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.
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APPA Biocarburantes
Company · Spain · EU Transparency Register 82064144358-30
2
positions filed
in the 326 files tracked
2
legislative files
of 326 tracked
1
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1205 trade and business associations on this site, they rank #637 by legislative files engaged — a count of participation, not a measure of influence.
0.8
declared lobbying FTE
self-declared
€25K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2010
in the register since
Declares membership of
- European Biodiesel Board (EBB) →
- International Sustainability & Carbon Certification Association (ISCC)
- European Committee for Standardization (CEN)
- Asociación Española de Normalización (UNE)
- Plataforma para la Promoción de los Combustibles Renovables
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026).
- Register category
- Trade and business associations
- Head office
- Madrid, Spain
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
APPA Biocarburantes filed 2 positions between 7 Nov 2024 and 26 Jan 2026, across 2 of the 326 legislative files tracked here, attaching a full position paper 1 time.
2024 · 1 filed2026 · 1 filed
What they argued
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.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
- FEAD - European Waste Management Association · 2 files in common
- European Biogas Association · 2 files in common
- Copa · 2 files in common
- FuelsEurope · 2 files in common
- Repsol · 2 files in common
Showing 5 of 22.
Is this your organization?
Everything on this page comes from APPA Biocarburantes’s own submissions to the European Commission — we have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.