Amendment of the Renewable Energy Directive: revising the values and modifying the methodology laid down in Annexes V-VI

Shell welcomes the opportunity to provide feedback on the Draft Act on Renewable energy revising biofuel, bioliquid and biomass fuel production pathway values and modifying methodology, specific to the Renewable Energy Directive Annexes V and VI review. Please find attached our contribution.

SEA-LNG welcomes the opportunity to contribute to the public consultation on the revision of Annexes V and VI of the Renewable Energy Directive. It recognises that regular updates to these annexes are essential to ensure that the regulatory framework reflects technological progress and innovation across the different biofuel, bioliquid, and biomass fuel value chains.

Contribution of the SVOL to the European Commission’s public consultation on the draft Delegated Directive amending Annexes V and VI to Directive (EU) 2018/2001 (RED): The association of owners of municipal, private and church forests in the Czech Republic (SVOL) considers the energy use of forest biomass to be an essential part of sustainable forest management, particularly in Central Europe, which has been…

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STX Group welcomes the European Commissions initiative to update the greenhouse gas accounting methodologies for biofuels, bioliquids and biomass fuels under the Renewable Energy Directive. We support the overall direction of the draft presented, as it strengthens the credibility of renewable fuels markets, improves investment signals, and reduces the scope for inconsistent interpretation across Member States.

The Programme for the Endorsement of Forest Certification (PEFC International) welcomes the opportunity to participate in the ECs proposed revision of the values for biofuel, bioliquid and biomass fuel production pathways, including the methodology in Part C of Annex V and Part B of Annex VI.

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the initiative Renewable energy revising biofuel, bioliquid and biomass fuel production pathway values and modifying methodology. Please find detailed comments in the Attachment.

BASF fully supports efforts to strengthen GHG accounting under the RED. To ensure a robust and trustworthy framework that accelerates the decarbonisation of European industry, we urge the Commission to prioritise: Updated and harmonised default values, including electricity grids; Flexible co-digestion accounting to preserve low-CI biomethane markets; Recognition of voluntary LDAR guidelines; Barrier-free, aligned…

The German Biogas Association (Fachverband Biogas e.V. FvB) represents nearly 5,000 members across the biogas and biomethane value chain, predominantly small and medium-sized enterprises. With the tightening of greenhouse gas (GHG) reduction requirements under the Renewable Energy Directive, reliable and practicable GHG accounting has become a decisive factor for the continued operation and economic viability of…

Sweden is highly dependent on bioenergy. It is our largest source of energy and accounts for 35% of the countrys total energy use. Half of our heating comes from bio-based district heating (90% in multi-family housing), and about 10% of the countrys electricity production. Seventy percent of Sweden is covered by forest, and the forest industry is one of the countrys most important basic industries.

This comment recommends that the use of emissions factors under the RED directive should be coupled with direct measurements using Carbon-14 testing, to ensure that the biomass-derived portion of biofuels and biomass-fuels is accurately determined before applying emissions factors, especially for co-processed fuels and imported fuels.

Summary of Nufarm contribution: - Relevance of RED art 29: it introduces sustainability and GHG emissions saving criteria for biofuels, bioliquids and biomass fuels, and it is only through these criteria that energy from these sources can be counted towards EU Member States shares of the EU renewable energy target.

The Methanol Institute (MI) welcomes the opportunity to provide feedback on the Delegated Directive amending Annex V and Annex VI to Directive (EU) 2018/2001 as regards rules for calculating the greenhouse gas impact of biofuels, bioliquids and biomass fuels and their fossil fuel comparators.

The amendment of Annexes V and VI of the RED is of great importance to the European biogas and biomethane producers, as the specifications on specific GHG emission values along the value chain have a significant impact on both the market access of European biogas and biomethane producers and the competitiveness of market players within individual markets (heat, electricity, mobility sectors).

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The eNG Coalition welcomes the European Commissions initiative to revise Annexes V and VI of the Renewable Energy Directive (RED III), notably to improve methodological consistency, lifecycle GHG accounting, and traceability of renewable fuels.

UPM likes to thank the European Commission for the opportunity to participate in the public consultation on the draft amendments to Annexes V and VI of the Renewable Energy Directive (RED III). Its seems that current methodologies for RFNBOs (DR2023/1885) and biofuels (Annex V and VI in the IR 2022/996) show different emission factors for grid electricity.

UNICA welcomes the European Commissions initiative to revise Annexes V and VI of the Renewable Energy Directive (RED) and recognises the strategic importance of ensuring that default greenhouse gas (GHG) emission values are aligned with the best available scientific evidence.

