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Mittelstandsverband abfallbasierter Kraftstoffe e.V. (Waste-based Fuels Association)

MVaK

The Mittelstandsverband abfallbasierter Kraftstoffe e.V.

Lobbying Activity

Response to Revision of the CO2 emission standards for cars and vans

10 Oct 2025

The Mittelstandsverband abfallbasierter Kraftstoffe e.V. (MVaK) represents thirty members who collect, prepare and convert suitable waste lipids, mainly used cooking oils and waste fatty acids, into waste-based and advanced biodiesel or trade the feedstocks and finished products. Our members are based in Germany, Austria and the Netherlands. Please find our feedback attached.
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Response to COMMISSION DELEGATED REGULATION on extending the scope of traceability of the Union database

6 Nov 2024

The Mittelstandsverband abfallbasierter Kraftstoffe e.V. (MVaK) represents twenty-nine members who collect, prepare and convert suitable waste lipids, mainly used cooking oils and waste fatty acids, into waste-based and advanced biodiesel or trade the feedstocks and finished products. Our members are based in Germany, Austria and the Netherlands. Thank you for the opportunity to comment on the draft Commission delegated regulation. We kindly ask you to take note of our statement attached.
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Meeting with Jens Gieseke (Member of the European Parliament)

26 Aug 2024 · Austausch zu Umweltpolitik

Response to Import of used cooking oils

31 May 2024

We would like to thank you for the opportunity to comment on the draft. We have attached our statement.
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Response to Update of list of sustainable biofuel feedstocks

2 Jan 2023

The MVaK welcomes the opportunity to provide feedback to the European Commission's proposal to extend the Annex IX (RED II). Please find the MVaK feedback in the attached document.
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Response to Methodology to determine the share of renewables in case of co-processing

19 Jul 2022

The Mittelstandsverband abfallbasierter Kraftstoffe e.V. (MVaK) represents 24 members which prepare suitable vegetable waste oils and residues, mainly used cooking oil and waste fatty acids, process them into waste-based biodiesel or trade feedstocks and finished products. The MVaK welcomes the opportunity to give feedback on the draft Delegated regulation on the methodology to determine the share of biofuel and biogas for transport, produced from biomass being processed with fossil fuels in a common process. The MVaK is one of the early proponents of the use of the 14C method as the only method to prove the correct attribution of the renewable biogenic fraction in co-processed fuels and to avoid instances in which a wrong correspondence between renewable input and renewable output occurs. In this context we strongly welcome the approach requiring 14C testing to verify the results of different accepted methods of attribution. Article 2.1 The article states that “[t]he mass balance method shall ensure that the bio-content of all outputs is proportional to the bio-content of the inputs and that the same share of biogenic material is allocated to each output.” This wording does not appropriately reflect how bio feedstocks are distributed in refinery operations given that the biogenic carbon will always be disproportionately distributed amongst different fuel products being produced in a refinery at the same time. In consequence, Article 2 should better convey the fact that the bio-content of outputs is proportional to the bio-content of the inputs and, quite importantly, that the correct share of biogenic material "...is allocated to each different output". On the contrary, assigning the same share to each output upon the basis of the current wording could allow an economic operator to claim an incorrectly high renewable content for the most valuable product (diesel, for example) when a majority of the renewable content resulting from the biogenic material is actually going to flare gas. Articles 3 and 5 If biomass-derived hydrogen is intended to be eligible to be assigned as a biogenic input for a process it is critically important that only the portion of the hydrogen that ends up in the usable fuel product is allowed to serve as an input for the energy balance method. This should be clearly stated in Article 3 as well as in Article 5. Article 6 Ensuring that 14C tests are performed regularly is a key precondition for the functioning of the system without loopholes. We believe that the current formulation of Article 6 could be improved by providing clear requirements to establish the periodicity of 14C testing. In addition, if the phrase “[t]he economic operators shall perform the calculation of the bio-content share at least for each batch or consignment” refers to 14C testing, it should state it specifically.
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Response to Adaptation to the emissions type-approval of heavy duty vehicles to accommodate the use of pure biodiesel

