European public consultation: Review of indirect land-use change (ILUC) delegated act

Background

The European Commission has published a draft with a review of the delegated regulation on indirect land-use change(ILUC) which is now open for public consultation. The amended delegated regulation updates the methodology and data for high ILUC-risk feedstocks for bio-based fuels and supplements the directive with a trajectory for a gradual decrease of their contribution towards renewable energy targets.

This review arises from concerns of high-ILUC risk feedstock expansion into areas with high carbon stock where in addition to palm oil, soy is likely to be considered a high-ILUC feedstock for biofuels.

Opinion from Platform Renewable Fuels

The expansion of soybean cultivation into land with high carbon storage is problematic. To address this issue, the EU Deforestation Act has been developed, but its implementation has been delayed.

As Platform Renewable Fuels, we see that the root cause of expanding cultivation into high-carbon storage land is not defined and addressed directly namely animal feed production. This concern is translated into restrictions on feedstock types for sustainable biofuels which could impact the flexibility and optimisation for opportunities in the protein transition where vegetable oil can also be supplied to other demand markets when the market is saturated. Soybean cultivation can also be an interesting as an intermediate crop or intercrop option in some contexts.

Expansion of soybean which has the largest demand in livestock farming, is now being pushed onto biofuel while the sectors already has rules in place prohibiting the use of soybean with negative effects. These strict sustainability frameworks do not exist for animal feed production.  

Providing feedback to the public consultation

You can submit your feedback on of the delegated regulation here until 18 February 2026 (midnight Brussels time).

‍