Hold the Door for Waste-based & Advanced Biodiesel


September 2022

Time is of the Essence, the European Climate is at Stake

The European waste-based biodiesel industry has always strived to bring low-quality wastes and residues to life, which would otherwise pollute the environment. The industry has set up local networks of companies collecting used cooking oil from food factories, restaurants, households and public collection points, among others.

Waste oils collected are used to produce biodiesel through transesterification, an efficient process that maximizes on-road and maritime GHG emissions reduction. In 2021, EWABA members produced more than 2 million tons of waste-based & advanced biodiesel, saving close to 6.3 million tons of equivalent CO2 emissions.

But the significant climate benefits stemming from the work of the waste-based biodiesel community are at risk since the proposed ReFuelEU legislative file could lead to an unintended mass diversion of feedstock from road/maritime to aviation to produce fuel for planes which is:

  • more expensive, around x4 the price of jet fuel and close to x2 the price of waste biodiesel
  • more energy intensive to produce, achieving 76% GHG savings (significantly less than 90% saved on average for waste biodiesel) and
  • less in total renewable fuel volumes. Literally as the feedstock conversion efficiency is higher for waste biodiesel than for waste oil-based aviation fuel, this results in less fuel being produced by using more feedstock to result in less GHG savings!

The trilogue negotiations between EU policymakers will define the outcome of the fit-for-55 package. Stemming from this package, important legislative files like the REDIII, ReFuelEU and FuelEU, will set the direction in renewable fuel mix across transport. Therefore, the EU legislator should consider taking a holistic and technologically neutral approach and not rely on 'silver bullets' and past mistakes to achieve climate neutrality. Liquid renewable fuels will continue to play an important role across harder to decarbonise sectors like heavy duty vehicle and maritime.

Watch our video below highlighting the ongoing survival risk for the waste & advanced biodiesel industry and find our proposed solutions for key transport legislative files (REDIII, ReFuelEU & FuelEU) in our trilogue Position Paper.

Frequently Asked Questions - FAQs

Why would the proposed SAF blending mandate be lethal for our industry?

The blending mandate envisaged by the EU is an undifferentiated, all-inclusive mandate that heavily relies on waste lipid feedstocks listed in Annex IX of the REDII, without any safeguards for their use for road/heavy duty and maritime sectors.

We estimate that a 2% SAF mandate in 2025 would require at least 1.5 million tons of waste lipids being diverted from road transport to aviation. This is an enormous figure if compared with a total demand of 2.5 million tons per year by the European waste-based biodiesel sector.

Due to this, up to 50 waste biodiesel factories in 21+ EU member states could be forced to close down because of a lack of feedstock to process, risking the jobs of 25,000 EU citizens currently employed in the sector.

What would be the environmental impact if this policy goes through?

In addition to the large economic damage, the EU’s outlined plans for SAF will not achieve the intended climate benefits. That is because:

  • HEFA production processes are less efficient when processing waste lipids such as used cooking oil compared to waste-based biodiesel
  • HEFA production from waste lipids has higher production costs and leads to lower GHG emissions savings compared to waste-based & advanced biodiesel
  • We have commissioned a study from Dutch consultancy Studio Gear Up in 2021 to calculate the GHG implications, focusing on UCO as a feedstock for waste-based biodiesel and HEFA

The expected diversion of waste lipids to aviation would result in at least 1 million tons of additional GHG emissions released to the atmosphere already in 2025, and rising in line with the SAF blending mandate.

Is there a ‘feedstock availability’ issue or is there enough feedstock for all transport sectors?

The HEFA production process based on lipids would require large volumes of wastes & residues that are constrained by availability and existing demand by other transportation sectors. The diversion of feedstock from one sector to the other is not justifiable in terms of the environment - worse climate mitigation effects, the economy – will possibly lead to the closure of SMEs operating in the biodiesel industry, or technology, since it limits investments in much needed novel technologies for aviation.

NGO Transport & Environment (T&E) has estimated that 8.1 million tons of UCO will be needed for all transport sectors to decarbonise (assuming all biodiesel demand from transport comes from UCO). While this figure is not fully representative as other feedstocks will also be in use, it illustrates the extent of the feedstock demand that the EU will face at least in the coming decade. An accurate way to prevent this effect would be to place a hard limitation on the use of Annex IX waste lipids under the ReFuelEU aviation mandate. This policy would also drive significant investments by the aviation fuel industry towards novel and scalable technologies such as Fischer-Tropsch, Alcohol-to-Jet and e-fuels, which are key to decarbonise aviation in the long-term.

But the aviation has no other alternative, isn’t that right?

This narrative is misleading - using waste lipids is merely the lowest cost option for aircrafts at the moment. National governments have the option to support novel and scalable pathways that achieve higher GHG savings and could ensure long-term decarbonisation of the sector. Examples are the UK that chose to focus on SAF from cellulosic residues, municipal solid waste, etc and Germany that is investing in e-fuels and plan a deployment stage in the mid-2020s. Both countries have excluded HEFA from the promotion mechanism.

The road transport sector will be electrified anyway

The Commission itself predicts that roughly 80-90% of all vehicles in Europe will still have a combustion engine in 2030, as stated in the EU Strategy for a Smart and Sustainable Mobility, adopted last December[1].

Especially in the heavy duty vehicle and maritime sectors, renewable liquid fuels are expected to be used for decades to come because of their high energy density, the absence of alternatives and the challenges in ‘electrifying’ these sectors.

Instead, incorporating higher blends of waste-based and advanced biodiesel is by far the best option to lower emissions today by using the existing diesel internal combustion engine fleet, which will still be present in significant volumes in EU roads at least over the next decades.

[1] The Strategy states “By 2030 at least 30 million zero-emission vehicles will be in operation on European roads”. There are currently 280 million motor vehicles in the EU, according to data from EU car manufacturers association ACEA. This number has been increasing steadily every year (e.g. in 2015 there were 255 million vehicles).

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