COMMISSION DELEGATED REGULATION on extending the scope of traceability of the Union database

Bioledger, an EU UDB Service Provider and Access Point, provides software enabling biofuel and feedstock companies across all supply chains and certification schemes to meet EU RED and UDB reporting requirements.

Novembre, 7th 2024 Terres Univia, lInterprofession des huiles et proteines végétales, is the Interbranch Association of vegetable oils and proteins in France. Terres Univia represents the interests of the French oilseed and protein crops supply chain and industry.

The Confederation of European Yeast Producers (COFALEC) which represents the interest of the European yeast industry, welcomes the opportunity to comment on the Delegated Regulation extending the scope of the data to be included in the Union Database (UDB).

The Methanol Institute (MI) is the global trade association for the entire supply chain of the methanol industry, representing the worlds leading methanol producers, consumers, distributors, and technology companies. MI represents its members from offices in Singapore, Washington D.C., Brussels, Beijing, and Delhi.

UPMs feedback on the draft Commission Delegated Regulation on supplementing Directive (EU) 2018/2001 of the European Parliament and of the Council, by further extending the scope of the data to be included in the Union database to cover relevant data from the point of production or collection of the raw material.

We thank the EC for the opportunity to provide feed-back on the DRAFT delegated act on the Union Database. The UDB has significant impacts on the European biofuel business and the further guidance on the implementation of the UDB is much needed. Responsibilities of Certification Bodies (CB) The CB is given a great responsibility in terms of maintaining the UDB up-to-date with valid certificates etc.

Bioenergia ry - the Bioenergy Association of Finland represents the bioenergy sector in Finland - including liquid and gaseous renewable fuels. Our main message is that the draft regulation should be suspended and re-evaluated with extra time. The deadline for application should be postponed until January 1, 2026. See attachment for more details.

Statement on the draft of COMMISSION DELEGATED REGULATION (EU) /... of XXX on supplementing Directive (EU) 2018/2001 of the European Parliament and of the Council, by further extending the scope of the data to be included in the Union database to cover relevant data from the point of production or collection of the raw material used for the fuel production by Bioethanol France representing French bioethanol…

EBOTA is grateful for the opportunity to provide feedback on the draft Delegated Regulation. Please find attached feedback which is provided by the members of the EBOTA RED Working Group (Chevron, Gunvor, Hartree, Litasco, Mercuria, P66, Targray, TOTSA, Trafigura and Vitol).

Repsol welcomes the draft delegated act and appreciates the opportunity to provide feedback through this public consultation. Repsol fully supports the implementation of the Union Database (UDB), recognizing it as an essential tool for ensuring traceability and mitigating the risks of fraud. Attached is a document with our suggestions and commentaries.

TotalEnergies Biogas welcomes this consultation by the European Commission on the revision of EU rules. We appreciate the opportunity to contribute to the development of policies that will enhance the quality and effectiveness of energy efficiency measures. As a leading biomethane producer in Europe and the US, TotalEnergies is committed to enhance the traceability and transparency of biofuels value chains.

While Hungary supports the aim of the UDB to improve traceability of biofuels and address problems related to fraud, we also have some questions and issues what we would like to raise because they will possibly have a large effect on the Hungarian biofuel market and on the organisations responsible for regulation. The unclear topics and the possible issues are listed below: 1.

- The current project should be frozen until complete termination of the current consultation and until full agreement is achieved between the various stakeholders, not just Member States, but also third countries - A reasonable timeframe for the implementation of the Union Database should be determined in co-ordination with Stakeholders, especially those with the operational responsibility to deploy the database -…

Eni S.p.A. welcomes the opportunity to provide comments to the draft Commissions Delegated Regulation on supplementing Directive EU 2018/2001 by further extending the scope of the data to be included in the Union database to cover relevant data from the point of production or collection of the raw material used for the fuel production. Please find attached our full contribution.

