Neste

Neste welcomes the overall increase in transport decarbonisation ambition through the Fit for 55 package and the specific target for transport in the renewable energy directive. However, Neste regrets that the European Commission proposes changing the GHG calculation rule for biofuels which are currently accepted under REDII so shortly after national transposition.

Neste (www.neste.com) supports the European Green Deal and its aim to increase the EU 2030 climate target to 55%. Neste itself targets carbon-neutral production by 2035. However, the right regulatory framework conditions must be put in place in order to fully deploy the GHG emission reduction potentials from different sectors.

MAKE SUSTAINABLE PLASTICS THE NORM IN THE EUS PACKAGING REGULATION: The Packaging and Packaging Waste Regulation (PPWR) is an opportunity to make a major leap towards more sustainable production and consumption of plastics in the EUs circular economy. Tackling sustainability of plastic packaging is critical as it is the single biggest use of plastics in the EU representing 40% of the market.

Neste Corp. (www.neste.com) is the world’s largest producer of renewable diesel refined from waste and residues, introducing renewable solutions also to the polymers and chemicals industries. Our business is focused on combating climate change and driving circular economy, and we are committed to becoming a solution provider in chemical recycling by providing cost-effective and sustainable innovations.

Neste Corp. (www.neste.com, the world's largest producer of renewable diesel refined from waste and residues, introducing renewable solutions also to the aviation and plastics industries) welcomes the initiative and the European Union’s goal to become climate-neutral by 2050 at the latest.

We at Neste welcome the opportunity to provide feedback to the European Commission on the review of the Waste Framework Directive and support the Commission’s overarching objective of reducing total waste generation and ensuring high-quality recycling.

Neste has replied to the detailed questionnaire in the public consultation. Below we restate some of our high level messages included already in the feedback to the public consultation: Considering the expected scope of carbon removals certification where it would cover only additional removals: the framework should clarify how to link the new scheme to existing regulated certification schemes (e.g.

Maintaining the free allocation of emission allowances is crucial to safeguard competitiveness and prevent carbon leakage 1) Tightening up the existing emissions trading Neste welcomes the Commission's proposals to strengthen the carbon price signal through the EU Emission Trading System (ETS), thus creating the conditions for low-emission investments in new technologies.

Neste fully supports the Green Deal’s ambition for climate neutrality in 2050 as well as stepping up the GHG emissions reduction target to at least 55% by 2030. In our view higher targets within the existing legislative framework can deliver these results.

The European Biotech Act II should turn industrial biomanufacturing into a growth engine in support of the EU Bioeconomy and the Clean Industrial Deal. It is an opportunity to extend the EUs competitive leadership in biotech and biomanufacturing and enable the clean transformation of Europe's industry.

1) Energy content and environmental performance based taxation is the right way to go Neste supports the shift in the ETD proposal from a volume to an energy content-based taxation model. In addition, rewarding environmental performance is very important and is taken into account in the proposal as sustainably produced renewable fuels, both biofuels and e-fuels, are proposed to be taxed at lower rates than fossil…

Neste (http://www.neste.com/en) supports the European Green Deal (EGD) and one of its aims to revise the Energy taxation directive (2003/96/EC) originating already from 2003. Thus, the revision is well-needed to be in line with the current EU policy objectives.

Neste is the world’s leading producer of sustainable aviation fuel and renewable diesel, and renewable feedstock solutions for various polymers and chemicals industry uses. We are also developing chemical recycling to combat the plastic waste challenge. Our ambition is to make the Porvoo oil refinery in Finland the most sustainable refinery in Europe by 2030.

The End of life vehicles Regulation (ELV) is an opportunity to make an important leap forward in an industry that is strategic for Europe. Tackling sustainability of vehicles in general, and plastics use in particular, is critical as the car industry is responsible for 10% of the overall consumption of plastics (6 million tons/year) in the EU.

June 2023 Neste position paper on the Net-Zero Industry Act Neste is the world’s leading producer of renewable hydrocarbons from various bio waste and residue materials, based on our proprietary NEXBTL technology. Neste’s solutions are used as sustainable aviation fuel (SAF), HVO renewable diesel, and renewable feedstock for polymers and chemicals.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Neste welcomes the overall increase in transport decarbonisation ambition through the Fit for 55 package. However, regarding emission standards for passenger cars and light commercial vehicles, Neste regrets that the European Commission misses the important opportunity to allow sustainable renewable and low-carbon fuels such as biofuels, biogas and efuels to accelerate climate protection.

