Ref. Ares(2021)2522609 - 14/04/2021
(CAB-VON DER LEYEN)
From:
(CAB-VON DER LEYEN)
Sent:
mercredi 14 avril 2021 10:47
To:
@hkstrategies.com'
Subject:
FW: Avril Group Urgent Request regarding Taxonomy
Dear
would like to thank you for your e-mail to Mr Seibert and himself concerning your request
regarding Taxonomy.
I herewith acknowledge receipt of this request.
We shall follow up on this with our colleagues in charge.
With very kind regards,
European Commission
Cabinet of President Ursula von der Leyen
200 Rue de la Loi
Berlaymont (BERL)
1049 Brussels/Belgium
@ec.europa.eu
http://ec.europa.eu/research
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From:
@hkstrategies.com>
Sent: Wednesday, April 14, 2021 10:07 AM
To:
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CAB-VON DER LEYEN) <
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Cc:
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Subject: Avril Group Urgent Request regarding Taxonomy
Dear
Dear
I am contacting you on behalf of the Avril Group, a French agro-industrial group specialising
in human nutrition, animal nutrition, renewable chemistry, and renewable energy, about the
urgent matter that is the EU Taxonomy.
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Avril is very concerned about the current draft of the delegated act of the Taxonomy which
he believes is legally questionable and unjustifiable.
First of all, the draft delegated act is incoherent and legally questionable. While it provides
for an express reference to the sustainability criteria of the Renewable Energy Directive
(2018 / 2001 - RED2), strengthening them on the reduction of CO2 emissions (65% vs. 50%),
the draft automatically excludes first-generation biofuels (“Food-and feed crops are not used
in the activity for the manufacture of biofuels for use in transport”) even if the latter meets
the aforementioned criteria. This has been corrected in the latest version of the act
concerning oleo chemistry but remains for first-generation biofuels.
Secondly, the draft delegated act is unjustified:
On the one hand, it would call into question the investment strategy of the
agricultural sector, which actively participates in the development of renewable
energies in the Union, provides many jobs in rural areas and contributes to the EU’s
energy and protein independence.
On the other hand, sustainable biofuels play a driving role in decarbonising
transport. In fact, first-generation biofuels now account for 45% of renewable
energies used in transport in the EU28 and saved about 46 million tonnes of CO2 in
2018. The industrial maturity of these biofuels contrasts with the still limited
development in advanced biofuels. It is the achievement of European renewable
energy objectives in 2030 that will be called into question.
In this regard, we kindly wanted to ask you to remove the sentence “Food-and feed crops
are not used in the activity for the manufacture of biofuels for use in transport” from the
final version of the text (in Annex I of the Delegated Act under point 4.13) in order ensure
better compliance between the two texts and protect the industry.
We would also be happy to discuss this matter with you at your earliest convenience.
Thank you in advance for your support,
Kind regards
On behalf of the Avril Group
@hkstrategies.com
Communications leadership
built on a 50-year legacy
Hill+Knowlton Strategies
Rue Montoyer 51, box 7
Brussels, 1000
Belgium
www.hkstrategies.com
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