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Neste Oyj

Neste Oyj is a leading producer of renewable diesel and sustainable aviation fuel.

Lobbying Activity

Meeting with Nicolás González Casares (Member of the European Parliament)

6 Nov 2025 · Sustainable Aviation Fuel

Meeting with Jeannette Baljeu (Member of the European Parliament)

4 Nov 2025 · Decarbonised fuel

Meeting with Polona Gregorin (Head of Unit Climate Action)

29 Oct 2025 · Neste challenges and policy suggestions, as a major European SAF producer

Meeting with Eero Heinäluoma (Member of the European Parliament)

28 Oct 2025 · Sustainable Aviation Fuels, Sustainable Transport Investment Plan

Neste Proposes SAF Accelerator Act to Support Clean Tech Frontrunners

4 Sept 2025
Topic — A strategic framework to boost public and private investments into renewable transport fuels.
Message — Neste proposes a SAF Accelerator Act to strengthen markets for early-movers. They suggest boosting carbon trading support and introducing a fuel banking mechanism.12
Why — These measures would secure the business case for Neste's multi-billion euro investments and improve profitability.34
Impact — Fossil fuel suppliers face reduced market share as the plan aims to end their use.5
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Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra) and FuelsEurope and

1 Sept 2025 · Heavy-duty sector and the role of carbon-neutral fuels

Neste warns EU plastic rules threaten chemical recycling investments

19 Aug 2025
Topic — Establishing common EU rules for calculating and reporting recycled content in plastic bottles.
Message — Neste urges the EU to include existing refineries in the chemical recycling chain. They call for a full impact assessment on industry competitiveness.123
Why — This would protect Neste's multimillion-euro investments and lower costs for the chemical recycling industry.45
Impact — European industry faces reduced competitiveness and reliance on imports if investments move abroad.67
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Meeting with Apostolos Tzitzikostas (Commissioner) and

17 Jul 2025 · Implementation Dialogue on ramping up renewable and low-carbon maritime and aviation fuels production in the EU

Meeting with Eddy Liegeois (Head of Unit Mobility and Transport)

11 Jul 2025 · Sustainable Aviation Fuels

Neste Urges EU to Align Innovation Fund with Biofuel Rules

8 Jul 2025
Topic — An evaluation of the EU Innovation Fund’s operations and its support for decarbonisation.
Message — Neste requests that the application process minimize unnecessary repetition and clarify greenhouse gas guidance. They argue that the Innovation Fund should follow the Renewable Energy Directive's methodology. They also claim current financial maturity requirements are not realistic for many sectors.123
Why — Aligning rules would prevent challenges when moving from project development into the operation phase.45
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Neste urges EU to make bioeconomy a growth engine

23 Jun 2025
Topic — This consultation seeks views on building a circular, climate-neutral European bioeconomy strategy.
Message — Neste calls for policies that create demand for biomolecules across sectors to replace fossil materials. They recommend maintaining existing sustainability criteria to avoid complexity and support sustainable fuel scale-up.12
Why — These measures would protect Neste's massive refinery investments and improve its competitive position.3
Impact — Foreign fossil fuel exporters lose market share as the EU prioritizes domestic bio-based production.4
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Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

19 May 2025 · Sustainable Fuels, Sustainable Transport Investment Plan

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

19 May 2025 · Circular Economy

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

19 May 2025 · to follow

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné), Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné)

19 May 2025 · Presentation of the company´s projects and situation and state of play of SAF market in Europe.

Meeting with Dan Jørgensen (Commissioner) and

19 May 2025 · Biofuels, hydrogen

Meeting with Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra)

19 May 2025 · Exchange on steps to support early movers in the clean industrial deal

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

14 May 2025 · Sustainable Fuels, Bioeconomy

Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur) and BASF SE

10 Apr 2025 · Biotechnology and biomanufacturing

Meeting with Tom Berendsen (Member of the European Parliament) and Corbion

10 Apr 2025 · Biotech

Meeting with Christine Singer (Member of the European Parliament)

9 Apr 2025 · REFUEL EU

Meeting with Aurel Ciobanu-Dordea (Director Environment) and Braskem Netherlands

27 Mar 2025 · Exchange of views on the Bioeconomy Strategy and bioplastics

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

24 Mar 2025 · Visit to Neste’s APAC Innovation Centre

Meeting with Magda Kopczynska (Director-General Mobility and Transport) and Airbus and

24 Mar 2025 · Exchange of views with EU aviation and land transport industry on key policy developments in Singapore and ASEAN

Meeting with João Cotrim De Figueiredo (Member of the European Parliament)

6 Mar 2025 · Industrial policy

Meeting with Niels Flemming Hansen (Member of the European Parliament)

5 Mar 2025 · EU’s upcoming industrial policies, competitive decarbonization, and the role of European renewable refineries

Meeting with Martine Kemp (Member of the European Parliament)

4 Mar 2025 · Renewable fuels & SAF

Meeting with Bruno Tobback (Member of the European Parliament)

19 Feb 2025 · Biofuels

Meeting with Katri Kulmuni (Member of the European Parliament) and UPM-Kymmene Oyj and Braskem Netherlands

17 Feb 2025 · Biobased plastics in ELVR

Meeting with Li Andersson (Member of the European Parliament) and UPM-Kymmene Oyj and Borealis AG

27 Jan 2025 · Biobased plastics

Meeting with Xavier Coget (Cabinet of Executive Vice-President Henna Virkkunen)

21 Jan 2025 · Level playing field for renewable aviation fuels

Meeting with Jeannette Baljeu (Member of the European Parliament) and Braskem Netherlands and Borealis AG

16 Jan 2025 · End of life vehicles regulation

Meeting with Jussi Saramo (Member of the European Parliament)

14 Jan 2025 · Siirtymä kohti kestävää energiantuotantoa

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur) and UPM-Kymmene Oyj and

7 Jan 2025 · End-of-life of vehicles Regulation

Meeting with Kristian Vigenin (Member of the European Parliament)

11 Dec 2024 · Exchange of views

Meeting with Andrea Wechsler (Member of the European Parliament) and BASF SE and

10 Dec 2024 · EU Energy and industry policy

Meeting with Magda Kopczynska (Director-General Mobility and Transport) and TotalEnergies SE and

6 Dec 2024 · Investments in sustainable liquid fuels production in the EU

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

14 Nov 2024 · sustainable aviation fuels (SAF)

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

14 Nov 2024 · • Overview of Neste’s activities • SAF

Meeting with Héloïse Auplat (Cabinet of Executive Vice-President Margrethe Vestager), Ramona Ianus (Cabinet of Executive Vice-President Margrethe Vestager)

8 Nov 2024 · sustainable aviation fuel

Neste urges phased Union Database implementation to avoid market disruption

6 Nov 2024
Topic — EU regulation extending traceability data in Union Database for renewable fuels.
Message — Neste requests extended reporting timelines from three days to 30 days, removal of automatic transaction cancellations, and phased implementation after regulation adoption. They want clarity on initial stock registration and limits on non-UDB data requirements to reduce administrative burden.123
Why — This would reduce compliance costs and prevent smaller certified suppliers from leaving EU markets.4
Impact — Regulators lose stricter oversight as longer reporting windows delay verification of sustainable fuel claims.5
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Response to Greenhouse gas emissions savings methodology for low-carbon fuels

25 Oct 2024

Please find enclosed Neste's feedback concerning the methodology to determine the greenhouse gas emission savings of low-carbon fuels.
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Meeting with Nina Carberry (Member of the European Parliament)

16 Oct 2024 · EU Energy Policy

Meeting with Sérgio Gonçalves (Member of the European Parliament)

3 Oct 2024 · Priorities for this mandate in the TRAN Committee

Meeting with Anna-Maja Henriksson (Member of the European Parliament)

2 Oct 2024 · Climate change and the green transition

Meeting with Maria Guzenina (Member of the European Parliament)

1 Oct 2024 · EU priorities

Meeting with Stefan Köhler (Member of the European Parliament) and Philip Morris International Inc.

11 Sept 2024 · Politischer Austausch

Meeting with Daniel Attard (Member of the European Parliament)

10 Sept 2024 · Renewable Fuels & Transport Decarbonisation

Meeting with Bruno Gonçalves (Member of the European Parliament) and European Digital Rights and

9 Sept 2024 · ITRE policies

Meeting with César Luena (Member of the European Parliament)

5 Sept 2024 · Biofuels

Meeting with Andreas Glück (Member of the European Parliament) and TotalEnergies SE and Eni S.p.A.

17 Jul 2024 · Climate and Energy Policy

Meeting with Aura Salla (Member of the European Parliament)

17 Jul 2024 · Neste's vision of circular solutions for polymers and chemicals

Meeting with Jeannette Baljeu (Member of the European Parliament)

17 Jul 2024 · Biofuels

Response to Import of used cooking oils

29 May 2024

Neste welcomes the Commission's aim to clarify the requirements for the import of used cooking oil (UCO) to the EU. Nevertheless, Neste wishes to express concerns on the magnitude of the proposed new requirements as they appear excessive for a material ultimately meant to be combusted in an engine. The use of UCO is clearly banned in the feed for farmed animals (Regulation (EC) 1069/2009, article 11). Consequently, especially the proposed new requirement for the third-country UCO plants of origin to be registered in accordance with the EU animal by-product regulation (EC) 1069/2009 appears disproportionate. We consider that the harmonisation of the UCO import requirements should be achieved with simple and easy-to-implement measures. The measures should neither add unrealistic obligations on UCO suppliers in third countries nor be detrimental for the EU biofuels industry. Please find our detailed feedback and recommendations in the attached file.
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Meeting with Aleksandra Baranska (Cabinet of Vice-President Maroš Šefčovič)

22 May 2024 · Sustainable alternative fuels

Meeting with Maroš Šefčovič (Executive Vice-President) and

8 Apr 2024 · Dialogue on Clean Mobility

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Transport and Environment (European Federation for Transport and Environment) and

8 Apr 2024 · Energy market

Meeting with Anna Cavazzini (Member of the European Parliament, Committee chair) and Apple Inc. and

23 Feb 2024 · Aktuelle Themen in der Europapolitik und Sachsen

Meeting with Ville Niinistö (Member of the European Parliament)

30 Jan 2024 · Current topics of energy and industry policy

Meeting with Nils Torvalds (Member of the European Parliament)

