Renewable energy: revising biofuel, bioliquid and biomass fuel production pathway values and modifying methodology

FuelsEurope and its members welcome the opportunity to comment on the draft revision of Annex V and VI of the Directive (EU) 2018/2001 (Renewable Energy Directive). As producer of renewable and low carbon fuels, we are fully committed to support the correct and effective deployment of clear rules for calculating the greenhouse gas impact of such products.

To this end, we want to share this set of recommendations and requests for clarifications, crucial to ensure the correct application of the revised annexes.

Key recommendations:

1. Recognition of fully renewable electricity
2. Maintain the reference to bio-ethers
3. Adjust the scope of eccs
4. Inclusion for carbon emissions that are permanently chemically bound in long-lasting products, captured in the production of biofuels, bioliquids or biomass fuels
5. Calculation of ep term when calculating bioliquids and biofuels greenhouse gas emissions. Period of calculation
6. Clarifications in Annex V tables
7. Clarification on the applicability of disaggregated default values to co‑processed products
8. Clarify the use of default values when bunkering operations are performed 150km from the production plant
9. Clarify the scope of application and definition of the Cstor factor
10. Clarify the applicability and methodology to calculate the “methane leakage” improvement factor
11. Clarifying the paragraph on compression and liquefaction
12. Define “standard” and “best” practice for methane leakages
13. Clarify the applicability of default and typical values