European Commission proposes Amendments to the Renewable Energy and Fuel Quality Directives

Last Wednesday the European Commission published a number of proposed amendments to the 2009 Renewable Energy and Fuel Quality Directives.  These amendments address criticisms that the current Directives do not take sufficient account of emissions from indirect land-use change (where demand for feedstock for biofuels drives food crop farmers onto land which has a high carbon stock) and do not provide sufficient incentive to the biofuels industry to adopt advanced (low-ILUC) biofuels.

Now the proposals have been published, they must be agreed by EU governments and
lawmakers in a process that can take up to two years. If adopted the proposals will have signficant impact on the biofuels industry.


The main thrust of the proposals is promote the development of advanced biofuels that have limited impact on the production of food and feed crops.  It will do that by limiting the use of food and feed crops such as cereals, starch-rich crops, sugars and oil crops and by providing additional incentives to develop fuels based on algae and wastes.

It also introduces a new mechanism for estimating emissions from carbon stock changes caused by indirect land-use change and simplifies the GHG calculation for European biofuel producers.

Finally it raises the minimum GHG savings threshold for new installations from July 2014.

Capping Usage of Feed Crops

The most direct impact of the proposed amendment is the intention to cap the proportion of total biofuels from cereals, sugars and oil crops to 5% of the total transportation energy mix, or roughly 50% of the renewable fuels mix.

This would have a significant impact on the expected growth in the usage of sugar-based Ethanol in petrol.  The impact on biodiesel is mitigated to some extent by the provisions to stimulate second generation biofuels, for example those produced from waste.  There has already been vocal opposition to these proposals from parts of the biofuels industry.

Estimated Indirect Land-Use Change Emissions

There are further provisions to limit the scope for biofuels produced from food and feed crops.  These fuels would also have to report an indirect land-use change emissions “cost” as follows:

Feedstock group Estimated indirect land-use change emissions
Cereals and other starch rich crops 12 gCO2/MJ
Sugars 13 gCO2/MJ
Oil crops 55 gCO2/MJ

Biofuels produced from all other feedstocks would be assumed to have zero indirect land-use change emissions.

Feedstock whose production has led to direct land-use change will still have to calculate an emissions factor using the existing formula. The previous bonus for restoring degraded or contaminated land to production will, however, be removed.

Stimulating Second Generation Biofuels

To provide added stimulus to the development of “second generation” biofuels, the amendments propose extension of the existing “double counting” provisions for certain feedstocks. In fact many second generation fuels would qualify for “quadruple counting” (their contribution towards the renewable energy target would be four times their energy content).

This proposal affects fuels produced from:

  • Algae
  • Biomass fraction of mixed municipal waste, but not separated household waste
  • Biomass fraction of industrial waste
  • Straw
  • Animal manure and sewage sludge
  • Palm oil mill effluent (POME) and empty palm fruit bunches
  • Tall oil pitch
  • Crude glycerine
  • Bagasse
  • Grape marcs and wine lees
  • Nut shells
  • Husks

The amendments propose that existing arangements for “double counting” would continue for:

  • Used cooking oil
  • Certain Animal fats
  • Non-food cellulosic material
  • Ligno-cellulosic material except saw logs and veneer logs

While the proposed amendments specifically exclude feedstock that has been intentionally modified or contaminated, the commitment to extend the range of wastes and residues that qualify for special treatment under the Directives will be welcomed by many in the industry, if only because it could lead to clarification and simplification of the procedures for accepting waste material coming into Europe.

Increasing the GHG Emissions Savings Threshold

Under the proposed amendments, the present GHG emssions savings threshold of 35% will not increase to 50% until January 2018 (presently 1st January 2017).  However the higher threshold of 60% for new installations commissioned after January 2017 in the present Directives will be brought forward to July 2014.

There is no proposed change to the present “grandfathering” clause for installations that were in operation prior to January 2008 and this exemption will cease to have effect from April of next year.

About Stephen Oliver

I am a management consultant/non-executive director and charity trustee based in Switzerland.
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