OpenLobby.EU
Explore

North European Oil Trade Oy

NEOT Oy

NEOT Oy is a fuel procurement company operating in the Baltic Sea region, whose ambitions are supplying fuel sector with increasing amount the sustainable renewable energy in transport sector.

Lobbying Activity

Response to Update of list of sustainable biofuel feedstocks

2 Jan 2023

North European Oil Trade Oy (NEOT) strongly supports the EU objective of net climate neutrality in 2050 and the circular economy. We warmly welcome the initiative of the Commission to update the list of sustainable biofuel feedstocks to Annex IX of RED as an important element continue transforming and accelerate the production of advanced biofuels. To support the finalisation of the delegated act (DA), NEOT appreciates the opportunity to contribute with our feedback. Please find our full feedback in the attached file.
Read full response

Response to Revision of the Energy Tax Directive

18 Nov 2021

North European Oil Trade (NEOT) contributes to this consultation from the perspective of an independent fuel procurement company in the Baltic Sea region. We supply annually roughly 7 billion liters of fuel products to transport, heating, aviation, and marine sectors in Finland, Sweden, and Norway. Our supply represents approximately 40% of the total fuel consumption in Finland, 30% in Sweden, and 35% in Norway. These countries have one of the highest emission reduction targets for transportation sector in the EU and Europe. Taxation based on energy content and environmental performance removes incentives from fossil fuels: NEOT welcomes the Commission’s proposal on amending the Energy Taxation Directive (ETD). We believe it is important to decrease fossil fuel favoring and align the ETD with the Green Deal objectives. We especially welcome the change on taxation of energy products based on their energy content instead of their volume and adjusting the lower minimum rates based on environmental performance. This rebalances the competitiveness of less carbon intensive fuels, such as biofuels over fossil fuels and provides clearer price signals to both business and consumers. NEOT has already gained good experience from Finland, where the fuel excise duty is already based on the fuel energy content. Regulatory overlap must be avoided: The Fit for 55 legislative proposal published by the European Commission aims at reducing the EU's greenhouse gas emissions by at least 55% by 2030 from 1990 levels. The Commission proposal seeks a holistic approach to emission reduction regulation. A comprehensive and ambitious climate package is welcomed. However, the complex package including multiple suggested policy instruments threatens to create a lot of regulatory overlap. Overlapping regulation weakens the cost-effectiveness of emission reduction measures and should therefore be avoided. In the transport sector especially the proposals on emissions trading, energy taxation and the obligation to distribute renewable energy (RED III) must be designed in a way that they do not overlap.
Read full response

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

North European Oil Trade (NEOT) contributes to this consultation from the perspective of an independent fuel procurement company in the Baltic Sea region. We supply annually roughly 7 billion liters of fuel products to transport, heating, aviation, and marine sectors in Finland, Sweden, and Norway. Our supply represents approximately 40% of the total fuel consumption in Finland, 30% in Sweden, and 35% in Norway. These countries have one of the highest emission reduction targets for transportation sector in the EU and Europe. NEOT proposes the following: • Emission mitigation policy must strive for technology neutrality, which allows the use of the most cost-effective emission reduction means. • To ensure technology neutrality, all energy carriers must be included in any reduction obligation. • Overlapping legislative instruments must be avoided in the transport sector, especially between emissions trading, the Renewable Energy Directive and energy taxation. • The scarcity of biofuel feedstocks and the time needed for the development of RFNBO fuels must be taken into account in the regulation. • The aviation and marine sectors will also draw from the same biofuel feedstock pool with road transport. Flexibility between mandates in different sectors is needed to be able to use the resources as efficiently as possible. • Predictability of legislation is important to encourage the large and forward-looking investments needed. • Cross-sectoral flexibility should be allowed between different sectors (emissions trading, effort sharing, LULUCF) to enable cost-effective emission mitigation and to fund carbon sinks. More detailed feedback is attached as a file.
Read full response