9 Jan 2024 · Renewable Coal Technology

Neste urges non-fossil plastic targets for end-of-life vehicles

2 Dec 2023
Topic — This initiative aims to improve vehicle recycling and promote circular automotive design and production.
Message — Neste requests non-fossil targets to move away from virgin plastics. They argue for including chemical recycling and mass balance credits to provide manufacturers with more flexibility.12
Why — This would increase market demand for Neste's specific renewable and chemically recycled feedstocks.3
Impact — Traditional plastic manufacturers face losing market share to renewable and recycled material competitors.4
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Meeting with Nils Torvalds (Member of the European Parliament, Shadow rapporteur for opinion)

14 Nov 2023 · PPWR

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

13 Nov 2023 · Talking about the ongoing preparation of the political guidelines for the next Commission

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

9 Nov 2023 · Informal exchange - decarbonising transport - tour d'horizon.

Meeting with Isabel Carvalhais (Member of the European Parliament)

8 Nov 2023 · Opportunities and challenges to produce algae as sustainable feedstock for the EU’s bioeconomy

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Rapporteur)

6 Oct 2023 · Heavy -Duty: CO2 and emission performance standards for new Heavy-duty vechiles

Meeting with Henna Virkkunen (Member of the European Parliament, Shadow rapporteur for opinion)

3 Oct 2023 · Heavy-Duty Vehicles

Meeting with Elsi Katainen (Member of the European Parliament)

26 Sept 2023 · Discussions about Neste's expectations & priorities 2024-2029 and plenary session

Meeting with Helmut Scholz (Member of the European Parliament)

12 Sept 2023 · Net Zero Industry Act

Meeting with Helmut Scholz (Member of the European Parliament, Shadow rapporteur for opinion)

12 Sept 2023 · The Net-Zero Industry Act

Neste calls for shift from carbon storage to utilization

30 Aug 2023
Topic — The consultation explores how carbon capture and storage can help achieve EU climate goals.
Message — Neste urges the EU to prioritize using CO2 as feedstock for fuels and materials. They recommend a comprehensive strategy that moves beyond simple end-of-pipe carbon storage.12
Why — This shift would create more demand for Neste's renewable feedstocks and sustainable ingredients.3
Impact — Traditional fossil oil producers lose market share as manufacturers switch to renewable carbon feedstocks.4
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Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur)

18 Jul 2023 · Verkehrs- und Umweltpolitik

Neste urges EU to include sustainable biofuels as strategic technology

15 Jun 2023
Topic — The Net Zero Industry Act aims to scale up European manufacturing of green technologies.
Message — The organization requests that the strategic technologies list includes sustainable biofuels and sustainable aviation fuel. They also advocate for including carbon capture and use to support hydrogen production. They emphasize the need for investment certainty to ensure a level playing field.12
Why — Strategic status would allow Neste to access financial support for its renewable fuel projects.34
Impact — The European transport sector loses through slower decarbonisation and continued reliance on fossil fuels.56
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Meeting with Sirpa Pietikäinen (Member of the European Parliament) and Aula Europe

6 Jun 2023 · Proposal Packaging and Packaging Waste Regulation

Meeting with Erik Bergkvist (Member of the European Parliament)

5 Jun 2023 · Möte (APA level)

Neste urges EU to include renewable fuels in heavy-duty vehicle standards

19 May 2023
Topic — EU regulation setting CO₂ emission standards for new heavy-duty vehicles to support zero-emission mobility.
Message — The company requests that the regulation recognize sustainable renewable and low-carbon fuels like biofuels and e-fuels as contributors to decarbonization targets. They want a carbon correction factor introduced to account for fuel emissions reductions and require carbon-neutral fuels for combustion engine vehicles sold after 2040.123
Why — This would protect their renewable fuel business by ensuring continued demand for biofuels in heavy-duty transport.45
Impact — Zero-emission vehicle manufacturers lose competitive advantage as combustion engines remain viable with renewable fuels.6
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Meeting with Henna Virkkunen (Member of the European Parliament, Shadow rapporteur for opinion)

10 May 2023 · Heavy-duty Vehicles

Meeting with Andris Ameriks (Member of the European Parliament, Rapporteur for opinion)

9 May 2023 · HDV CO2

Response to Ecodesign for Sustainable Products - Product priorities

5 May 2023

Attachment: 1. Life Cycle Assessment of renewable liquid hydrocarbons, propylene and polypropylene, derived from bio-waste and residues (Elsevier, 2022) Polymer and plastics as intermediates The Ecodesign for Sustainable Products Regulation (ESPR) is an opportunity to make a major leap towards more sustainable production and consumption of products in the EUs circular economy. As 87.6% of EU plastics production is based on virgin fossil raw materials, the ESPR should support the transition to non-fossil plastics to support the EUs climate targets, create green jobs and reduce the reliance on imports of fossil raw materials (the use of oil as feedstock for plastics is likely to grow by 2050, even with major increases in recycling). Neste supports including polymers and plastics as a priority group under ESPR, with a narrow focus on the feedstock used for polymer production. Achieving the climate neutrality targets requires polymers and plastic production to move away from fossil. Prioritising polymers and plastics will allow the European Commission to identify the current gap needed to tackle the market failure that hampers the demand for recycled and renewable feedstock for polymer production; In addition, the ESPR is a regulatory mechanism that would support the EUs target of 20% non-fossil carbon for chemical and plastics production. Practical implications - non fossil content targets To reach a climate neutral plastics economy and decouple plastics packaging from the use of virgin fossil resources, reports from the Ellen MacArthur Foundation, the Minderoo Foundation and the Plastics Industry show that non-fossil renewable raw materials for plastics is needed in addition to reduction, reuse and recycling of plastics. Ecodesign measures for intermediates like polymers and plastics could include recycled and renewable (bio-based) content, as identified in the JRC report. The use of a virgin input to plastics will remain necessary because of the loss of material from reuse and recycling loops. The potential non-fossil virgin inputs for plastics include CO2-based and renewable biobased feedstocks. If just 10% of EU plastics switch from fossil to non-fossil biobased feedstocks, a study for the Commission shows that it would result in annual reductions of 4.4 Mtoe of fossil feedstocks and emission reductions of 6.2 Mt of CO2-eq. This is a very conservative estimate with only 30% GHG emission savings compared to fossil plastics. The evidence calls for the promotion of non-fossil virgin feedstocks as a complementary step to the other circularity measures to meet the EUs Green Deal and strategic autonomy objectives.
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Neste calls for non-fossil targets in EU plastic packaging rules

14 Apr 2023
Topic — The European Commission is updating requirements to promote sustainable packaging and recycling.
Message — Neste proposes adding new non-fossil targets for virgin plastics to support climate goals. They also suggest letting renewable materials help meet recycling targets during supply shortages.12
Why — The proposal would create regulatory incentives and market demand for Neste's renewable products.3
Impact — Fossil fuel suppliers face reduced demand as the industry moves away from oil.4
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Meeting with Silvia Modig (Member of the European Parliament)

12 Apr 2023 · Regulation on packaging and packaging waste and other topical issues

Meeting with Virginie Joron (Member of the European Parliament, Rapporteur for opinion)

15 Mar 2023 · polymers, plastiques recyclés ou fabriqués à partir du biologique

Meeting with César Luena (Member of the European Parliament)

15 Mar 2023 · MEP Luena's Team on the Packaging and Packaging Waste Regulation

Meeting with Asger Christensen (Member of the European Parliament)

14 Mar 2023 · Packaging and Packaging Waste Regulation

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

14 Mar 2023 · Meeting on PPWR

Meeting with Ville Niinistö (Member of the European Parliament)

14 Mar 2023 · PPWR

Meeting with Petri Sarvamaa (Member of the European Parliament)

14 Mar 2023 · Packaging and Packaging Waste

Meeting with Mauri Pekkarinen (Member of the European Parliament)

7 Mar 2023 · Meeting on Packaging and Packaging Waste Regulation, PPWR

Meeting with Heidi Hautala (Member of the European Parliament, Shadow rapporteur) and Nokia and Technology Industries of Finland (Teknologiateollisuus ry)

7 Mar 2023 · CS3D and Finnish Tech Sector

Meeting with Elsi Katainen (Member of the European Parliament)

7 Mar 2023 · Packaging and Packaging Waste Regulation, (PPWR)

Meeting with Salvatore De Meo (Member of the European Parliament, Rapporteur) and FoodDrinkEurope and

6 Mar 2023 · PPWR

Meeting with Luisa Regimenti (Member of the European Parliament, Shadow rapporteur) and Cosmetics Europe and

1 Mar 2023 · PPWR

Meeting with Henna Virkkunen (Member of the European Parliament)

26 Jan 2023 · EU Environmental Policy

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen)

19 Jan 2023 · Green Deal, Innovation Fund

Meeting with Cláudia Monteiro De Aguiar (Member of the European Parliament, Shadow rapporteur)

13 Sept 2022 · Refuel Aviation

Meeting with Barbara Thaler (Member of the European Parliament, Rapporteur for opinion) and TotalEnergies SE and

6 Sept 2022 · RED

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

1 Sept 2022 · Renewable Energy Directive

Meeting with Mauri Pekkarinen (Member of the European Parliament, Rapporteur for opinion)

1 Sept 2022 · Current EU affairs

Meeting with Nils Torvalds (Member of the European Parliament)

1 Sept 2022 · RED III

Meeting with Henna Virkkunen (Member of the European Parliament)

31 Aug 2022 · EU Energy Policy

Meeting with Elsi Katainen (Member of the European Parliament)

31 Aug 2022 · TRAN-Legislations

Meeting with Petri Sarvamaa (Member of the European Parliament)

31 Aug 2022 · Renevable energy directive

Neste urges flexibility in biofuel testing and allocation methods

15 Jul 2022
Topic — EU methodology for determining biofuel share from biomass processed with fossil fuels.
Message — Neste requests more flexible testing requirements, including occasional rather than per-batch radiocarbon verification and allowing stoichiometric allocation methods instead of only proportional allocation. They also propose extending permissible deviation in testing from 1% to 6% and reducing sample storage requirements from two years to three months.1234
Why — This would reduce their testing costs and storage requirements while allowing methods that better align with their refinery operations.56
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Neste urges EU to include paraffinic diesel alongside B100 biodiesel

29 Jun 2022
Topic — EU regulation on emissions type-approval for heavy duty vehicles using pure biodiesel.
Message — Neste requests that XTL paraffinic diesel be included as a reference fuel alongside B100 biodiesel. They argue technology neutrality requires recognizing multiple solutions. They want existing fuel flexibility provisions maintained and adjustments made to CO2 legislation and VECTO to include well-to-wheel calculations.123
Why — This would expand market opportunities for their renewable diesel product competing with biodiesel.45
Impact — Biodiesel producers lose regulatory preference as sole alternative to fossil diesel.6
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Neste urges more flexibility in EU industrial emissions revision