Please find attached our recommendations in the document attached, that can be summarized as: Extend the transaction timeline beyond three working days to accommodate the complexities of data reporting. Define the triggering point for gas injection in alignment with regulated gas market processes, particularly those related to the balancing network point.

Dear Sir, Madam, The Austrian Chamber of Commerce (WKO) thanks for the opportunity to comment on the draft delegated act on Article 31a(2) of Directive 2018/2001 on improving the traceability of data throughout the supply chain and asks for the considerations set out in the Annex to be taken into account.

Filed in German · English published by the European Commission

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe has taken notice of the Commissions Delegated Regulation on extending the scope of the data to be included in the Union Database (UDB) as it can potentially be an important tool for increased transparency under the Renewable Energy Directive (RED).

EWABA members have been generally supportive to the proper and timely implementation of the UDB in order to address sustainability concerns and ensure accurate traceability of waste and advanced feedstocks. Our industry is investing a significant amount of resources to be compliant with this system and we expect that once it becomes operational it will bring a new era of transparency and traceability to the EU…

The EBB welcomes the initiative to mandate EOs to report raw material data into the UDB: this is key to ensure full traceability along the whole value chain and thus to facilitate robust verification, and is fully in line with long-standing EBB positions and commitments in that direction.

The European Biogas Association (EBA) welcomes the opportunity to comment on the draft delegated regulation aimed at extending the tracking scope of the Union Database (UDB). This measure represents a long-awaited step toward strengthening the traceability and sustainability of renewable fuels, which EBA strongly supports.

We would be able to provide the following feedback from the Austrian Chamber of Agriculture in the context of the consultation on the proposed Delegated Act. The Austrian Chamber of Agriculture fully supports the letter from the 16 Member States, including Germany, France, Italy, the Netherlands and Austria, dated 15 October 2024, to the EC, DG Energy.

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INERATEC appreciates the opportunity to provide feedback on the Draft of the Delegated Act, which extending the scope of the data to be included in the Union database to cover relevant data from the point of production or collection of the raw material used for the fuel production. This Act is crucial for extending the scope of traceability of the EU database for renewable and recycled carbon fuels.

The current project timeline should be frozen until complete termination of the current consultation and until full agreement is achieved between the various stakeholders, especially with the representatives of Member States. In practice until the adoption of the delegated act, the use of the UDB should be entirely at the discretion of the economic operators.

After gathering all the necessary information, we consider Agrana Stärke’s strength that the UDB has no benefit in terms of workload. For the large quantities we carry out each year (1 million tonnes of raw material, 5 different raw materials from 4 to 5 countries from very many different suppliers), the burden seems to be immense to manage or verify these transactions.

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The German Chamber of Commerce and Industry (DIHK) supports the objective of the delegated act and the Union database to improve transparency and traceability throughout the supply chains of liquid and gaseous renewable fuels.

Thank you very much for your experience. 1. The vast majority of AACS participants are already registered with the UDB. All RLH warehouses have access. I have RWA access to this database. 2. At present, it is not possible to record stock as the country of origin (only Austria?) cannot be stored. (See e-mail in annex) 3. There are no interfaces for entering storage stands or transactions using Excel file or similar.

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La Fédération du Négoce Agricole (FNA) représente les entreprises de négoce agricole en France. Ces dernières couvrent deux fonctions : Lapprovisionnement des exploitants agricoles, produits, services et solutions ainsi que la collecte des grains, mise en marché et valorisation de la production. Vous trouverez ci-dessous nos commentaires sur ce projet d'acte délégué : 1.

"Anagrasa, representing the Spanish Rendering (Animal Fats Category 1, 2 and 3) production sector, supports any initiative to avoid any Biofuel fraud risk within or from outside the European Union, as long as it means the same working conditions, requirements and opportunities to European and foreign companies and its supply chain.

Position of the BDBe on the public consultation on the draft delegated act to extend the scope of traceability of the EU database I. General comments The present draft of the delegated act of the EU Commission is intended to further extend the scope of the information to be included in the Union database. The intention is to obtain data on the production or collection of raw materials used for fuel production.

