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Novozymes

Novozymes produces a wide range of industrial enzymes and microorganisms.

Lobbying Activity

Response to ReFuelEU Aviation - Sustainable Aviation Fuels

18 Nov 2021

Novozymes welcomes the Commission’s proposal to implement dedicated legislations for the decarbonization of aviation through sustainable renewable fuels but strongly objects to the decision to exclude or penalize biofuels produced from food and feed crops. The ReFuelEU Aviation regulation proposal surprisingly includes a concern over crop-based biofuels due to concerns regarding GHG emissions from indirect land-use change. ILUC concerns were addressed in 2018 in the RED II delegated act on high ILUC-risk biofuels (Article 26(2) of Directive (EU) 2018/2001), which singled out problematic feedstocks and confirmed that European crop-based ethanol does not drive deforestation. As per the existing RED II, only high ILUC-risk biofuels must be limited and then progressively phased out. This approach is continued in the Commission’s proposal for the revision of the RED II. In addition, the European Commission’s annual Renewable Energy Progress Report found that no correlation had been observed between food prices and increased biofuel demand. The EU needs to take a step-wise approach towards a fast transition to sustainable aviation industry. To succeed with the ambitious and important decarbonization targets set out by the European Commission for aviation, the transition must include both a plan for broad advanced biofuel implementation as well as a fast introduction of cheaper, higher TRL crop-based fuels. Several potential SAF pathways have been identified and received ASTM (American Society for Testing & Materials) approval, including hydrogenated vegetable oils (HEFA), catalytic conversion of ethanol or butanol to jet (AtJ), synthesized iso-paraffin (advanced fermentation to hydrocarbons), biomass gasification and Fischer-Tropsch synthesis to jet, and bio-oil production/upgrading from algae and others. AtJ technologies, in particular, offer great potential for significant SAF growth, due to feedstock availability and pathway developments. Gevo, Boyogy, LanzaJet, and Red Rock are examples of technology developers of AtJ processes. Crop-based alcohols (e.g. ethanol or buthanol) are attractive intermediate molecules because they are readily available and abatement costs are low compared to advanced fuels based on the Annex IXA & B feedstocks. Novozymes strongly recommends the EU Commission to recognize and support crop-based production of fuels for aviation, to accelerate the decarbonization, and to be able to meet the SAF growth targets. The proposal of the Commission for the ReFuelEU Aviation Regulation disqualifies sustainable crop-based biofuels from contributing to the sustainable aviation fuel obligation, and therefore cannot contribute to the objectives of incorporation of non-fossil fuels in aviation. This decision violates the principle of technology neutrality. Crop-based biofuels are already subject to stringent sustainability criteria under the Renewable Energy Directive and should be allowed to contribute to the sustainable aviation fuel mandates alongside RFNBOs and biofuels made from Annex IX feedstocks. To consider crop-based fuels as having a GHG emission on par with fossil fuels is fundamentally wrong. The production of European ethanol emits – including ILUC emissions – on aver-age 64% less GHG compared to fossil fuels . European ethanol producers are at the forefront when it comes to investing in low-carbon innovations such as carbon capture (as incentivized by the sustainability criteria in the EU’s Renewable Energy Directive (RED)). The EU should continue to support and protect such green investments. With this proposal, the crop-based ethanol sector is unfairly treated despite its supply of an immediate, widely available, and cost-effective alternative to fossil fuels. See attached for elaborated notes.
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Response to FuelEU Maritime

