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Verband der Deutschen Biokraftstoffindustrie

VDB

The Verband der Deutschen Biokraftstoffindustrie represents the interests of the German biofuel industry at national and European levels.

Lobbying Activity

Meeting with Maxi Espeter (Cabinet of Commissioner Christophe Hansen)

28 Jan 2026 · Certification of biofuels

Meeting with Christian Ehler (Member of the European Parliament)

20 Oct 2025 · THG-Quotengesetz Deutschland

Meeting with Jutta Paulus (Member of the European Parliament)

16 Jul 2025 · Kraftstoffe

Meeting with Christian Ehler (Member of the European Parliament)

15 Jul 2025 · Biokraftstoffe

Meeting with Kamil Talbi (Cabinet of Commissioner Dan Jørgensen)

15 Jul 2025 · Biofuels

Meeting with Kitti Nyitrai (Head of Unit Energy) and Transport and Environment (European Federation for Transport and Environment)

20 Jun 2025 · Discussion on fraud prevention and relevant sanctions

Meeting with Stefan Köhler (Member of the European Parliament) and Deutscher Raiffeisenverband e.V.

19 Mar 2025 · Politischer Austausch

Meeting with Christian Ehler (Member of the European Parliament)

4 Feb 2025 · RED III

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

30 Sept 2024 · General exchange on current challenges of alternatives fuels

Meeting with Jens Gieseke (Member of the European Parliament)

23 Jul 2024 · Austausch zu Umwelt- und Verkehrspolitik

Meeting with Andrea Wechsler (Member of the European Parliament)

23 Jul 2024 · EU Energy Policy

Meeting with Christian Ehler (Member of the European Parliament)

18 Jun 2024 · Energy policy

German biofuel industry urges safeguards for existing feedstock classifications

2 Jan 2023
Topic — The consultation reviews adding new sustainable feedstocks for producing biofuels and biogases.
Message — The VDB requests a grandfathering provision to protect existing national classifications of advanced biofuel feedstocks. They also advocate excluding intermediate crops and defining damaged crops to prevent fraud.123
Why — This would prevent the devaluation of current investments and maintain existing biofuel value chains.45
Impact — Regulators and the environment lose if difficult-to-monitor feedstocks enable widespread fraudulent conduct.6
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

German biofuel lobby warns against strengthening oil refinery oligopoly

19 Jul 2022
Topic — Rules for determining the share of renewables when processed with fossil fuels.
Message — The association demands precise scientific testing and strict accounting to ensure only transport-specific biogenic content counts. They also call for biogenic shares to be verified before entering the market.123
Why — These regulations would safeguard the market position and investments of biodiesel producers.4
Impact — Large oil companies lose the ability to easily strengthen their market oligopoly.5
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German biofuel industry demands higher targets and strict fuel accounting

17 Jun 2022
Topic — A consultation on calculating greenhouse gas emission savings for non-biological and recycled fuels.
Message — VDB requests dedicated renewable electricity for production and significantly higher climate targets. They also oppose overrating the climate benefits of grid electricity.12
Why — These rules would protect the market position of biofuels against competing energy sources.3
Impact — Producers using standard grid power would see their reported emissions increase dramatically.4
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Response to Commission Regulation on the influence of heavy-duty trailers on the CO2 emissions of towing trucks