GasNet welcomes the Commissions proposal to support the correct accounting of liquid and gaseous renewable fuels and recycled carbon fuels to achieve the Renewable Energy Directive (RED) targets based on the functional and operational Union database.

The BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V. (Federation of the German Waste, Water and Circular Economy Management Industry) was founded in 1961 and is the German industry association for the private recycling and resource management sector.

Biogas Danmark welcomes the opportunity to comment on the draft delegated regulation regarding the Union Database (UDB) for renewable fuels. Representing the entire value chain within the biogas industry in Denmark including biogas producers, suppliers of feedstock, traders and users of energy and certificates, we aim to ensure that the regulatory framework supports sustainable growth and remains feasible and…

Olleco is the largest collector and processor of UCO in the UK and we also collect UCO in the EU. We support the implementation of the UDB as a tool to prevent fraud within the biofuels industry, however we are concerned that development and testing has not involved all stakeholders.

SYNACOMEX, as French trade organization, supports the main objective of the EU Database (UDB) thus to enable the traceability of liquid and gaseous renewable fuels and recycled carbon fuels to ensure that only sustainable volumes are counted towards the EUs decarbonization targets.

FuelsEurope welcomes the opportunity to express its views on the draft Delegated Regulation extending the scope of the data to be included in the Union Database (UDB). FuelsEurope strongly supports the ongoing enhancements of the UDB, as it is essential for fuel manufacturers to have a robust and reliable tool to ensure traceability and mitigate the risks of fraud.

Copa and Cogeca represent the European farmers and their agri-food cooperatives. We call on the Commission to suspend the draft delegated regulation on Union Data Base for biofuels and biogas. We fear the lack of workability of the implementation of the UDB the efficiency of the database to check physically whether a certificate was legitimately issued the use of data from farmers and the data protection the…

Copa and Cogeca represent the European farmers and their agri-food cooperatives. We call on the Commission to suspend the draft delegated regulation on Union Data Base for biofuels and biogas. We fear the lack of workability of the implementation of the UDB the efficiency of the database to check physically whether a certificate was legitimately issued the use of data from farmers and the data protection the…

Cooperation Agricole Métiers du grain is the unified representation of cooperatives for cereals, protein crops and supplies at French level. It supports French agricultural cooperatives in establishing good practices for storing and conserving grains to meet the expectations of all their outlets. The Mertiers section of Grain values the leading role of cooperatives in environmental transitions.

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The European Compost Network welcomes the Commissions draft delegated regulation implementing the Renewable Energy Directive (EU) 2018/2001 aiming to increase the use of renewable energy from renewable sources, including biogas and biomethane produced from bio-waste. However, we would like to highlight some significant concerns regarding the proposed provisions. You will find attached our detailed position.

It would be good if all the data from the AMA mass balance could be adopted into the UDB. We already report purchases and sales quarterly. The UDB means additional administrative effort. Furthermore Data input within 72 hours onto UDB is difficult or impossible to implement, in many cases we have to wait to get the weight from the goods recipient.

The Ministry for Climate Action (FCM) has the honour of submitting its opinion as follows. Concerning article 3 paragraph 2 There is no deadline/timeline specified as to when all the obligations mentioned in Article 3 para. 2 must be completed. This will lead to considerable legal uncertainty. Concerning article 3 paragraph 6 Some categories of Annex IX materials, e.g.

In general, the establishment of the platform is essential in order to avoid fraud, but it: — Is a significant administrative burden, whereas the Walloon administration already requires reports containing the same information. It seems essential to unify a single reporting system.

Filed in French · English published by the European Commission

AOP welcomes the opportunity to provide feedback in this public consultation on extending the scope of traceability of the EU database. As a key tool for promoting transparency, traceability, and regulatory cohesion within the EU, the UDB requires a clear and robust framework to support consistent application across Member States.

