Les Dérivés Résiniques et Terpèniques
DRT
A world leader in plant-based chemistry, we produce pine-based ingredients and biobased substances.
ID: 299147238608-28
Lobbying Activity
Response to Revision of the Renewable Energy Directive (EU) 2018/2001
16 Nov 2021
In line with the waste hierarchy and the cascading use of biomass principle, feedstocks available in limited volumes, providing high socio-economic and environmental benefits and having higher value uses other than energy recovery shall be allocated in priority to those industrial uses.
DRT proposes 2 options to ensure those feedstocks (incl. tall oil) are used to meet the EU Green Deal ambition:
1. Remove feedstocks from Annex IX having a reduced impact on the targets, including tall oil
Annex IX lists the feedstocks that are eligible to produce advanced biofuels and can be counted twice towards the national RES targets under RED II. However, the listed feedstocks cannot all equally contribute to fulfil the advanced biofuel targets to the same level, as the feedstock’s volumes availability and their share of pre-existing use other than energy recovery are not taken into account. We therefore recommend co-legislators to remove feedstocks having a high share of pre-existing industrial higher value uses and low volumes available so that they can benefit higher decarbonisation objectives than energy recovery or provide alternatives to other sectors currently without substitutes to fossil fuels. Following this option, tall oil would no longer count towards the advanced biofuel targets, and its use would be safeguarded for its higher value uses providing decarbonisation solutions for hundreds of products / industrial sectors.
2. Differentiating the Annex IX Part A feedstocks having pre-existing industrial uses other than energy recovery
DRT welcomes the inclusion of the cascading use principle and the delegated act (DA) aiming to specify its implementation in the proposal. Although this is a positive first step, the scope of the DA needs to be clarified and thoroughly defined (incl. waste, residues and by-products listed in Annex IX) to effectively prevent undue distortive effects on the biomass raw material market. To do so, co-legislators should specify that the definition of biomass under RED II Article 2(24) covers liquid and solid biomass, by-products, waste and residues including biomass fraction of wastes and residues from forestry and forest-based industries.
Several feedstocks listed on Annex IX (esp. by-products and residues stemming from wood) have pre-existing industrial higher value uses other than energy recovery and limited volumes available. As such, they should be prioritized for their higher value uses other than energy recovery to ensure substantial GHG emissions reduction and competition on the raw material market. Thus, we consider that the scope proposed under Article 1(2) of the proposal should be clarified and cover such feedstocks. It is crucial that the criteria developed under the DA are clear and objective to safeguard both current and future innovation for their highest environmental benefits. In this light, DRT recommends the use of the following criteria for the implementation of the cascading use principle (Article 3 – paragraph 3.a(iii)):
1. Total available volume of the feedstock at EU level;
2. Share of pre-existing industrial uses other than energy recovery;
3. For the share mentioned in (2), a threshold could be considered above which the revised directive would create distortive effect on the raw materials market and hamper the achievements of the EU Green Deal.
The establishment of such criteria to all residues and by-products from woody biomass should allow the differentiated Annex IX Part A feedstocks to be excluded from public support schemes and from multipliers while still being eligible to contribute to the advanced biofuel targets.
It is therefore urgent that co-legislators seize the opportunity of the RED II review to clarify the scope and give a legal basis to the implementation of the cascading use principle while aligning Annex IX with the EU Green Deal ambition to produce bioenergy with the highest sustainability standards and ensure a fair and future proof green transition.
Read full responseMeeting with Laure Chapuis (Cabinet of Commissioner Kadri Simson) and Kreab Worldwide
21 May 2021 · DRT position on REDII revision.
Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Kreab Worldwide
2 Feb 2021 · Chimie, énergies renouvelables
Meeting with Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius) and Kreab Worldwide
26 Jan 2021 · The revision of the RED II in the context of the European Green Deal
Response to Revision of the Renewable Energy Directive (EU) 2018/2001
21 Sept 2020
DRT is a French medium-size enterprise at the forefront of the biobased chemicals industry. By dedicating 5% of its workforce to R&I, DRT has developed a unique know-how in the treatment and distillation of Crude Tall Oil (CTO). DRT uses this by-product from the paper pulp kraft process to produce over 300 tall oil biobased chemical substances reducing the carbon footprint of daily life products with a safe and sustainable life cycle. DRT is an indispensable actor of the European Green Deal (EGD) enhancing sustainability and decarbonisation in many key circular value chains of the EU economy, including plastics and packaging, construction, and the agri-food sector. Since June 2020, DRT is owned by the family company FIRMENICH, leader in the production of organic chemical ingredients based on plant-based materials.
DRT welcomes the publication of the inception impact assessment on the RED II review, and firmly supports Policy Option 4 including the reopening of Articles 29 to 31 covering the sustainability criteria and GHG emissions of bioenergy. This would be the only viable option to ensure all the objectives of the EGD are appropriately taken into consideration under the revised RED II.
