Delegated Act on Methodology for determining GHG emission savings from RFNBO/RCF (Annex I) FuelsEurope’s Case Studies for RFNBO and RCF production

FuelsEurope, the European Association representing the refining industry, strongly supports the EU objective of net climate neutrality in 2050 and the circular economy, and stands ready to support policy makers to reach such goals. The refining industry is actually transforming and sustainable Low Carbon Liquid Fuels, including both RFNBOs and RCFs, are the centrepiece of this transition (strategy described in the Vision 2050 and CleanFuelsForAll publications). In this context, we warmly welcome the initiative of the European Commission to propose a detailed methodology with the required criteria to provide a stable framework to rule the production of these RFNBO/RCF in the close future.

In preparation for the certification of RFNBO/RCF cases, a core group of technical experts from different member companies have assessed the implications of the methodology described in the Delegated Act and identify some key relevant areas that, in the absence of harmonisation across certification bodies, would likely lead to a non-homogeneous and multiple interpretation, leaving to the auditors the final decision on aspects that would be key to determine the business case for the industrial production of these fuels. Now that the Delegated Act is about to be adopted, FuelsEurope would like to share our main concerns and eventual proposal for interpretation (in no contradiction with the text included in the relevant Delegated Acts and Renewable Energy Directive texts) as the result of the technical work internally conducted.

In this regard, we would kindly invite the European Commission to consider the implications of the assessed case studies and the proposals presented by FuelsEurope and eventually add, at least at certification level, some clarification on the relevant aspect identified, ideally as part of the system documents likely to be approved in the short term, to ensure an even interpretation across Europe, avoiding any potential market distortion from multiple interpretations by different auditors in the non-that-far-future.