The Sustainable Biomass Program (SBP) is a voluntary certification scheme designed for biomass, including wood pellets, chips, biochar, biocarbon and other processed wood-based products. SBP is recognised for certifying compliance with sustainability and greenhouse gas saving criteria of the Renewable Energy Directive EU/2023/2413.

This feedback is submitted on behalf of the sugarcane producing companies in response to the Commissions public consultation on the proposed revision of the typical greenhouse gas emission values for sugarcane ethanol as set out in Annex V of the Directive.

The project introduces new elements to better take into account greenhouse gas emissions and reflects, in this respect, the current state of bioenergy research. This is an undeniable step forward. However, the practical implementation of these findings for those involved in the sectors concerned remains, at this stage, largely insufficiently explained and raises real questions as to its operational feasibility.

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Business & Science Poland welcomes the opportunity to participate in the consultation on the revision of default values for production pathways and changes to the rules for calculating the GHG emissions of biofuels and biomass fuels. BSP hereby submits its position in the attached document.

Gas Infrastructure Europe (GIE), representing over 70 operators of natural gas, hydrogen, storage, and LNG terminal infrastructures, welcomes the opportunity to contribute to the consultation on revising biofuel, bioliquid and biomass fuel pathway values and methodology under RED III.

FEAD, the European Waste Management Association, welcomes the review of RED Annexes V and VI and thanks the Commission for the opportunity to comment. FEAD puts forward the following recommendations: The introduction of an equivalent negative emission credit for biowaste as to what is currently granted to manure Clarifying what are standard and best practices in view of defining GHG emission saving values Updating…

SUBLIME Energie warmly thanks the European Commission for the opportunity to contribute to the consultation on the Delegated Directive amending Annexes V and VI of Directive (EU) 2018/2001 of the European Parliament and of the Council. Please find our contribution attached.

NextChem would like to thank the European Commission for the opportunity to participate in the public consultation on the draft amendments to Annexes V and VI of the Renewable Energy Directive (RED III). Given the Companys experience in the field of fuel production technologies, we would like to share the following suggestions: (1) the GHG values for grid electricity seem to be inconsistent between biofuels (Annex…

FuelsEurope and its members welcome the opportunity to comment on the draft revision of Annex V and VI of the Directive (EU) 2018/2001 (Renewable Energy Directive). As producer of renewable and low carbon fuels, we are fully committed to support the correct and effective deployment of clear rules for calculating the greenhouse gas impact of such products.

FEDIOL, the EU vegetable oil and proteinmeal industry association, representing the interests of the European oilseed crushers, vegetable oil refiners, and bottlers, welcomes the opportunity to share its comments and suggestions on the draft Delegated amending Annexes V and VI to Directive (EU) 2018/2001 of the European Parliament and of the Council, as regards rules for calculating the greenhouse gas impact of…

ePURE the European Renewable Ethanol Association represents bioethanol producers from crops, wastes, and residues who are committed to supporting a sustainable energy transition. Based in Brussels, ePURE speaks for 41 member companies and associations, including 20 producing members, operating approximately 50 state-of-the-art biorefineries across 16 EU Member States.

In view of simplicity and consistency of the legislation, CIRCULère (VICAT Group, member of France Ciment) firmly suggests that the clarification described in the EC Guidance Document Biomass and other zero-rating under the EU ETS version 3, will also be included to the Annexes V and VI of the Renewable Energy Directive (RED).

ENGIE welcomes the opportunity to comment on the Delegated Directive amending Annex V and Annex VI to Directive (EU) 2018/2001 of the European Parliament and of the Council, as regards rules for calculating the greenhouse gas impact of biofuels, bioliquids and biomass fuels and their fossil fuel comparators. Please find attached our position paper.

This contribution is submitted by Albioma, a renewable electricity producer active in the French Outermost Regions. It is made in the framework of the Commissions consultation launched on 15 December 2025 under Article 31(5) of the Renewable Energy Directive (EU) 2023/2413 (RED III), which requires the review and, where justified, revision of the values and methodologies laid down in Annexes V and VI through a…

Bioethanol France thanks the Commission for the opportunity to comment on the proposal to update Annexes V and VI of the Renewable Energy Directive (RED III). 1) Update of typical and default values for GHG emission savings of biofuels: Bioethanol France welcomes the proposal to update the typical and default values for biofuels, and in particular for bioethanol produced from sugar beet, wheat and maize.

The Spanish Biocidal Products Association (Biocirc), as a representative body of companies operating in the fields of bioenergy, renewable gases, advanced and synthetic biofuels, bioproducts and bio-refining, welcomes the opportunity to comment on the proposed revision of the methodology for calculating greenhouse gas (GHG) emission savings provided for in Annexes V and VI to Directive (EU) 2018/2001.