21 Mar 2022

The revision of CO2 fleet limits for heavy-duty vehicles must ensure the eligibility of renewable fuels. It is indispensable to create additional options for meeting the fleet limits alongside the development of engine efficiency (which is technically limited) and the promotion of electromobility (which cannot cov-er all applications in heavy-duty transport). Equal treatment of different options for CO2 savings in road vehicles can be promoted via a consistent well-to-wheel methodology. This allows in particular the crediting of renewable fuels and is urgently required in order to establish a level-playing field in the sector of transport. Renewable fuels in this context are all kinds of liquid and gaseous fuels of non-fossil origin, especially all sustainable biofuels: crop-based biofuels and biofuels as defined in Annex IX Part A and Part B of RED II. Eligibility provides the necessary economic incentive for OEMs to approve vehicles for the use of higher biofuel blends. Consequently, not only the climate but also the development of technology and the roll-out of additional volumes of renewable fuels that are not yet sold in the market like advanced biofuels (Annex IX Part A) and fuels based on renewable electricity (PtG and PtL) would benefit from such a prospective political decision. The crediting proposal of Frontier Economics is supported in this respect. In general, it will also be difficult to explain to European citizens why money is spent for not meeting fleet limit targets and not reducing GHG instead of investing in sustainable renewable fuels and saving GHG emissions considerably. As fleet limits make vehicles more expensive in a lopsided manner and as the logistics sector is already facing existential problems due to high fuel prices, it is crucial to introduce this crediting option for al-ternative sustainable fuels to relieve the burden on the economy and consumers. Finally, the supply crisis in the EU resulting from the war in Ukraine must be taken into account. The physical contribution to fuel supply from biofuels replacing fossil fuel imports was about 4.5 million tons in Germany in 2020 alone.
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Meeting with Markus Pieper (Member of the European Parliament, Rapporteur) and EPIA SolarPower Europe and

24 Nov 2021 · RED III

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

18 Nov 2021

Please find our comments attached.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

Please find our comments attached.
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Response to FuelEU Maritime

8 Nov 2021

Please find attached our comments on the initiative.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

8 Nov 2021

Please find attached our comments on the initiative.
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Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

Please find attached our comments on the initiative.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

Please find attached our comments on the initiative.
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and FuelsEurope and

23 Mar 2021 · Renewable fuels to climate neutrality and economic growth

Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

VDB welcomes the Commission’s initiative to establish a sustainable finance Regulation. It is crucial to steer financial flows in a reasoned manner to promote climate-friendly growth and transition towards a carbon neutral economy. In this context, the EU taxonomy framework must be in line with the European Green Deal objectives to achieve an increased emission reduction performance in the Union. However, regarding biofuels, the draft delegated regulation would contradict the legal provisions that have been defined in the Directive (EU) 2018/2001 (RED II) which is currently being transposed into national law across Member States. Distinguishing between crop-based and advanced biofuels is not permissible according to RED II. In fact, RED II supports all types of sustainable biofuels: • Sustainable biofuels, crop-based, waste/residue-based as well as advanced biofuels, can count towards the target to provide at least 14 percent of renewable energy in the European transport sector by 2030; • The contribution of crop-based biofuels shall be no more than one percentage point higher than their 2020 share, with a maximum of 7 percent; • RED II stipulates the phase-out of high indirect land-use change-risk feedstock for which significant expansion of the production into land with high-carbon stock is observed, as determined in the Commission Delegated Act and its Annex; • Advanced biofuels, specified as those made from feedstock of Annex IX Part A of RED II, are sub-ject to a ramping-up sub-target of 3.5 percent by 2030. It would be inconsistent to have the RED II legislation defining and supporting sustainable biofuels (including crop-based ones explicitly) and the sustainable finance policy of European Union excluding the same biofuels. As the European Green Deal sets up the target to achieve a reduction of 90 percent in transport-related GHG emissions by 2050, investments in clean technologies and sustainable alternative fuels are essential to reach the transition that is needed. Therefore, it is necessary to define the regulatory framework for the use of climate-friendly energy sources. Biofuels, electromobility, electricity-based fuels and enhanced energy efficiency together make climate protection in transport possible. Without renewable fuels the necessary GHG reductions cannot be achieved in road transport and the GHG budget will be exhausted prematurely. Biofuels such as biodiesel, bioethanol and biomethane have saved around 9.7 million tonnes of greenhouse gases in 2019 in Germany alone. It is evident that the GHG balance of the transport sector would be even more devastating if biofuels did not make a substantial contribution to climate protection. Compared to fossil fuels, biofuels reduce greenhouse gases by up to 90 percent. The en-tire production process is considered here, starting with the emissions from the agricultural cultivation, transport, and the industrial processing of the raw materials.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

