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TEREOS

Tereos est une coopérative agricole sucrière transformateur de matières premières agricoles (betteraves, céréales) en sucre, amidon, alcool, éthanol notamment.

Lobbying Activity

Meeting with Dominique Bilde (Member of the European Parliament)

28 Nov 2023 · La filière sucrière européenne à l'épreuve des traités de libre-échanges

Response to Update of list of sustainable biofuel feedstocks

30 Dec 2022

In general terms, Tereos welcomes the revision of Annex IX as the EU needs to accelerate the decarbonization of the transport sector to achieve its Green Deal objectives. Since liquid biofuels will play an indispensable role in relishing this challenge and given that conventional biofuels are capped, increasing the list of Annex IX feedstocks is a prerequisite. However, this list must be consistent and in line with practical and industrial realities. 1- The Commission can only add feedstocks to Annex IX Part A & B, not remove them (Article 28.6) - Annex IX-A of RED-II includes item (d) Biomass fraction of industrial waste not fit for use in the food and feed chain under which Member States (MS) have classified several feedstocks. Annex IV of the recently published Delegated Regulation Act 2022/996 of 14/6/2022 contains a non-exhaustive list of all feedstocks falling in item (d). - However, in its proposed revision of Annex IX, the Commission has included in part B several feedstocks that MS have already included in item (d) of Part A. These include items 2) (c), (d), (e), (f), and (o). These feedstocks ought to be included in Part A. 2- Specifics on added feedstocks - Item (r): the reference head and tails should be inserted after residues. - Item (f): the reference with less than 20% starch content should be deleted as in certain MS, the pragmatic approach taken is not based on the starch content but on a case-by-case analysis recognizing the waste status, if applicable. - Item (j): the notion of damaged crops must be carefully defined and controls particularly tight to avoid the EU triggering and attracting a world production of damaged crops. - Item (n): there is no reason to discriminate and discard sugarbeet vinasses as this feedstock is not used in the feed sector in the EU-27. The exclusion of sugarbeet vinasses ought to be deleted. - Item (o): for the sake of clarity, retentates originate from sweeteners refining rather than sugar refining. 3- Other comments - Regarding the inclusion of beet pulps in Annex IX, Tereos believes that, in a context of high pressure for the industry to reduce its greenhouse gas emissions combined with a downward trend of certain meat consumption, flexibility between feed and energy uses should be established. Whilst recognising that the feed sector should always have priority over the energy one, a system should be put in place allowing Member States to define, after a case-by-case examination, which feedstocks and in which proportion, can be considered as residues suitable for energy uses. Adding a category like the current Annex IX Part A-d) in Part B could be an option. - Using the technology as a criteria to distinguish between Part A (innovative) and B (mature) materials is not automatically in line with the industrial reality for most feedstocks included in Part A. - Another more relevant criteria should govern this classification i.e., whether the material is considered a waste (Part A) or a residue (Part B). - It is the role of the competent authority to define this distinction taking all parameters into consideration, including local circumstances, verified by auditors and the certification process in place. - Consequently, the reference and waste in items (c), (d), (e) should be removed. - Finally, in order to not penalize the economic viability of annex IX materials and potential related investments, the targets associated to Part A and part B in RED-III should be lifted in due proportion of the increased feedstock availability.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and KDC Conseil SRL

30 Mar 2020 · EU bioethanol policy

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

7 Jun 2016 · Circular Economy and Bioeconomy