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APAG supports the Commissions review of Annexes V and VI and the reliance on the JRCs scientific expertise. At the same time, APAG calls for a clear and explicit limitation of the proposed animal fats pathway values to Category 1 and Category 2 animal fats only; and careful consideration of policy coherence and market impacts when revising GHG accounting rules.

-Adding default values also for cases where biogas/biomethane is not used for energy self-production In the draft of the Annex VI all default values «assume that process energy is supplied from own biogas/biomethane production». Consequentially, «other practices should be calculated with actual values».

Alianza Net-Zero Mar revision of biofuel, bioliquid and biomass fuel production pathway values and modifying methodology Valencia, Spain. January 26th, 2026. The following changes are proposed: 1) Regarding the following paragraph (that can be found repeated several times in the Annexes): If biomethane is transported in either its compressed or liquefied form, an additional disaggregated value of 2.4 or 4.9 g…

Ladies and Gentlemen, Evonik welcomes the opportunity given by the European Commission to comment on the revision of Annexes V and VI of the Renewable Energy Directive 2018/2001. It follows from the draft Annex V to the Delegated Directive that both typical and default greenhouse gas emissions savings values have been removed for ETBE and TAEE (Part A) and for bio-MTBE (Part B).

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We underline the critical importance of Annex VI in unlocking the full potential of bioLNG in the EU. BioLNG represents one of the most, if not the most credible solution for decarbonising key hard-to-abate sectors, namely heavy and maritime transports.

We welcome the opportunity to contribute to the public consultation on renewable energy concerning the revision of biofuel, bioliquid and biomass fuel production pathway values and the modification of the underlying methodology.

The European Fat Processors and Renderers Association (EFPRA) represents the EU rendering sector, which plays a critical role in the circular bioeconomy by transforming animal by-products into safe, traceable, and sustainable raw materials for renewable fuels.

The European office of the Institute for Agriculture and Trade Policy welcomes the opportunity to provide feedback on the European Commissions proposal of the review of Annex V and Annex VI of the Renewable Energy Directive (Directive (EU) 2018/2001). Please find our comments in the file attached.

FEDENE is the French representative federation for energy efficiency services and heat decarbonization, covering the entire value chain, a sector that brings together over 1,500 businesses and 50,000 employees in France. Please find attached FEDENE's contribution to the consultation.

EUSTAFOR welcomes the opportunity to voice its opinion in the public consultation on the proposed Revision of Annex V & VI of the Renewable Energy Directive. Our organisation supports continuous evaluation and updating of the methodology to accurately reflect reality, including the latest scientific evidence, and thus positively impact the mitigation of climate change.

CIROM welcomes the opportunity to comment on the ECs public consultation for the revision of the Annexes V and VI of the Renewable Energy Directive (RED). In view of simplicity and consistency of the legislation RED with Directive EU- ETS 2003/87/EC and Waste Framework Directive, CIROM proposes the insertion of the following recital and new points to the Annex V (bioliquids), part C (Methodology) and Annex VI…

ERGaR is providing input to this consultation in order to contribute practical, market-based expertise to the revision of Annexes V and VI and to support the development of a clear, workable and harmonised GHG accounting framework for biomethane across the EU.

The proposed 40% gap between typical and default values forest biomass fuels supply chains is not justified since the motivation behind it seems like to discourage the use forest biomass. This is not appropriate for a technical annex. A decision to change values mentioned in this way does not seem particularly fact based or supported by scientific reports.

The European Commission is required to review Annexes V and VI under Article 31(5) of the Renewable Energy Directive. While the revision aims to simplify the structure of these Annexes it is important to maintain the existing GHG default values which are used by several operators in the renewable energy value chains as specially small operators might not have the ability to calculate the actual GHG values.

FEDIAF, the European Pet Food Industry Association, welcomes the opportunity to contribute to this consultation and to provide technical input on the proposed amendments to Annexes V and VI of Directive (EU) 2018/2001.

The Club Biogaz and the Centre Technique National du Biogaz et de la Méthanisation (CTBM) thank the European Commission for the opportunity to contribute to this public consultation on the draft legislation concerning the revision of Annexes V and VI of the Renewable Energy Directive.

Biogas Danmark welcome the initiative to update Annex VI as the green value and especially the transparent and clear rules and interpretation hereof is crucial for the willingness to pay for green solutions. However, Biogas Danmark believe the current draft needs clarification - especially in regard to the requrements to comply with the introduced best practice.