29 Jun 2022

The Mittelstandsverband abfallbasierter Kraftstoffe e.V. (MVaK) represents 23 members which prepare suitable vegetable waste oils and residues, mainly used cooking oil and waste fatty acids, process them into waste-based biodiesel or trade feedstocks and finished products. Combustion engines will very likely remain the most important option for vehicle propulsion in heavy-duty transport well beyond 2030. It is therefore important that vehicles with combustion engines can also make a notable contribution to the climate goals of the European Union. This would be made possible by an increased use of B100. B100 is a particularly efficient option for heavy duty vehicles and climate. On the one hand, the use of B100 is comparatively economical for trucking companies and, on the other hand, B100 achieves high greenhouse gas savings, especially if the biodiesel is made from waste oils. We therefore welcome the initiative of the European Commission to include FAME B100, which meets the CEN standard EN 14214:2012+A2:2019, as one of the reference fuels in Regulation (EU) 582/2011 and to facilitate type approval testing for B100. In order to achieve the EU climate targets, a significant increase in the number of heavy-duty vehicles approved for the use of B100 would be of utmost importance, while at the same time supporting regional value added creation. Finally, a comment on the new point 1.4.1 of Annex I: We recommend the uniform and consistent use of the term biodiesel.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

18 Nov 2021

The MVaK represents 21 members which pretreat suitable vegetable waste and residues, mainly used cooking oil and waste fatty acids, process them into waste-based biodiesel or trade feedstocks and finished products. Biodiesel cannot be used in aviation due to its cold flow properties but it is a perfect option for the existing ICEV fleet to also contribute to climate protection. In 2018, the use of waste-based biodiesel in German road transport reduced GHG emissions by 3.6 million tons. The MVaK welcomes the opportunity to comment on the European Commission's proposal for a regulation as key element of the ReFuelEU Aviation initiative, as this in its current form is a considerable threat to the continued existence of its medium-sized members. As a general remark, we believe that feedstock efficiency, fair competition and an approach that is open to technology are essential in order to develop new technologies and to achieve the EU climate goals. Unfortunately, this drafted regulation does not meet these criteria. The proposal completely disregards the fact that used cooking oils and other waste oils for climate protection are most efficiently converted into biodiesel and used in road transport or the maritime sector. The proposed consumption mandate from 2025 will divert most, if not all, of the waste oils currently used in road transport to aviation and thus withdraw them from their current users, the producers of biodiesel. At the same time it increases the greenhouse gas emissions of the transport sector as a whole, as the waste oil conversion efficiency is less favorable for aviation fuel production compared to biodiesel production. Further information in this regard can be found in the study "Conversion efficiencies of fuel pathways for Used Cooking Oil", which is attached to our feedback. In addition, the current proposal violates the principle of fair competition. It means that two groups of buyers, biodiesel producers on the one hand and aviation fuel producers on the other, compete for the same feedstocks, in this case waste oils with limited availability, whereby only the group of aviation fuel producers has to supply a mandate. Basically, waste and residues that are already being used efficiently, such as waste oils that are produced into biodiesel for road transport and the maritime sector, should not be taken in account as a feedstock option to fulfill a new mandate in another transport sector. And finally, the draft fails in part to meet the important criterion of promoting the development of new technologies and thus using new, previously unused waste and residues. The sub-target for e-kerosene is the exception. But it is far too unambitious. Rather, a sub-target is also required for the use of so-called alcohol-to-jet fuels, which are supposed to make up a substantial part of the renewable aviation turbine fuels consumed, but without a sub-target alcohol-to-jet fuels have no chance to compete with lipid-based aviation turbine fuels. We also would like to mention that in the Impact Assessment to the draft proposal it is stated that there will be enough collectable waste oils available in the EU for the production of renewable fuels for the supply of aviation and road transport, and that there would be hardly any diversion of these oils from biodiesel production into the production of aviation turbine fuels. At the same time, however, it is not explained at any point what amount of collectable waste oils is assumed in the EU. In conclusion, we would like to emphasize once again that if this draft regulation is not fundamentally changed, the existence of medium-sized producers of waste-based biodiesel in the European Union will be at stake and, at the same time, the overall GHG emissions of the transport sector will not be reduced but rather increased.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

