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Preem AB

Preem

Preem is Sweden's largest fuel company and one of Sweden's largest export companies.

Lobbying Activity

Meeting with Isabella Lövin (Member of the European Parliament) and Stena Recycling Holding Ab

25 Sept 2025 · Circular economy and green transition

Response to COMMISSION DELEGATED REGULATION on extending the scope of traceability of the Union database

7 Nov 2024

We thank the EC for the opportunity to provide feed-back on the DRAFT delegated act on the Union Database. The UDB has significant impacts on the European biofuel business and the further guidance on the implementation of the UDB is much needed. Responsibilities of Certification Bodies (CB) The CB is given a great responsibility in terms of maintaining the UDB up-to-date with valid certificates etc. If failing handling of certificates etc. the consequences for the Economic Operators (EO) can be suspension or withdrawal from the UDB. Such failure from a CB can have enormous economic and reputational consequences for the EO, but there seem to be no structured demands on CBs and their contribution in the DRAFT delegated act. (Article 3, Paragraph 3, 7 and Article 6, Paragraph 1, 2) Initial stock entry Article 4 is unclear to us, and possibly others. Shall all EOs register all eligible initial stock available from a certain point in time, or does this refer to First Gathering Point and Collecting Point only? If not, the full implementation of the UDB will be significantly delayed. Transaction data entry Entering transaction data within 3 working days from the issuing of suppliers invoice or bill of lading is to short and not justified. While the suggested short timeline could help speed up important transfer of sustainability information between parties in the supply chain, there is also an overwhelming risk of a significant accumulation of cancelled transactions. The 3 day rule is likely to cause a lot of cancelled transactions, extra work for both seller and buyer, and introduce risk for system malfunction. For these reasons, the EC should motivate the choice of the 3 days. (Article 5, Paragraph 1) Other It would have been appreciated if this Delegated Act would have been made available much earlier to clarify the implementation of UDB for EOs. The UDB still has several severe bugs, which makes it unreliable. Examples of such bugs include incorrect change of country of origin when processing an imported raw-material, and failure to forward transportation distances for Etd calculations. The UDB team has failed to reply to EOs when pointing out these mal-functions. The UDB introduces a double work for EOs, on top of the already well functioning 3rd party certified or reviewed voluntary and national schemes. Due to the many mal-functions and the fact that the UDB does not support EOs business needs relating to e.g. easy monitoring availability of certain raw-materials, the UDB in its current form will not replace the EOs already existing systems for managing transactions and sustainability information through the value chain. The UDB was established to ensure traceability of biofuels and biobased raw-materials, but due to the mal-functions described above, this ambition is not reached. Further clarifications needed to be included in the delegated act Geographical scope: Shall biofuels produced in Europe and exported to non-EU countries, e.g. Norway, be registered in the UDB? Shall a transaction be registered in UDB only when ownership of material changes? Or shall also registration be done e.g. when a third party pre-treats a raw-material as a service without change of ownership (aka tolling agreement)?
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Meeting with Karin Karlsbro (Member of the European Parliament) and The Coca-Cola Company and Folksam Group

9 Feb 2024 · Klimatområdet, ledarskap och hållbart företagande

Meeting with Emma Wiesner (Member of the European Parliament, Shadow rapporteur)

21 Feb 2023 · koldixidinfångningsteknologi

Response to Update of list of sustainable biofuel feedstocks

2 Jan 2023

Feedback concerning Commission delegated directive (EU) amending Annex IX to Directive (EU) 2018/2001 of the European Parliament and of the Council, as regards adding feedstocks for the production of biofuels and biogas Preem AB (publ.) Summary Preem welcomes the initiative to amend Annex IX with extensional feedstocks for renewable fuel production, a step in the right direction. The increased need for renewable fuels in Europe due to ambitious climate targets within the transport sector requires high accessibility to sustainable feedstock. An increased number of accepted feedstocks is also important to increase the willingness to invest and to develop new technology routes and value chains for renewable fuel production. However, there are several contradictions in the proposal, that does not favors an increased production of renewable fuels. Expansion of Annex IX B need to come with a flexibility on the Annex IX B cap Allocation of feedstocks to Annex IX A and B based on matureness of technology From Annex IX A to B, undermining investments Annex IX should be the sole list for feedstock classification
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Response to Methodology to determine the share of renewables in case of co-processing

