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The European Energy Policy for 2020–2030 RED II: what future for vegetable oil as a source of bioenergy?

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The support for vegetable oils biodiesel is defined by the Renewable Energy Directive (RED). After three years of negotiations, RED II (recast of the 2010–2020 RED I) has been adopted and published in December 2018. RED II sets the framework for the EU renewable energy policy for 2021–2030. Although RED II gives a priority to advanced biofuels and electricity in transport with specific targets and multipliers. For crop-based biofuels as vegetable oil biodiesel, RED II offers the possibility to preserve the current investments by giving the Member States the possibility to cap their consumption at the national 2020 consumption level (plus 1%) with maximum of 7%. With the idea to cut the link of crop-based biofuels with deforestation, a change of approach on the ILUC issue is introduced by RED II with the definition of “high ILUC-risk feedstocks with a significant expansion on land with high carbon stocks”. The high ILUC-risk feedstocks will be capped in each Member State at the 2019 level until 2023, and then progressively eliminated by 2030. An exemption from these constraints is provided for to low ILUC-risk feedstocks not linked to deforestation – direct or indirect – and identified by a certification granted to additional feedstocks produced either through productivity improvements or from cultivation on abandoned or degraded land. An Implementing Act will further detail by 2021 the conditions of the low ILUC-risk certification. In a Delegated Act published in March 2019, the EU Commission classified the palm oil as the sole high ILUC-risk feedstock with more than 40% expansion on high carbon stock land ( vs. 8% for soybean) on the base of the current available data. Nevertheless, there is a certain uncertainty on the final use of palm oil in bioenergy, as the details of the certification of low ILUC-risk feedstocks are unknown before the publication of the Implementing Act (2021), and as the Delegated Act himself will be reviewed in 2021 and 2023.
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REVIEW
The European Energy Policy for 20202030
RED II: what future for vegetable oil as a source of bioenergy?
Philippe Dusser
*
Ex-AVRIL, Paris, France
Received 12 July 2019 Accepted 2 October 2019
Abstract The support for vegetable oils biodiesel is dened by the Renewable Energy Directive (RED).
After three years of negotiations, RED II (recast of the 20102020 RED I) has been adopted and published in
December 2018. RED II sets the framework for the EU renewable energy policy for 20212030. Although
RED II gives a priority to advanced biofuels and electricity in transport with specic targets and multipliers.
For crop-based biofuels as vegetable oil biodiesel, RED II offers the possibility to preserve the current
investments by giving the Member States the possibility to cap their consumption at the national 2020
consumption level (plus 1%) with maximum of 7%. With the idea to cut the link of crop-based biofuels with
deforestation, a change of approach on the ILUC issue is introduced by RED II with the denition of high
ILUC-risk feedstocks with a signicant expansion on land with high carbon stocks. The high ILUC-risk
feedstocks will be capped in each Member State at the 2019 level until 2023, and then progressively
eliminated by 2030. An exemption from these constraints is provided for to low ILUC-risk feedstocks not
linked to deforestation direct or indirect and identied by a certication granted to additional
feedstocks produced either through productivity improvements or from cultivation on abandoned or
degraded land. An Implementing Act will further detail by 2021 the conditions of the low ILUC-risk
certication. In a Delegated Act published in March2019, the EU Commission classied the palm oil as
the sole high ILUC-risk feedstock with more than 40% expansion on high carbon stock land (vs. 8% for
soybean) on the base of the current available data. Nevertheless, there is a certain uncertainty on the nal
use of palm oil in bioenergy, as the details of the certication of low ILUC-risk feedstocks are unknown
before the publication of the Implementing Act (2021), and as the Delegated Act himself will be reviewed
in 2021 and 2023.