23 Jun 2022
Topic — The consultation seeks to update EU legislation ensuring industry contributes to environmental sustainability.
Message — Neste requests more time for transformation plans and asks they be kept at company level. They argue for flexible emission limits within established ranges to avoid excessive investment costs. They also want environmental management rules to avoid overlapping with existing regulations.123
Why — This would prevent unreasonable investment costs and protect sensitive business trade secrets.45
Impact — Environmental regulators and local communities lose access to detailed installation-level data.67
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Meeting with Nils Torvalds (Member of the European Parliament)

23 Jun 2022 · Fit for 55

Meeting with Henna Virkkunen (Member of the European Parliament)

21 Jun 2022 · Renewable Energy Directive

Neste urges EU to accept all CO2 sources for renewable fuel production

17 Jun 2022
Topic — EU methodology for assessing greenhouse gas emissions from renewable and recycled transport fuels.
Message — The company requests removal of restrictions on CO2 sources for renewable fuel production, arguing all CO2 that would otherwise be emitted should be accepted. They seek full credits for captured CO2 and annual updates to grid emission values to reflect rapid decarbonization.123
Why — This would accelerate their production capacity expansion and provide flexibility for annual GHG calculations.45
Impact — Environmental groups lose stricter standards ensuring CO2 sources are genuinely additional to climate goals.6
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Meeting with Frans Timmermans (Executive Vice-President) and Wärtsilä Corporation and

9 Jun 2022 · climate leadership from businesses

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

7 Jun 2022 · renewable energy directive

Meeting with Marco Campomenosi (Member of the European Parliament)

3 May 2022 · STAFF LEVEL Meeting with NESTE

Neste Urges Alignment Between Carbon Certification and Renewable Rules

2 May 2022
Topic — The Commission is developing a regulatory framework for certifying sustainable carbon removals.
Message — Neste wants the framework to align with existing renewable energy rules. They suggest removals should either offset emissions or be included in product footprint calculations. Finally, they recommend using voluntary schemes to manage certification.123
Why — This would help Neste reduce the life-cycle carbon footprint of its sustainable fuel products.4
Impact — Operators of biomass combustion for heat and power would see their technology excluded from promotion.5
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Meeting with Pascal Canfin (Member of the European Parliament)

29 Apr 2022 · Fit for 55

Neste urges early EU rules for low-carbon fuel investments

12 Apr 2022
Topic — Revision of EU gas rules to integrate renewable and low-carbon energy markets.
Message — Neste calls for low-carbon fuel rules to take force as early as possible. They argue regulation should be pragmatic and avoid creating barriers for investment decisions. They warn the 70% savings threshold may restrict opportunities for low-carbon processes.123
Why — This would provide the regulatory certainty needed to protect their capital investments.4
Impact — Environmental groups lose if high emission savings standards are relaxed or delayed.5
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

11 Apr 2022 · Renewable Road Transport

Meeting with Silvia Modig (Member of the European Parliament)

6 Apr 2022 · Fit for 55 -package

Meeting with Mauri Pekkarinen (Member of the European Parliament)

5 Apr 2022 · Discussion on Fit for 55

Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur) and Finnish Forest Industries Federation (Metsäteollisuus ry)

28 Mar 2022 · RED III

Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

We at Neste welcome the opportunity to provide feedback to the European Commission on the review of the Waste Framework Directive and support the Commission’s overarching objective of reducing total waste generation and ensuring high-quality recycling. In pursuing an improved overall environmental outcome of waste management, we believe there is an urgent need for a comprehensive approach that integrates all sustainable solutions to ensure that both binding and voluntary targets are met. Therefore, a comprehensive legal framework that acknowledges all recycling technologies, including chemical recycling, is crucial to achieving these goals. In the paper attached we do not only provide an input regarding chemical recycling, but also an overview of the projects that NESTE has already started implementing and that serve as evidence of our ongoing commitment to circularity: 1. Chemical recycling in the WFD; 2. Benefits of chemical recycling as a complementary technology to mechanical recycling; 3. Evidence of Neste’s first series of liquified waste plastic processing at industrial scale.
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Meeting with Nils Torvalds (Member of the European Parliament)

22 Feb 2022 · Renewable energy

Meeting with Caroline Nagtegaal (Member of the European Parliament, Shadow rapporteur)

7 Dec 2021 · AFIR/ReFuelEU aviation/RED

Meeting with Henrik Hololei (Director-General Mobility and Transport)

1 Dec 2021 · ReFuelEU Aviation

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson)

30 Nov 2021 · To discuss the decarbonisation of the European transport sector especially with a view to the Fit for 55 package and the proposal on the Renewable Energy Directive (RED III).

Neste backs energy tax shift but warns on electricity-biofuel link

17 Nov 2021
Topic — EU proposal to restructure energy taxation based on environmental performance and content.
Message — Neste supports energy content-based taxation rewarding environmental performance with lower rates for renewable fuels. They want Member States to retain flexibility for diesel tax rates and exemptions for high-blend biofuels. They oppose mandatory linking of electricity and biofuel tax levels.1234
Why — This would maintain preferential tax treatment for their renewable fuel products and protect diesel competitiveness.56
Impact — Fossil fuel producers face higher relative taxation as renewables receive preferential rates.7
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Neste urges EU to recognize renewable liquid fuels in infrastructure rules

17 Nov 2021
Topic — EU regulation on deploying alternative fuel infrastructure for low-emission transport.
Message — The company requests that the regulation continue recognizing renewable liquid drop-in fuels as viable alternatives, maintain flexibility for Member States to adapt infrastructure to local conditions, and align the new rules with existing EU legislation like the Renewable Energy Directive and Fit for 55 package.123
Why — This would protect their market for renewable diesel without requiring new infrastructure investments.45
Impact — Zero-emission vehicle adoption is slowed by prolonging reliance on combustion engines.67
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Neste urges broader feedstocks and higher SAF blending targets

17 Nov 2021
Topic — EU regulation mandating sustainable aviation fuel blending to reduce aviation emissions.
Message — Neste requests expanding eligible feedstocks beyond Annex IX materials, increasing blending targets above current levels, and allowing Member States to set higher national mandates. They argue current modest targets will make aviation climate goals difficult to achieve.123
Why — This would expand markets for their existing SAF production capacity reaching 1.5 million tonnes.45
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Neste urges EU to maintain biofuel feedstock flexibility in renewable energy rules

17 Nov 2021
Topic — Revising EU Renewable Energy Directive to align with higher 2030 climate targets.
Message — Neste requests removing proposed indirect emission factors for residue feedstocks and eliminating the 1.7% cap on Annex IX Part B feedstocks. They argue these restrictions would unfairly penalize sustainable biofuels and limit feedstock availability shortly after national implementation of current rules.123
Why — This would protect their existing biofuel investments and maintain access to diverse feedstocks.456
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Neste urges broader feedstock base for maritime renewable fuels

5 Nov 2021
Topic — EU regulation on renewable and low-carbon fuels in maritime transport.
Message — Neste requests that maritime fuel regulations permit all sustainable biofuels meeting RED II criteria, not just non-food/feed crop fuels. They want winter transport emissions exempted from trading schemes and global regulatory alignment with IMO standards.123
Why — This would lower their fuel costs and reduce compliance burdens for Nordic operations.45
Impact — Environmental groups lose stronger protections against food-crop based biofuels that compete with food production.
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Oil Refiner Neste Urges Maintaining Free Emission Allowances

5 Nov 2021
Topic — EU proposal to tighten emission trading system and expand to new sectors.
Message — Neste requests that free allocation of emission allowances remain at current levels for sectors outside the carbon border adjustment mechanism, particularly oil refining. They warn that overlapping measures create unpredictable effects and increase investment risks.123
Why — This would protect their international competitiveness and reduce compliance costs for refining operations.45
Impact — Climate goals are weakened as free allowances reduce the carbon price signal for refiners.6
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Neste urges protection of free carbon allowances for refineries

5 Nov 2021
Topic — EU proposal to strengthen emissions trading and market stability reserve for 2030.
Message — Neste requests that free allocation of emission allowances in the EU ETS should remain at current levels for sectors outside the carbon border adjustment mechanism, such as oil refining. They warn that too many overlapping measures create unpredictable effects on allowance demand and price.12
Why — This would protect their competitiveness and avoid compliance costs from purchasing allowances.34
Impact — Climate goals lose as refineries maintain free pollution permits instead of paying.5
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Neste urges keeping road transport emissions in Effort Sharing Regulation

5 Nov 2021
Topic — Amending binding annual greenhouse gas emission reductions by Member States for 2021-2030.
Message — Neste requests that road transport remain under the Effort Sharing Regulation rather than being moved to the EU emissions trading system. They emphasize maintaining member state flexibility in meeting targets and ensuring a broad feedstock base for biofuels.123
Why — This preserves demand for their biofuel products by allowing national implementation flexibility.45
Impact — No clear harm is identifiable; the position aligns with Commission impact assessment.
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Neste urges EU to credit renewable fuels in vehicle emission standards

5 Nov 2021
Topic — New EU regulation strengthening CO2 emission standards for passenger cars and light commercial vehicles.
Message — Neste requests that the EU either widen the definition of zero-emission vehicles to include renewable and low-carbon fuels, or introduce a voluntary crediting system. They argue this would allow sustainable fuels in internal combustion engines to contribute to emission reduction targets.12
Why — This would create market demand for their renewable diesel and alternative fuel products.34
Impact — Battery electric vehicle manufacturers face increased competition from combustion engine vehicles using alternative fuels.5
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Response to Policy framework on biobased, biodegradable and compostable plastics

26 Oct 2021

Neste welcomes the opportunity to participate in this consultation. We have provided detailed feedback, with concrete proposals, in the attachment. Below a summary of the key points: In material value chains, the introduction of sustainable bio-based and other renewable feedstock into products can have a positive climate impact, and are needed to complement recycled feedstocks by covering unavoidable material losses of recycling; Bio-based drop-in feedstocks provide an immediate alternative to the use of fossil resources in plastics manufacture at minimum infrastructure costs; Credible and implementable sustainability criteria together with traceability requirements for bio-based content are needed to ensure credibility of sustainability claims. Neste supports using partly the existing sustainability criteria for biofuels, with needed adjustments; Policy recommendations: Promote the mandatory use of bio-based plastics (or bio-based content) or prioritise their use by specifying the circumstances under which bio-based plastics are to be preferred over (virgin) fossil-based plastics; Clear and harmonised labelling for the bio-based content in all material end-use segments. Increase the use of bio-based plastics in green public procurement; Recommending that Extended Producer Responsibility (EPR) scheme obligations be modulated to incentivise bio-based content; At national level, providing appropriate financial incentives. Neste in brief: Neste (NESTE, Nasdaq Helsinki) creates solutions for combating climate change and accelerating a shift to a circular economy. We refine waste, residues and innovative raw materials into renewable fuels and sustainable feedstock for plastics and other materials. We aim at helping customers to reduce greenhouse gas emissions with our renewable and circular solutions by at least 20 million tons annually by 2030.
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Response to European Bioeconomy Policy: Stocktaking and future developments