Answer to the public consultation Draft Delegated Act on extending the traceability of the Union database We, the undersigned voluntary schemes, have recently coordinated our efforts in the deployment of the Union Database. From this encounter we have considered the huge efforts conducted by all voluntary schemes in the past two years to deploy successfully the UDB.

1.- APPA Biocarburantes regards positively the Commission's proposal to extend the scope of the UDB to the raw materials used to produce renewable fuels and recycled carbon fuels, although we deem that it should be evaluated to limit this extension, at least initially, to the raw materials with a higher risk of fraud, such as those included in Annex IX of the RED III.

SNAM welcomes the opportunity to provide feedback on extending the scope of traceability of the Union database. We recognize the importance of the platform in ensuring traceability and transparency and acknowledge the need for the Commission to strike the right balance between transparency outcomes and regulatory proportionality, as applied to the decision on whether and to which extent expanding the scope of data…

I'm simply finding a frailty! So far, we have only wasted our valuable working time for more than one and a half years, because we are constantly encouraged to enter our data, but this is never possible! I don’t know where to start the complaint: When registering, I have to use my private mobile phone (but the EU really doesn’t get anything!) When I put the language in German, I will see the months in Cyrillic…

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French biomethane producers have been proactively and successfully traceable to their production under the Red II Directive last year. However, this accepted trend has no impact on the administrative time devoted to biomethane production activity, whereas 80 % of French installations are agricultural type installations, which therefore combine several activities.

Filed in French · English published by the European Commission

Quatra is one of the market leaders on the European market in the collection of used cooking oil (UCO) and food waste that is used for renewable and sustainable energy (biofuel). We are therefore closely following your development of UDB. We have several concerns. A: The usage of the NTR ID to uniquely identify each partner in the collection process has several issues.

GRDF welcomes the European Commission’s initiative to extend the scope of the Union database (UDB) to cover relevant data from the point of production or collection of raw materials used for fuel production. While we support the UDB’s overall objective of contributing to market transparency and traceability in the fuel supply chain, some provisions would need to be clarified and improved in order to better support…

Filed in French · English published by the European Commission

ecoMotion, a biodiesel company with plants in Denmark, Germany and Spain, that has been active for over twenty years, is dedicated to promoting rigorous sustainability standards, guaranteeing the transparency of its supply chain, and employing thorough verification processes. We are highly welcoming the introduction of the UDB, as it is a system necessary for increasing transparency and preventing fraud.

Formed in 1933, CBH is Australias largest cooperative, owned and managed by 3,500 Western Australian grain growers. CBH strongly supports the objectives of Directive (EU) 2018/2001 (the Renewable Energy Directive, or RED II) to foster renewable energy production.

The recording of transactions by the French storage agencies does not meet the UDB’s initial objective of controlling export fraud. One solution would be to lay down stricter rules for certifying bodies abroad or to prohibit the acceptance of certificates from countries that do not allow on-the-spot checks by independent auditors.

Filed in French · English published by the European Commission

Hexagon welcomes the extension of the scope of traceability within the UDB as a vital step toward enhancing the sustainability and accountability of renewable fuels. The proposed policy text establishes a rigorous framework for biofuel trade, emphasizing certification through national and voluntary schemes and mandating that economic operators register in the UDB and provide detailed transaction data.

- The current project timeline should be frozen until complete termination of the current consultation and until full agreement is achieved between the various stakeholders, especially with the representatives of Member States. In practice until the adoption of the delegated act, the use of the UDB should be entirely at the discretion of the economic operators.

Submission by the Hungarian Biofuels Association (HBA) The Hungarian Biofuels Association (HBA) welcomes the opportunity to provide input on the European Commission's proposal to extend the Union Database (UDB) requirements. While we recognize the Commission's intent to enhance transparency within the biofuels supply chain, we believe certain aspects of the proposal lack necessary clarity.

