Joint industrial letter on Delegated Act GHG methodology RFNBO/RCF
The signatories of this letter are committed to the energy transition and the objectives of the Green Deal, identifying Renewable Fuels of Non-Biological Origin (RFNBO) and Recycled Carbon Fuels (RCF) as one of the key common pillars to contribute to a low carbon transport and industry sector in Europe. The development of the RFNBO technologies followed by their scale-up and mass deployment both in Europe and internationally need to start in this decade to ensure the objectives set by the FitFor55 package are effectively achieved. In this context, the co-signers 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 in different sectors have assessed the implications of the methodology described in the Delegated Act and identify some key relevant areas subject to multiple interpretation that, in the absence of harmonisation across certification bodies, would likely lead to a non-homogeneous landscape, 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.
Following the adoption of the Delegated Acts, this letter raises the main concerns identified, summarising the proposals that could lead to a workable interpretation of the provisions, in no contradiction with the text included in these Delegated Acts and Renewable Energy Directive.
Calling for a clear and unique interpretation of the relevant aspects identified, ideally as part of the system documents of future accredited certification bodies, the ultimate objective of this letter is to contribute to a uniform interpretation across Europe, avoiding any potential market distortion from multiple interpretations by different auditors in the non-that-far-future.
Read the full letter below.