Response to Updating the EU Emissions Trading System

8 Nov 2021

North European Oil Trade (NEOT) contributes to this consultation from the perspective of a Finnish fuel distributor. Our supply represents approximately 40% of the total fuel consumption in Finland, an EU Member State that has one of the highest emission reduction targets for transportation sector in the EU. NEOT welcomes the Commission’s proposal for amending the directive on EU Emission Trading System (ETS) and of extending ETS to transport and buildings sector. As a market-based policy tool ETS for transport and buildings sector has potential of being a technology-neutral and effective instrument for mitigating transport emissions. Regulatory overlap must be avoided: The Fit for 55 legislative proposal published by the European Commission aims at reducing the EU's greenhouse gas emissions by at least 55% by 2030 from 1990 levels. The Commission proposal seeks a holistic approach to emission reduction regulation. A comprehensive and ambitious climate package is a welcomed. However, the complex package including multiple suggested policy instruments threatens to create a lot of regulatory overlap. Overlapping regulation weakens the cost-effectiveness of emission reduction measures and should therefore be avoided. In the transport sector the proposals on emissions trading, energy taxation and the obligation to distribute renewable energy (RED III) must be designed in a way that they do not overlap. To avoid overlap in the transport and buildings ETS and RED III emission reduction obligation, the utilization of ETS emission allowances from transport and buildings sector in fulfilling also the RED III emission reduction obligation should be allowed to create flexibility between the two mandates. Cost-effectivity with sector integration: Flexibility between different sectors (emissions trading, effort sharing, LULUCF) brings cost-effectiveness in emissions reduction actions. Therefore, cross-sectoral flexibility should be allowed e.g. via a model where part of the transport emission obligations could be fulfilled by purchasing emission rights resulting from carbon sequestration projects or carbon capture and utilization (CCU) actions done in other sectors, such as LULUCF. In this way, it is possible to encourage the implementation of e.g. carbon sinks and direct funding from other sectors to sectors where emissions reduction measures are cheapest.
Read full response

Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

9 Jul 2021

North European Oil Trade (NEOT) welcomes the commission’s initiative on more detailed rules for voluntary schemes on verifying sustainability and greenhouse gas emissions saving criteria and low indirect land-use change-risk criteria. NEOT contributes to this consultation from the perspective of a Baltic fuel trader and supplier. According to Article 10 a major non-conformity should lead to an immediate suspension of the economic operator’s certificate. Immediate suspension causes a significant risk for the economic operator and may lead to the discontinuation of business. Instead of immediate suspension, economic operators should be first given a timeframe within which the remedy should be provided. The suspension or withdrawal of the certificate should happen only if the economic operator fails to provide remedy for the major non-conformity. According to Chapter IV Article 18 paragraph 1 information included in Annex I shall be passed on from economic operator to economic operator through the supply chain. According to Annex I paragraph 2 points (d) and (e) the place of physical loading and delivery point shall be passed along the supply chain. Clarity should be given for handling the information mentioned in Annex I paragraph 2 points (d) and (e) in cases of trading. Biofuel traders do not always store the supplied biofuel in their own storages, and instead might deliver biofuel directly from the supplier’s storage to the customer’s storage. Supplier and customer information is sensitive information to traders and it should not be required for the biofuel traders to reveal this information to their suppliers or traders. According to Chapter IV Article 19 paragraph 2 point (j) where biofuels are blended with fossil fuels with similar molecular structure, the information about the sustainability and GHG emissions saving characteristics assigned to the blend shall be established in accordance with Article 23. Article 23 only refers to the processing of co-processed fuels and not blending. Therefore, it should be clarified which points of Article 23 shall be applied to blending of biofuels with fossil fuels with similar molecular structure. C14 tests should only be required for producers of co-processed fuels to determine the amount of biofuel produced from the biomass entered in the process. After that, C14 tests should not be required for blended fuels, as following the mass balancing rules ensures that no more biofuel is withdrawn from a blend that is entered in the blend. According to Chapter IV Article 20 paragraph 2 point (a) the emission factors set out in Annex IX shall be applied for the purpose of determining the GHG emissions of biofuels. It should be clarified whether the emission factors should be applied only when an actual value for the GHG emissions is calculated, and if other sources could be used in case an emission factor is not found in Annex IX. Annex IV sets out a list of feedstocks considered as waste or residue. We urge the commission to at minimum add to the list the feedstocks defined as waste or residue in Annex IX of RED II. Feedstocks missing from the Annex IV but defined as waste or residue in RED II Annex IX are for example bark, branches, pre-commercial thinnings, needles, saw dust, cutter shavings, black liquor, brown liquor, fibre sludge, lignin and tall oil, which are defined as biomass fraction of wastes and residues from forestry and forest-based industries in RED II Annex IX part 1 point (o). The regulation is proposed to enter into force retroactively from 1 July 2021. A transition period should be provided for voluntary schemes and economic operators to implement the changes.
Read full response

Meeting with Helena Hinto (Cabinet of Commissioner Kadri Simson), Kitti Nyitrai (Cabinet of Commissioner Kadri Simson), Laure Chapuis (Cabinet of Commissioner Kadri Simson) and Kreab Worldwide

22 Mar 2021 · RED II and EU-ETS revisions; Finnish NECP; The role of biofuels in the future.

Meeting with Silke Obst (Cabinet of Commissioner Violeta Bulc)

7 Feb 2019 · Climate solutions for the transport sector

Meeting with Adalbert Jahnz (Cabinet of Vice-President Maroš Šefčovič)

6 Feb 2019 · Finnish emissions reductions targets under the Effort Sharing Decision

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc) and St1 Nordic Oy

9 Jul 2015 · Meeting with North European Oil Trade Oy/St1 Biofuels Oy

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

16 Jun 2015 · Energy Union