EFPRA represents the European Rendering industry, producing i.e. animal fats of Category 1, 2 and 3. EFPRA fully supports any initiative to avoid biofuel fraud risks within or from outside the European Union, as long as it means the same working conditions, requirements and opportunities for European (EU) and Third Countries (TC) companies and their supply chain.

At our level, we do not understand how registering transactions on a single platform will help to control import fraud, especially since the traceability of agricultural sectors is already controlled by the French public authorities.

Filed in French · English published by the European Commission

COCERAL supports the main objective of the EU Database (UDB), which is to enable the traceability of liquid and gaseous renewable fuels and recycled carbon fuels to ensure that only sustainable volumes are counted towards the EU's decarbonisation targets. However, COCERAL cannot support the draft delegated act proposed by the Commission. THE FULL AND DETAILED POSITION OF COCERAL IS ATTACHED.

Hello, I invite you to find my opinion below. 1/Je questions the effectiveness of the establishment of such a database to prevent fraud due to the import of incorrectly declared goods from non-European countries of origin, the registration of transactions by French storage agencies does not meet the initial objective of the UDB to control export fraud.

Filed in French · English published by the European Commission

ePURE, the association representing the European producers of renewable ethanol from sustainably grown crops, waste and residues, supports the aims pursued by the UDB to improve transparency and traceability of biofuels and to serve as a tool for a harmonised accounting system within the EU.

Neste supports the UDBs role in verifying sustainable, certified fuel use for renewable targets but is concerned about rushed implementation, potentially impacting the functioning of the market. Addressing these issues before mandating the system is essential. Key points of our response to the draft Delegated Regulation below, with more detailed comments and recommendations on the proposal attached.

Italian Ministry for the Environment and Energy Security thinks that the UDB will be a very useful instrument to avoid frauds, anyway currently several major challenges remain unaddressed and need to be tackled before making the UDB a mandatory tool. Find in the draft regulation attached some preliminary comments.

The Mittelstandsverband abfallbasierter Kraftstoffe e.V. (MVaK) represents twenty-nine 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 welcome the Commission initiative to extend the scope of the data to be included in the Union database (UDB) to cover relevant data already from the first gathering point, collecting the produced raw materials, and to cover all stages of the supply chain in a chain of custody approach until the respective fuels are put on the market in the Union for final consumption.

In general Envien Group welcomes and supports introduction of the Union Database for biofuels (UDB) as a tool to bring more transparency and traceability to the EU biofuels markets and to increase fraud prevention.

We would like to make a few comments that do not necessarily relate solely to the Delegated Act, but also to fundamental issues. For example, there is still no binding start date for all Economic Operators; we ourselves would be ready to start, but cannot find any counterparts who are willing to do so. Without the initial stock registration, only a gradual process is possible, in which all transactions are recorded.

The APPB acknowledges that, in view of the state of the overall biofuel market under the RED II Directive and the expectations created by the forthcoming implementation of the RED III Directive, action is needed to increase the requirement for the regulatory framework to identify all actors in the value chain, from feedstock producers to companies placing those biofuels on the market.

Filed in Portuguese · English published by the European Commission

The proposed delegated act intends to prevent irregularities and « double counting » by adding a huge workload on economic operators (EO) that have already achieved a trusted level of traceability. This additional workload must be put in balance with the risk of irregularities : unless it is proven that the biofuel chain cannot be considered reliable, extending the scope of the data to be included in the Union…

If the aim is to control export fraud, rules should be laid down only for the import of agricultural raw materials, and not for domestic products produced and collected by national operators. One solution would be to lay down stricter rules for certifying bodies abroad or to prohibit the acceptance of certificates from countries that do not allow on-the-spot checks by independent auditors.

Filed in French · English published by the European Commission

1. Questioning the effectiveness of setting up such a database to prevent fraud caused by the import of incorrectly declared goods from non-European countries of origin, the registration of transactions by French storage agencies does not respond to the UDB’s initial objective of controlling export fraud.