Keywords: Renewable Energy Directive (RED II) / biofuels / biodiesel / indirect land use change (ILUC) / Delegated
Act / high ILUC-risk / low ILUC-risk / palm oil / deforestation
Résumé La politique énergétique européenne pour 20202030. RED II : quel avenir pour lhuile
végétale comme source dénergie renouvelable ? Le soutien au biodiesel dhuiles végétales est déni par
la Directive sur les énergies renouvelables (RED). Après trois ans de négociations, la Directive RED II, qui
prend la suite de RED I (20102020) a été adoptée et publiée en décembre 2018. RED II dénit le cadre de la
politique de lUnion Européenne en matière dénergie renouvelable pour 20212030. RED II afche une
priorité donnée aux biocarburants « avancés » (2
e
et 3
e
génération) ainsi quàlélectricité dans les transports :
ceux-ci bénécient de soutiens particuliers au travers des objectifs spéciques et des multiplicateurs
permettant de comptabiliser avec un facteur de 2, 3... 4 fois leur incorporation effective au regard des
objectifs. En ce qui concerne les biocarburants issus de cultures tel que le biodiesel dhuile végétale, RED II
ouvre la possibilité (mais pas la garantie) de préserver les investissements actuels, en plafonnant leur
utilisation dans le cadre de plafond nationaux xés par États membres au niveau de leur consommation 2020
(plus 1 %) avec un maximum de 7 %. RED II renforce la durabilité des biocarburants issus de cultures en
organisant lélimination dici 2030 de ceux qui sont liés à la déforestation qui sont dénis dans une nouvelle
catégorie de matières premières à « haut risque de changement daffectation des sols indirect » (haut risque
de CASI ou high ILUC-risk) dont lexpansion au niveau mondial sest produite sur des terres à stocks élevés
Contribution to Topical Issue Biodiesel / Biodiesel.
*Correspondence: philippe.dusser@outlook.com
OCL 2019, 26, 51
©P. Dusser, Hosted by EDP Sciences, 2019
https://doi.org/10.1051/ocl/2019040
Oilseeds & fats Crops and Lipids
OCL
Available online at:
www.ocl-journal.org
This is an Open Access article distributedunder the terms of the CreativeCommons Attribution License(https://creativecommons.org/licenses/by/4.0), which permits
unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.
de carbone. Avant leur élimination progressive à partir de 2023 jusquen 2030, une période transitoire de
2020 à 2023 prévoit le plafonnement national au niveau de consommation 2019 des matières premières à
haut risque de CASI. Une exemption est prévue pour une partie de ces matières premières dans le cadre
dune certication de « faible risque de CASI » (low ILUC-risk). Les matières premières certiées doivent
démontrer quelles nont pas entrainé de déforestation directe ou indirecte, quelles proviennent soit dune
amélioration de la productivité, soit de la culture de terres abandonnées ou dégradées. Un acte dexécution
attendu dici 2021, doit clarier les conditions précises de la certication. Un Acte Délégué de la
Commission (mars 2019), a classé la seule huile de palme dans la catégorie haut risque de CASI en raison
dun niveau de plus de 40 % dexpansion sur les terres riches en carbone (contre 8 % pour le soja).
Cependant une certaine incertitude demeure sur la manière dont sera effectivement encadrée lutilisation
dhuile de palme dans les biocarburants : elle dépend en effet de lActe dExécution sur la certication
« faible risque-CASI » (2021) et des révisions prévues de lActe Délégué, en 2021 et 2023.
Mots clés : Directive sur les énergies renouvelables (RED II) / biocarburants / biodiesel / changement dutilisation des
sols indirect (CASI/ILUC) / Acte Délégué / haut risque de CASI / faible risque de CASI / huile de palme / déforestation
RED II After a 3 years negotiation, the Directive nally
allows the stabilization of the crop-based biofuels consump-
tion for 20212030.
The RED II Directive 2018/2001 on the promotion of the
use of energy from renewable sources (recast of the previous
Directive (RED I) adopted in late 2008 for the period 2010 to
2020) has been adopted the 11th December 2018 and sets the
framework of the renewable energy policy for the period
20212030. The Member-States must have transposed the
RED II in national legislation by the end of June 21.
The Renewable Energy Directive which denes the policy
for biofuels in transport crucial for the outlet of vegetable oils
in Biodiesel has a much broader perspective as it addresses
the use of renewable energy in all sectors: electricity (RES-E),
heating and cooling (RES-H&C), and transport (RES-T).
In the RED II debates, the crop-based biofuels issue has been
intensely negotiated by the co-legislators (Parliament and
Council):
The original proposal from the Commission (Novem-
ber 2016), only provided targets for advanced biofuelsand
renewable electricity (6.8% of which 3.6% for advanced). On the
contrary, the crop-biofuels already limited since 2015 to a
maximum cap of 7% (ILUC Directive) were to be phased down by
half with a country cap of 3.8% in 2030 (nota:rst drafts from the
Commission even envisaged a total phase-out of crop-biofuels).
In the EU Council, countries had different approaches:
some were very opposed to rst generation biofuels, but the
majority decided to keep the RED I main framework as
amended just two years before by the 2015 ILUC Directive.