The MVaK represents 21 members which pretreat suitable vegetable waste and residues, mainly used cooking oil and waste fatty acids, process them into waste-based biodiesel or trade feedstocks and finished products. The MVaK welcomes the opportunity to comment on the European Commission’s proposal on the Renewable Energy Directive revision. As a general remark, we believe that feedstock efficiency, fair competition and an approach that is open to technology are essential in order to develop new technologies and to achieve the EU climate goals. In the following we would like to comment on some elements of the proposal. 1. System change to a GHG reduction target With regard to the EU climate goals, the development of new technologies and the need to make full use of all sustainable options for reducing GHG in transport, we believe the GHG reduction target in transport should be set more ambitious than at least 13%. However, the system change represents for biofuels made from feedstocks listed in Annex IX Parts A and B a not inconsiderable competitive disadvantage compared to a double counting mechanism within the framework of an energy target for the use of renewable energy in the transport sector. Even if waste-based biodiesel achieves the highest GHG savings in Annex V of the RED II, the promotion mechanism emanating from the GHG savings obligation alone does not represent a strong enough incentivization to ensure the presence of waste-based biodiesel in the EU road fuel mix in a scenario in which waste lipids for aviation are being over-supported via its unrestricted inclusion in a protected market enabled by the proposed aviation blending mandate in the ReFuelEU Aviation proposal. For this reason we believe that a further promotion mechanism is required to ensure that waste-based biodiesel continues providing a decarbonizing solution for ICEVs in the 2025-2030 period. Such promotion would be best embodied in the incorporation of a 2 % sub-target for the contribution of biofuels produced from feedstocks in Part B of Annex IX for the road sector. 2. 1,7% limitation to the contribution of biofuels produced from feedstocks in Part B of Annex IX We strictly reject any limitation to the contribution of biofuels produced from feedstocks listed in Part B of Annex IX, in particular if exclusively applied to the road sector. A restriction is all the more incomprehensible as each of the presumed motives behind it has been adequately taken into account with other measures: (1) Leaving space for Annex IX Part A biofuels to develop: This is not relevant any longer as part A biofuels benefit from a sub-target. (2) Antifraud mechanism: The RED II has set in motion the creation of a pan-EU track and trace database for biofuels and bio-liquids, which will become fully operational for all biofuels and bio-liquids traded in the EU up to feedstock origination as from October 2022. This new development alone would prevent inappropriate market occurrences from happening, but the system is about to be further reinforced as the Commission is set to adopt very shortly an implementing act with revised stricter standards for certification schemes. Furthermore, the Commission is also preparing a delegated act with a revision of Annex IX, set to be adopted in Q1 2022. This revision is widely expected to result in new feedstocks being added to Part B of Annex IX, further justifying the elimination of the limitation. 3. Introduction of B10 The MVaK welcomes the provision modifying the Fuel Quality Directive by endorsing a 10% biodiesel content (B10) in the existing EU fuel standard. This represents a major step forward in terms of efficient defossilization of road transport through the incorporation of more highly sustainable waste-based biodiesel. An industry analysis of the existing light and heavy duty fleet shows that many vehicles in the EU are compatible with higher biodiesel blends, in many cases even beyond B10.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