12 Jul 2022

Preem welcomes the delegated regulation on the methodology to determine the share of biofuel and biogas for transport, produced from biomass being processed with fossil fuels in a common process. The flexibility of different methods suggested in the regulation is a welcome approach and provides a good basis for increased use of co-processing and hence fast increased production of renewable fuels. Preem also agrees that 14C method for regular verification using the yield method is a good solution but question the use of 14C for the mass- and energy balance methods, since it will not fill its purpose as a verification tool as those methods will not show the exact yields in the produced product range. Some additional clarifications and details in the suggested regulation are needed, see comments below. Article 1:2 “Economic operators shall ensure that the share of biofuels or biogas is above the detection limit of the testing method.” Introduction and development of new technologies and feedstocks can be hindered and delayed by the above suggested paragraph. During the introduction and learning period of new technologies and feedstocks low flow of feeds may be necessary to avoid harm to equipment and to the environment. The suggested text will be a hindrance to the development of renewable fuels using co-processing. Suggestion: If the economical operator can prove their methodology elsewhere in the refinery, shares below the detection limit may be acceptable for developing new technologies and for new feedstock. All economic operators should be given the possibility to develop and use a stepwise introduce renewable feedstocks into a present process, which is one of the strengths and benefits with co-processing. Article 1:4 “When economic operators report co-processing results, they shall provide details on the accuracy and precision of the testing method used.” Details regarding accuracy and precision should be limited to flowmeters and regular verification using 14C method (for yield method). Article 1:5 “Verification through radiocarbon (14C) testing shall be required for all outputs claiming a carbon-based bio-content. “ The verification of gas streams such as butene, propene and internal fuel gases cannot (to our knowledge) be verified by 14C method. A practical solution to this is important, for example by clarify that the verification is limited to liquid streams. As mentioned above Preem also agrees that 14C method for regular verification using the yield method is good but we question the use of 14C for the mass- and energy balance methods since it will not fill its purpose, as those methods will not show the exact yields in the product range. This needs to be further clarified in the regulation. Article 2:3 The paragraph is repeated in article 3 – to be removed. Article 4:1 Preem assume that the yield method 1B are to be based on data received from the technical supplier of refinery equipment. To do this test in full operation in the refinery may be possible at occasions but not regularly, that would be a massive disturbance to the production. This must be clarified in the paragraph. Article 4:2 “they shall use the 14C testing as a control method to verify its yield factor at least whenever they change operating conditions.” Preem assumes this is on a regular basis not every time the operational conditions changed to a previously known and run condition and feedstock blend. Suggestion: Define change of operation conditions to “new” operating condition (not previously verified by 14C). Article 4:3 What is the difference in this article compared to Article 4:2 needs to be clarified. Article 5 This article needs to be clarified and exemplified, as written it is impossible to understand how this would work practically. Very common when producing renewable fuels is to remove oxygen using hydrogen, is oxygen considered to be an impurity such as Sulphur. Also, to consider is the fact that
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

12 Jul 2021

Feedback: Sustainable biofuels, bioliquids and biomass fuels – voluntary schemes (implementing rules) Article 21 and Annex IV: Specific rules for waste and residue For the definition of waste and residues it is referred to Directive 2018/2001 (RED) in Article 21 of the draft act, but Annex IV in this draft act do not harmonize with the definition of waste and residues in RED Annex IX point o regarding the biomass fractions of waste and residues from forestry and forest-based industries. In Annex IV point 2b of the draft act only crude tall oil is defined as waste under the scope of forestry residues and waste. In directive 2018/2001 it clearly states in Annex IX part A point o that bark, branches, precommercial thinnings, leaves, needles, tree tops, saw dust, cutter shavings, black liquor, brown liquor, fibre sludge and lignin are considered to be fractions of waste and residues from forestry and forest-based industries. To harmonize the directives and recognize the use of forest-based waste and residues all the mentioned waste and residues in Directive 2018/2001 Annex IX part A point o should be included in the draft act Annex IV point 2b. There is a clear value-addition when the fractions of wastes and residues in the 2018/2001 list are being utilized for production of sustainable biofuels. Several projects are already in full-scale production and more are currently under construction. It is important that the two directives share the same definition regarding waste and residues Article 23. Specific rules for co-processing In point 1 of article 23 in the draft act it is required from the economic operators to apply the methodology set out in delegated act as adopted pursuant to Article 28(5) of Directive 2018/2001. First, the delegated act to Article 28(5) of Directive 2018/2001 is not yet available, not even a draft has to our knowledge been presented. Hence, the methodology of this act is not known per today. Secondly, point 2 and 3 in article 23 in the draft act is a detailed description of a methodology the economic operators are required to follow to identify renewable shares during co-processing. We question these descriptions as we are already required by point 1 in this article to follow the methodology in the delegated act related to Directive 2018/2001. Assuming the methodology described in point 2 and 3 is the same method as in the delegated act to Article 28(5) of Directive 2018/2001 point 2 is redundant. If the methodology in point 2 of this draft is to be considered to be the main rule in addition to the methodology that are to be presented in the delegated act according to Article 28(5) of Directive 2018/2001, it should be noted that the methodology described in point 2 is not viable for all co-processing possibilities. Low blends of co-processed renewable feeds into complex refining systems will generate a low output of renewable fuel components in several streams not allowing for C-14 methodology to be used due to restrictions in detection level of the measurement method. In these cases, the calculation-based method should be recognized as the sole method for determining and verification of the renewable product share from the co-processing operation. To claim regular C-14 measurements for verification for these types of streams will hinder the development of feedstocks and refining technologies for production of advanced renewable fuels (Directive 2018/2001 Article IX Part A). Article 28. Entry into force To be able to implement changes in this draft act, operators should allow for proper transition periods since internal systems and processes needs to be adjusted accordingly. No such transition period is given in this draft act.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

21 Apr 2020

The European Commission's presentation of the European Green Deal has raised the need for new policies within the EU, in order to realize the joint climate goals and ambitions. Within the framework of the upcoming Strategy for Sustainable and Smart Mobility, the Commission has stressed the importance of new regulation enabling a sustainable transition for the aviation industry. An increased use of Sustainable Aviation Fuels (SAF) has been proposed by the Commission to be a key factor in the sustainable transition for European aviation. On that note, Preem agrees and sends hereby our feedback on the Impact Assessment for ReFuelEU Aviation – Sustainable Aviation Fuel roadmap, in which we argue that increased production and use of SAF probably is the number one measure in making the European aviation industry sustainable in the years ahead. Find our feedback attached. The feedback is written in Swedish.
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