The CouncilsGeneral approachof December 2017 provid-
ed a specic transport target of 14% (raising the ambition from
the 10% of the RED I), maintained the crop-biofuels cap at 7%;
with regards to advanced biofuels, as most countries found the
targets difcult to reach, the Council provided high multi-
pliersto reduce the effective obligation.
In the EU Parliament, the negotiation of a position was
extremely intense between political groups, as well as complex
due to the number of committees involved: two responsible
committees (ITRE for the global report and ENVI for the
biofuels), and approximately 10 other committees for opinion
(among which AGRI):
The Greens (with MEP Bas Eickhout as rapporteur in the
European Parliaments Environment Committee ENVI
responsible for biofuels) defended extremely negative
positions against crop-based biofuels, getting the ENVI
Committee to vote for a total phase-out of crop-based
biofuel (0% in 2030) and immediate elimination of palm
oil as a feedstock in 2021, while providing an accounting of
ILUC gures in the GHG balance sheet;
The MEP supporting EU agriculture in the Parliament,
under the lead of the EPP (European Peoples Party),
argued in favor of the biofuels issued from EU agriculture,
and fought for an exemption for highly sustainable crop-
based biofuelsdened as co-producing protein, thus
mitigating the EU protein decit;
The nal position of the Parliament (January 2018) retained
the concept of a general transport target (12%), a
compromise position on crop-based biofuels setting the
capforeachcountryat the level reachedin2017,andaradical
positiononthepalm oil with animmediatephase-out in 2021.
The nal compromise was reached by the co-legislators
(Parliament and Council) in June 2018, eventually adopted in
November and published by the Commission inDecember 2018.
1 RED II targets and caps
RED II provides overall targets for renewable energy, a
specic support to advanced biofuelsand electricity in
transport, and a capping of crop-based biofuels.
The main dispositions are the following:
1.1 A global and a transport target
An overall target of 32% for renewable energy in the
energy mix (against 27% in the original proposal);
a transport target of 14% (against no target in the
Commissions proposal, and 10% in RED I).
1.2 Capping the crop-based biofuels
1.2.1 A cap of 7%
A cap for crop-based biofuels is imposed in each Member
State at 2020 consumption level plus 1 percentage point with
a maximum of 7% providing an optional minimum of 2%
for countries that didnt reach 2% consumption in 2020 (the
original proposal cut by half the current 7% cap to 3.8%).
Nevertheless, Member States have options to lower the cap
or differentiate feedstocks:
Page 2 of 9
P. Dusser: OCL 2019, 26, 51
proportionality option: for caps lower than 7%, Member
States can reduce proportionally the 14% transport target;
ILUC differentiation option: based on ILUC gures
(unchanged from RED II) Member states have the option
to introduce different caps for the various crop-based
biofuels (oil-feedstocks vs. starch or sugar);
1.2.2 Phasing out high ILUC-risk feedstocks
High ILUC-risk feedstock(such as palm oil) will be
subject to a sub-cap (under the 7% crop-based cap) at the 2019
consumption level from 2021 to 2023 and then phased-out to
0% by 2030.
High ILUC-risk feedstocks are dened as those for which
a signicant expansion of the production area into land with
high carbon stockis observed (Fig. 1).
Low ILUC-risk feedstocksare exempted from this
constraint. They are dened as additional feedstock causing no
or minor ILUC as they result from productivity improvement
(beyond what is expected without existence of the RED
directive incentive) or produced on areas which were
previously not used for cultivation of crops(Fig. 1).
A Delegated Act requested by RED II from the
Commission to dene the feedstocks for which a signicant
expansion is observed, as well as the relevant criteria for low
ILUC-risk certication.
These denitions will be reviewed and adjusted by June
2021 before the entry into force of the Directive, and at the
occasion of the 2023 review.
1.3 Targets and limitations within the 14% transport
target
Within the 14% transport target there are:
a specic target for the advanced biofuels (Annex IX part
A: lignocellulosic biofuels, algae...) of 3.5% in 2030 (0.2%
in 2022, 1% in 2025);
limitations for waste and residues (Annex IX part B: used
cooking oils, animal fats) are set at 1.7% (option for
Member States to set higher limit if they can prove the
availability of the supply).
1.4 Multipliers for accounting under the 14% target
feedstocks in both Annex IX part A & part B may count
double in the 14% target. Hence the effective use of
advanced (part A) may be as low as 1.75% (3.5%: 2) while
the part B effective limitation may be as high as 3.4%
(1.7% 2);
renewable electricity will count 4 times when used in road
transport and 1.5 times in rail;
renewable used in maritime and aviation may count
1.2 times.