The disaggregated default values in Annex V, Part D play a central role in the RED GHG accounting framework by forming the basis for compliance calculations in the absence of actual data. The draft exhibits multiple material inconsistencies and apparent calculation errors, which significantly affect the accuracy and credibility of the methodology and must be addressed without delay.

SUEZ welcomes the opportunity to contribute to the call for evidence on the revision of Annex VI of the Renewable Energy Directive. As a major European player in environmental services, SUEZ operates across the entire waste management value chain, including the production of renewable energy through anaerobic digestion and biomethane valorization.

The disaggregated default values in Annex V, Part D play a central role in the RED GHG accounting framework by forming the basis for compliance calculations in the absence of actual data. The draft exhibits multiple material inconsistencies and apparent calculation errors, which significantly affect the accuracy and credibility of the methodology and must be addressed without delay.

Based on the draft Delegated Directive amending Annexes V and VI to Directive (EU) 2018/2001 as well as on our day-to-day audit practice, Control Union Poland identified several gaps and needs for clarification in the current Annex VI RED II. Our comments refer to solid biomass fuels and Part B methodology for GHG calculation. Please read our feedback in the attached PDF file. With kind regards Control Union Poland

Finnish Energy, representing the energy sector in Finland, appreciates the opportunity to contribute to the consultation on the proposed revision of the Greenhouse Gas (GHG) emission saving methodology under Annex V and VI of the Renewable Energy Directive (REDIII).

Contribution of the Renewable Gases Commission of the French Renewable Energy Trade Association (Syndicat des énergies renouvelables - SER) - Revision of Annexes V and VI of the Renewable Energy Directive (RED) The French Renewable Energy Trade Association (Syndicat des énergies renouvelables - SER) was established in 1993 to promote the interests of industrial stakeholders and professionals in the sector to public…

ClonBio Group Limited operates biorefineries in both Europe and North America, which produce food, feed, fertilizers and gaseous and liquid biofuels. Accordingly, we are also familiar with non-EU regulatory environments.

Update of typical and default values for GHG emission savings of biofuels : We support the removal of pathways based on lignite, as this ensures that only production routes used by economic operators are retained. However, unlike wheat and maize, the production pathways for bioethanol from sugar beet do not consider cogeneration unit based on forest residues.

In the context of the public consultation procedure launched by the European Commission on the initiative to revise the values of biofuel, bioliquid and biomass fuel production pathways and the applicable methodology, in implementation of Annexes V and VI to Directive (EU) 2018/2001 (RED II), and in accordance with the principles of public participation and regulatory improvement set out in EU legislation, we would…

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The revision of RED Annex VI is a key opportunity to address existing gaps in the GHG calculation methodology for biomethane and biogas. It is also a good opportunity to bring some clarifications on several methodology aspects. This legislation is important for our sector, as it determines the eligibility of biomass fuels as renewables energy sources, and their carbon intensity.

After reviewing the Commissions Draft Delegated Directive amending Annexes V and VI to Directive (EU) 2018/2001 (RED), APPA Biocarburantes submits the following comments: 1. The JRC analysis shows that most typical GHG emission saving values have increased relative to those currently in force in the RED.

In view of simplicity and consistency of the legislation, Febelcem firmly suggests that the clarification described in the EC Guidance Document Biomass and other zero-rating under the EU ETS version 3, will also be included to the Annexes V and VI of the Renewable Energy Directive (RED). Please find more details in the attached Cement Europe position paper, supported by Febelcem.

Dear Madam/Sir, Verd S.A., a leading biodiesel producer from waste-based feedstocks in Greece, together with its affiliated company Prasino Ladi S.A., the market leader in the collection of Used Cooking Oil (UCO) in Greece, are pleased to submit their comments and observations in the context of the current public consultation on the proposed revisions to Annexes V and VI of the Renewable Energy Directive.

Comments from BAV e.V. on the draft delegated act on Annexes V and VI to the Renewable Energy Directive (RED) The Bundesverband der Altholzbereiter und -verwerter e.V. (BAV) would like to thank the European Commission for the opportunity to participate in the public consultation on the draft amendments to Annexes V and VI to the Renewable Energy Directive (RED).

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The Austrian Association for Building Materials and Ceramic Industries, as the legal representative of the Austrian building materials industry, represents 320 member companies with a total annual turnover of 3.1 billion and almost 13,000 employees.

The Austrian Biomass Association supports ambitious climate targets and robust, scientifically sound GHG accounting. However, in their current form, the proposals lead to disproportionate burdens on the sector, increase administrative complexity, and jeopardize existing and future investments in renewable bioenergy.

