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Lantmännen ekonomisk förening

Lantmännen

Lantmännen är ett lantbrukskooperativ och norra Europas ledande aktör inom lantbruk, maskin, bioenergi och livsmedel och ägs av 20 000 svenska lantbrukare.

Lobbying Activity

Response to Revision of the Energy Tax Directive

18 Nov 2021

Lantmännen welcomes and is pleased to have the opportunity to share its recommendations on the review of Directive 2003/96/EC (hereafter ETD) in the context of the European Green Deal. The ETD revision represents an opportunity to update the Directive to ensure it is harmonized with recent EU energy and transport legislations, incentivize the use of all renewables in transport - including sustainable crop-based biofuels - and reduce the use of fossil-fuels. Lantmännen is calling Member States to ensure that all sustainable biofuels benefit from a substantially lower minimum tax rate than fossil fuels and remain eligible to full tax exemption under the ETD review. All renewable energy sources must be promoted to reduce the share of fossil fuels in the transport energy mix and ensure the achievement of the ambitious EU climate target of -55% by 2030. This is all the more important in a context where transport’s emissions continue to rise annually (+ 20% since 1990). Please see the enclosed position paper.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Please find enclosed the comments from Lantmännen, Sweden.
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Response to Revision of the CO2 emission standards for cars and vans

5 Nov 2021

Please find enclosed the feedback on the Vehicle CO2 regulation from Lantmännen, Sweden.
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

27 Jul 2021

Lantmännen welcomes the opportunity to comment on the draft Commission Implementing Regulation on voluntary schemes in the context of the implementation of the Renewable Energy Directive (RED II). In our enclosed paper, Lantmännnen would like to draw attention on the lower competitiveness of ethanol producing biorefineries resulting from the possible changed methodology for the calculation and allocation of GHG emissions from the production and use of biofuels as regards Carbon Capture and Replacement (CCR) / Carbon Capture and Storage (CCS). For our ethanol biorefinery, Lantmännen Agroetanol, this would lead to a significant drop in GHG savings obtained through CCR. This would have a major financial impact on EU biorefineries such as Lantmännen, on the EU biofuel market but also on reaching the European and national climate targets for the transport sector. Lantmännen Agroetanol has heavily invested in CCR and captured CO2 from its ethanol production process in full commercial scale ever since 2014. The captured CO2 is used only to replace fossil-based CO2, mainly on the Nordic market. While CCS and CCR emissions used to be allocated to the fuel only, the revised RED II methodology seems to split emissions between the fuel and the different by-products from the fuel production process (Annex V, para. 17 and 18). The RED II methodology therefore fails to fully account for the GHG savings CCR/CCS is achieving today for sustainable ethanol fuels and the decarbonisation of the road transport sector. During the ethanol production process, CO2 is naturally produced during the fermentation phase, where sugar is transformed into ethanol (see illustration in the paper). The advantage is that the CO2 produced is of high purity and concentration, which makes it easier to be captured. As a result, 100% of the CO2 captured comes from the fermentation phase when the ethanol molecule is created. There is no link to other by-products from the process, e.g. the protein feed production. In this light, the capture of CO2 in the ethanol production process should be allocated fully to the ethanol product and not at all to the by-products. This is also proven by the fact that if a plant like this would only produce feed from the same feedstock (cereals), there would be absolutely no CO2 emitted from the process. Consequently, the CO2 produced and then captured is totally correlated to the production of the ethanol molecule. In case the RED II calculation methodology were to be maintained as suggested, the Commission should at least ensure that existing CCR/CSS investments are protected through the principle of grandfathering, since they contribute to the EU climate objectives. The already existing massive investments in CO2 capture in ethanol plants have been undertaken at a very high cost and in the faith that they would be supported and even promoted by the EU legislators. It would be inacceptable that these investments in modern technology, that contribute to reduce GHG emissions, in line with the EU Climate Law, are made worthless due to retroactive changes in the EU legislation, which is contra-productive to the climate, business and investors certainty.
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Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and Shell Companies and

15 Jun 2021 · Fit for 55 package

Response to Revision of the Energy Tax Directive

1 Apr 2020

Contribution from Lantmännen to the Revision of the Energy Taxation Directive, April 2020 As part of the Green Deal, we welcome the Commission’s intention to revise the Energy Taxation Directive. Since its inception in 2003, the Directive has become outdated and does not reflect the EU’s emission reduction ambitions, nor supports the development and expansion of renewable energy, particularly in the transport sector. The revision represents an opportunity to update the Directive to ensure it is harmonized with recent EU energy and transport legislation, incentives the use of renewables in transport including sustainable biofuels and reduce the use of fossil-fuels, whilst also expanding the Directive to cover other modes of transport and industries. With that in mind, we urge the Commission to consider the following when revising the Directive: Better incentives for renewable fuels by changing taxation rules The current Directive applies the same standard tax treatment to renewable fuels as it does to fossil-based fuels, focusing on volumes: ‘any product […] shall be taxed at the rate for the equivalent motor fuel’. This imposes high taxes on renewables like biofuels with lower energy density, which disincentivizes use of these fuels by the public and investment by companies. For example, under the current rules, every gram of CO2 emitted from ethanol is taxed almost five times more than CO2 emitted from petrol on a Euro per gram of CO2 equivalent basis. In light of the EU’s ambitions to reach climate-neutrality and the Paris Climate agreement, minimum taxation rates must switch from physical fuel volume to GHG emission intensity, to ensure only renewable fuels such as sustainable biofuels are incentivized. The sustainability criteria for these fuels have already been set in the recently-revised Renewable Energy Directive, with clear definitions and GHG emission reduction limits. To ensure fairness across the EU, a minimum taxation price should be set at EU level and apply to all fuels, both local and imported, and for tax to be taken at the final point of consumption. This ensures that only the best renewable fuels are being incentivized, which in-turn will reduce emissions in the transport sector and boost the ongoing development of more sustainable, low GHG emission biofuel. Exemptions for agricultural production Strong competition from third countries with low or zero taxation on fuels and energy used in agricultural production undermines the competitiveness of sustainable European agriculture. Any changes to the taxation on energy use for European agriculture must be at the same level as in third countries. This could be assured through the European Commission’s plans for a Carbon Border Adjustment Mechanism, where agricultural products from third countries could be subject to a taxation on carbon. Any removals of exemptions for agriculture must be fully assessed and implemented before consideration. It is important to note that energy efficiency is high in the agriculture sector compared to other sectors; one unit of energy input (mainly fuel and energy to produce fertilizers) will, thanks to the crops’ photosynthesis, give back almost ten units in the harvested biomass. This unique and extremely high energy efficiency must not be impacted by unfair taxes. An example of this point: Swedish agricultural fields produce biomass with a total energy content of 53.4 TWh. In the cultivation and production, 5.8 TWh is used directly and indirectly in the form of e.g. fuel and mineral fertilizers. That means an energy ratio of 9.2 (each kWh inserted into the plant cultivation section gives 9.2 kWh back), which is something unique to agriculture.
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Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström) and Kreab Worldwide

21 Mar 2018 · Ongoing trade negotiations in area of agriculture and spirits

Meeting with Astrid Ladefoged (Cabinet of Vice-President Karmenu Vella)

29 Nov 2016 · Energy package

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Kreab Worldwide

12 Oct 2016 · renewable energy /biofuels

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström) and Kreab Worldwide and Mannheimer Swartling Advokatbyrå

7 Sept 2016 · Biofuels & energy