2 The sustainability criteria
2.1 CO
2
savings
Higher CO
2
savings are required for the eligibility of
biofuels depending of the date of the plants:
Eligibility thresholds:
*50% for installation in operation before Oct 2015;
*60% after Oct 2015;
*65% after 1 Jan 2021;
*70% for electricity, heating & cooling after 2021 and 80%
after 2026;
the fossil comparator has been raised to 94 g CO
2
/MJ (vs.
83.8 g CO
2
/MJ in RED I).
2.2 Environmental criteria
Like in RED I, biofuels must not be produced from raw
materials originating from:
Fig. 1. High and low ILUC-risk feedstocks are accounted under the cap of food & feed crops.
Page 3 of 9
P. Dusser: OCL 2019, 26, 51
high biodiversity land as of January 2008;
high carbon stock land that changed use after 2008;
land that was peatland in January 2008.
The RED II introduces new sustainability criteria for
forestry feedstocks:
harvesting takes place with legal permits, not exceed the
growth rate of the forest;
biofuels and bioenergy from forest materials must comply
with requirements which mirror the principles contained in
the EU LULUCF regulation.
3 Form of support in Member States
Member States are free to choose the most suitable form
of support for renewables in transport, for example volume
mandates, energy mandates or GHG emission savings
targets.
While most countries have chosen national blending
mandates, Germany has introduced a different kind of
support through the introduction of GHG quotatargets
in 2015. RED II will allow these different schemes to
co-exist.
4 Timing of implementation and reviews
National Energy and Climate Plan(NECP) due by each
Member State must present a trajectory to reach RED II
targets. The Commission veries that the NECPs lead to
fullling the overall EU targets. Draft NECPs have been
presented in 2018, the nal versions must be sent by end of
2019.
Transposition of RED II by Member States is due by
June 31st, 2021.
In 2023: mid-term review:
both the 32% overall target and the transport 14% sub-
target may be increased (and not decreased);
denition of the trajectory for the elimination to 0% in
2030 for high ILUC-risk. Eventual modication of high
and low ILUC-risk.
In 2026 Commissions proposal for the post 2030
Renewable Energy policy (RED III).
Appendix A High and low ILUC risk: The
Delegated Act on high and low ILUC-risk
biofuels (EU 2019/807 13th March 2019)
1 High ILUC-risk biofuels
High ILUC-risk fuels are those produced from feedstock
with a signicant expansion into land with high carbon stocks
with the following cumulative conditions:
the global production area of the feedstock has increased
annually by more than 1% and 100 000 hectares after 2008.
more than 10% of such expansion has taken place on land
with high carbon stock.
The expansion is calculated with a formula which takes
into account factors that inuence the amount of GHG
emissions:
xhcs ¼xfþ2:6xP
PF ;
where,x
hcs
= share of expansion into land with high-carbon
stock;x
f
= share of expansion into land referred to in Article 29
(4)(b) and (c) of Directive (EU) 2018/2001;x
P
= share of
expansion into land referred to in Article 29(4)(a) of Directive
(EU) 2018/2001 including peatland;PF = productivity factor.
PF shall be 1.7 for maize, 2.5 for palm oil, 3.2 for sugar
beet, 2.2 for sugar cane and 1 for all other crops.
An Accompanying Report (COM 2019 142 nal) pro-
vides the data on which are based (cf. Tab. 1).
The 10% expansion on high C land level over which a
feedstock is classied as high ILUC-risk. This level is set as to
ensure that the emissions from land use change on high C land
doesnt negate the direct savings resulting from the fossil fuel
replacement by the biofuel. The report evaluates
1
it at 14%.
The expansion on high carbon stocks for several feed-
stocks.
According to the report data, and the formula, only palm oil
with an expansion gure of over 40% is classied as high
ILUC, while Soybean (with 8%), Corn (with 2.4%), and Sugar
Cane (with 2.3%), although expanding on forestland are under
the 10% threshold.
1
Accompanying Report (Page 12: Box 2: The impact of indirect land
use change on biofuel GHG emission savings).
If land with high stocks of carbon in its soil or vegetation is converted
for the cultivation of raw materials for biofuels, some of the stored
carbon will generally be released into the atmosphere, leading to the
formation of carbon dioxide (CO
2
). The resulting negative green-
house gas impact can offset the positive greenhouse gas impact of the
biofuels or bioliquids, in some cases by a wide margin.