Roadmap & IIA: “The main objective of the initiative is to reduce CO2 emissions from cars and vans cost-effectively” - Renewable fuels are the fastest and one of the most cost-efficient way to reduce the life-cycle GHG emissions of road transport until there is enough renewable electricity for electric vehicles - Renewable fuels are currently not taken into account in the vehicle CO2 Regulations - The third option…

The establishment of an EU mass balance method for calculating recycled content in plastics is vital to enable scale-up of chemical recycling. However, the current draft proposal effectively excludes existing refineries from the chemical recycling value-chain for EU recycled content targets with several critical impacts.

I) Continuing the acknowledgment of the potential of all alternative fuels in the AFIR proposal is crucial The full potential of all alternative fuels must be included into the range of tools to reduce CO2 emissions efficiently.

Neste Corp. (neste.com) fully supports the Green Deal’s ambition for climate neutrality in 2050 and measures to encourage greater use of low-emission fuels. General remarks Any future review of the AFID Directive should seek to provide coherence and alignment of legislation with EU decarbonisation ambitions, and acknowledge all fuels that have a proven environmental record, including all alternative and renewable…

The scale-up of chemical recycling is an opportunity to advance the EUs objective of creating a competitive circular economy that reduces GHG emissions and boosts EU raw material autonomy. The mass balance (MB) decision for recycled content under the Packaging and Packaging Waste Regulation (PPWR) must prioritize the competitive scale-up of chemical recycling assets in the EU to avoid heavy reliance on imports to…

Neste welcomes the ReFuelEU Aviation initiative. A European blending mandate for Sustainable Aviation Fuels (SAF) is timely and necessary as it will immediately reduce CO2 emissions in the hardest to abate transport sector: aviation does not have an immediate alternative to fossil fuels.

Neste Corporation (see www.neste.com) supports the Green Deal’s ambition for climate neutrality in 2050 and welcomes the opportunity given by the Commission to provide input to the publication of the Inception Impact Assessment (the Document) on the ReFuel EU aviation sustainable aviation fuels.

Neste Corp. (www.neste.com) is the world’s largest producer of renewable diesel refined from waste and residues, introducing renewable solutions also to the polymers and chemicals industries. Our business is focused on combating climate change and driving circular economy, and we are committed to becoming a solution provider in chemical recycling by providing cost-effective and sustainable innovations.

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.

Neste welcomes the FuelEU Maritime initiative to reduce greenhouse gas emissions from maritime transport. 1) Broad feedstock base for renewable fuels is needed to cost effectively reduce emissions in maritime transport Neste supports a broad feedstock base for sustainable biofuels.

Neste supports the European Commissions drive towards a carbon neutral transport sector promoting ambitious CO2 emissions targets. However, regarding emission standards for Heavy Duty Vehicles, Neste regrets that the Commission misses the important opportunity to allow sustainable renewable and low-carbon fuels such as biofuels, biogas and e-fuels to accelerate climate policies.

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.

Neste welcomes the initiative of the European Commission to provide a common framework for calculating GHG emissions of transport operations in the freight and passenger transport sectors. We share the concerns of the EU Commission about the rising levels of GHG emissions of the transport sector.

Neste (www.neste.com, the world's largest producer of renewable diesel refined from waste and residues, introducing renewable solutions also to the aviation and plastics industries) welcomes the opportunity to provide feedback on the Commission’s inception impact assessment on the European vehicle emissions standards – Euro 7 for cars, vans, lorries and buses.

Neste Corp. (www.neste.com, the world's largest producer of renewable diesel refined from waste and residues, introducing renewable solutions also to the aviation and plastics industries) welcomes the revised Gas Directive proposal.

Nestes Input on the Fitness Check of EU Airport Legislation pertaining the Groundhandling Directive 96/67/EC Neste welcomes the Commissions initiative to carry out a fitness check of EU airport legislation to determine if it is still fit for purpose and delivering on its objectives.

Neste welcomes the European Commission's Green Deal and the related Fit for 55 package to meet the EU's increased 2030 climate target. Neste is committed to a carbon neutral production by 2035 and to reducing our customers' carbon footprint by at least 20 million tonnes per year by 2030. The right regulatory framework is key to realising the full greenhouse gas reduction potential.