The document attached provides Enagás GTSs technical feedback on Annex VI of the RED III implementation, focusing particularly on the treatment of biomethane transport, liquefaction and related emissions accounting. A key concern is the lack of clarity and methodological consistency in how virtual liquefaction is addressed.

— The Austrian Land & Forestry companies welcome the update of the efficacy assessment for nitrous oxide and the introduction of the bonus for biomethane from slurry. — The proposed adjustments in Annexes 5 and 6 leave the general question unanswered as to why the GHG saving for biomass as a renewable energy source can only be taken into account with complicated calculations taking into account countless factors for…

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I. With regard to the default value for the liquefaction of biomethane The Directive should explicitly recognise the pathway of equivalent liquefaction – an opportunity in Spain given the regasification plants – and should also allow for the use of a methodology based on real values, using emissions from the national electricity mix – The European Commission proposes a default value for the liquefaction of…

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Enagás welcomes the European Commissions initiative to revise Annexes V and VI of Directive (EU) 2018/2001 and supports the effort to improve the accuracy, transparency and regulatory consistency of greenhouse gas accounting for biomethane, bioLNG and associated logistic pathways.

The emission values and methodology of RED do not only dictate the criteria for national inventories but also underpin key decisions made by EU Member States and must therefore accurately reflect real-world climate impacts. In light of the climate crisis, assessments should adopt precautionary assumptions. Assumptions based on overly optimistic projections or omitting relevant emission sources must be avoided.

FULL SUBMISSION IN ATTACHMENT CEFS, representing EU sugar manufacturers, takes note of the draft Delegated Directive proposing amendments to Annexes V and VI to the Renewable Energy Directive (RED). Annex V Part C, Point 11 First, CEFS supports a technical correction in point 11 of Part C, where the reference to solid or gaseous biomass fuel should be corrected to biofuel, in line with the scope and terminology of…

As Snam, the largest infrastructure operator in Europe, we welcome the European Commissions initiative to review Annexes V and VI of the Renewable Energy Directive (RED). We consider this revision a timely and important step to ensure that the regulatory framework adequately reflects technological developments and supports the effective decarbonisation of the energy system.

Polish Power Plants Association (TGPE) welcomes the EC consultation on revising the GHG accounting methodology and default values in Annexes V and VI of the RED, however we propose some modifications. 1. Draft assumes predefined energy conversion efficiency values, namely 70% for heat and cooling production and 25% for electricity generation.

Utilitalia appreciates the opportunity to provide feedback on such important issue, and remains fully committed to contribute to possible future moments of dialogue. In Italy, the biogas and biomethane sector is growing rapidly, and ongoing investments suggest it will continue to grow for years to come.

Iberdrola welcomes the European Commissions proposal to revise Annex V and Annex VI of the Renewable Energy Directive, recognising the importance of strengthening the EU framework for GHG accounting and ensuring consistency across bioenergy pathways.

We welcome the updated nitrous oxide efficacy values and also the introduction of a 45 gCO/MJ bonus for biomethane from manure. The planned amendments to Annexes V and VI of the Renewable Energy Directive (RED III) raise some questions and serious concerns about regulatory consistency and fairness.

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Esterifrance is the professional organization representing FAME producers on the French territory. Esterifrance is composed of 7 members with a total of 10 FAME factories located in France. We are contributing to this public consultation on Annexes V and VI of the RED which is essential for our business. We would like to thank the European Commission for this consultation and for its work to simplify the text.

Liquid gas Europe welcomes the European Commissions consultation on revising the greenhouse-gas (GHG) accounting methodology and default/typical values in Annexes V and VI of the Renewable Energy Directive, which will directly shape how biofuels, bioliquids and biomass fuels are recognised across EU markets.

We welcome the opportunity granted by the European Commission to comment the review and update of Annexes V and VI of the Renewable Energy Directive. The update includes a thorough and scientifically robust revision of emission factors and background data carried out by the JRC.

With reference to a consultations held by the European Comission on Renewable energy revising biofuel, bioliquid and biomass fuel production pathway values and modifying methodology, attached please find comments of Polish Association of Heat Energy (Polskie Towarzystwo Energetyki Cieplnej) on the Directive amending Annex V and Annex VI to Directive (EU) 2018/2001 of the European Parliament and of the Council on the…

GIDARA Energy is dedicated to reducing global carbon emissions and fostering a circular economy by providing cost-effective solutions for sustainable fuel and chemical production, with a strong focus on energy efficiency and global carbon emissions. GIDARA Energy is a portfolio company of Ara Partners, a global private equity firm that is decarbonizing the industrial economy.