27 Jul 2021

Neste response on the Roadmap on European bioeconomy policy: stocktaking and future developments A strong European bio-based sector is indispensable to achieve the European Green Deal’s climate neutrality target by 2050, while accelerating the economic recovery. A comprehensive approach integrating all sustainable solutions is urgently needed and the bio-based industries have a key role to play in reducing the EU's dependence on fossil fuels. A full implementation of the EU Bioeconomy Strategy across multiple policy areas is therefore essential to meet all the ambitious EU targets. Neste is committed to accelerating resource efficiency, by increasing the amount of potential waste and residues that are returned to material life. We believe that to create a resource efficient circular economy, we need to extract as much value as possible from raw materials being used, such as by utilising unavoidable waste and residues from production processes. Unlocking the value of waste The EU has an opportunity to valorise these specific material streams that occur during the processing of existing raw materials. A clear policy framework with a holistic definition of processing residues is needed that can support the industry in diversifying feedstock portfolios and moving away from fossil fuels. A strong, clear policy direction There is a number of upcoming policy initiatives aimed at delivering the objectives of the Green Deal, but we are yet to see a strong signal from policy makers to utilise the potential of the bioeconomy in these areas. By setting the right policy framework and incentives, the European Commission can encourage Neste and others to innovate, diversify their feedstock portfolio, and maximise value from existing resources, preventing valuable materials from being wasted, decreasing dependence on fossil fuels, reducing greenhouse gas emissions and offering truly circular solutions which promote resource conservation. About Neste Neste is a world leader in producing hydrocarbons based on biomass, from which bio-based plastics can be made. For more than ten years, Neste has been investing in R&D to turn a variety of low-quality waste & residues from sustainable sources into valuable chemicals for use in plastics production. We source waste and residues globally for our renewables refineries located in Finland, the Netherlands and Singapore. We continue to invest in developing our ability to process an even wider range of low-quality waste and residues to support industry transformation towards a resource-efficient economy. We have set a target to grow their share from the current 80% to 100% of the company’s total annual renewable raw material inputs by 2025. More information can be found at www.neste.com Registration on EU Transparency Register: 10257354120-19
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Neste urges member states retain authority over waste classification

27 Jul 2021
Topic — EU rules for verifying sustainability criteria for biofuels, bioliquids and biomass fuels.
Message — Neste requests that member states, not individual auditors, determine waste or residue status of feedstocks. They want Annex IV to remain non-exhaustive, allowing new waste and residue definitions. They seek inclusion of intermediate cropping and silvopastoral crops in the eligible feedstock list.123
Why — This would preserve regulatory flexibility for developing novel low-ILUC feedstocks and value chains.45
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Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson)

6 Jul 2021 · RED II revision – GHG calculation rules – transport

Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

10 Jun 2021 · Roundtable of the Clean Hydrogen Alliance: 3rd meeting of the co-chairs

Neste urges streamlined forest biomass sustainability rules for biofuels

28 Apr 2021
Topic — EU operational guidance on forest biomass sustainability criteria under renewable energy rules.
Message — Neste requests that the guidance adhere to existing RED II language and avoid excessive requirements. They argue that compliance with national forestry practices should be sufficient and propose recognizing forest certification schemes. For low-risk sourcing areas, they seek a simplified compliance process using an EU-approved list.1234
Why — This would reduce compliance costs and administrative burden for their forest biomass sourcing operations.56
Impact — Environmental groups lose stricter oversight mechanisms for detecting unsustainable forest biomass harvesting practices.7
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

27 Apr 2021 · SSMS, Fit for 55 Package

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

23 Apr 2021 · ReFuel EU

Response to Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies

29 Mar 2021

Neste answer to: State aid General Block Exemption Regulation (GBER) - exemptions to approval requirement for the Green Deal and EU industrial and digital Strategies, Roadmap & Inception Impact Assessment Consultation BACKGROUND Neste is a company that creates solutions for combating climate change and accelerating a shift to a circular economy. We are the world’s leading producer of renewable diesel and sustainable aviation fuel, developing chemical recycling to combat the plastic waste challenge. NESTE’S POINT OF VIEW We welcome the EU target of carbon neutrality by 2050 but also it is important to recognise that all tools and technologies are needed and Member States should not be hindered to be forerunners in reaching a carbon-neutral society. GBER should be fully aligned with the relevant sectoral legislation, e.g. with the RED II Directive for biofuels. General block exemption Regulation (GBER) and EEAG provisions never were in line with the definitions of the Renewable Energy Directive. Now that the recast Renewable Energy Directive (RED II) has been enacted, there is an opportunity to align the definitions and the approach to aid with the RED II. Most importantly, the undefined concept of "food based biofuels" in GBER should be replaced with the concept of "biofuels produced from food and feed crops". The concepts of "biofuels" and "food and feed crops" are defined in Article 2 of RED II. When designing the approach to aid under GBER and EEAG, it should be noted that the outcome of the RED II Directive was to maintain "biofuels produced from food and feed crops" eligible for national support schemes as defined in RED II. The volumes of these biofuels will be capped at 2020 consumption levels (+1 %-unit, max 7%), but they will remain eligible for national support schemes. Therefore the differentiation between "biofuels produced from food and feed crops" and other biofuels in the GBER should be questioned. Do not discriminate technologies based on feedstock, instead overall greenhouse gas reductions should work as a base Neste believes that all biofuels should be defined on neutral criteria, rather than origin or technology. It is important for the GBER to promote the technologies reducing greenhouse gas emissions most effectively. The approach with a GHG emission reduction threshold is also proposed in the draft delegated act on Sustainable Finance Taxonomy screening criteria for biofuels. Also Taxonomy criteria should be fully RED II aligned. By this way, when updating the Renewable Energy Directive, all other regulations would be automatically updated, too - without any harmful delays.
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Meeting with Pascal Canfin (Member of the European Parliament)

4 Mar 2021 · Fit for 55

Meeting with Henrik Hololei (Director-General Mobility and Transport)

24 Feb 2021 · SAF

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

24 Feb 2021 · Renewable energy, circular economy

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

23 Feb 2021 · Discussion of EU action to reduce greenhouse gas emissions through decarbonisation of European transport, including the upcoming revision of the Renewable Energy Directive (RED II).

Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

8 Dec 2020

The 2014 EEAG has allowed certain countries within EEA to boost the consumption and therefore production of biofuels through tax measures complementary to national biofuel blending obligations. While the provisions in EEAG on biofuels are not entirely clear and drag behind the EU legislation in terms of definitions, they have allowed these countries to pursue ambitious biofuels policies, which have resulted in very significant greenhouse gas emission reductions in the transport sector. With the revision on EEAG we call for fact-based, coherent, predictable and clear guidelines as regards biofuels that are based on understanding of markets, technologies and raw materials. EEAG should be fully aligned with the relevant sectoral legislation EEAG and related GBER provisions never were in line with the definitions of the Renewable Energy Directive. Now that the recast Renewable Energy Directive (RED II) has been enacted, there is an opportunity to align the definitions and the approach to aid with the RED II. Most importantly, the undefined concept of "food based biofuels" in EEAG should be replaced with the concept of "biofuels produced from food and feed crops". The concepts of "biofuels" and "food and feed crops" are defined in Art. 2 of RED II. When designing the approach to aid under GBER and EEAG, it should be noted that the outcome of the RED II Directive was to maintain "biofuels produced from food and feed crops" eligible for national support schemes as defined in RED II. The volumes of these biofuels will be capped at 2020 consumption levels, but they will remain eligible for national support schemes. Therefore the differentiation between "biofuels produced from food and feed crops" and other biofuels in the EEAG should be questioned. When the EEAG was elaborated in 2014, the European Commission held the view that food based biofuels should no longer receive public support after 2020. However, this is no longer the case, as the EC proposal and especially the final text of RED II as adopted by the EU legislator make clear. It should be noted that there are also biofuels that are produced from residues or wastes that are not listed in Annex IX, part A, of RED II, but still are eligible for national support schemes. Art. 27.1.b which defines the numerator of the obligatory share of renewable energy in transport and corresponding blending obligations, makes it clear that the energy content from all types of renewable energy are eligible - hence also biofuels made from feedstocks which are neither "produced from food or feed crops" (definition excludes explicitly waste and residues) nor are included in the list of "advanced biofuels", are eligible for national support schemes. Do not discriminate technologies based on feedstock pathways, instead overall greenhouse gas reductions should work as a base As the climate ambitions are strengthened the Commission will have to rely more on biofuels, at least in the transition phase to electricity. In the recent publication of the JRC on Well-to-Wheels emissions from a large number (>1600 pathways) of fuels it was clear that biofuels almost always were significantly better than fossil gasoline, diesel or natural gas. Some biofuel pathways (waste as feedstock) represent even a lower GHG route than zero-emission vehicle pathways with electricity and hydrogen. This must be reflected in the EEAG. We believe that all biofuels should be defined on neutral criteria, rather than origin or technology. It is important for the EEAG to promote the technologies reducing greenhouse gas emissions most effectively. Thus, the EEAG should judge the potential of state aid based on GHG reduction. We firmly believe that biofuels, being new technologies and more expensive to produce than fossil fuels, need financial support.Biofuels contribute greatly to the overall EU climate goals.Emerging biofuel pathways need several years to reach financial break even, and will need additional support.
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Response to Climate change mitigation and adaptation taxonomy