The full carbon effects of such conversion should therefore be taken
into consideration for the purpose of indentifying the level of
signicant feedstock expansion into land with high carbon stock
resulting from biofuel demand. This is necessary to ensure that
biofuels lead to greenhouse gas emission saving. Using the results of
the GIS assessment, the average net loss of carbon stock when biofuel
feedstock replaces land with high carbon stock23 can be estimated in
about 107 tonnes of carbon (C) per hectare24. Spread over 20 years,
that amount is equivalent to a yearly emission of 19.6 tons of CO
2
per
hectare.
It should be noted that the GHG emissions savings also depend on the
energy content of the feedstock produced on the land each year. For
annual crops, except maize and sugar beet, the energy-yield can be
estimated at about 55 GJ/ha/y26. By combining both gures one can
estimate the land use change emissions associated to biofuels
production on deforested land at around 360 g CO
2
/MJ. By
comparison, the emissions savings resulting from replacing fossil
fuel with biofuels produced from these crops can be quantied in
about 52 gCO
2
/MJ27.
Given these assumptions, it can be estimated that the land use change
emissions will negate the direct GHG savings resulting from fossil
fuel replacement when biofuel crop expansion into land with high-
carbon stock reaches a share of 14% (52 g CO
2
/MJ / 360 g CO
2
/
MJ = 0.14).
Page 4 of 9
P. Dusser: OCL 2019, 26, 51
2 Low ILUC-risk biofuels
As explained by the Commissioner Cañete: Fuels are
considered as low ILUC-risk only if produced from
additional feedstock produced on a delineated area that is
the direct result of applying an additionality measure. Only
measures that are nancially attractive because they allow to
reap the nancial premium arising from such certication
are eligible and eligibility of measures is limited to a period
of 10 years.
There is an exemption to prove the nancial criterion:
for the small holders (cultivating on less than 2 ha and
being independent from big plantations);
as well as for the production coming from abandoned and
degraded land;
the certication of low-ILUC-risk will be audited by
voluntary schemes.
3 Monitoring and review of the Delegated Act
The Commission will by June 30th, 2021 review all
relevant aspects of the report on feedstock expansion, in
particular the data on feedstock expansion, as well as the
evidence on the factors justifying the smallholders
provision, and, if appropriate, amend this Regulation. This
revised report shall be submitted to the European
Parliament and the Council and become the basis for the
application of the criteria set out in Article 3.
The Commission shall review thereafter the data included
in the report considering evolving circumstances and latest
available scientic evidence:
a further review of the criteria set out in this Delegated Act
is foreseen by the RED II for September 1st, 2023.
an implementing act laying out the details for certication
of low ILUC-risk biofuels is currently under preparation
by the Commission and is expected to be published
before 2021.
4 The Delegated Act is criticized by all
sides by palm producers as well as
by anti-palm NGOs
The Delegated Act on ILUC-risk biofuels was closely
followed and harshly debated with radically opposite views on
the one hand by the palm oil producing countries and by the
NGO and the EU Agricultural Organisations on the other.
Palm oil producing countries (Indonesia, Malaysia, Colum-
bia) have declaredthat they will le a complaintbefore the WTO.
Environmental NGOs, after a strong lobby to strengthen
the conditions of the low ILUC-risk exemptionare still
not satised by the fact that soybean is not classied as high
ILUC-risk.
EU agricultural producers see in the ILUC-risk approach as
a positive move as it cuts the link between crop-based biofuels
and the deforestation, putting the pressure on feedstocks
directly responsible, and allowing for a mitigation of ILUC
overall. Nevertheless, they are still concerned by the
exemptions of the low ILUC-risk as they see many loopholes
which may allow high ILUC-risk coming by the back door.
The EU Commission, under the diplomatic pressure of
South-East Asian Countries, has always been reluctant to
take too strong a stance against palm oil use in biofuels. It is
only under the pressure of the European Parliament and
obliged by the political agreement reached by the co-
legislator, that the Commission delivered the regulation set
by the Delegated Act.
Appendix B Palm: a controversial feedstock
1 The palm issue
1.1 ILUC: the palm oil expansion is responsible for
the ILUC gures of all other vegetable oils biofuels
The palm oil issue has constantly negatively impacted the
debate on biodiesel and vegetable oil use as feedstock for
Table 1. Feedstock expansion on high carbon land. (Source: Commission Delegated Regulation (EU) 2019/807 of 13 March 2019).
