FuelsEurope’s interpretation of the Delegated Regulation on Co-processing Methodology
1. Spreads: 1% absolute deviation of main method vs. measure and consideration of overall mass-balance:
- The term “deviation” in article 6.4 should be understood as the spread in absolute percentage between the 14C measure and the bio-content expected from the main method defined by the operator.
- This “deviation” is not the inherent accuracy of the 14C method.
2. Need for 14C testing in case of 5% deviation of variables and process parameters from baseline
- The 5% deviation in Art. 6.5 refers to absolute % changes of the co-processing unit’s parameters and variables.
- The deviation of parameters to the baseline should be appraised over an entire batch or consignment.
3. Default yield factors defined at Member State level
- Use of default yields set at Member State level has validity across the European Union. Operators are free to derogate to these yield factors and seek independent certification.
4. Co-processing of waste-based bio and non-bio-origin feedstocks.
- The methodology cannot apply to fully non-renewable waste feedstock material.
- The delegated act on RFNBO/RCF greenhouse gases methodology rules over this delegated act if the non-bio-origin feedstock produces RCF or RFNBO or RFNBO. However, with regards to the share of renewable feedstock, flexibility should be granted to operators that would like to demonstrate a higher share of biomaterial through 14C testing.
5. Role of 14C testing when mass balance is the main method
- 14C testing is needed only for the initial setup of mass balance as main method before becoming a secondary method.
6. CHN Analysis
- Reference to CHN elemental analysis in the Delegated Act is only indicative.
7. Sampling point
- Member States shall not impose 14C testing at the refinery gate.
8. Storage of gaseous samples
- Gaseous samples have a shorter shelf-life than the required retention (2 years).
9. Compliance with Article 6.3 to quantify any loss of carbon from biogenic origin and compliance with the requirement to determine 14C in gaseous samples:
- Use of 14C testing to quantify the loss of carbon from biogenic origin due to the process of removing oxygen from the biogenic feedstock is only illustrative as alternative methods exist.