(Ethanol Europe Renewables/EurActiv) The Energy Directive (RED 2) transport decarbonisation ambitions ostensibly promote major capital investment in truly advanced biofuels breakthrough technologies. However, the Directive will not generate meaningful advanced biofuels investment. Instead, it incentivises fake wastes to meet biofuels targets for 2030. This is clear from what has happened with 2020 biofuels targets.
The European Commission made this possible by quietly greenwashing feed and food products as advanced biofuels. Today, almost all EU “advanced biofuel” comes from these fake wastes, including starch, feed grade palm oil, imported used cooking oil (UCO), and even bread. French interests have even tried to get molasses classified as a waste. Non-feed products with important chemical markets, like tall oil, are also given waste status.
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Many imported feedstocks have higher levels of ILUC than domestic EU crops for biofuels. And here, in an Orwellian twist, the “ILUC Directive” is, in practice, about shifting Europe’s biofuel mix from low-ILUC to high-ILUC biofuels.
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A major incentive for fraud is double counting which increases the monetary value of fake wastes. For instance, a litre of double counted used palm oil imported from the US (where it is an animal feed) and a litre of fossil diesel are counted as two litres of biofuel. Fuel suppliers have a clear reason to pay more for a biofuel that allows more use of fossil oil than for a biofuel that takes oil off the market.
The premium for double counted biofuel is in turn reflected in better prices for waste feedstock. This explains why used cooking oil often costs more than unused cooking oil, especially in the United Kingdom and why there is such a strong surge in imports. For instance, only 23% of the UCO for biodiesel in the UK comes from the UK with UCO from non-EU countries comprises 41% of the total used. Exports of Chinese UCO and UCO based biodiesel to the EU increased five-fold to over 200,000 tons in 2017.
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Traditional biofuel feedstocks (like feed wheat and unrefined rapeseed oil) that are not actually human food are labelled “food-based biofuels” by the Commission, while it confers a special category on fake wastes. Many of these “wastes” are imported from developing countries and displace feed based biofuels from crops grown by EU farmers.
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Another Court indictment of the Commission’s waste regulation was that it enables different standards to apply in different member states. Waste in one country is not waste in the neighbouring state.
The ILUC Directive allows a member state to classify as waste any materials that were listed as a waste before the ILUC Directive entered into force. The French beet ethanol industry used this to classify molasses as waste in France, though without double counting. Finns did it with waste bread.
Today a substantial proportion of French ethanol is produced from molasses, a food. The French industry lobbied to get molasses approved as a waste in RED 2. The Parliament challenged this (and palm oil, and tall oil) in amendments. In the trialogue the Parliament’s position must become law.
Giving preferences to starch slurry and other double counted feedstocks when they are valuable food, feed of chemical products is just wrong.