PHB: reaction to Transport & Environment/Cerulogy on animal fats for biofuels | 2023

Transport & Environment raised concerns about the use of animal fats for biofuels building on the study they commissioned, which was carried out by Cerulogy.

The Cerulogy report points towards inconsistencies and gaps between different sources in the reporting of animal fats categories 1, 2 and 3. The author interprets these gaps in the data and the statistical differences between different reporting sources as gaps in the reporting itself, which he says could point to fraudulent practices or category 1 & 2 fats being erroneously reported as being category 3.

The study's author considers several possible reasons for these inconsistencies, one example being the possible advantages of animal fats being in category 1 & 2 and used as feedstock for biofuels, as this would make those biofuels be double counted, making them more attractive and thus increasing their market value. The report’s author suggests there’s a possibility that category 3 fats are intentionally contaminated with category 1 & 2 fats, which might “degrade” the entire volume and qualify it for double counting when used as biofuel. However, classifying a category 3 animal fat under categories 1 or 2 would only make sense if the resulting biofuel’s double counting yields more profit than the high-end application of a category 3 animal fat in pet food or cosmetics.

Based only on that there might be advantages to lowering the categorisation of animal fats in certain cases, a surge of strong suspicions of fraud has arisen from within “the industry”, according to the author. It’s worth pointing out that in this case, “the industry” refers to producers of pet food and cosmetics, who are the ones competing for animal fat feedstock with other industrial parties.

Cerulogy points out there is insufficient evidence to assume fraud is happening. Nevertheless, the study does not shy away of strongly suggesting the possibility of fraud in the conclusive statements of the article.

The Platform Renewable Fuels wants to point out that sustainability certification requires evidence of category 1 & 2 animal fats, independently verified by auditors.