The European Commission has released for consultation a revised list of permissible waste and advanced feedstocks for biofuel production listed in Annex IX Part A and B of the EU's renewable energy directive (RED II).
Major changes include removing brown grease from the list of so-called advanced or Part A feedstocks and placing it under mature Part B feedstocks. This would give the product the same status as used cooking oil (UCO) and potentially limit the pool of commercially scalable feedstock available for the production of advanced Fame.
According to market participants, around 25-30pc of freely traded volumes of advanced Fame in Europe are from brown grease, while around 65-70pc are Pome derived and a far smaller volume from other feedstocks such as acid oils.
The commission plans to add a range of other non-feed crops such as "non-food crops grown on severely degraded land, not suitable for food and feed crops" to Part A. But commercial volumes of feedstock from these sources are yet to materialise and it is not entirely clear what would be permitted under Part A as the crops need to be grown on land that cannot be used for food, excluding cover crops grown between harvests in places such as Argentina.
Also to be recognised as advanced feedstocks are non-food or non-feed alcoholic distillery residues and wastes (fuel oils) and raw methanol from pulping stemming from the production of wood pulp.
The EC aims to add intermediate crops to Annex IX Part B, including catch crops and cover crops grown in single harvest areas. It further adds to Part B non-feed and non-food starchy effluents with less than 20pc starch content and a range of similar feedstocks such as brewers' spent grain, liquid whey permeate, deoiled olive pomace, damaged crops and municipal wastewater and derivatives other than sewage sludge.
The use of Annex IX Part B feedstock is capped at 1.7pc under RED II, but flexibility on the cap is being put forward in proposals from the EU parliament and from EU member states. Biodiesel industry sources now call for a mechanism to increase the 1.7pc cap to take account of the new Annex IX feedstocks.
"If kept as drafted it would be win-win for industry at large and potentially terminate the feedstock competition issue," said Angel Alberdi, secretary general of waste-based biofuels association EWABA. But Alberdi added that the expansion of mature feedstocks under Part B makes the current 1.7pc cap "completely and utterly inoperative".
The new feedstock list is open for consultation until 2 January. The list could be formally adopted by the EU towards the end of the first quarter of 2023. This requires EU member states and the EU parliament to not explicitly reject the commission's proposals over the next two months.
Following adoption, member states would have 18 months to fully implement the new list into national legislation.
