Ref. Ares(2017)2689530 - 29/05/2017
Mr José Manuel Silva Rodriguez
200 rue de la Loi
Brussels, 18th September 2012
Re: Indirect Land Use Change (ILUC) and European biofuels promotion policy
Dear Director General,
We have heard that the European Commission is currently examining a proposed directive
modifying the directives on the promotion of the use of energy from renewable sources and fuel
quality. This would include introducing ILUC factors, limiting the proportion of biofuels
produced from certain arable crops and encouraging the development of biofuels produced from
waste and residues. Copa-Cogeca believes that these initial proposals run counter to the aims of
climate and energy policy as well as the Bioeconomy Strategy. We would therefore like to share
our observations with you.
The introduciton of ILUC factors in EU legislation is completely unacceptable as it is
scientifically impossible to evaluate the effects of land use change related to EU biofuels policy.
Copa-Cogeca has already pointed out the inadequacies of the IFPRI report (2011) on numerous
occasions. Arbritrary ILUC factors would penalise biofuels production in the EU and would not
reduce land use change in third countries. However, 1.5 to 2 million hectares of arable land are
currently not cultivated in the EU and the productivity gains from agricultural inputs are a
positive development. Furthermore, the level of ILUC factors set to be introduced immediately
in the Fuel Quality Directive would threaten many recent investments made in response to the
targets set 3 years ago. The biodiesel sector would be condemend to rapid decline and
disappearance. The ethanol sector, still in its infancy, would see its development prospects
The introduction of a 5% limit on biofuels produced from certain arable crops would make it
impossible to achieve the target of renewable energy sources providing 20% of the EU's final
energy consumption by 2020. Furthermore, it would eliminate the improvements to the EU's
supply of protein for animal feed made over the last few years. Indeed, the development of the
EU biofuels industry has been one of the few measures that have allowed imports of protein for
animal feed to be reduced by 2 million tonnes soya meal equivalent over the last 3 years.
The introduction of an incentive for producing biofuels from waste and residues using the
statistical trickery of quadruple counting would artificially inflate the contribution of second
generation biofuels, which are not commercially available in the EU or in third countries.
Furthermore, this incentive could lead to a surge in waste and residue imports such as imports
of used cooking oil.
Finally, the definition of waste and residues is so broad that products which are not waste could
be included in this category (molasses and cooking oil, for example).
Copa-Cogeca would therefore ask the European Commission to revise its proposed directive by
coming up with effective and constructive measures which meet the objectives of energy and
climate policy. In particular, Copa-Cogeca requests that the European Commission
Copa - Cogeca |
European Farmers European Agri-Cooperatives
61, Rue de Trèves | B - 1040 Bruxelles | www.copa-cogeca.eu
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remove ILUC factors from both directives;
maintain the objective of renewable energy sources providing 10% of energy consumed
by the transport sector;
guarantee that existing and future investments will continue;
provide a precise definition of waste and residues using a positive list;
remove double and quadruple counting, which will lead to first generation biofuels being
replaced by fossil fuels;
define a separate binding objective higher than 10% for advanced biofuels;
maintain the legal basis allowing sustainability criteria to be verified in bilateral
agreements (Directive 2009/28 Article 18(4));
put in place an agricultural research programme focused on increasing the productivity
of arable crops.
We hope that these comments will be granted your full consideration.
Philip Lowe (ENER), Jean-Luc Demarty (TRADE), Jonathan Faull (MARK),
Daniel Calleja Crespo (ENTER), Robert-Jan Smits (RTD)
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