Remarks on the initiative: VDB welcomes the Commission’s initiative to revise the Guidelines on State aid for environmental protection and energy. With an increasing use of sustainable biofuels, agriculture and forestry would make a growing contribution to climate protection and to the production and use of sustainable protein feed. Biofuels such as biodiesel, vegetable oil and biomethane are technological options that promote the circular economy and are in line with the farm-to-fork strategy in the context of implementing the European Green Deal. In this regard, an essential prerequisite for the use of biofuels in agriculture and forestry in Germany is the need to allow tax exemption for sustainable biofuels within the Guidelines until at least 2030. Apart from biofuels, there are no serious decarbonization options for agricultural and forestry machinery. VDB is therefore concerned about the planned expiry of the energy tax refund for sustainable biofuels at the end of 2020 and refers specifically to the regulations in numbers 113 and 121 of the Commission's Guidelines on State aid for environmental protection and energy. Like any other economic sector, the biofuels industry needs an appropriate policy and legal framework: Against this background, we advocate to establish the conditions for the notification of tax refunds of biofuels within the context of the current revision of the State aid Guidelines. We request that points 113 and 121 of the guidelines are included in the decision on the prolongation. It should be considered that biofuels from agricultural crops are subject to comprehensive sustainability criteria and must meet strict greenhouse gas reduction requirements in accordance with the Renewable Energy Directive (RED II). General remarks: As the European Green Deal sets up the target to achieve a reduction of 90% in transport-related GHG emissions by 2050, investments in clean technologies and sustainable alternative fuels are essential to reach the transition that is needed. Therefore, it is necessary to define the regulatory framework for the use of climate-friendly energy sources. Biofuels, electromobility, electricity-based fuels and enhanced energy efficiency together make climate protection in transport possible. Without renewable fuels the necessary GHG reductions cannot be achieved in road transport and the GHG budget will be exhausted prematurely. Biofuels such as biodiesel, bioethanol and biomethane have saved around 9.7 million tonnes of greenhouse gases in 2019 in Germany alone. It is evident that the GHG balance of the transport sector would be even more devastating if biofuels did not make a substantial contribution to climate protection. Compared to fossil fuels, biofuels reduce greenhouse gases by up to 90 percent. The entire production process is considered here, starting with the emissions from the agricultural cultivation, transport, and the industrial processing of the raw materials.
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Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

Policies to reduce the GHG emissions of newly registered cars are one of the most important instruments within the transport sector. Within this instrument ambitious performance standards for passenger cars are needed. However, it must be noted that 1. policy measures must have a significant and measurable effect on GHG emissions 2. besides setting ambitious goals, it is above all important to achieve them. At present, it must be stated that these two important conditions are not met.   In detail: The ICCT states (ICCT: From laboratory to road: A 2017 update) that in the EU system of measuring fuel economy and CO2 emissions there is a considerable gap between the test results and on-road performance of cars. The divergence has been growing in recent years; it has increased from 8% in 2001 to 31% in 2013 and reached 42% in 2016. The gap is expected to grow up to over 50% by 2020. In practical terms this means that car manufacturers take the low hanging fruits by optimizing their cars according to the test cycle but do not achieve efficiency gains in real operation. These facts should not hide that there undoubtedly is a progress in making cars more efficient though. Car companies offer a variety of highly efficient cars that even nowadays comply with the 95 g CO2/km target which will fully come into effect in 2021. However, it has been shown in the meantime that the 95 g CO2/km mandate will be extremely challenging for car manufacturers and will only be achievable in an economic way under very favor-able conditions. The recently adapted emission standards for the period after 2021 set an even more challenging target and are not achievable solely by ICE engines but only with a high share of electric cars. The share of electric cars in the next decade, in turn, depends on different factors, of which not all are in the hands of the automobile industry. Especially the expansion in the charging infrastructure, the further development of battery technology and costs will have a significant impact on the final con-sumer’s acceptance of electric cars. Even though car manufactures can influence the price of elec-tric cars, if necessary, by cross-subsidizing among their new car fleet, the price is only one argument among many deciding factors for car customers. 3. Conclusions and suggestions Taking these uncertainties into account, the compliance with the 2025 and 2030 targets is very much in jeopardy. Alternative compliance options are needed to make the targets achievable and there-by minimize the risk of high penalties which endanger the economic position of the automobile industry and do not deliver CO2 reduction at all. The review clause that requires the European Commission to re-assess and, if necessary, amend the regulation is a viable opportunity to include other compliance options, e.g. the use and consideration of renewable fuels, in the regulation. The amendment should allow OEMs to voluntarily finance additional renewable fuel (on top of the volumes mandated under RED II) and count the corresponding emission reductions against their fleet targets. In contrast to previous ways of achieving emission savings, some of which only contributed on paper (optimization of vehicles for test cycles), the use of renewable fuels always achieves the desired GHG reduction. Studies by Frontier Economics (Frontier Economics: Crediting System for Renewable Fuels in EU Emission Standards for Road Transport have shown that crediting renewable fuels is economically feasible and can be implemented in the system of CO2 emission standards. This additional option would put OEMs into a position to reduce the risks of missing their mandate and consequently help the EU and their member states to reliably achieve the emission reduction goals. We therefore strongly recommend a review of the options for including the crediting of renewable fuels in the Regulation.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Please find our comments attached.
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Response to Sustainable and Smart Mobility Strategy

