Brussels, 21 January 2015
EBB - EOA - FEDIOL Joint Position on the 2nd Reading Report of Environment Committee
The European Biodiesel Board (EBB), the European Oilseeds Alliance (EOA) and the EU Vegetable Oil
and Protein Meal Industry (FEDIOL) constitute the EU biodiesel production chain, including farmers,
primary processors of oilseeds and biodiesel producers. The EU biodiesel production chain has been
raising strong concerns about the indirect land use change (iLUC) since 2011, and about a debate based
on research which is widely considered as immature.
The EU biodiesel production chain takes note of the balanced Council 1st reading agreement, but would
like to ask the Members of the European Parliament to:
1) Deliver on the legal obligations to safeguard existing investments from the introduction of
iLUC methodology into EU legislation. Article 19(6) of the Renewable Energy Directive
(2009/28/EC) and Article 7d(6) of the Fuel Quality Directive require that appropriate measures are
taken to protect certainty for investments made before the iLUC methodology is introduced. A
safeguard clause need to be defined whereby the quota of biodiesel and biofuels produced till now
are excluded by ILUC accounting and reporting
2) Maintain 7% cap for conventional biofuels in order to protect the jobs and investments across the
production chain in Europe. The average consumption of biofuels in Europe is already at more
than6% of the total transport fuel use and in some countries, such as France, Germany, Sweden and
Poland, the biofuels consumption has already exceeded 7%. Endorsing the cap of 7% is the only
realistic way forward for avoiding economic loss across Europe.
3) Acknowledge the existence of iLUC-free and low-iLUC risk biofuels, which can be produced by
mitigating and avoiding the potential occurrence of iLUC through improving efficiency through the
production chain, increasing agricultural yields and through using set-aside (unused) agricultural and
degraded land.
4) Biodiesel from waste and residues (UCO, Tallow and FOG) are to be included in the advanced
biofuels definition and list. Advanced biodiesel from waste and residues are fully covered by this
definition since they have 95% GHG savings, out of land and need more investments. It would be
discriminatory and illogical to exclude them from the list of advanced within a legislation to promote
alternative sources.
5) Insist on the principle of technology-neutrality in considering biofuels. The legislation should
respect the Member States’ ability to achieve the renewable energy use in transport and no
differentiation shall be made between the biofuels using same or similar technologies. There should
also be no differentiation between advanced biofuels produced from waste and residues (e.g. Annex
IX, parts A and B)
6) Recognise the strategic importance of biodiesel in terms of energy and protein security. The
EU imports 30-35 million tonnes of diesel per annum, half of which comes from Russia, making the
EU economy dependent on politically unstable regions. Biodiesel production in Europe increasingly
helps reduce this dependency as a genuine European biofuel. The EU is also dependent on imports
of protein feed material for its food demand. Biodiesel production produces valuable protein meals as
co-products, which reduces EU’s protein imports by more than 2.5 billion Euros every year, while also
reducing the EU’s environmental footprint in 3rd countries.
7) Finally consider all the direct advantages that Biodiesel brings for European citizens on
security of energy supply, reducing protein deficit, creating investment, jobs and economic activity
while contributing to rural development