PHB: Support for industry letter calling for stimulation of intermediate crops | 2023

A recently published industry letter calls for the stimulation of intermediate crops, such as catch and cover crops, by inclusion in the Annex IX Part A of the Renewable Energy Directive II (RED II), where it would be subjected to a minimum subtarget. This proposal challenges the current revision of the feedstock list, which suggests placing intermediate crops in Part B where it would be subjected to a limiting cap which takes away the perspective for growth.

Platform Renewable Fuels supports the main messages of this industry letter, recognising the need for a perspective of growth rather than a restrictive cap.

For the Platform Renewable Fuels the intermediate crops could either be placed in the ‘other’ category or Annex IX A, as long as they are not included under Part B. This is because Part B of Annex IX already includes Used Cooking Oils (UCO) and animal fats, which are likely to contribute a large portion of the available capacity. This would mean that there is little to no potential for intermediate crops to contribute to an increased production of sustainable and renewable fuels.

Given the criterion of ‘mature technology’ for the inclusion in the capped Annex IX B, it is understandable to extend the concept of ‘advanced technology’ to also include the innovations that are needed to come to a good implementation of intermediate crops in the system. The Platform would like to re-emphasise that adding feedstocks that are converted with mature technology to Annex IX Part B creates a disincentive for reaching cost-effectiveness for the market. Investments in and ‘advanced’ technology (which by definition has the goal to reach maturity one day) come with high risk, as they are confronted with their feedstock being moved to the capped Annex IX Part B list. Therefore the Platform asks the European Commission to remove mature technology as a basis for adding feedstocks to the capped Annex B category.

The letter can be found here.