The MVaK represents 21 members which pretreat suitable vegetable waste and residues, mainly used cooking oil and waste fatty acids, process them into waste-based biodiesel or trade feedstocks and finished products. In 2018, the use of waste-based biodiesel in German road transport reduced GHG emissions by 3.6 million tons. Waste-based biodiesel makes an indispensable contribution to climate protection in European road transport, as it enables the existing ICEV fleet to also make a contribution to climate protection. The MVaK welcomes the opportunity to comment on the European Commission’s proposal on the Energy Taxation Directive (ETD) revision. In the following we would like to comment on some elements of the proposal. 1. Methodology change to an energy taxation based on the energy content of energy products and electricity (in EUR per gigajoule) In principle, we welcome the intended change in taxation of energy products to a taxation based on the energy content of energy products. We also welcome the overall lower minimum levels of taxation applicable to biofuels, although we are of the opinion that taxing these fuels, especially if they achieve a particularly high GHG reduction, is counterproductive for their increasing use. However, we consider a taxation of energy products based on their actual GHG emissions to be much more effective if the European Union wants to achieve its ambitious climate targets. The higher the GHG emissions of an energy product, the higher the taxation should be. Such taxation methodology would much more encourage the use of renewable energies, in particular from waste and residues, in the transport sector, and would also encourage the development of new production technologies and the utilization of additional, previously unused waste and residues. 2. Differentiated minimum tax rates for different energy products (Annex I, Tables A and B) In the context of the proposed change of the taxation methodology of energy products on the basis of their energy content, we consider it as urgently necessary to specify or supplement the designation "advanced sustainable biofuels and biogas" in the last line of each table to the effect that biofuels produced from feedstocks listed in Annex IX Part B of the RED II, are clearly included in this category. Such a clarification is more than justified. On the one hand, because Annex IX Part B feedstocks fall into the waste and residual materials category. Furthermore, biofuels made from used cooking oils are characterized by a particularly high reduction in GHG emissions, the use and production of which should be promoted accordingly and their higher production costs should be taken into account. In addition, the use of higher blends of wasted-based biofuels to fossil fuels would be encouraged, as these would become more attractive in terms of price for consumers at the pump. 3. Minimum tax rate of zero applicable over a transitional period for the use of certain renewable energies in the aviation and maritime sector (Articles 14 + 15) Basically, we see the rationale to set minimum tax rates of zero for “sustainable biofuels and biogas, low-carbon fuels, renewable fuels of non-biological origin, advanced sustainable biofuels and biogas, and electricity”. However, we would like to point out that in both aviation and maritime, the ReFuelEU Aviation Initiative proposal and the FuelEU Initiative proposal are intended to introduce funding mechanisms that will increase the use of such fuels in these segments. From our point of view, a tax relief going beyond this represents a clear disadvantage for the consumption of these fuels in road transport, which if produced from feedstocks listed in Annex IX Part B of RED II do not receive further funding if consumed in this sector. We therefore see it as necessary that minimum rates of zero shall also apply to such fuels if consumed in road transport over a transitional period.
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Response to FuelEU Maritime

8 Nov 2021

The Mittelstandsverband abfallbasierter Kraftstoffe e.V. (MVaK) represents 21 members which prepare suitable vegetable waste and residues, mainly used cooking oil and waste fatty acids, process them into waste-based biodiesel or trade feedstocks and finished products. The MVaK welcomes the opportunity to comment on the European Commission’s FuelEU Maritime proposal. Our members fully support the climate goals of the European Union and welcome the proposed regulation. By using waste-based biofuels fuels the maritime sector can make an immediate contribution to climate protection. In this context, we consider it practicable to use an increasing, mandatory GHG reduction target as key instrument for the sector, as it is in line with the intended change in methodology provided for in the RED II amendment. We also welcome that biofuels made from waste oils listed in Annex IX Parts A and B of RED II, including in particular used cooking oils, should play an “essential” role in achieving the climate goals of the maritime sector, as being stressed in Recital 11. Waste-based biodiesel in particular is an excellent fuel option for the maritime sector with regard to efficiency, to carbon abatement costs and to CO2 mitigation as stated in the studio Gear Up study: “Used cooking oil: one feedstock, different technologies. A comparative study”. In addition, many engines have already been approved for biodiesel usage in inland navigation, both for the usage of pure biodiesel and for the usage of different blends. The list “Approvals in inland navigation for operation with biodiesel (B7 | B20 | B30 | B100)”, which is attached to this statement, provides information about the current approval situation. In addition, numerous bunkering of waste-based marine fuels in seagoing vessels have also proven the suitability of engines used in this segment. As a general remark, we believe that feedstock efficiency, fair competition and an approach that is open to technology are essential in order to develop new technologies and to achieve the EU climate goals. We believe that the proposed trajectory for GHG intensity limits introduced in draft article 4.2 could surely have more ambitions targets in the 2025-2030 period to also stir development of sustainable advanced renewable liquid fuels produced from feedstocks listed in Part A of Annex IX of RED II. Such increase would be even more justified if and when the Commission adopts an expected delegated act adding new feedstocks to Annex IX. This adoption is expected during the early stages of the passage of the FuelEU legislative procedure therefore it would allow for an informed revision of the early years in the trajectory. Furthermore, we believe that additional feedstock could be made available as result of the ongoing electrification of road transport. In order to guarantee high sustainability standards and to trigger the development of novel technologies, a threshold value for a minimum greenhouse gas reduction of a renewable and low-carbon fuel taken into account should be introduced. We believe these greenhouse gas emission savings should be at least 65 % if compared to fossil fuel emissions.
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

