The European Commission issued a proposal Nov. 30 for the post-2020 Renewable Energy Directive and, as discovered in the leaked draft more than a week ago, the EU plans to incrementally reduce so-called first-generation biofuels such as ethanol from grains and biodiesel from crop oils from 7 percent in 2020 to 3.8 percent in 2030.

In response to the proposal, the European Biodiesel Board stated this plan “reveals a worrying weakening of ambitions by the EU in addressing climate change, energy security and the decarbonization of the European transport sector.” 

Raffaello Garofalo, EBB secretary general, said, “The exclusion of conventional biofuels from the incorporation obligation of fuel suppliers is unacceptable. With the high costs for decarbonization in transport, this exclusion would likely mean an increase of fossil fuels in transport due to lack of availability of advanced biofuels, and an abandonment by the EU of the COP21 ambitions and objectives.”

Philippe Dusser, the secretary general of the European Oilseed Alliance, said, “This proposal, which does not take into consideration protein-generating biofuels, will have a dramatic impact on EU agriculture given the positive externalities of conventional biofuels produced from domestic feedstocks in reducing the animal feed and protein deficit in Europe.”

Esterifrance, the union of French producers of biodiesel from vegetable oils, animal fats and waste oils, condemned the proposal, calling it “a radical change in direction, which demonstrates an absence of consultation and lack of realism regarding a decision taken without scientific foundations and whose consequences for French biodiesel—mainly produced from rapeseed—will be disastrous.”

Furthermore, the EBB pointed out that this revised RED, if implemented as-is, will result in a dramatic reduction of animal feed and worsen the large EU protein deficit. The legislation will also destroy an industry created by EU legislation that, according to the EBB, maintains 220,000 jobs, mainly in rural areas.

In addition to the threat this plan poses to EU farmers, which would provide “an almost total annihilation of the efforts made by the sector for more than 40 years to regain France’s independence in terms of vegetable proteins for livestock feed,” Esterifrance stated, the proposal represents “an extraordinary threat to companies working in this sector, which have already been severely impacted by the lack of visibility and regulatory stability relative to renewable energies in Europe.” At least 10 production plants across France and 20,000 biodiesel-related French jobs are at risk from this plan, according to the organization.

“By choosing to call into question the future of a sector that has invested considerably in research and innovation, the commission is also placing a brake on the development of new generations of biofuels, which the new directive nevertheless aims to favor,” Esterifrance said.

Esterifrance also pointed out that the European Commission made no distinction between biofuels made from protein-rich oilseeds such as biodiesel from rape and those made from low-protein crops such as ethanol from starchy grains.

On that same topic, EBB stated, “The proposed differentiation between biodiesel and bioethanol is unjustifiable as it is not science based. As recognized by the commission many times, and stressed out on several occasions by independent scientific parties such as California Air Resources Board in the U.S., indirect land use change (ILUC) is a theory and cannot be observed or measured. Only by maintaining a 7 percent target for protein-generating biofuels, reversing the subsidiarity granted to the member states, which would allow them to differentiate between biodiesel and bioethanol and promoting a gradual and realistic phasing-in of advanced biofuels, long-term stability and legislative certainty can be granted to the overall European value chain. This is further illustrated by the U.S. EPA, which announced this same week a considerable increase in biofuels blending obligations in the U.S., as the best way to achieve decarbonization.”

The revised RED would also increase European imports of fossil fuels, according to Esterifrance, “thus casting doubt on the ability of its member states to comply with the undertakings made in the context of the Paris agreement.” The association added that the French biodiesel sector provides €1.5 billion (USD$1.6 billion) worth of annual savings in imports of fossil fuels and oilseed meals for livestock feeds.

“The proposed exclusion of conventional biofuels from the incorporation obligation in transport is the wrong approach,” EBB stated. “Conventional biofuels have a key complementary role in decarbonizing transport. They resulted in some 35 million tons of gross avoided CO2 emissions, the equivalent of the CO2 emission of Slovakia in 2013. In addition, they contributed to an overall 116 million tons of oil equivalent drop in EU demand for imported fossil fuels, corresponding to €30 billion per year savings. Advanced biofuels will not be able to substitute immediately the proposed drop of conventional biofuels in transport, as wrongly anticipated by the commission.”

Kristell Guizouarn, the chair of Esterifrance, said, “This reversal by the European Commission wipes out all the efforts made to achieve the decarbonization of transport. Inevitably, and as early as 2020, this will lead to an increase in fossil fuel imports, to the detriment of our agriculture and industry. This is indefensible and unacceptable.”