8 Nov 2021

Novozymes welcomes the Commission’s proposal to implement dedicated legislations for the decarbonization of maritime through sustainable renewable fuels but strongly objects to the ill-founded decision to exclude or penalize biofuels produced from food and feed crops. The FuelEU Maritime regulation proposal surprisingly includes a concern over crop-based biofuels due to concerns regarding GHG emissions from indirect land-use change. ILUC concerns were addressed in 2018 in the RED II delegated act on high ILUC-risk biofuels (Article 26(2) of Directive (EU) 2018/2001), which singled out problematic feedstocks and confirmed that European crop-based ethanol does not drive deforestation. As per the existing RED II, only high ILUC-risk biofuels must be limited and then progressively phased out. This approach is continued in the Commission’s proposal for the revision of the RED II. In addition, the European Commission’s annual Renewable Energy Progress Report found that no correlation had been observed between food prices and increased biofuel demand. The EU does not have the luxury to wait for the perfect fuel solution for the maritime industry. To succeed with the ambitious and important decarbonization targets set out by the European Commission, the maritime industry needs to get all technologies in play. Many technologies exist at various technology readiness levels including biodiesel, crop-based ethanol, LNG (liquid natural gas), advanced ethanol, lignin alcohol oil, biobased methanol, pyrolysis oil, e-methanol , . Among the most mature and efficient solutions are UCO-based biodiesel (which has severe volume limitations) and crop-based ethanol. Alcohols, like crop-based ethanol, advanced ethanol and methanol can also be mixed with lignin to make highly sustainable and cost-efficient fuels with big potential as a marine fuel. These lignin fuels are being explored by the LEO coalition including Maersk (LEO; lignin ethanol oil) , . Maersk is the largest container shipping line and vessel operator in the world. Crop-based ethanol is attractive because it is a readily available technology and abatement cost are low compared to advanced fuels based on the Annex IXA & B feedstocks. Allowing crop-based ethanol as a maritime fuel will accelerate the decarbonization of the maritime sector. Therefore, Novozymes strongly recommends the EU Commission to recognize and support crop-based fuels within the Marine sector. The EU commission’s concern about crop-based biofuels, as expressed in the FuelEU Mari-time Regulation (in its current format), effectively excludes feed and food crop-based fuels for use in the maritime sector. In the methodology set out, crop-based biofuels are arbitrarily and without scientific foundation considered to emit as much GHG emissions as the least favorable pathway for the fossil fuel they would replace, effectively privileging the use of fossil energy over sustainable renewable fuels. The methodology therefore fundamentally contradicts REDII, which the proposal is based upon. To consider crop-based fuels as having a GHG emission on par with fossil fuels is fundamentally wrong. The production of European ethanol emits – including ILUC emissions – on aver-age 64% less GHG compared to fossil fuels . European ethanol producers are at the forefront when it comes to investing in low-carbon innovations such as carbon capture (as incentivized by the sustainability criteria in the EU’s Renewable Energy Directive (RED)). The EU should continue to support and protect such green investments. With this proposal, the crop-based ethanol sector is unfairly treated despite its supply of an immediate, widely available, and cost-effective alternative to fossil fuels. For full comment, please see file attached. Novozymes welcome the opportunity to further discuss and elaborate.
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

12 Jul 2021

Novozymes supports the overall goal of the draft implementing regulation. However, there are a couple of key topics that need to be addressed before implementation: 1) Annex IV of the Implementing Regulation states that when deciding if a substance can be considered as residue or waste, economic operators and auditors must use the list set out in this Annex, which is based on the substrates/feedstocks included in the revised list of the Annex IX to Directive (EU) 2018/2001 • However, for ligno-cellulosic crops or fractions of crops, Annex IV only mentions energy cane, energy crops and grasses (incl. Virginia mallow), grass pulp, bagasse as examples. This is not in line with the statement that the waste and residue list is based on the Annex IX to Directive (EU) 2018/2001, which includes (p) Other non-food cellulosic material. In reference (42) non-food cellulosic material’ is defined as: “feedstock mainly composed of cellulose and hemicellulose, and having a lower lignin content than ligno-cellulosic material, including food and feed crop residues, such as straw, stover, husks and shells; grassy energy crops with a low starch content, such as ryegrass, switchgrass, miscanthus, giant cane; cover crops before and after main crops; ley crops; industrial residues, including from food and feed crops after vegetal oils, sugars, starches and protein have been extracted; and material from biowaste, where ley and cover crops are understood to be temporary, short-term sown pastures comprising grass-legume mixture with a low starch content to obtain fodder for livestock and improve soil fertility for obtaining higher yields of arable main crops”. For equal treatment of REDII Annex IX materials, all non-food cellulosic fractions identified as example advanced biofuel sources in Annex IX, should also be mentioned as examples in the waste & residue list in Annex IV of the Implementing Regulation. • However, except crude tall oil, all the wastes and residues from forestry and forest based industries are excluded in Annex IV. This is not in line with the statement that the waste and residue list is based on the Annex IX list to Directive (EU) 2018/2001, which includes (o) Biomass fraction of wastes and residues from forestry and forest-based industries, namely, bark, branches, precommercial thinnings, leaves, needles, tree tops, saw dust, cutter shavings, black liquor, brown liquor, fibre sludge, lignin and tall oil. For equal treatment of REDII Annex IX materials, also the forest-based fractions must be in the waste & residue list in Annex IV of the Implementing Regulation. In fact, the point (o) clearly and specifically defines those forest-industry feedstock as “waste and residue”. 2) Annex IX-a of REDII is currently being revised by the Consortium. Once the conclusion is available, Annex IV must be updated in accordance with the conclusions of the Annex IX-a revision.
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Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