4 Dec 2020

Neste Corp. (neste.com) fully supports the Green Deal’s ambition for climate neutrality in 2050 as well as stepping up the GHG emissions reduction target to at least 55% by 2030. Neste also supports the objectives of the EU’s sustainable finance action plan and climate targets. Neste itself targets carbon neutral production by 2035 (including conventional oil refining). Thus, we think that fostering sustainable financing by providing transparent information is important for the financial markets to contribute to climate action. Due to limited space, only Annex I section 4.13 is commented here, please find attached Neste’s comments also to the sections 3.16, 6.3, 6.6, 6.10 and 6.17. Manufacturing of biofuels (section 4.13) Neste welcomes the fact that the draft Delegated Act considers all waste- and residue-based biofuels that comply with the GHG emission saving threshold as environmentally sustainable. These biofuels can reduce up to 90% of greenhouse gas emissions compared to fossil fuels according to the method of the EU’s Renewable Energy Directive (RED II). They clearly meet the Taxonomy Regulation’s criterion for contributing substantially to climate change mitigation and for Do Not Significant Harm (DNSH) principle. However, consistency with RED II is not complete, which should be the case in order not to exclude sustainable biofuels which can significantly reduce greenhouse gas emissions. Therefore, taxonomy should be fully consistent with the existing EU law (RED II) regarding the sustainability criteria for feedstock. - Food and feed crop based biofuels should not be excluded as there is already a 7% cap for them in RED II, and as there is also the Delegated Act on high-ILUC feedstock that phases out high ILUC risk crops such as palm oil. Also this exclusion would seem to leave out some categories of “novel vegetable” oils such as cover crops, winter crops, cultivation in degraded land etc. that have no or low ILUC effects, high GHG reduction potentials as well as other agricultural benefits. - RED II should continue to set the sustainability criteria for biofuels, and full alignment means taxonomy technical screening criteria would be updated automatically in case of changes to RED II. Classifying biofuels as only transitional activity is ill-suited. Several Member States will be relying on significant greenhouse gas emission reductions from the use of biofuels in transport when aiming for carbon-neutrality by 2050. - There will be a need for biofuels until 2050. While electrification will gradually advance in the passenger car segment, there will still be internal combustion engine cars sold in 2030 and beyond, and the average age of scrapped cars is close to 20 years in several European countries. For vans and trucks, the internal combustion engine will remain the dominant technology for a long time, and the life-cycle of these vehicles is longer than in passenger cars. To reach the ambitious goals of the EU Green Deal, investments into biofuels in transport should be incentivised by Taxonomy screening criteria like in the original Sustainable Finance Regulation, not discouraged. - Without a wide base of sustainable raw materials the GHG emission reduction targets in transportation, aviation included, will be very difficult to reach. It is therefore important to have all the sustainable waste and residue feedstocks included that reduce greenhouse gas emissions significantly (at least 65%) to be eligible under the Taxonomy’s scope. Long term view and consistency on regulation are very important in capital intensive industries like energy. - If taxonomy criteria would be too limited, investors might decide not to invest into all RED II complying (but not Taxonomy eligible) biofuel production capacity, which would slow down the possibilities to reduce GHG emissions - in contradiction with the ultimate target of the Taxonomy criteria and the whole sustainable finance framework.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

3 Dec 2020 · SAF

Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

Neste (neste.com) fully supports the Green Deal’s ambition for climate neutrality in 2050 as well as stepping up the GHG emissions reduction target to at least 55% by 2030. In our view higher targets within the existing legislative framework can deliver these results. Maintaining the existing EU regulatory frameworks, which were very recently agreed to reach the 2030 targets and which were implemented or are being implemented by the Member States provide much-needed predictability for investors. ESR should be kept in parallel to the EU ETS (Option 2) The ESR has been a well-functioning tool in driving decarbonisation in the non-ETS sectors. Giving an overall target for each Member State has allowed the MSs to decide on the regulation most fit for their national circumstances. This has resulted in very ambitious blending mandates for biofuels in some of the MSs, most notably Sweden and Finland where steadily increasing levels of mandates have had very positive effects in decarbonising road transport. This was also just recently acknowledged by EEA, the European Environment Agency(*). The ambition level inside the ESR should be increased to reflect the overall emissions reduction targets - and also aim for more even responsibilities between ETS and non-ETS sectors. This can best be done without abolishing the ESR. Instead, increasing the Member States’ greenhouse gas emission targets further would be a good solution. Furthermore, under ESR-sector, RED II has been an effective tool when it comes to driving down emissions from road transport. Therefore, in our view, the best option is to keep RED II, ESR and fuel quality directive (FQD) article 7a as the main instruments for this sector. Road transport not to be included in the EU ETS Decarbonisation of road transport is already driven by several means. As noted, they have proven to be very effective. These measures have been agreed until 2030, like the ETS Phase 4, and businesses across Europe have made their investment plans accordingly. Dismantling, or just revising, the framework for the next decade would be very harmful, decreasing predictability and consistency and thus, slowing down or stopping the investments already in the pipeline. In addition, including transport in the ETS would lead to overlapping regulation. Energy Taxation Directive would be the proper place to add CO2 tax on fuels. Moreover, the anticipated carbon price (25-50€/t, subject to volatility) in the ETS is not sufficient to drive road transport decarbonisation. This would mean, under the same emission cap, that other ETS sectors like industry would have to reduce their emissions more as well as pay more for the emissions allowances they would need. The road transport sector would continue to use fossil fuels instead of reducing their emissions more than there is potential to have electrification in place. -- *) https://www.eea.europa.eu/data-and-maps/indicators/greenhouse-gas-emissions-intensity-of/assessment: In Finland and Sweden emission intensities for road transport fuels decreased by more than 6% according to the data. This is because their road transport fuel mixes have relatively high proportions of biofuels (8% in Finland and 23% in Sweden) and, on average, the biofuels used have relatively low emission intensities.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Neste fully supports the Green Deal’s ambition for climate neutrality in 2050 as well as stepping up the GHG emissions reduction target to at least 55% by 2030. In our view higher targets within the existing legislative framework can deliver these results. When redesigning legislative framework fit for 55% target, coherency and visibility to future legislation are essential for the industry implementing these targets. ETS is linked to several other legislative actions like CBAM, ETD, ESR, RED II, LULUCF etc. While implementing the Green Deal all of these are under review. This makes commenting on one single piece of legislation challenging. Road transport decarbonisation should stay outside ETS The EU biofuels industry has reached a world-scale status and competence largely due to drivers provided by progressive regulation on biofuels. To provide sufficient visibility and predictability for actors, the RED II framework should be the key also from now on. RED II is agreed until 2030, and businesses across Europe have made their investment plans accordingly, thus dismantling, or just revising, this framework now would be very harmful. RED II should be maintained as a key tool to decarbonise transport. Extending ETS to road transport would only mean double regulation in the transport sector. Anticipated carbon price of the ETS not sufficient to drive transport decarbonisation The carbon price required to be effective for transport would be considerably higher than currently estimated for future ETS. That would lead to high and unacceptable cost for most other industrial sectors leading to threat of carbon leakage as well as investment and job leakage from the EU to other areas. Combining current ETS and road transport under the same emission cap may lead to a situation where other ETS sectors will have to reduce their emissions as well as pay more for emissions allowances they would need. The road transport sector would continue to use fossil fuels instead of reducing their emissions more than there is potential to have electrification in place. RED II has the intention to drive the adoption of emerging lignocellulosic fuels and other advanced biofuels based on raw materials listed on RED II Annex IX, part A. A cross-sectoral ETS approach only would eliminate the incentive to invest in first-of-their-kind production units as ETS price levels are very unlikely to provide the economic attractiveness needed to operate these units profitably. Interlinking between ETS, CBAM and energy taxation directive revision need to be solved coherently. In some countries - like Finland and Sweden - fuel CO2 taxation has successfully contributed to transport decarbonisation. Learning from these best practices should be considered when revising taxation and overlapping with ETS avoided. ETS needs to properly consider CCS and CCU CCS and CCU are increasingly raising interest as tools for decarbonisation and circularity of carbon. ETS as of now does not provide an enabling and clear role for those technologies. For CCS, e.g. ship transport of CO2 to storage facilities must be unequivocally allowed. For CCU, Power-to-X technologies offer new circular uses for carbon. Deduction of the carbon captured and utilised for further uses needs rules which incentivise novel technologies to be developed. Uncertainties of regulatory treatment of CCS and CCU are hindering technological development in this area.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

29 Oct 2020 · Sustainable aviation fuels

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

20 Oct 2020 · virtual meeting on the decarbonisation of the European transport sector and strengthening of the circular economy.

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

16 Oct 2020 · Sustainable/Green finance

Meeting with Jutta Urpilainen (Commissioner) and Aula Europe

13 Oct 2020 · decarbonisation and circular economy

Meeting with Henrik Hololei (Director-General Mobility and Transport)

12 Oct 2020 · Sustainable aviation fuel

Meeting with Adina-Ioana Vălean (Commissioner)

1 Oct 2020 · Decarbonisation of road and the sustainable mobility strategy

Meeting with Adina-Ioana Vălean (Commissioner)

1 Oct 2020 · Transport

Neste warns RED II revision threatens investment certainty

21 Sept 2020
Topic — The Commission is reviewing the Renewable Energy Directive to align with 2030 climate goals.
Message — Neste cautions that reopening legislation before implementation creates uncertainty and slows investment. They recommend only increasing numerical targets rather than renegotiating technical articles or sustainability criteria.123
Why — Maintaining current rules provides the regulatory certainty needed to protect Neste's ongoing industrial investments.45
Impact — Carbon tax advocates lose influence as Neste pushes for fuel mandates over pricing mechanisms.6
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

6 Aug 2020

Neste Corp. (www.neste.com) is the world’s largest producer of renewable diesel refined from waste and residues, introducing renewable solutions also to the polymers and chemicals industries. Our business is focused on combating climate change and driving circular economy, and we are committed to becoming a solution provider in chemical recycling by providing cost-effective and sustainable innovations. Neste has pledged to work towards chemically recycling more than 1 million tons of plastic waste annually from 2030 onwards. Neste is also a founding member of the European Plastics Pact, where we are working towards four goals aimed at design, responsible use, recycling capacity and the use of recycled content. We support the development of an EU legislative framework that enables and accelerates circular value chains. Therefore Neste also supports the Commission’s intention as part of the European Green Deal to review the requirements on packaging and packaging waste in the EU, including the aim to improve packaging design to promote reuse and recycling, to increase recycled content and sustainably produced and recyclable bio-based content in plastics as a way to reduce the use of virgin fossil-based plastics and CO2 emissions, and to reduce packaging waste. To support these goals, Neste invests in chemical recycling technologies to liquefy waste plastic, which can help Member States reach packaging waste recycling targets, and enable the incorporation of high quality recycled content in plastic materials. Moreover, Neste produces concrete solutions such as drop-in bio-based plastics for packaging, which can help the EU meet its ambitious targets, being inherently recyclable and reducing the use of virgin fossil raw materials. Please find our detailed feedback in the attached document.
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Response to Sustainable and Smart Mobility Strategy