The key benefit of tall oil-based chemistry is the replacement of petrochemicals and other related chemicals with biobased substances from a renewable by-product in industries ranging from construction, rubber, cement or electronics. Following the “cascading use of biomass” principle, which prioritizes material recovery over energy recovery (advanced biofuels), the limited amounts of tall oil available shall be allocated in priority for its higher value uses. Tall oil-based chemistry proposes higher benefits for the environment and the economy than tall oil-based advanced biofuels: 4 times more economic value, 20 times more jobs, and 25% savings in CO2 emissions. DRT’s activities are therefore a key enabler of the EGD by strengthening the EU circular economy while contributing to the objective of climate-neutrality by 2050.
Although tall oil-based chemical industry is a high-added value sector, it is being threatened by the production of advanced biodiesel from tall oil incentivized by the double counting resulting from its listing in the Annex IX of the RED II. Since the adoption of the RED II in 2018, DRT has faced difficulties in maintaining a supply of CTO, jeopardizing the entire value chain and the EU CTO-based biochemicals industry, for the following reasons:
- Tall oil is one of the feedstocks listed on the Annex IX presenting the lowest volume available, with a non-elastic supply as it depends entirely on the paper pulp production from pine trees
- Tall oil is one of the only feedstocks listed on the Annex IX having a viable technology on the market for advanced biodiesel production
- 100% of European available volumes of tall oil are currently used while the RED II is not fully implemented yet, creating market distortions due to the incentive for the production of advanced biodiesel from tall oil, which, in turn, increases prices
- Higher CTO prices have an impact on viability of tall oil-based biochemicals compared to their petrochemicals conventional alternative, leading to increased emissions in industry sectors, job loss, and going against the objectives of the EGD
For these reasons, DRT believes the inclusion of tall oil on the Annex IX of the RED II goes against all the benefits biochemistry from tall oil can provide for the EGD initiatives, and leads to market distortion due to policy incentives for one of the uses, disregarding the cascading use of biomass principle while promoting energy recovery before material recovery.
DRT therefore recommends the reopening of Article 29 and removal of tall oil from the Annex IX or stronger provisions ensuring the priority of tall oil for its material recovery to preserve pre-existing high value uses in support of the objectives of the EGD.
Read full responseResponse to Chemicals strategy for sustainability
19 Jun 2020
DRT Position
DRT is a French medium-size enterprise at the forefront of the sustainable chemicals industry. Its headquarters are located in Les Landes, where it was founded in 1932 by seven woodland owners. Today, DRT is an enterprise with an international outlook - 90% of its revenues are generated on international markets and 1 500 people are employed worldwide, which contribute to generate a turnover of over €500M. Since 27 May 2020, DRT is owned by the family company FIRMENICH, leader in the production of organic chemical ingredients based on green materials. FIRMENICH has a large biotechnology department with industrial achievements and invests €390M euros in R&D.
By dedicating 5% of its workforce to Research and Innovation, DRT has developed a unique know-how in the treatment and distillation of Crude Tall Oil (CTO). DRT uses this by-product from the paper pulp kraft process to produce over 300 biobased chemical substances for a variety of daily life products benefitting from a reduced carbon footprint and a safe and sustainable life cycle. DRT is an indispensable actor of sustainable chemistry aiming at greening many key value chains of the EU economy including plastics and packaging, construction, and the agri-food sector.
I. Sustainable chemistry as a key enabler of a “toxic-free” environment
Sustainable chemistry reduces the EU economy’s dependency on fossil fuels by substituting fossil-fuel based chemicals with biobased chemical substances.
In addition, CTO presents extremely low hazard to human health, notably in terms of mutagenicity and carcinogenicity.
CTO-based chemistry enables the decarbonisation of products for which there are currently no other alternatives to fossil-based substances, such as tyres or asphalts. They are also at the heart of circular economy, as they are obtained from renewable feedstocks and used to produce various daily-life products with high added value.
II. Sustainable chemistry as a key player of the transition towards safe and sustainable innovation
Sustainable chemistry is actively involved in the development of innovative business models for the entire value chain. DRT is committed to responsible sourcing, with manufacturing sites located as close as possible to resources, and 90% of its suppliers having an environmental certification.
For the sector to expand and provide environmental benefits on a larger scale for the EU economy, chemical industries should benefit from incentives to ease the switch to a safe and sustainable chemical business model able to fulfill the EU climate and sustainability objectives.
III. Recommendations
DRT recommends the inclusion of the following elements in the Strategy:
1. Development of a clear definition of sustainable chemistry based on objective criteria including:
- The origin and traceability of the feedstock used
The Strategy should prioritise the use of renewable and traceable feedstocks such as CTO or, if not possible, waste, residues and by-products with no competitive higher value uses.
- The carbon footprint of the product
Sustainable chemicals production allows significant CO2 emissions reduction by using carbons from a renewable feedstock in products with few or no alternatives to fossil-fuel based substances.
- The CSR criteria of the producer
This is essential to give social and environmental transparency to the entire supply chain and demonstrate the benefits of sustainable chemicals through appropriate environmental safeguards and proper stewardship of the supply chain.
2. The application of the cascading use of biomass principle to all by-products from biomass used in sustainable chemicals, to prioritise material recovery over energy recovery in case of competing uses and ensure that biomass is used for its highest economic, social and environmental value.
Read full response