Filed in French · English published by the European Commission

One solution would be to lay down stricter rules for certifying bodies abroad or to prohibit the acceptance of certificates from countries that do not allow on-the-spot checks by independent auditors. In addition, the French public authorities already ensure traceability of the French agricultural sectors. The scope of the UDB should be limited only to transactions involving imported agricultural goods

Filed in French · English published by the European Commission

Good afternoon, Our products are checked during the audits and with the audit of 100 % of our contributors the risk of fraud and close to 0. The deadlines for reporting are unsustainable and the products are already declared in FranceAgrimer. Impose this system only on the product arriving outside the EU.

Filed in French · English published by the European Commission

Good afternoon, Our products are checked during the audits and with the audit of 100 % of our contributors the risk of fraud and close to 0. The deadlines for reporting are unsustainable and the products are already declared to France AgriMer. Impose this system only on the product arriving outside

Filed in French · English published by the European Commission

As a project consortium for the SusAlgaeFuel Project (Funded by the European Commission under grant agreement 101147601), which encompasses the entire value chain of SAF production, including feedstock sourcing, production, and processing, we welcome the extension of the scope of the UDB.

Please see the attached file for comments submitted on behalf of the U.S. Grains Council (USGC) in response to the draft delegated regulation extending the scope of traceability of the EU database (UDB). Thank you. Kind regards, [name removed] Ethanol Manager for the EU, UK and Canada U.S. Grains Council

Marquis Energy is a corn ethanol producer located in Hennepin, IL and is home to one of the largest dry mill ethanol plants in the US. Marquis Energy has been ISCC certified since 2010 and currently supplies hundreds of thousands of tons of ISCC certified ethanol into the EU or UK annually.

GEREGRAS, representing the Spanish UCO recyclers (Collecting Points (CP)), with National Register of Associations, Group 1, Section 1 under number 589552 since 15 October 2007. Vat.: ESG785148609, supports any initiative to avoid any fraud risk within or from outside the European Union, if it means the same working conditions, requirements and opportunities to European and foreign companies and its supply chain.

We welcome the extension of the data included in the Union Database to cover relevant data from the point of production or collection of the raw material used for fuel production. However, as Article 31a(2)s purpose is to improve the traceability of data along the entire supply chain, it is essential to ensure that the data reported are accurate.

FEDIOL, the European association representing the vegetable oil and protein meal industry, supports the objective of increasing transparency and preventing irregularities and frauds under the Renewable Energy Directive and recognises the role of the Union Database for Sustainable Biofuels (UDB) in attaining this objective.

— Effectiveness and scope: The recording of transactions by the French storage agencies does not meet the objective of checking fraud. It is suggested to restrict the UDB to transactions of imported agricultural goods and to impose stricter rules on foreign certifiers. — Recording frequency: A record every 72 hours is considered unsuitable. A quarterly or monthly frequency would be more appropriate.

Filed in French · English published by the European Commission

This proposed regulation represents a positive step by the EU in addressing fraud within the renewable energy sector. Fraud not only undermines the achievement of climate and renewable energy targets but also creates unfair competition for compliant producers. Ensuring a level playing field is crucial for fostering genuine progress toward sustainability goals.

Manual input of each individual consignment during harvest represents a huge additional effort and is difficult to implement within the given time. There are often small differences in weight between the booked removal weight and the input weight taken by the customer.

Filed in German · English published by the European Commission

A general problem is that the Commission publishes very little and constantly changing information, so there is a lot of uncertainty. The closest known deadlines are also taken from the UDB public wiki. In principle, all first collection points (FGPs) and collection points (CPs) should have already started uploading their sourcing contacts (i.e. non-certified points of origin) to the UDB.