23 Jul 2020

Please find attached our comments on the strategy.
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Response to Strategy for smart sector integration

8 Jun 2020

VDB welcomes the initiative of the European Commission on sector coupling. It is essential to create a smarter and more integrated energy system in order to further reduce GHG emissions. All sectors have to fully contribute to decarboni-sation, including those where progress has been low to date, in particular transport. Creating an integrated energy system by linking sectors and exploiting synergy effects is a key task. But meeting the ESR target requires even stronger efforts: The electrification of road transport is by far not sufficient to achieve the sec-tor’s fair share of GHG reduction. Taking into account the fleet of vehicles still in use in 2030, renewable liquid and gaseous fuels will have to deliver the lion’s share of decarbonisation in road transport. Road transport is responsible for the overwhelming majority of GHG emissions in transport, and liquid fuels will deliver the overbearing share of energy in road transport at least until 2030 and most likely also in the following decade. Bio-diesel is the most important renewable fuel and relevant for decarbonising the decisive diesel fuel segment. An increase in the admixture of biodiesel is re-quired to maintain the total amount of renewable fuel. This is necessary be-cause the volume of renewable fuels declines in line with declining overall fuel sales. The HDV sector is particularly suitable for this purpose as modern EURO VI engines are in principle suitable for B20, B30 or B100, and several manufactur-ers have already approved their vehicles. The Commission should ensure, for example by providing incentives, that these higher blends are widely available at filling stations in the EU. Furthermore, hydrogen produced from renewable electricity will have to play a key role in this con-text, together with the replacement of natural gas by biomethane produced from agricultural wastes.
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Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

VDB Comments Revision AFID
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Response to FuelEU Maritime

24 Apr 2020

Addressing climate protection in the field of maritime shipping is an excellent initiative of the Euro-pean Commission. So far, this mode of transport has contributed virtually nothing to decarbonising Europe. This is mainly due to a lack of regulation. In order to reduce GHG emissions in maritime shipping effectively, a binding mandate is needed. The mandate could either regulate the share of renewable energy used or the GHG reduction achieved by the fuel. Any multiple counting that favours the use of renewable fuels in maritime shipping over road transport has to be avoided. It would only shift efforts from road transport to maritime shipping which does not make sense at all. If the mandate forms part of the RED II transport target, then the target has to be increased significantly. At the same time, the energy consumption of the maritime sector has to be included in the denominator according to Art. 27 (para. 1 lit. a) of the RED II. All renewable maritime fuels that are offset against a binding mandate must be produced sustainably according to the sustainability criteria of the RED II - also PtL based on renewable electricity. ISO 8217 already allows to blend up to 7% FAME (fatty acid methyl ester) into marine fuels. It is therefore appropriate to allow FAME as relevant option for a mandate, especially as it can be used in existing ships and infrastructure. This should be complemented by PtL and renewable LNG like Bio-LNG. Their use can be expanded successively, notably by investing in production capacity, new ships and infrastructure if necessary.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