EDF group thanks the European Commission for the opportunity to contribute to the consultation on the draft Delegated Act revising Annexes V and VI of the Renewable Energy Directive. The Group wishes to share several technical and operational observations regarding the proposed default values, the associated methodologies, and the envisaged implementation framework.

Roserv Green Energy welcomes the Commissions initiative to revise the GHG calculation rules in Annexes V and VI. Our company is developing a large scale renewable fuels complex in South Eastern Europe, integrating HVO/SAF production, low carbon hydrogen (SMR supplied with biomethane and off gas), biomethane from agricultural residues and manure, and a bioethanol facility with a transition pathway from Gen 1…

The Cool Heating Coalition, the civil society voice on heating and cooling, supports the update to the pathway values for biomass. We want to further highlight the opportunity to shift to healthier homes and improved land use. Research by the Joint Research Centre concludes that biomass for space heating has "detrimental effect on air quality" , both inside our homes and outdoors.

LyondellBasell (LYB) is a leader in the global chemical industry creating solutions for everyday sustainable living. Through advanced technology and focused investments, we are enabling a circular and low carbon economy. Across all we do, we aim to unlock value for our customers, investors, and society.

In view of simplicity and consistency of the legislation, Cement Europe firmly suggests that the clarification described in the EC Guidance Document Biomass and other zero-rating under the EU ETS version 3, will also be included to the Annexes V and VI of the Renewable Energy Directive (RED). Please find more details in the attached Cement Europes position paper.

Dear Madam/Sir, Please find attached a position paper by Euroheat & Power, the European District Heating Association. For any questions, please do not hesitate to reach out to [name removed], Senior Policy Advisor ([email removed]). Thank you in advance for taking into account our recommendations. Kind regards, [name removed]

The Biomass based chemicals group, a Product Group of Aispec, one of the 17 Sector Associations of Federchimica (the Italian Federation of the Chemical Industry, consisting of over 1.500 companies and 96.000 employees), welcomes the opportunity granted by the European Commission to comment on the revision of the Annexes V and VI of the Renewable Energy Directive 2018/2001 (RED II).

Please find attached OFICEMENs position paper for the European Commissions public consultation on updating pathway values and methodology in Annexes V and VI under the Renewable Energy Directive (EU) 2018/2001. The submission shares evidence and operational experience from the cement sector regarding waste-derived fuels with biogenic content and the practical application of greenhouse gas accounting rules, with a…

The consortium RED bois-énergie France brings together the main structures of the forest-based and energy industries in France to facilitate the implementation of the RED among operators. He highlighted the late publication of the JRC report on biomass fuels for a good understanding and sharing of these developments. However, he thanked the Committee for the explanation webinar that took place on 16/01/2026.

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The Italian Compost and Biogas Consortium (CIC) welcomes the opportunity to provide feedback to the proposed delegated directive, that will have an impact on the Italian biogas and biomethane production from bio-waste and other organic-based waste origin.

Bioenergy Europe welcomes the opportunity to provide feedback on the proposed revision of the Greenhouse Gas (GHG) emission saving methodology under Annex V and VI of the Renewable Energy Directive (REDIII). While we support the Commissions efforts to update the frameworkspecifically by including previously missing segments such as the accounting of permanent carbon storage (BECCS) and default values for…

Currently, in practice RED does not allow for carbon capture and storage by means of biochar (BRC) although it has the same effect as liquid CO2 stored according to the CCS-directive. The future regulation should be updated to support the market for carbon capture by means of biochar e.g.

The draft Delegated Directive introduces an amendment to the methodology for calculating greenhouse gas emissions from biomass fuels by incorporating the CSTOR multiplying factor, which is set at 115 % where there is no suitable storage facility and at 100 % where there is such a facility or a record of deliveries to confirm the balance between the delivery and conversion of solid biomass fuel to energy.

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CMA-CGM welcomes the draft Delegated Directive updating GHG values/methodologies for biofuels, bioliquids and biomass fuels and proposes the following concise changes: - Expand eligible biogas/biomethane feedstocks to include forest residues, straw, waste/residue wood, farmed wood, forest-residue chips, short-rotation coppice, stemwood and wood-industry residues (aligning with Heat/Power and Biofuels accounting).

The present position addresses not only the draft Delegated Directive itself, but also the Joint Research Centre study underpinning the proposed amendments, as these documents cannot be meaningfully assessed in isolation from one another. I. The Renewable Energy Directive, among others, intended to support EU-based renewable biofuel production, investments and value chains.

Position of CZ Biom Czech Biomass Association on the revision of Annex V and Annex VI to Directive (EU) 2018/2001 CZ Biom Czech Biomass Association supports the European Commissions efforts to update the methodology for calculating greenhouse gas emissions under the Renewable Energy Directive, in particular for biogas and biomethane.

