as ultimately adopted by the EU legislator will reflect our constructive suggestions, set out in our attached submission.
Read full responseResponse to Updating the EU Emissions Trading System
8 Nov 2021
Iogen Corporation supports “Fit for 55”, the transformational changes that are required to achieve the EU’s 2030 decarbonisation goals and climate-neutrality by 2050. Indeed, we as a company are fully dedicated to using our world-leading advanced biofuels technologies to develop deep carbon-negative fuels based on green biohydrogen, a process we have successfully commercialised. Many of the specific proposals in the Fit for 55 package could affect the use of this important contribution to reducing greenhouse gas emissions, both positively and negatively, as set out below. We hope the measures as ultimately adopted by the EU legislator will reflect our constructive suggestions, set out in our attached submission.
Read full responseResponse to FuelEU Maritime
8 Nov 2021
Iogen Corporation supports “Fit for 55”, the transformational changes that are required to achieve the EU’s 2030 decarbonisation goals and climate-neutrality by 2050. Indeed, we as a company are fully dedicated to using our world-leading advanced biofuels technologies to develop deep carbon-negative fuels based on green biohydrogen, a process we have successfully commercialised. Many of the specific proposals in the Fit for 55 package could affect the use of this important contribution to reducing greenhouse gas emissions, both positively and negatively, as set out below. We hope the measures as ultimately adopted by the EU legislator will reflect our constructive suggestions, set out in our attached submission.
Read full responseResponse to Detailed implementing rules for the voluntary schemes recognised by the European Commission
27 Jul 2021
Iogen Corporation, a leader in cellulosic biofuel technology, appreciates the opportunity to comment on the Commission’s draft Implementing Regulation on Rules to Verify Sustainability and Greenhouse Gas Emissions Saving Criteria and Low Indirect Land-Use Change Risk Criteria (Ares (2021) 4234307 of June 29, 2021) (the “draft IR”).
The methodologies proposed in the draft IR should promote the development and deployment of renewable hydrogen in the transport sector, as this will be critical to the EU’s efforts to attain net zero by 2050, a point underlined by the bold “Fit for 55” proposals adopted on July 14.
Renewable hydrogen, whether derived through electrolysis (so a renewable fuel of non-biological origin, RFNBO) or through the bio-based pathway, clearly falls within the scope of the draft IR. It is thus essential that the draft IR facilitates the development and use of renewable hydrogen, and at a minimum avoid any unintended consequences that could disadvantage the uptake of such an important renewable energy source.
The development and deployment of RFNBO hydrogen from electrolysis faces considerable technical and other cost constraints that the Hydrogen Strategy for a Climate-Neutral Europe, the European Clean Hydrogen Alliance and similar EU efforts are striving to overcome. At Iogen, we have begun to open a new market for hydrogen of both biological and non-biological origin that will substantially increase the demand-pull for the technology. This potential demand-pull is expressly called out in the Hydrogen Strategy, which states “An immediate application in industry is to reduce and replace the use of carbon-intensive hydrogen in refineries….”
Indeed, the EU currently uses approximately 5 million tonnes of fossil hydrogen in the production of motor fuel. This hydrogen is used in a number of refinery-based “hydro-processing” operations, where it is co-processed with fossil hydrocarbons to manufacture finished fuel. Roughly 90% of this hydrogen is incorporated directly into fuel and represents the energy equivalent of 14.6 B litres of diesel fuel, a volume that can and should be made with renewable hydrogen.
This large potential volume of renewable hydrogen demand is roughly 50% of the EU’s 10 million tonne renewable hydrogen production goal for 2030 and, under Directive (EU) 2018/2001 (RED II), could be a major inducement now to the development of the EU’s renewable hydrogen industry. The key is ensuring relevant regulations don’t put barriers in the way of its deployment.
RED II and the draft IR offer a unique opportunity to jump start hydrogen production in the EU by supplying high-value transportation applications:
• Renewable hydrogen, whether made by electrolysis or from the reforming of biogas, meets the sustainability criteria of RED II
• Transport fuels made by co-processing mixtures of renewable hydrogen and fossil hydrocarbons qualify for inclusion in RED II because of their renewable content
• With the existing infrastructure already in place to incorporate hydrogen into motor fuel, the EU has a fast, ready and practical path for the near-term introduction and market growth of renewable hydrogen in the transportation sector
Unfortunately, the draft IR leaves unresolved ambiguities about the treatment of renewable hydrogen incorporated into transport fuels, primarily relating to the need to:
1. ensure the “product group” concept for mixtures is implemented consistently, effectively and in alignment with the RED II mass balance system;
2. ensure Article 19(2) addresses the mass balance system consistently and in alignment with RED II;
3. ensure co-processed mixtures of renewable hydrogen and fossil fuels fall within the scope of the mass balance system; and
4. ensure Article 23(2)’s co-processing rules can handle bio content that either does not contain carbon or comes from a consignment under the mass balance system that is withdrawn from a mixture.
See detailed feedback in the attachment.
Read full response