21 Apr 2020

Addressing climate protection in the field of aviation is an excellent initiative of the European Commission. So far, this mode of transport has contributed virtually nothing to decarbonising Europe. This is mainly due to a lack of regulation. In order to reduce GHG emissions in aviation effectively, a binding mandate is needed. The mandate could either regulate the share of renewable energy used or the GHG reduction achieved by the fuel. Any multiple counting has to be avoided because it only would shift efforts from road transport to aviation which does not make sense at all. If the mandate forms part of the RED II transport target, then the target has to be increased significantly. At the same time, the energy consumption of the aviation sector has to be included in the denominator according to Art. 27 (para. 1 lit. a) of the RED II. Energy use in aviation is huge and still increasing. Therefore, it is obvious that new kinds of renewable fuels have to be deployed that allow for making use of a broader variety of feedstocks. Biofuels produced by advanced technologies like Biomass-to-Liquid (BtL) from solid and other unconventional biomass as well as electricity-based fuels like Power-to-Liquid (PtL) are fuels with a significant feedstock potential. Their market run-up must therefore be prepared, through appropriate support measures such as a binding mandate. On the other hand, important volumes of liquid biofuels are and will be needed to decarbonise road transport - not as an alternative but in addition to electrification. Biofuels made of cultivated biomass are not considered for use in aviation under the RED II. Biofuels produced from used cooking oils and animal fats (Annex IX Part B, RED II) are used in well-established production chains for road transport, where they make a substantial contribution to reducing emissions. Fostering the use of feedstocks that are established in the field of road transport in aviation would divert raw material flows but not generate additional GHG savings. On the contrary, the production of aviation fuels from these raw materials leads, due to more complex production processes, to worse greenhouse gas savings than their use in the established pathways for road transport. We therefore encourage the COM to open new options for aviation. Only then we will achieve additional GHG-savings for the overall transport sector.
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Response to 2030 Climate Target Plan

14 Apr 2020

Please find attached our comments on the 2030 Climate Target Plan.
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Response to Revision of the Energy Tax Directive

31 Mar 2020

Please find attached our comments on the Revision of the ETD.
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Response to Climate Law

5 Feb 2020

Please find file attached.
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Response to High and low Indirect Land-Use Change (ILUC) - risks biofuels, bioliquids and biomass fuels

7 Mar 2019

The Association of the German Biofuel Industry (Verband der Deutschen Biokraftstoffindustrie e. V. – VDB) represents the interests of twelve biofuel producers in Germany with a production capacity of 2.3 million tons. This equals approximately 60% of the total capacity in Germany. VDB wishes to submit the following comments on the draft delegated act on high and low iLUC-risk biofuels, published by the European Commission on February 8th. VDB acknowledges the effort of the Commission and the usage of the best available scientific data. The delegated act is meant to enforce the European legislator’s intention to phase out the use of feedstock which is linked to deforestation and peatland drainage and can thus not be considered being sustainable. VDB understands the draft delegated act as a potential compromise to match sustainability issues with the economic interests of biomass producers in third countries and biomass use in the form of biofuels in the EU while respecting the overarching goal to effectively reduce land use change. Unfortunately, there is a lack of data on the volumes of low iLUC palm oil that have to be expected under the rules of the draft act. Despite the political, economic and ecological importance of the file, a proper impact assessment has not been carried out beforehand. This does not only stand in contrast to the Commission’s dedication to better law-making but also puts the European biofuel and agricultural industry into a position of insecurity. In general, unless it is amended, the proposed regulation will have no effect on deforestation: It neither efficiently limits the total amount of palm oil use nor does it sanction deforestation in certain regions. Not including provisions that will have an effect on deforestation would contradict instead of support the European Union’s own policy against deforestation as, e.g., expressed in the Roadmap on the EU initiative on Stepping up EU Action against Deforestation and Forest Degradation, published on 14th December 2018. In order to achieve efficient forest conservation, the delegated act needs to be amended according to the following principles: (see attached document)
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Meeting with Peter Wehrheim (Cabinet of Commissioner Phil Hogan)

21 Mar 2018 · Renewable energy directive

Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan)

9 Nov 2016 · Energy union