CRPA welcomes the opportunity to comment on the draft delegated directive updating Annexes V and VI of Directive (EU) 2018/2001. - Default values: more accurate coverage of biogas and biomethane production pathways is needed Default values take in consideration only settings that assume the process energy is supplied from own biogas/biomethane production. Other practices have to be calculated with actual values.

This contribution presents CMAs views on the ongoing revision of Annex VI of Directive (EU) 2018/2011 (RED), with a specific focus on the biogas and biomethane sector. While acknowledging the overall high quality of the proposal and the robustness of the scientific evidence underpinning it, several elements require clarification to ensure legal certainty and consistent implementation across Member States.

The Foreign Investors Council (FIC) is a business association representing around 110 of the largest foreign investors in Romania, whose combined activities account for roughly a quarter of the country's GDP. In its submission (file attached), FIC Romania provides feedback on three main topics: simplified greenhouse gas accounting for certain biomass waste fuels, clearer rules on how biomethane emissions are treated…

LoCI Controls, Inc. (LoCI) is an established and respected real-time data and control company using patented technology to reduce emissions from landfills and increase methane capture. LoCI requests that the European Commission (EC) adds incremental methane capture from landfills voluntarily deploying an advanced gas capture system (ACS) as a best practice (the Proposed Methodology) and sufficient emission factors…

Centrica welcomes the revision of Annex VI and appreciate the Commissions efforts to strengthen the framework. However, we would like to offer some recommendations to ensure clarity, practicality, and consistency in implementation. Please find these in the attached document.

Centrica welcomes the revision of Annex VI and appreciate the Commissions efforts to strengthen the framework. However, we would like to offer some recommendations to ensure clarity, practicality, and consistency in implementation. Please find these in the attached document.

A2A welcomes the opportunity to comment on the draft delegated directive updating Annexes V and VI of Directive (EU) 2018/2001. A2A welcomes the proposed revision of Annex VI to update default values and introduce new production pathways, such as sewage sludge; the introduction of provisions on bio-LNG; the valorisation of the application of methane emissions reduction technologies and practices, and of emissions…

T&E Response to Annex V / VI Consultation T&E welcomes the opportunity to comment on the proposed updates to Annex V and VI of the Renewable Energy Directive. While we appreciate the Commission's efforts to reflect recent changes in biofuels emissions, several areas require greater clarity and transparency.

EBA welcomes the draft revised Annex VI and appreciates the opportunity to provide feedback through the attached Position Paper. EBA remains fully committed to continuing a constructive dialogue with the Commission and relevant stakeholders, including by providing further clarifications where needed and supporting the development of a clear, robust and practicable emissions accounting framework for the biogas and…

Dear Madame/Sirs, please find below the feedback on the draft revised Annex VI of CIB Consorzio Italiano Biogas. The CIB represents the agricultural biogas/biomethane sector produced from no-waste biomass, which accounts for the largest share of total national production.

EnBW is one of Germanys largest utilities (30.000 employees, 50 billion investments in the energy transition until 2030) and active physical producer and marketer of biogas and biomethane in the EU. We highly appreciate the Commissions continued efforts to strengthen the sustainability framework for renewable fuels. Please find our analysis and feedback in the attached file.

The update of the values provided is acknowledged. Although the MRR Regulation requires that all industrial CO emissions from fixed EU ETS installations be accounted for in fulfilling their compliance obligations, it also provides, in accordance with the EU ETS Directive, for the assignment of a zero-emission factor to emissions resulting from the combustion of sustainable biomass.

We appreciate the opportunity to comment on the European Commission (Commission) draft amendments to Annexes V and VI of (EU) 2018/2001. In general, we support updating the typical and default greenhouse gas (GHG) emissions values to more accurately reflect current industry practices. Additionally, we have identified several typographical errors in the table of typical and default GHG emissions values in Part D.

A.P. Moller Maersk (Maersk) welcomes the opportunity to provide feedback on the draft Delegated Directive updating pathway values and elements of the lifecycle methodology in Annex V and Annex VI to Directive (EU) 2018/2001.Please see attached position paper.

We support the European Commissions efforts to standardise and update the methodological framework for monitoring biomass sustainability. Based on practical experience, we identify several issues related to selected values and assumptions, including biomass import distance categories, default value increases, conversion efficiency and moisture content assumptions, and the proposed Cstor factor, which may create…

SHV Energy welcomes the opportunity to comment on the draft revision of Annexes V and VI to Renewable Energy Directive. As a major distributor of LPG, bioLPG and renewable DME, SHV Energy supports ambitious and robust GHG accounting that is workable and enables the scale up of renewable fuels in line with RED III. In this light, our key points of feedback are outlined below. 1.

