The EU energy policy promotes renewable energy sources for the European Union seeking to decrease dependency on third countries and to reduce greenhouse gas emissions. FEFAC believes that biofuels can provide an interesting contribution to this objective while offering new economic opportunities for EU agriculture.
In addition, there is no doubt that the EU biofuel policy was probably one of the most effective EU policies (besides CAP), , to increase homegrown supplies of vegetable proteins in the EU during the last decade. Production of biofuels from agricultural crops, i.e. bioethanol from cereals and biodiesel from oilseeds in particular from rapeseed helps to produce protein-rich co-products such as dried distillers grains and oilseed meals, especially rapeseed meal.
However, the agricultural raw materials used as feedstock for biofuel production are also used to produce food and feed, which means the food, feed and fuel outlets compete for the same limited resources such as land and water. This can be especially intensified in times of crisis when competition for biomass increases hand in hand with global demand for food/feed and energy. Hence, the additional pressure on agricultural markets should be maintained at an acceptable level. A limit of a max of 7% of food-feed crops contributing to renewable energy production at the national level is a good compromise at present & outlined in the recast Renewable Energy Directive (2018).
The contribution of advanced biofuels (also second-generation biofuels) and biogas produced from the feedstock listed in Part A of Annex IX should be also carefully assessed, especially when Commission is entitled to review this annexe every 2 years through the delegated act. In this category, several feedstocks (or so-called co-products), coming as an unavoidable and unintentional consequence of the production process in industrial installations could be listed. However, the feed industry, a circular economy champion, uses vast amounts of co-products of the food and non-food sector, in the production of industrial compound feed thus reducing pressure on arable land use change and related emissions.
All feedstocks that are listed directly (e.g. molasses) or indirectly (e.g. poultry fat is included within animal fat) in the EU Feed Materials catalogue must be preserved for feed use in order to not undermine the feed sector’s contribution to the EU climate neutrality target. The introduction of the waste hierarchy concept (1. Prevention of waste, 2. Re-use of water, 3. Recycling of waste 4. recovery 5. Disposal) within the RED regulation, should provide certainty for the feed sector.