27 Jul 2021

The MVaK - Mittelstandsverband abfallbasierter Kraftstoffe e.V. represents 21 members that process suitable vegetable wastes and residues, mainly used cooking oil and waste fatty acids, into waste-based biodiesel or that trade the feedstocks and finished products (www.mvak.eu). Our members are based in Germany, Austria and the Netherlands and make an indispensable contribution to reducing greenhouse gas emissions from road transport in the EU. We welcome the opportunity to state our views on the draft implementing regulation. Please find our feedback in the attached document.
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Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

Thank you for the opportunity to respond to this inception impact assessment on the upcoming revision of Regulation on CO2 standards for cars and vans. The MVaK, a Berlin-based association representing the interests of German, Austrian and Dutch waste-based biodiesel producers, strongly supports the introduction of a new mechanism allowing the contribution of sustainable renewable and low-carbon fuels for the purposes of compliance with CO2 reduction targets and welcomes the Commission’s preparatory work. The greenhouse gas (GHG) reduction potential of sustainable biofuels such as waste-based biodiesel in contraposition to fossil fuels should be taken in consideration. In Germany in 2019 waste-based biodiesel from used cooking oil (UCO) had 92.77 % GHG savings when compared with fossil diesel. In this context policy coherence would require that the contribution of renewable and low carbon liquid fuels, and specifically sustainable biofuels in application of the Renewable Energy Directive (RED II), should be enshrined in the upcoming revision by means of allowing car manufacturers to count sustainable biofuel use when proving compliance with new reduction targets. This would equally contribute to the EU renewed 2030 climate ambitions as a milestone towards carbon neutrality in 2050.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

20 Sept 2020

The MVaK represents companies from Germany, Austria and The Netherlands that operate along the entire value chain from waste collection to its processing into biodiesel. Below are our recommendations. 1. Upward revision of the 14% transport obligation (Article 25 (1)) The upcoming revision of the RED II will review the general 32% target of use of renewable energy in 2030, as stated in the European Green Deal and further confirmed in a recent Commission inception impact assessment on the upcoming RED II revision. This increased ambition is indeed a pre-requisite to pave the way towards achieving net zero emissions in the European economy by mid-century. In this regard and given the transport sector’s consistent position as a generator of a quarter of the EU GHG emissions, we believe that an increase of the specific 14% transport obligation for fuel suppliers to a minimum of 27% should be included in the new legislation. Taking into consideration the decarbonization potential of numerous technologies and feedstocks providing low-carbon liquid fuels the level of the new transport target should be significantly more ambitious compared to the eventual increase of the general renewable energy target. 2. Elimination of the 1,7/3,4% soft cap on the contribution of feedstocks in Part B of Annex IX (Article 27 (1)(b)) The revision of the RED II must not restrict today's most sustainable biofuels. In this respect the 1,7/3,4% soft limitation to the contribution of feedstocks in part B of Annex IX to the transport obligation should be eliminated as its rationale will be more flawed than even before by June 2021 for the following reasons: a. The limitation was never sound policy-making During the RED II negotiations the limitation was effectively deleted from subsequent drafts of the deal and it was only reintroduced in the final text of the Directive as a result of last-minute political bargaining between competing interests. Early deletions showed that co-legislators understood that the soft limitation rationale as an anti-fraud mechanism was deeply questionable, especially given the fact that other measures within the RED II were better suited to address these issues. By the expected date of publication of the proposal to revise the RED II in June 2021 this argument will be even more powerful as the Commission will adopt a new Union database and more stringent revised certification schemes. b. Adoption of a Union database In June 2021 at the latest the European Commission will set up a Union database for all biofuels and bio liquids in application of Article 28 (2) of the RED II. This database will include data on the transactions made and the sustainability characteristics of fuels, including their life-cycle GHG emissions, and therefore it will greatly minimize the scope for unsound market practices without the need of an artificial limitation of sustainable biofuels. c. Improved certification schemes By June 2021 the European Commission will endorse newly revised certification schemes including a wide range of improvements in application of Article 30 (4) and (8) of the RED II. A good number of these improvements will build upon industry-driven adjustments included in the “EWABA Standard of Transparency” listing measures identifying weak spots in the biofuels value chain. The adoption of revised stricter certification schemes will further reduce opportunities for fraud, thus strengthening the case to eliminate the soft limitation to part B of Annex IX. d. Inclusion of new feedstocks in Annex IX Also in June 2021 the Commission will approve the first amendment of Annex IX as established in Article 28 (6) of the RED II. This revision is highly likely to result in new feedstocks also being added to part B of Annex IX. Keeping a limitation whose level originally referred to used cooking oil and animal fats’ availability in a scenario in which new feedstocks are added to part B would be another example of unsound policy-making.
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Response to Sustainable and Smart Mobility Strategy