25 May 2018 · The future of food and farming

Response to Update of the 2012 Bioeconomy Strategy

20 Mar 2018

Novozymes welcomes the initiative of the European Commission (EC) to update the 2012 EU Bioeconomy Strategy. Novozymes believes that a stronger political & financial support to the bioeconomy will help Europe to transit to a low carbon economy, boost jobs & growth & address environmental & climate challenges.The 2012 EU Bioeconomy Strategy & its Action Plan has been a great step towards the development of a bio-based economy & has since successfully fostered R&I across the EU not least through the establishment of the public private partnership of the Bio-Based Industries Joint Undertaking (BBI JU). New value-chains, advanced biorefineries & sustainable bio-based solutions have been created by the BBI JU while reducing EU´s dependency on fossil resources & re-industrialising rural areas. The bioeconomy already makes great contributions to the UN SDGs. By being applied in field such as renewable fuels, agriculture, & water, the bioeconomy addresses many SDGs, incl. but not limited to SDG 2-6-7-15. The need to address today´s challenges has given the bioeconomy impetus to develop further. Industrial biotechnology is a key enabler of the bioeconomy helping converting biomass in various downstream products, making existing industrial process more resource efficient & providing solutions for sustainable agriculture, renewable energy & many others. It should be an imperative for Europe to continue building on its current success, supporting the full deployment of the bioeconomy across all sectors & transforming challenges in business opportunities. Novozymes calls on the EC to consider the following measures for creating a successful European bioeconomy: • Increase funding for R&I Ensure the continuation of the BBI JU post 2020 under the FP9 for accelerating the deployment of bio-based industries & crossing the innovation valley of death; keep financing industrial biotechnology under the Key Enabling Technologies to boost innovation in this area broadly recognised as a key enabler of the Bioeconomy; establish a EU Bioeconomy Strategic Investment Fund to help pool resources from different financing mechanisms. • Ensure a coherent, stable & predictable regulatory environment Ensure a stable regulatory environment to attract further investments & secure profitable returns of the existing ones; prevent policy obstacles to the market uptake of bio-based which have been developed by EU R&I funds (e.g. sustainable biofuels); improve policy integration to exploit the interdisciplinary nature of bioeconomy in all the respective policy areas such as agriculture, bioenergy, environment, R&I & water; develop an ambitious EU SDGs Strategy to be linked to the Bioeconomy Strategy ensuring the implementation of SDGs in the EU agenda. • Raise awareness & boost market uptake of bio-based products Implement market stimulation measures to enable a competitive bioeconomy. Green public procurement, mandates, tax incentives & binding targets for certain bio-based products are needed to accelerate their competitiveness & deployment at commercial level; increase public awareness of bio-based economy by implementing communication strategies at European, national & local level; establish a EU Bioeconomy Week to ensure social understanding & appreciation of bio-based economy & R&I in the bioeconomy area. Novozymes welcomes Roadmap´s objective of gaining a better understanding of the environmental & other impacts of increased biomass production & direct & indirect impact of the Bioeconomy on natural resources & existing sectors using biomass. Biomass from arable crops & residues in both the Roadmap & SWD cannot be justified based on latest evidence & science. Many synergies already exist between growing food & biomass for fuel & materials, & good policies can boost them further. A successful bioeconomy policy should promote all its sustainable components & focus on how to produce biomass sustainably for food & feed needs as well as for fuels & materials.
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Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič) and Shell Companies and

14 Jul 2017 · Presentation and discusson about decarbonisation of transport as well as Europe on the Move and Clean Energy for All Europeans - packages

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc) and Robert Bosch GmbH and

5 Jul 2016 · decarbonisation of transport

Meeting with Jyrki Katainen (Vice-President) and

25 Feb 2016 · Advanced biofuel industry in Europe

Meeting with Violeta Bulc (Commissioner) and

25 Feb 2016 · Meeting with Mr Anders Fogh Rasmussen and Advanced Biofuels CEOs

Meeting with Carlos Moedas (Commissioner) and UPM-Kymmene Oyj and

25 Feb 2016 · Meeting with CEOs of European countries commited to the development of low carbon transport fuels

Meeting with Jyrki Katainen (Vice-President) and UPM-Kymmene Oyj and

25 Feb 2016 · Biofuels

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

16 Sept 2015 · Biofuels

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

15 Sept 2015 · Advanced biofuels, challenges and opportunities ahead from a technology and investment perspectiv

Meeting with José Mendes Bota (Cabinet of Commissioner Carlos Moedas)

11 Sept 2015 · Introduction about Novozymes new strategy and enzymatic solutions

Meeting with Margrethe Vestager (Commissioner)

29 Jun 2015 · Circular Economy

Meeting with Phil Hogan (Commissioner)

25 Mar 2015 · Bio Based Economy

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

25 Mar 2015 · Circular Economy

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

25 Mar 2015 · Bio based economy

Meeting with Jon Nyman (Cabinet of Vice-President Cecilia Malmström)

19 Feb 2015 · Green Goods negotiations

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

17 Feb 2015 · The role of biofuels in the Energy Union

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

16 Feb 2015 · The 2030 energy and climate policy and Energy Union

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

11 Dec 2014 · BIOFUELS + BIO-ECONOMY