16 Jul 2020

Neste (http://www.neste.com) welcomes the Commission’s roadmap for the EU Strategy for a Sustainable and Smart Mobility. Neste supports the European Green Deal and its target to reduce transport-related greenhouse gas emissions by 90% by 2050. Neste itself targets carbon-neutral production by 2035 (footprint) and at least 20 Mt CO2eq emission reduction by 2030 for our customers (handprint). The right regulatory framework conditions must be put in place in order to fully deploy the GHG emission reduction potential from different sectors. <b>Coherence and alignment of all relevant regulations needed</b> Coherence and alignment of legislation is important in order to achieve cost-effective solutions and a predictable and supportive regulatory environment. The policies and legislation set and updated by the Sustainable and Smart Mobility Strategy should therefore be drafted in full consistency with all existing legislation such as AFID (Alternative Fuel Infrastructure Directive), CVD (Clean Vehicle Directive), vehicle CO2 regulations, FQD (Fuel Quality Directive), RED II (Renewable Energy Directive), ESR (Effort Sharing Regulation), and ETD (Energy Taxation Directive) added with a CO2 component. Specifically, Reference Fuel and Vehicle CO2 Regulations should be aligned with AFID and other aforementioned directives by <b>supporting all the available low-emission solutions with well-to-wheel (WtW) based assessment</b>. Such technology-neutral approach ensures a level playing field and market competition resulting in more flexibility and lower total costs, helping <b>to secure affordable and sustainable mobility for all</b>. <b>Sustainable biofuels needed</b> To ensure that Europe as a whole meets the targets set by the European Green Deal, we must urgently consider all available sustainable and technically advanced solutions like sustainable biofuels. Paraffinic biofuels (such as HVO, Hydrotreated Vegetable Oil) improve the quality and efficiency of fuels and are fit for the current car, bus, and truck fleets as blended or as 100% non-blended (neat) biofuel in line with EN 15940. Regarding sustainable aviation fuels (SAFs), the demand needs to be created by regulations. Voluntary demand has been slowly growing but it is not enough to drive the decarbonisation of aviation with the necessary speed. Jet fuel taxation or sharpening of ETS will not lead to decarbonisation of aviation nor incentivising the necessary SAF production investments. Lead times for investments and development of new pathways are long. Thus, we need to start to deploy SAF immediately with readily available pathways and with a long-term credible outlook created by regulatory support such as blending mandates that will then trigger the investments. <b>RED II is the right instrument for road transport decarbonising</b> RED II is the key driver for decarbonizing transport until 2030. RED II has the intention to drive e.g. the adoption of emerging lignocellulosic fuels and other advanced biofuels based on raw materials listed on RED II Annex IX, part A. A cross-sectoral emission trading scheme (EU ETS) approach would eliminate the incentive to invest in first-of-their-kind production units, as ETS CO2 price levels are very unlikely to provide the economic attractiveness needed to operate these units profitably. As a consequence, the EU ETS would not be the right instrument for fulfilling the emission reduction needs in the road transport sector. <b>Need for consistency between EU Taxonomy and sectoral legislation</b> For example, the RED II sets stringent sustainability criteria for renewable energy, including biofuels. Under RED II, all biofuels must reduce GHG emissions by at least 50...65% compared to fossil fuels. To reach the ambitious goals of the Green Deal, investments into all sustainable biofuels that at least halve the greenhouse gas emissions in transport should be incentivised by Taxonomy, not discouraged.
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

23 Jun 2020 · Sustainable biofuels in the EU Taxonomy, Neste's position paper

Response to Chemicals strategy for sustainability

18 Jun 2020

Neste Corp. (www.neste.com) agrees that Europe needs an innovative, responsible and sustainable chemicals industry and needs to strengthen its capacity to produce chemicals in a sustainable and competitive way. Neste is in favour with the aim to simplify and strengthen the legal framework. The chemicals legislation in the EU covers more than 40 pieces of legislation and these have overlaps and inconsistencies that make complying with all relevant legislation challenging. Industry and all actors in the field should with reasonable resources be able to clarify, understand and follow all the requirements they are obliged to. An example of some inconsistency is the interphase between environmental and worker protection and Seveso legislation in relation to exposure scenarios according to the REACH Regulation. Overlaps create situations where a company gets conflicting requirements or guidance on the same issue of handling a certain chemical safely. The overlapping requirements create heavy administrative burden in the companies and often do not lead to better protection of the environment or worker health. As this issue has been acknowledged by several actors in the legislative field already years ago, we are hopeful that it will be effectively addressed in the coming strategy. Neste supports the development of an EU legislative framework that enables and accelerates the development of the European recycling ecosystem and value chains. To accelerate circularity, the interface between waste-chemicals-product legislation is a key for Neste. Our aim is to provide value for society by developing circular waste feedstock to high value products for transportation and chemical and plastics industries. Therefore legal clarity, similarly interpreted in the whole EU, in that field is extremely important to us. The utilization of waste as feedstock is creating global markets and should be enhanced also by legislative means when we are truly building a new circular economy. Neste sees that renewable, low-emission and circular solutions for transportation, aviation and marine uses as well as for the chemical and plastics industries supports the targets of the Green Deal and the Chemicals strategy. Neste supports the European Green Deal (EGD) and its aim to increase the EU’s climate ambition. Neste itself targets carbon-neutrality by 2035. However, the right regulatory framework conditions must be put in place in order to fully deploy the GHG emission reduction potentials from different sectors. To ensure that Europe as a whole meets the targets set by the European Green Deal, we must urgently consider all available sustainable and technically advanced solutions like sustainable biofuels, aviation fuels and bio-based polymers and chemicals. The assessment of complex substances needs to be regulated and carried out based on science but with focus on avoiding unnecessary animal testing. Utilization of new methods like read-across will enhance a sustainable way to understand properties of complex substances and further lead to sound chemicals management. Generally, there is a need to understand more holistically the eventual purpose of the safety legislation and risk assessment. It should not be to maximise the amount of different one-chemical related restrictions or requirements but more to make it sure that manufacturing, importing, distributing and using chemicals and products is not harming human health or the environment. To ensure that risk management of chemicals is on the right level we must look at the actual risks in different situations. This requires a lot from companies but it would also require the legislators, agencies and authorities in the EU to work for the same path and ensure that all possible is done to avoid duplication and contradictions in the legislation and its interpretation valid at the time.
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Neste urges EU to include renewable fuels in integration strategy

8 Jun 2020
Topic — This consultation explores better linking energy sectors to optimize the European energy system.
Message — Neste argues for including renewable fuels to decarbonize sectors like aviation and heavy-duty transport. They propose an EU-wide blending mandate for sustainable aviation fuels and well-to-wheel emission assessments.123
Why — Policy support for liquid fuels secures long-term demand for Neste's refinery investments.4
Impact — Electric vehicle manufacturers lose market dominance if liquid fuels extend combustion engine lifespans.5
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Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

Neste Corp. (neste.com) fully supports the Green Deal’s ambition for climate neutrality in 2050 and measures to encourage greater use of low-emission fuels. General remarks Any future review of the AFID Directive should seek to provide coherence and alignment of legislation with EU decarbonisation ambitions, and acknowledge all fuels that have a proven environmental record, including all alternative and renewable liquid fuels. The 2014 Directive defines alternative fuels in an open inter alia type of list which should remain that way in order to enable technology neutrality and the development of possible new technologies and fuels to replace fossil sources. As stated in the AFID, “biofuels [...] are currently the most important type of alternative fuels [...]. They can also contribute to a substantial reduction in overall CO2 emissions if they are produced sustainably. They could provide clean power to all forms of transport”. Accordingly, the scope of the Directive should not be limited to those fuels that require major fleet renewals or deployment of new infrastructure. As neat (not blended with fossil fuels), also alternative and renewable liquid fuels, such as renewable diesel complying with the European EN 15940 standard, need their own storage tanks etc. if not replacing some other fuel from the market. The new Directive should continue to recognise the value that alternative and renewable liquid drop-in fuels play in facilitating a greater and faster decarbonization, given their compatibility with the existing vehicle park. Dedicated fleets with their own refuelling infrastructure would also offer cost-effective ways to increase volumes of alternative fuels. Furthermore, there are great differences between the EU Member States in terms of size of the land area, population density, geography, weather conditions etc. Similar technological targets should therefore not be mandatory throughout the whole transport network in all MSs. It should be the Member States setting up national and local deployment targets. There is no one single solution fit for all regions. Alignment of legislation is important in order to achieve cost-effective solutions and a predictable regulatory environment. The new Directive should therefore be developed in full consistency with other existing legislation such as the Clean Vehicles Directive and relevant ongoing regulatory procedures, such as the RED II implementation, review of the ETD and the technical assessment of the FQD. In addition, Reference Fuel and vehicle CO2 Regulations should be aligned with AFID and other directives by supporting all the available low-emission solutions, incl. synthetic and paraffinic fuels, with well-to-wheel based assessment. CVD counts heavy-duty vehicles using neat biofuels as ‘clean vehicles’. Therefore, developing the AFID framework to support the objectives of the CVD is important. Sustainable feedstocks for the future Renewable paraffinic diesel (HVO) demand is expected to be more than 20 mill. tons annually based on existing and proposed regulation in Europe and North America. The currently identified waste and residue feedstock pool in 2030 is globally around 35 mill. tons a year. There is significant growth potential in scalable new technologies e.g. lignocellulosics, MSW and algae oils. New scalable feedstocks enable deeper decarbonisation of transport. Rapid growth and cost reduction in renewable electricity also drives the development of ren. hydrogen and Power-to-Liquids. They enable the production of sustainable liquid fuels besides biomass by utilizing CO2 as feedstock. In the longer term the commercialization of these technologies will help to tackle the scarcity of biofuel feedstocks. Hence, combustion engines remain a viable technology using alternative and renewable liquid fuels that contribute to the decarbonization of transportation and decrease the dependence on crude oil. See attached our proposal to update recital 6 of the AFID.
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

