EBB - European Biodiesel Board

See PDF attached for the EBB submission to this consultation. Please note that the document submitted is a high-level submission to this consultation, but does not constitute a complete EBB position paper addressing all the multiple elements in that proposal (still under preparation).

With more than 11 million tonnes of biodiesel produced per year, the EU is the world leader in the production and use of biodiesel for transport. Sustainable biodiesel (both crop and waste-based) is delivering today significant GHG emissions savings and constitutes an essential tool for the decarbonization of the European road transport sector, not only in passenger cars but specially in light and heavy-duty…

The European Biodiesel Board (EBB) reiterates the points raised during the consultation on the call for evidence on the revision of the Climate Delegated Act (CDA), as the sectors concerns have not been addressed (or very marginally) in the draft Delegated Regulation (DR).

The revision of the EU Taxonomy Climate Delegated Act (CDA) is the right occasion to correct some long-standing major inconsistencies with relevant EU legislation on biofuels: as highlighted in the Commissions call for evidence, inconsistencies, gaps in alignment with updated EU legislation and overly complex technical screening criteria are among the major issues mentioned by stakeholders affecting the usability of…

The EBB welcomes the opportunity to respond to this consultation and to take part in this important debate. We have always been a strong advocate of the goals set in the Paris Climate Agreement (COP21), and have been constantly working towards providing the EU with practical solutions to accelerate the decarbonization of the European transport sector.

The European Biodiesel Board (EBB), representing EU's FAME and HVO producers, reiterates the arguments raised by the Network for Sustainable Mobility in the past (see attached). In particular: - This legislative proposal (just like the CO2 standards Regulations, under review) should be based on a completely technologically neutral approach when defining Zero-Emission Vehicles.

With more than 11 million tonnes of biodiesel produced per year, the EU is the world leader in the production and use of biodiesel for transport. Biodiesel constitutes a significant European renewable energy source, and the main European solution to reduce emissions from transport and dependence on imported oil.

- Consistent with IPCC guidelines, CO2 pricing should not apply to biofuels and biomass. - Derogation for fuels used in agriculture, horticulture and forestry must be maintained. - The ETD should differentiate between sustainable biofuels and fossil fuels. Therefore, the proposal to attribute the same tax rate to fossil fuels (petrol and diesel) and sustainable crop-based biofuels in 2033 should not be accepted.

The EBB welcomes the opportunity to respond to the EC’s consultation, and to be part of the preparatory process leading to the necessary revision of the EU ETD. At this stage, and without having more elements to understand what are the EC’s intentions in this revision, the EBB can already say that it fully supports a revision of the ETD that bring this directive in line with EU climate & energy policy objectives…

The European Biodiesel Board (EBB) is a non-profit organisation established in January 1997. Biodiesel (FAME and HVO) and bio-based aviation fuel (HEFA) are the main European solutions to reduce emissions from transport and dependence on imported oil.

The European Biodiesel Board (EBB) reiterates the points raised during the consultation on the call for evidence on the revision of the Climate Delegated Act (CDA), as the sectors concerns have not been addressed (or very marginally) in the draft Delegated Regulation (DR).

- The current EU CO2 standards for vehicles only account for tailpipe emissions (Tank-To-Wheel). This restrictive approach distorts competition between powertrain technologies and misleadingly labels electromobility as emissions free. It fails to incentivise biofuels and biogas with a lower GHG footprint and renewable content by not recognising their biogenic energy content.

With more than 11 million tonnes of biodiesel produced per year, the EU is the world leader in the production and use of biodiesel for transport. Biodiesel constitutes a significant European renewable energy source, and the main European solution to reduce emissions from transport and dependence on imported oil.

As the association representing EU HEFA SAF producers, we would like to focus on the aviation sector's "green transformation" mentioned in the Call for Evidence. The EBB strongly believes that the current and upcoming years will be key to determine the decarbonisation path of the aviation sector, and that the EU can lead global efforts by setting the right regulatory framework for the full uptake of Sustainable…

- Biofuels comply today with strict single EU-wide sustainability criteria. This allows all sustainable biofuels to have a role in the decarbonization of European transport. The approach to feedstocks and GHG savings calculations in the Aviation and Maritime proposals unduly deviate from the RED II (and RED III) sustainability criteria.

The EBB welcomes the opportunity to respond to the EC’s consultation, and to be part of the preparatory process of the ReFuelEU Aviation - Sustainable Aviation Fuels (SAF) initiative, as well as upcoming EC activities designed to gather further stakeholder input. The EBB recognizes the importance and particular difficulties for decarbonisation of the aviation sector.

Like for all other sectors, the decarbonization of the Heating & Cooling (H&C) sector needs to be fair, efficient and inclusive. And like for all other sectors, the key to achieving these three objectives is technological neutrality: in other words, taking into account all possible solutions and allowing to adapt the EU decarbonization goals to all geographical and technical specificities, thus maximizing the…

The European Biodiesel Board (EBB) underlines the strategic importance of the automotive sector, which contributes about EUR 1 trillion to EU GDP and sustains 13 million jobs. As the sector faces an industrial and environmental transformation driven by technological innovation and global competition, the review of Regulation (EU) 2019/631 on CO standards for LDVs represents a critical opportunity to align…

- A successful EU decarbonisation transport policy should build on the achievements of the RED II and other EU policies, not reverse them. - European sustainable biofuels today account for over 89% of renewables in the European transport. They are the most widely available alternative to fossil fuels and deliver significant GHG emissions savings, and should continue to decarbonise all transport modes.

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 Biodiesel Board (EBB) is pleased to have the chance to contribute to the call for evidence and supports the principle of making more efficient use of expertise and resources by proposing a “one substance, one assessment” approach to chemical safety assessments.