Fuel EU: Animal fats category 3 are not suitable for Sustainable Maritime Fuels

Following the provisional political agreement concluded between the
European Parliament and Council of the EU on the Fuel EU Maritime proposal, APAG, FEDIAF and
FEFAC would like to express their views.

Last week, the European Parliament and the Council of EU reached an agreement on the proposal
for the Fuel EU Maritime Regulation, boosting the transition towards sustainable maritime fuels.
Whilst we welcome the efforts to decarbonise the shipping sector, we would like to stress that
this should not put other sectors at risk.

Achieving EU decarbonisation while safeguarding the bioeconomy sector
While the biofuels sector can thrive on other types of feedstocks, the oleochemical industry
cannot function sustainably without access to sufficient quantities of animal fats category 3.
Similarly, pet food and feed industries heavily rely on it. Fats derived from category 3 by-products
have many functions in feed, providing a source of energy and palatability but above all essential
fatty acids. An increase in demand, from any mode of transport, but in particular the maritime
sector, would keep animal fats category 3 from being used in production of pet food and animal
feed as well as other oleochemical uses.

Calling for a strong cascading principle use and waste hierarchy

We welcome the alignment on sustainable maritime biofuels by qualifying feedstocks listed in
Annex IX of the Renewable Energy Directive as sustainable biofuels for maritime transport and the
move towards renewable liquid and gaseous fuels of non-biological origin (RFNBOs). In line with
the objectives of the European Green Deal, this supports our industries by protecting their
sustainable business models and their continued access to raw materials.

However, we have been sharing our concerns on diversion of one of the key feedstocks – animal
fats category 3 – for biofuel production. For our industries, animal fats category 3 are one of the
key ingredients. We, therefore, call for a strong cascading use principle and waste hierarchy to
minimise distortive effects on the biomass raw material market and harmful impacts on
biodiversity.

The oleochemical, pet food and feed industries are enablers of the circular economy and examples
of industrial symbiosis: our industries upgrades rendered animal fats (category 3), a by-product
from the meat processing and rendering industry, into a large variety of bio-based products. These
products, in turn, are used by other industrial sectors and end-users across the EU. As a result, our
industries keep renewable raw materials in the loop and help achieve the objectives of the
European Green Deal. This would continuously be possible with a sufficient supply of animal fats
category 3 in the EU market.