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Ref. Ares(2016)6446978 - 16/11/2016
Wednesday 16 November 2016 13:10 
FW: Concern about definition of "advanced biofuels" in RED Recast 
Please register - gracias 
Sent: Wednesday, November 16, 2016 10:03 AM 
Subject: Concern about definition of "advanced biofuels" in RED Recast proposal 
Dear Miguel, 
It was good to talk to you again after many, many years. 
As I mentioned, as the world's largest high-quality renewable diesel producer, Neste is 
very concerned about the the definition of "advanced biofuels" in the draft of the RED 
recast proposal. It is now based on the so called Annex IX list of raw materials of the so-
called ILUC Directive, and therefore excludes some waste and residue raw materials that 
Neste has used for years.  
We believe this definition would severely limit the volumes of available advanced 
biofuels and therefore will prevent any meaningful contribution of advanced biofuels to 
the decarbonisation of transport by 2030. This could also exclude raw materials of some 
EU refiners which are looking to transform their fossil oil refineries into renewable fuel 
production. In addition to lack of availability, there is no doubt that a  narrow list of raw 
materials will result in high prices for these raw materials, and consequently, high prices 
for biofuels.  
There is an alternative, broader definition of advanced biofuels, which was prepared by an 
expert working group this year under the chairmanship of DG ENER. This working 
group,  the so-called Sub-Group on Advanced Biofuels (SGAB) under the Sustainable 
Transport Forum, was a joint initiative of DG MOVE and DG ENER and was composed 
of 34 experts from across stakeholder groups, nominated by the European Commission. 
The definition of advanced biofuels proposed by the SGAB is as follows: 
 "Advanced Biofuels are those produced from biomass1 other than food crops while 
meeting the EU sustainability regime2 under the legislation in force3."

1 Biomass as defined under RED or any amendment to it. 
2 Sustainability regime as defined under EU Legislation 
3 Existing legislation in force at the time of consideration. 
Furthermore, the SGAB definition is consistent with existing EU State Aid rules; Both the 
“block exemption regulation” (EU 651/2014) and the State Aid Guidelines on State aid 
for environmental protection and energy 2014-2020, (2014/C 200/01) make a distinction 
between “food-based” and “advanced biofuels”.  And “food-based” biofuels is defined in 
Article 2, paragraph 113, as biofuel produced from cereal and other starch rich crops, 
sugars and oil crops as defined in the ILUC Directive). 
Thanks, Miguel, for considering this and for an opportunity to talk. 
I copy 
 to this message. 
Best regards, 

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