10 Aug 2020

We would like to thank you for the opportunity to comment on the roadmap on the upcoming Commission Communications on an EU Strategy for a Sustainable and Smart Mobility. The MVaK represents 22 members from Germany, Austria and the Netherlands that process waste and residues, mainly used cooking oil and waste fatty acids, into sustainable alternative fuels like waste-based biodiesel; or trade in feedstocks and finished products. In 2018, the consumption of sustainable biofuels in Germany in road transport reduced GHG emissions by 9.5 million t CO2-eq (source: BLE, Evaluation and Progress Report 2018). The consumption of waste-based biodiesel alone contributed 3.6 million t CO2-eq to these total savings. Thus, sustainable biofuels are already making an important and unique contribution to reducing GHG emissions of cars, light and heavy duty vehicles with conventional combustion engines. Even if alternative drive systems will find increasing use in road transport in the next few years, vehicles with conventional combustion engines will be an integral part of EU vehicle fleets for a few decades to come. Biofuels from waste and residues are characterized by a particularly high GHG reduction, which in the case of waste-based biodiesel is higher than 90%. If the waste-based biofuel is produced from used cooking oils, it also triggers the expansion of a used cooking oil collection with additional benefits for our environment and human health. Because on the one hand, the used cooking oil is not disposed of down the drain into the sewer system and on the other hand, the used cooking oil is withdrawn from multiple uses being hazardous to human health. In its Strategy for a Sustainable and Smart Mobility, the European Commission should therefore include biofuels produced from waste and residues as an important part of its mix of measures, should motivate the mobilization of the full potential of these biofuels without setting restrictions, and should pave the way for an EU wide consumption of diesel containing more than 7 percent biodiesel. With a view to the EU transport sector as a whole, a sustainable mobility strategy should also aim to achieve GHG emission reduction targets using the most efficient production methods, to encourage the use of new sustainable feedstocks and to promote regional added value. In addition, a sustainable mobility strategy should ensure that sustainable feedstocks that are already sensibly used are not diverted from their existing use as road transport fuel to other less efficient and less climate-friendly uses through indiscriminate subsidies. An EU Strategy for Sustainable and Smart Mobility should be linked to existing directives such as RED II and FQD in order to ensure a consistent framework for promoting renewable energies in the transport sector.
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Response to FuelEU Maritime

24 Apr 2020

The MVaK (Mittelstandsverband abfallbasierter Kraftstoffe e.V., waste-based biofuels association) represents 22 medium-sized companies operating along the value chain of waste-based biodiesel production in Germany, Austria and The Netherlands. MVaK members operate a production capacity of about 1 million tons of waste-based biodiesel which reduces GHG emissions by more than 90 percent. The MVaK welcomes the recent publication of an Inception Impact Assessment (IIA) on a future Directive titled FuelEU Maritime – Green European Maritime Space aiming to reduce GHG emissions in the maritime sector. Various low-carbon fuel options are already commercially available to sustainably mitigate GHG emissions in the maritime sector. Waste-based biodiesel is one of these options. We would welcome a Directive that not only aims to reduce greenhouse gas emissions in the maritime sector, but also enables investments in expanding the production of low-carbon fuels, develops novel feedstock streams, secures or even expands employment in medium-sized companies and creates regional added value.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