Dear Sir/Madam, Please remove the obligation for arable farmers to provide information from the Regulation. Still, producers have an insurmountable amount of administrative tasks. This is an unnecessary problem or additional cost for older producers. I would ask you to take into account the situation of arable producers. President Tamás of Petroházi, National Association of Grains Producers

Filed in Hungarian · English published by the European Commission

Article 3 - Initial registration of economic operators in the Union database by the voluntary and national schemes 1. Voluntary and national schemes shall register in the Union database all economic operators dealing with biomass raw materials collection, preparation or first transformation into intermediary products, who all are individually certified by the voluntary and national schemes for the purposes of…

The scope of the UDB should be extended as a matter of priority for Annex IX feedstocks. However, this is not a priority for other raw materials. Extension of the perimeter will result in a significant administrative burden for operators. For example, for a medium-sized crushing/esterification unit such as ours (400 kt rapeseed/year), this represents approximately 50 seizures per day.

Filed in French · English published by the European Commission

As a key player in the biofuel and waste management sectors in Portugal, Wasteoil Network has been driving sustainability for over eight years. We manage nearly 20,000 collection points and support the Used Cooking Oil (UCO) industry with ISCC-certified users.

This report by the Chanakya initiative analyses the climate change objectives of the EU, focusing on the EU commitment to achieving net zero GHG emissions by 2050 and examines how RRFs can contribute to this ambition.

The delegated act in consultation opens the discussion on a proposal which reflects the absence of consultation for two years. 2BS supports an alternative working method on the subject, based on the principle of If it is not broken, please dont fix it!: - to organize joint working sessions with Member States, Voluntary Schemes and Stakeholders.

The German Raiffeisen Association (DRV) welcomes the Commission’s intention to fill legal uncertainties and gaps in the introduction of a Union Biofuels Database (UDB) by means of a delegated regulation. However, the DRV doubts whether the introduction of such a database will prevent fraud caused by the import of incorrectly declared goods from countries of non-European origin.

Filed in German · English published by the European Commission

We urgently warn that the UDB in its current form is rushed and mandatory with hot needle. The issue of deforestation-free supply chains has already shown that the damage is much greater if such a system is to be enforced with great urgency and without a functioning and end-to-end approach to the economy.

Filed in German · English published by the European Commission

While the system is essential for increasing transparency and preventing irregularities, certain operational details can create challenges for the operators involved. The deadlines established for data entry, such as three working days for transaction registration, are quite tight.

We understand the need for a platform that resume all the information and allows traceability and transparency throughout the process; however, the implementation of information in UDB should only be mandatory when the platform is fully functional. From that point on, there should be a longer transition period to cause less inconvenience.

Statement by the Union for the Promotion of Oil and Protein Crops (Union zur Förderung von Oel- und Proteinpflanzen e. V. (UFOP) https://www.ufop.de/) UFOP welcomes the creation of the Union database in principle, but nevertheless requests that the following criticisms and demands be taken into account: Criticism: - the challenge of recording the affected companies in the goods chain practically worldwide is…

Our certificates have still not been correctly uploaded to the union database after weeks of trying. I have been told by the UDB that they are still completing registration for all users. Therefore, my feedback would be to ensure everything is uploaded on time before deadlines.

Feedback on the union data base: For us, the UDB (union data base) causes enormous additional bureaucratic effort. All data listed in the UDB is checked in the CB's (certification body for ISCC i.e.) recurring audits and must be reported annually or quarterly; this means that all data is already available today and can be viewed by the CB; the way in which the data is requested by the UDB (detailed, short time…

Climate change progress slow in EU countries Then EU citizens health decrease Government responsible of citizens health My citizens die of climate of earth Ex-temperature rise Rain increase Sea level rise etc.. Government Fast take Action of climate change progress in EU

The directive mentions transparency and traceability. It appears that it refers to traceability of data. What is also important is adding a tracer in the fuel to make sure that it is a fuel made using renewable ingredients in a renewable manner and arrives from the production site to the site of the receiver in the same form, manner and composition.

As far as the freight transport is concerned, the most critical aspect to support the deployment of alternative fuels, including electric and (potentially) hydrogen, is the lack of transparency along the value chain. There are controls for the Well to tank segment of production chain, after the distribution there are no controls.