GASNAM, the Iberian association promoting the use of renewable gases in mobility, thanks the European Commission for the opportunity to comment on the revision of Annexes V and VI of the Renewable Energy Directive (EU) 2018/2001 (RED II). Please take note of the attached pdf.

Filed in Spanish · English published by the European Commission

The MVaK represents thirty-one members who collect, prepare and convert suitable waste lipids, mainly used cooking oils and waste fatty acids, into waste-based and advanced biodiesel or trade the feedstocks and finished products. Our members are based in Germany, Austria and the Netherlands. We have attached our statement.

Dear Madam/Sir, on behalf of our members, we at EWABA (the European Waste-based and Advanced Biofuels Association) are pleased to provide you with our feedback concerning the current public consultation on the new Annex V (and VI) of the Renewable Energy Directive. We hope the attched comments (please see the enclosed pdf) are a constructive help and act to strengthen the legislation further.

With Delegated Directive (EU) 2024/1405, the European Commission is expanding the range of crops that can be grown as raw materials for biofuel production to include catch crops and cover crops. However, crops as such are not named.

I have a few comments and suggestions: (1) Biogas/biomethane: 15a. It is not clear when installations qualify for the best practice conditions (and improvement factors) for methane leakage. Particularly for these points it is not very clear what is needed to meet the conditions: - Piping, maintenance, overpressure events, leaks - Digestate composting or airtight storage with biogas recuperation - Biogas upgrading to…

We understand the topic we address in the position paper attached is on the sidelines of the overall consultation. Alternative paths to liquefaction of biomethane will indeed be addressed in the context of the RED III implementing regulation. This said the topic is of fundamental importance for the future decarbonisation of the transport sector and it require full attention.

DEAR European Commission, On behalf of the Polish Pellet Council, we would like to thank the European Commission for the opportunity to participate in the public consultation on the draft amendments to Annexes V and VI of the Renewable Energy Directive (RED III).

Filed in Polish · English published by the European Commission

General comment on biomethane pathways (page 17, Annex VI) We note that the draft amendment to Annex VI updates greenhouse gas (GHG) calculation methodologies and default values for biomethane produced via anaerobic digestion and gasification pathways.

In Annex - Ares(2025)11154567 the table for DISAGGREGATED DEFAULT VALUES FOR GASEOUS BIOMASS FUELS PATHWAYS (Page 35) states that the use of the default values requires that "process energy is supplied from own biogas/biomethane". It should be clarified that this is for the biomethane generation process only i.e. it is not required for ancillary processes such as digestate treatment, CO2 liquefaction, etc.

The consolidation of the typical and default values into one table appears to have removed some of the disaggregated default values from the original Annex V. We specifically request that the values in part D in the table called "Disaggregated default values for transport and distribution of final fuel only.

Unem welcomes the opportunity granted by the European Commission to comment on the revision of the Annex V and VI of the Renewable Energy Directive 2018/2001 (RED II). It appears from the draft Annex V to the Delegated Directive that typical and default values of the greenhouse gas emissions savings for renewable fuel ethers ETBE, TAEE (part A) and bio-MTBE (part B) have been removed.

In summary, we propose the following: - We support updating the Global Warming Potentials (GWPs) in line with the latest IPCC assessment, but we consider that their application should not take place during 2026.

Dear all, thank you very much for the opportunity to share our feedback. Please find most relevant points below: 1. The current methodologies for RFNBO, LCF, and RCF show different datasets for electricity emission factors compared to Annex V and VI in the IR 2022/996. This creates inconsistencies in GHG calculations across fuel categories.

For biomethane from manure, biowaste and crop silage, the draft sets processing disaggregated default values (ep, DDV) of 114.24, 70.20 and 68.28 gCOe/MJ, respectively. The corresponding processing methane-emissions improvement factors (eme,i) provided for best practice are 97.4, 55.4 and 53.8 gCOe/MJ.

The Biogas upgrading to biomethane section of the best practice methane emission improvement factors (eme,i) table (Annex VI, Part B, Point 15a of Directive (EU) 2018/2001), the incentive structure appears internally inconsistent with the stated purpose of eme,i.

Until now, the minimum GHG savings for biofuels amount to 65% and the minimum GHG savings for renewable fuels of non-biological origin (RFNBO) amount to 70%. This makes the calculation of GHG emission reduction of fuels from combined power and biomass to liquid (PBtL) plants extremely complex (and error-prone). Therefore, I suggest to set the same minimum GHG saving requirements both for biofuels and RFNBO.