20 Apr 2020

The Mittelstandsverband abfallbasierter Kraftstoffe e.V. (MVaK) is a Berlin based association representing 22 medium-sized members along the value chain of waste-based biodiesel production in Germany, Austria and The Netherlands. The Commission’s Inception Impact Assessment (IIA) “ReFuelEU Aviation - Sustainable Aviation Fuels” sets out the Commission’s early thinking about a future legislative instrument to promote so called Sustainable Aviation Fuels (SAF), including a blending mandate and prioritization measures to direct liquid road transport fuels towards aviation, among others. Waste-based biodiesel cannot be used as aviation fuel given its cold flow properties. Hence we fear that a blending mandate or prioritization measures including UCO and animal fats as feedstocks would lead to the destruction of existing waste-based biodiesel value chains and would create economic damage in the majority of Member States by preventing regional added value. Regional UCO collectors and regional trading companies would be pushed out of the market or would be negatively affected as their customers will be reduced to a handful of multi-national HVO producers. Medium-sized regional waste-based biodiesel producers would lose their feedstock base. Furthermore, UCO-based biodiesel production is more efficient than HVO/HEFA/HEFA+ production and results in higher GHG savings than UCO-based HVO, as established in Annex V of the RED II. This difference is even higher as the values in Annex V relate to HVO for road transport and not HEFA or HEFA+, being used for aviation and being even more energy intensive to produce. And, as the number of electrical cars is increasing slowly, EU member states might lose waste-based biodiesel as their key tool to decarbonize existing car and truck fleets and finally to reach their near term climate targets. Therefore we believe that an upcoming legislative instrument to promote SAF should exclude UCO and animal fats as feedstocks for fuels accountable to a possible aviation target or any other similar promotion measure. Also prioritization measures should not target feedstocks for waste-based biodiesel production, such as UCO and animal fats, as they are already successfully and efficiently used by our members for the production of road transport fuel with GHG emission reductions higher than 90 %.
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Response to Import of used cooking oils

23 Jul 2019

On behalf of MVaK, a waste-based biofuels association representing members from Germany, Austria and The Netherlands, we would like to thank the Commission for the opportunity to comment on the proposed Comission Regulation supplementing Regulation (EU) No 142/2011 as regards health requirements for the import of used cooking oil (UCO). Our industry welcomes the fact that the proposed Regulation confirms the long-standing approach of the Commission allowing market operators to choose between waste and animal by-products status for UCO imports. However, we would like to note that the approach set out by this Draft Regulation will necessarily require that numerous market operators across different Member States either: i) adapt administrative procedures in their whole value chain to keep on selling their by-products to biogas and fertilizer producers under animal by-products controls, or ii) renounce to these sales and maintain UCO's waste status. In an industry characterised by extremely low margins either option will result in additional expenses or revenue loses, which is extremely regrettable. Furthermore, we are concerned that under the proposed draft imports should only be allowed via approved entry points. There are too few such points in Member States and these cannot cover the demand at the moment. The import points are partly booked out for months. We therefore suggest that this requirement is replaced by a provision establishing checks to random UCO samples. Finally, regarding Section 13 of the Draft Annex to the Commission Regulation, we would like to point out that: 1) The obligation under Section 13 (3) to maintain representative samples of each UCO consignment for a period of two years would require that numerous operators keep at any given moment several thousand UCO samples. This requirement would immediately result in additional investment in storage infrastructure and staff. We consider this requirement and its related expenses to be exaggerated and unjustifiably onerous. For this reason we would welcome if the requirement to maintain samples would refer to a 1-year period instead. 2) Regarding Section 13 (1) (b) ii & iii, it is essential to ensure that the joint storage of imported UCO, e.g. in a tank facility, can continue. It should be ensured that the documentation requirements in the context of channeling do not prevent mixing in tank farms and subsequent processing of individual batches. 3) Samples obtained by the lower aperture of a flexi-tank (the most common transportation method of UCOs) are highly likely to contain higher amounts of water and impurities given the natural sedimentation of UCO components in the tank. For this reason these samples might not be representative of the actual UCO composition. In cases in which a sample obtained from a flexi-tank does not meet the requirements of Section 13 (1) (a) a second reading should be allowed ensuring that the relevant sample is obtained from the discharged UCO. Many thanks for your consideration.
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