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Swedish Bioenergy Association

SVEBIO

Svebio's goal is to promote the use of bioenergy in an economically and environmentally optimal way, in Sweden and in other countries.

Lobbying Activity

Response to High and low Indirect Land-Use Change (ILUC) - risks biofuels, bioliquids and biomass fuels

8 Mar 2019

As we understand it, this is not a regulation of indirect land use change, but added criteria for direct land use effects, aiming at stopping import to EU of palm oil for diesel production, and palm oil diesel, in addition to the general sustainability criteria in RED. The Commission states that the regulation should be based on the most recent data, and allow for future changes to be taken into account. We agree. The sustainability criteria for biofuels have now been in place for almost ten years, and should have an impact on the development in producing countries, also where palm oil is produced. It is important to monitor the development to be able to consider on-going improvements. When deforestation is stopped or reduced to low levels in the major producing countries, and this can be proven, imports to EU will resume. We find the proposed criteria for “high land-use change risk” balanced. Concerning “low land-use change risk” we think “severely degraded” should be changed to “degraded”. In the definitions, we think that small holders should be higher than the proposed 2 – 5 hectares. It is important to promote sustainable palm oil production, not least in countries in Africa. In general, EU should focus on working directly with the concerned countries to reduce direct negative land-use change.
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Response to Prolongation of State aid rules reformed under the State aid modernisation package that expire by the end of 2020

7 Mar 2019

The Swedish producers of sustainable biofuels like ethanol, biodiesel and biogas based on "food and feed" based feedstock are dependent on tax exemption (not paying carbon tax and energy tax), that is considered state aid. This system har been in place for many years. With the prolongation of EEAG to 2022, this support will be discontinued 2020 (p 121, also p 113), which will cause big problems for these producers, and threatens to increase the GHG emissions from transport in Sweden. If the guidelines are prolonged to 2022, this should also be done with the time limit in p 121. The issue of support after 2022 can then be considered for the time period after 2022. This issue concerns companies offering pure or high-blend biofuels like: Ethanol E85 and ED95 B100 - pure biodiesel RME HVO100 - pure HVO diesel Biogas
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