FuelsEurope statement on Delegated Acts RED III

FuelsEurope welcomes the Commission’s initiative to propose a draft Delegated Directive to update the list of sustainable biofuel and biogas feedstocks in Annex IX of the Renewable Energy Directive (EU) 2018/2001 (RED) as an important element for our members to continue transforming and accelerate the production of advanced biofuels.

We welcome the proposal to add new feedstocks to both part A and part B of the Annex IX of the Renewable Energy Directive.

The proposed additions of feedstocks to Part A have significant potential to contribute to the EU’s ambitious combined target of using 5.5% of the energy consumed in transport in the form of advanced biofuels and renewable fuels of non-biological origin (RFNBOs) in 2030. The addition to part A of intermediate crops and crops grown on severely degraded land would add these feedstocks to the list of eligible raw materials for the production of Sustainable Aviation Fuels (SAF) defined in ReFuelEU Aviation. It would bring an encouraging perspective to the market to invest in these feedstocks to help meet the ambitious SAF mandate applicable to fuel suppliers, Union airports and aircraft operators from 2025 onwards.

Annex IX B biofuels and biogas are critical for achieving cost-efficient transport decarbonisation. Adding new feedstocks to Part B requires increasing the 1,7% cap (RED Article 27.1 (c) (iv)) to unlock the potential of the added feedstocks. Without prejudice to the right of the Member State to request a local increase of that cap (RED Art. 27. 2), FuelsEurope would encourage the European Commission to consider exercising its power to adopt a delegated act and increase the cap consistently at the Union’s level in accordance with articles 27.3 and 35 of the RED.

Liana Gouta, Director General FuelsEurope, stated "It is essential that the review of Annex IX enshrines both the need for long-term clarity on feedstocks’ classification and the scalability of available feedstocks. The timeline over which industry invests and produces fuels is measured in decades – therefore long-term certainty in feedstock classification is a key enabler to secure investment to produce biofuels and biogas at scale in order to achieve the EU climate neutrality ambitions and energy security, especially for the decarbonisation of the hard to abate transport sectors."