Neste (www.neste.com, the world's largest producer of renewable diesel refined from waste and residues, introducing renewable solutions also to the aviation and plastics industries) welcomes the opportunity to provide feedback on the Commission’s Inception Impact Assessment on the Delegated Regulation on a climate change mitigation and adaptation taxonomy. Neste supports the objectives of the EU’s sustainable finance action plan and climate targets. Neste itself targets to carbon neutral production by 2035 (including conventional oil refining). Thus, we think that fostering sustainable financing by providing transparent information is important for the financial markets to contribute to climate action. Equally, investments into all solutions that are commercially available today and at least halve the greenhouse gas (GHG) emissions in transport, such as sustainable biofuels, should be incentivised by the taxonomy, not discouraged. Climate change mitigation through all available means is needed, as otherwise we run the risk of not achieving the rapid decarbonisation of transport that is needed to limit global warming to well below 2°C. We have only limited time to reach the ambitious goals of the EU Green Deal and the Paris Agreement, so the taxonomy should be inclusive and open to all effective solutions to reduce climate emissions in the short and long term. Regarding Technical Expert Group’s (TEG) report (Annex p. 200), Neste supports the inclusion of chemical recycling as taxonomy-eligible technology, but it should also be eligible for refineries, not only for plastic manufacturing. With chemical recycling of waste plastics, virgin crude oil use can be reduced and the carbon footprint of refinery products like petrochemical feed can be reduced notably. This is resource efficient use of materials and contributes to both climate change mitigation and circular economy. It is crucial that coherence of EU legislation is maintained to ensure viability and credibility of the rules among citizens, investors, and industries when the regulative framework is prepared by the Commission. This requirement to take into account consistency with existing EU legislation and methodologies is set in Article 14 of the taxonomy primary regulation (2018/0178 (COD)). Long-term predictability and consistency of regulation are fundamental for capital intensive industries like the energy industry. Inconsistent regulation is counterproductive and poses a risk to the financing of projects that would offer a significant contribution to climate change mitigation. TEG report (Annex p. 249) is in contradiction with the Renewable Energy Directive recast (RED II) as well as the aforementioned regulation establishing the framework for sustainable investment. The RED II Directive, adopted in 2018, sets stringent sustainability criteria for renewable energy, including biofuels. It mandates that all biofuels must reduce GHG emissions by at least 50 % compared to fossil fuels - and the best of them have GHG emission savings of up to 90 % or more according to RED II methodology. In addition, sustainable biofuels made from waste and residues do not have an indirect land use change (ILUC) effect, as stated in the Directive (Annex VIII, Part B). Therefore, Neste requests that the Commission rectifies the TEG’s inconsistencies in the delegated regulation on climate change mitigation and adaptation objectives by adhering to the principle of technological neutrality, and aligning the technical screening criteria with the existing RED II sustainability criteria, which have already been approved in accordance with the ordinary legislative procedure in 2018 and is being implemented into national laws with binding effect. Having a different set of criteria in Taxonomy would lead into very big confusion among investors, industry and consumers. Please see attached document for further information.
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Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

24 Apr 2020

Neste (www.neste.com, the world's largest producer of renewable diesel refined from waste and residues, introducing renewable solutions also to the aviation and plastics industries) welcomes the opportunity to provide feedback on the Commission’s inception impact assessment on the European vehicle emissions standards – Euro 7 for cars, vans, lorries and buses. The possible setting of either more stringent limits to currently regulated pollutants or any limits for currently unregulated pollutants should start with a careful assessment of the real benefit for air quality. The limits should be relevant for urban air quality but at the same time other non-urban applications should not be affected too harshly by too costly solutions without showing noticeable benefit in air quality. The best way to improve air quality by means of road transport is to increase the vehicle fleet turnover rate. Current Euro 6d-temp vehicles already have a very good emission performance. The issue is more about the older fleet of vehicles still on the road. Instead of trying to cut the cost of the Euro 7/VII type approval or introducing more stringent pollutant limits, the emphasis should be on making the end product affordable to consumers and professional users so the penetration of new vehicles to the market would be as fast as possible. The complexity of the emissions regulation is mostly there for a reason. The current test procedure for Euro 6d-temp vehicles is reliable and produces good real world emission performance. Any simplifications should be evaluated very carefully. If the test procedure is simplified too radically there’s a risk that some specific phenomena can be missed. The methods used to determine type approvals have to be accurate and repeatable. RDE is a very capable tool for checking that the emissions control systems work in real world conditions, but it’s not suitable for producing comparable results like the kind needed for CO2 type approval figures. Accurate and repeatable results can only be achieved in a controlled environment such as a climate controlled chassis dynamometer. When considering the harmonization of regulation it should be kept in mind that different vehicle classes have very different applications. For example, for passenger cars g/km is a good unit for measuring a pollutant emission, but for trucks g/tonne-km and for buses g/seat-km should be used as g/km would lead to a bigger number of smaller trucks and buses, which is not a desirable outcome regarding total emissions and congestion. Also, the average driving profile is very different when comparing passenger cars, city-buses and long distance heavy duty trucks and this should be reflected in the type approval procedure. The Euro 7/VII regulation should enable, and if possible, even promote the use of alternative renewable fuels - as should all fuel and vehicle relevant legislation, including reference fuel regulation. Renewable fuels are a quick and cost-effective solution for reducing the CO2 emissions from road transport. No regulation should be put in place to prevent the use of renewable fuels if the limits for local emissions are met. The regulation should be technology neutral by defining the target but not the technical means to achieve them. In addition, the regulation should also be affordable for all parties and cost-effective for improving air quality where there is a need for that.
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Neste urges EU to adopt binding aviation fuel mandates

21 Apr 2020
Topic — The EU is consulting on ways to boost sustainable aviation fuel use and production.
Message — Neste recommends a blending mandate of at least 8% to 10% by 2030 to provide investment certainty. They also urge that all sustainable waste and residue feedstocks be eligible for use under the new rules.123
Why — This policy would secure long-term demand and financial security for Neste's massive global production facilities.45
Impact — Traditional fossil fuel suppliers would lose market share as mandatory blending requirements prioritize renewable alternatives.6
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Response to 2030 Climate Target Plan

15 Apr 2020

Neste supports the European Green Deal and its aim to increase the EU 2030 climate target. Neste itself targets carbon-neutrality by 2035. However, the right regulatory framework conditions must be put in place in order to fully deploy the GHG emission reduction potentials from different sectors. Sustainable biofuels needed To ensure that Europe as a whole meets the targets set by the European Green Deal, we must urgently consider all available sustainable and technically advanced solutions like sustainable biofuels. Paraffinic biofuels (such as HVO, Hydrotreated Vegetable Oil) improve the quality and efficiency of fuels and are fit for the current car, bus, and truck fleets with any blend ratio up to 100% non-blended biofuel in line with EN 15940. Regarding sustainable aviation fuels (SAFs), the demand needs to be created by regulations. Voluntary demand has been slowly growing but it is not enough to drive the decarbonisation of aviation with the necessary speed. Jet fuel taxation or sharpening of ETS will not lead to decarbonisation of aviation nor incentivising the necessary SAF production investments. Lead times for investments and development of new pathways are long. Thus, we need to start to deploy SAF immediately with readily available pathways and with a long-term credible outlook created by regulatory support such as blending mandates that will then trigger the investments. Revision of key legislation must avoid creating investment uncertainty The EU Clean Energy Package has just been adopted and is now still partly in the implementation phase in the Member States. Many industrial investment decisions are already taken regarding the new Directives and Regulations, like RED II. It would be very counterproductive for climate change mitigation efforts if these legislations were reopened as it would probably mean multiyear legislative processes creating regulatory uncertainty and slowing down the new investment decisions already in the pipeline. In addition, these Directives and Regulations include already existing review dates that could still leave enough time to make adjustments needed to achieve increased 2030 targets. However, if some regulations must be updated earlier than planned, it should be done by changing only the essential parts of the legislation, for instance by increasing only numerical targets and leaving the other texts untouched. This would minimise the regulatory uncertainty. Considering e.g. possibly revision of the RED II, the revision should only go for increasing the numerical targets (e.g. increase the 14 % target for renewables in transport by 2030, aviation multiplier up from current 1.2, etc.) but not open other articles as it could lead to prolonged negotiations and slow down the investment decisions and GHG emission reductions. RED II is the right instrument for road transport decarbonising RED II is the key driver for decarbonizing transport until 2030. RED II has the intention to drive e.g. the adoption of emerging lignocellulosic fuels and other advanced biofuels based on raw materials listed on RED II Annex IX, part A. A cross-sectoral emission trading scheme (EU ETS) approach would eliminate the incentive to invest in first-of-their-kind production units, as ETS CO2 price levels are very unlikely to provide the economic attractiveness needed to operate these units profitably. That’s why the EU ETS would not be the right instrument for fulfilling the emission reduction needs in the road transport sector. Need for consistency between EU Taxonomy and sectoral legislation For example, the RED II sets stringent sustainability criteria for renewable energy, including biofuels. Under RED II, all biofuels must reduce GHG emissions by at least 50...65% compared to fossil fuels. To reach the ambitious goals of the Green Deal, investments into all sustainable biofuels that at least halve the greenhouse gas emissions in transport should be incentivised by Taxonomy, not discouraged.
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Response to Revision of the Energy Tax Directive

1 Apr 2020

Neste (http://www.neste.com/en) supports the European Green Deal (EGD) and one of its aims to revise the Energy taxation directive (2003/96/EC) originating already from 2003. Thus, the revision is well-needed to be in line with the current EU policy objectives. <b>Accelerated transport decarbonisation by CO2 tax</b> Incentivising low-carbon transport fuels would promote transition towards decarbonisation of the transport sector. The revised EU energy taxation directive should introduce a CO2 tax element. CO2 taxation for transport fuels is used by some member states, e.g. in Finland and in Sweden. Current Finnish fuel excise tax model could act as a starting point when designing a CO2 tax component. Sweden is another member state, where transport fuel CO2 component is in use. Coherence with other EU legislation for fuels is essential. Therefore, when designing a tax model for low-carbon fuels, <u>all RED II compatible sustainable biofuels</u> need to be properly taken into consideration. <b>Rethink the minimum tax concept to support emission reduction</b> The current directive includes minimum tax levels for diesel fuel and petrol. To promote decarbonisation of transport, the revision should allow an exemption from minimum tax for environmentally preferred fuels. Alternatively, a CO2-based/tiered minimum tax could be a good solution. <b>Introduction of sectoral taxes</b> In case sectoral taxes are planned - e.g. for aviation and maritime - we strongly support them to follow a similar low-carbon incentivisation model as for the other transport fuels.
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Meeting with Virginijus Sinkevičius (Commissioner)

18 Feb 2020 · Circular Economy Action Plan

Meeting with Taneli Lahti (Cabinet of Commissioner Jutta Urpilainen)

18 Feb 2020 · Sustainable finance

Meeting with Kadri Simson (Commissioner) and

18 Feb 2020 · Sustainable transport fuels

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

18 Feb 2020 · Discussion on sustainable transport fuels

Meeting with Henrik Hololei (Director-General Mobility and Transport)

10 Feb 2020 · Visit of facility, Sustainable fuels

Response to Climate Law

6 Feb 2020

Neste Corp. (www.neste.com, the world's largest producer of renewable diesel refined from waste and residues, introducing renewable solutions also to the aviation and plastics industries) welcomes the initiative and the European Union’s goal to become climate-neutral by 2050 at the latest. To achieve this objective, it is essential to reduce greenhouse gas (GHG) emissions from all sectors of the European (as well as global) economy, keeping the global temperature rise well below 2ºC above pre-industrial levels and pursuing efforts to limit the temperature increase even further to 1.5ºC. This may well lead to the need to increase the 2030 GHG emissions reduction target, which the European Commission will evaluate by summer 2020. In this respect, those sectors that made the least efforts should be tackled with priority, with particular regards to those covered by the Effort Sharing Regulation as well as the aviation sector. Existing technology already offers a drop-in solution to significantly reduce emissions in the transport sector (incl. aviation). Investments need to be supported with predictable and stable policy framework to ensure a successful clean transition in this regard. One policy option could be to introduce already 2040 interim targets based on the coming impact assessment to show the way towards climate-neutrality by 2050. For the transport sector, all biofuels that meet the sustainability criteria of the recast Renewable Energy Directive (RED II) are needed to achieve the greenhouse gas savings targets in many Member States. All of them must continue to be eligible for national fuel supplier obligations. The final sustainable finance taxonomy screening criteria should be consistent with RED II and therefore encourage - not dissuade - investment to sustainable biofuels. This is essential not only for the 90% GHG emission reduction needed by 2050 in the transport sector (according to the European Green Deal Communication) but also to meet the Paris Agreement goals and a climate neutral EU. Therefore, it is important that any EU measures targeting transport decarbonisation foresee an increase in the share of sustainable renewable- as well as waste and residue based fuels in the transport energy mix. This is vital also for the aviation sector and for the further introduction of sustainable aviation fuels that Neste already now produces with significantly increasing capacity by 2022. ‘ReFuelEU’ for aviation will be a highly important tool for creating the demand and investment certainty for sustainable aviation fuel production, e.g. through an incentive like a blending mandate. The EU ETS (emissions trading scheme) would not be the right solution for GHG emission reductions of the road transport sector. RED II has the intention to drive the adoption of e.g. emerging lignocellulosic fuels and other advanced biofuels. A cross-sectoral ETS approach would eliminate the incentive to invest in first-of-their-kind production units, as ETS price levels are very unlikely to provide the economic attractiveness needed to operate these units profitably. The same point goes for available biofuels in general, which are existing, well-suited solutions to decarbonize in particular heavy-duty, long-haul transport. While production units exist, they would likely shut down amid lack of profitability, stripping the EU of an important option to deliver immediate emission reductions compatible with existing infrastructure. This would also pose a threat to the development and production of sustainable aviation fuels (SAF). Neste will be ready and keen to continue discussions and to support the EU Climate Law as well as the European Green Deal efforts by the Commission together with other EU Institutions. At the same time, every day, Neste is already doing its utmost to provide sustainable solutions for several sectors in order to create a healthier planet for our children.
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and Shell Companies and

5 Feb 2020 · European Green Deal

Meeting with Henrik Hololei (Director-General Mobility and Transport)

24 Oct 2019 · sustainable alternative fuels production and perspectives

Meeting with Henrik Hololei (Director-General Mobility and Transport)

15 Oct 2019 · Sustainable aviation fuels

Meeting with Ditte Juul-Joergensen (Director-General Energy)

15 Oct 2019 · Clean energy transition, decarbonisation of the transport sector.

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and Aula Europe

23 Sept 2019 · sustainable finance

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen) and Aula Europe

23 Sept 2019 · Climate change

Response to Import of used cooking oils

19 Jul 2019

Neste is in a view of that this amendment to EU 142/2011 is not defining clearly enough the different cases (especially in case C below): A) Used Cooking Oil where the frying oil is of purely vegetable origin and it has been used to fry non-animal food should not fall under the Animal By Products (EU 1069/2009) regulations as it does not contain material of animal origin. This is quite explicitly said in the amendment, so it is ok. B) Where the frying oil is of animal origin (e.g. lard, beef tallow etc.) then the used cooking oil would contain material of animal origin and thus fall under Animal By Product regulations => cat 3. C) Where the frying oil is of purely vegetable origin and has used to fry e.g. hamburger meat is not clearly defined. In this case, meat safe for human food consumption will not have negative health impacts on used cooking oil originated from vegetable oils and thus, should be out of the scope of this Animal By Products regulation. - Neste is also concerned about the fact that UCO collectors in 3rd countries will not be ready for this ABP registration. Even the authorities in many countries are missing and/or not able to give ABP registration numbers needed. This would hinder, not facilitate UCO import from 3rd countries (even if it has been argued in proposal that this is to facilitate imports). - Period for retaining a representative sample (Annex points 3 & 4): The period of two years for retaining a representative sample of each consignment of imported UCO, as stated in paragraph 3 of the new section 13, is too long. Depending on the frequency of the imports and the amount of the consignments this could potentially cause a need for warehouses to keep tens of thousands of samples which would be difficult and a very expensive burden. In alternative we propose to reduce the period to retain the samples to a maximum of 6 months.
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Meeting with Tatu Liimatainen (Cabinet of Vice-President Jyrki Katainen)

6 Jun 2019 · Future of Europe, EC priorities

Neste Pushes for Permanent Recognition of Biofuel Sustainability Gains

8 Mar 2019
Topic — EU consultation on criteria for high and low indirect land-use change risk biofuels.
Message — Neste requests setting a fixed 2008 date for crop sustainability gains to remain permanent. They also advocate for expanding the definition of small farms to fifty hectares.12
Why — A fixed cut-off date protects Neste’s market access for their certified fuel products.3
Impact — Environmental groups lose if revised calculations reduce the reported expansion into high-carbon lands.4
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Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

31 Jan 2019 · sustainable biofuel

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

28 Jan 2019 · Follow up to RED II

Meeting with Karmenu Vella (Commissioner) and

8 Jan 2019 · Chemical Recycling

Meeting with Jyrki Katainen (Vice-President)

8 Jan 2019 · chemical recycling technology

Response to Evaluation of the Industrial Emissions Directive

28 Nov 2018

The IE directive including BAT requirements is ambitious and its implementation is currently going on. Some industry sectors can expect to have full implementation in place by end of 2018. This is not the case with all important industry sectors. For example, the 4 years' legal implementation period for the energy production industry (LCP) BAT conclusions, published in December 2017, is running until end of the year 2021. Therefore, it is too early to start evaluation of practical impact and achievements of the IE directive already in 2020, because implementation is unfinished with certain important industry sectors. Furthermore, in order to make an effective review it is very important to understand that emission data available in 2020 will not be 'on-line', but typically two years old. This means that reliable evaluation of the directive objectives should be envisaged a few years later. In Finland, the current IE directive was fully implemented in 2014 and several respective BAT conclusions have been implemented, including pulp and paper and oil refining. Respectively, environmental permit requirements and limits have been tightened through permit decisions e.g. during 2016 - 2018, in order to correspond to relevant BATAELs. Quality of the environment in Finland is generally good (air quality, in example, typically meets all EU air quality standards). Therefore, stricter environmental controls may not be necessary at all member states and consequently, reasonable derogations and flexibility mechanism should be awarded for such member states where the environmental conditions meet the environmental quality needs.
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Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella)

18 Oct 2018 · Bio-economy

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Aula Europe

5 Jun 2018 · plastic strategy, and Neste's presentation on bio-based solutions promoting circularity

Meeting with Pedro Velasco Martins (Cabinet of Vice-President Cecilia Malmström)

11 Apr 2018 · Palm Oil Sustainability, RED, Indonesia.

Meeting with Miguel Arias Cañete (Commissioner)

15 Feb 2018 · Renewables

Meeting with Henrik Hololei (Director-General Mobility and Transport)

15 Feb 2018 · biofuels

Meeting with Silke Obst (Cabinet of Commissioner Violeta Bulc)

13 Feb 2018 · Biofuels topics

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska) and Aula Europe

31 Jan 2018 · Renewable energy directive

Neste urges EU to count renewable fuels as zero-emission

5 Dec 2017
Topic — The consultation addresses proposed carbon dioxide emission standards for heavy-duty vehicles.
Message — Renewable fuels should be assigned zero tank-to-wheels CO2 values in regulations. Measurements should also account for the favorable carbon content of alternative fuels.12
Why — This change would increase market demand for Neste's renewable fuel products.3
Impact — Fossil fuel suppliers would lose their competitive advantage over renewable fuel alternatives.4
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Meeting with Jyrki Katainen (Vice-President) and Aula Europe

4 Sept 2017 · Renewable Energy Directive

Meeting with Henrik Hololei (Director-General Mobility and Transport)

4 Sept 2017 · biofuels

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

18 Nov 2016 · biofuels

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

17 Nov 2016 · Energy Package

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

13 Oct 2016 · Renewable Energy Directive and biofuels

Meeting with Jos Delbeke (Director-General Climate Action)

13 Oct 2016 · Low emission mobility

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

15 Sept 2016 · Energy Union proposals

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Bayerische Motoren Werke Aktiengesellschaft and

30 Jun 2016 · EU decarbonization policy 2030

Meeting with Henrik Hololei (Director-General Mobility and Transport)

2 Dec 2015 · advanced biofuels

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella), Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

15 Jun 2015 · Circular Economy

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

16 Mar 2015 · Future of biofuels

Meeting with Jyrki Katainen (Vice-President)

11 Mar 2015 · Investment Package

Meeting with Miguel Arias Cañete (Commissioner) and

11 Mar 2015 · Biofuels

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

9 Mar 2015 · ILUC directive

Meeting with Vladimir Sucha (Director-General Joint Research Centre)

9 Jan 2015 · Meeting on evaluation of the current cooperation (results of the petroleum refineries fitness check, well to wheel project) and discussion on future scientific challenges in the areas of alternative fuels and genotoxicology and fuels.

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

9 Jan 2015 · STATE OF PLAY AND OUTLOOK FOR THE EUROPEAN REFINERIES SECTOR, COMMISSION PRIORITIES IN ENERGY AND CLIMATE POLICY

Meeting with Gonzalo De Mendoza Asensi (Cabinet of Vice-President Miguel Arias Cañete), Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

12 Dec 2014 · ADVANCED BIO-FUELS