Expansion/an
since 2008
Share expansion on high C land (%) Expansion on high C land (%)
kha % Forest Wetland Formula
Art. 29(4)b & (4)c Art. 29(4)a
x
f
x
P
x
hcs
=(x
f
þPF x
P
)/PF
Coef. x
P
2.6
Wheat 263.4 0.1 1.0 1.0
Mais Coef. PF 1.7 4027.5 2.3 4.0 2.4
S. Cane Coef. PF 2.2 299.8 1.2 5.0 2.3
S. Beet Coef. PF 3.2 39.1 0.9 0.1 0.0
Colza 301.9 1.0 1.0 1.0
Palm Coef. PF 2.5 702.5 4.0 45.0 23.0 41.9
Soya 3183.5 3.0 8.0 8.0
Sunower 127.3 0.5 1.0 1.0
Page 5 of 9
P. Dusser: OCL 2019, 26, 51
bioenergy. The very rapid development of the palm oil
production in South-East Asia, is associated with important
GHG emissions as it is linked to a rapid and very signicant
deforestation, occurring for 50% on peatland releasing
high quantities of CO
2
in the atmosphere. Furthermore, the
loss of biodiversity from the destruction of the primary
forest by expanding palm oil plantations leads to more
criticism.
Although the expansion of the palm production is driven
by the demand for food, and that less than 20% is used for
energy in the world (13 million tons vs. 74 million tons
total production), the high carbon impact of the palm oil
expansion weighsonILUCguresof all other vegetableoil.The
indirect emissionsaccounted in the ILUC econometric
model for vegetable oils used for bioenergy are based on the
assumption that it must be replaced on the world food
market by an increased palm oil production. In the various
ILUC models, the palm oil very high GHG emissions explain
that ILUC gures of all other vegetable oils biofuels are higher
than those of other biofuels feedstocks as starch and sugar (used
for ethanol).
Nevertheless, concerning rapeseed biodiesel, even with the
indirect burden from palm oil on its own ILUC gures, the
most recent models (GTAP and Globiom) nd ILUC gures
for rapeseed biodiesel that are 4 to 5 times lower than that of
palm oil (Fig. 2).
Fig. 2. ILUC emissions Various models results by feedstocks.
Whats more, the Globiom study has shown that the
deforestation and peatland drainage was responsible for
almost the entire ILUC: a simulation on the Energy mix
2020shows an global ILUC gure reduced from 97 g CO
2
/
MJ to 4 g CO
2
/MJ if there were no peatland drainage and the
deforestation rate were low (Tab. 2).
2 Palm oil use in the EU biodiesel
production has been growing these last
5 years, linked to development of HVO
capacities
Another issue with the palm oil use in EU biofuels is
although it is yet by far not the major feedstock, its share has
been increasing over the latter years: every increase of the EU
biodiesel since 2015 has been via palm oil use.
This is linked to the development of the technology of
hydrotreated vegetable oil (HVO) through investments
generally made by the major Oil Companies.
While classical biodiesel produced with the esterication
process(vegetable oil methyl ester) doesnt allow for using
more than an EU level average of 15 to 20% of palm oil for
quality issue (winter grade the palm turning solid at low
winter temperature), the HVO eliminates this constraint as the
process ( under high temperature and pressure) produces a fuel
similar to fossil fuel.
The development of HVO plant capacities, which may use
indistinctly any vegetable oil, and hence run on lower priced
palm oil and palm oil products (PFADs), triggered an increased
quantities of palm oil and products in biofuels (biodiesel and
bioethanol) with a share raising from 15% to 2530% of the
total in a few years (Fig. 3).
3 The new approach of ILUC through
ILUC-risk biofuelswill help to mitigate
ILUC overall and improve the sustainability
of biofuels
Moving from an ILUC concept to an ILUC risk feedstock
approach puts the pressure on the very source of the ILUC. It
will encourage the palm producing countries to improve the
sustainability of their palm production, and act against
deforestation.
Table 2. ILUC models results for Energy mix 2020 for various
scenario.
Scenario Globiom
(g CO
2
/MJ)
IFPRI
Mirage (g CO
2
/MJ)
Energy mix 2020 97 38
Deforestation
Low
Very low
87
48
No peatland drainage
þvery low deforestation
4
Page 6 of 9
P. Dusser: OCL 2019, 26, 51
Appendix C EU Biodiesel: originally an
alternative to mandatory set aside and a
way to unlocking the production of local
protein
1 The history of biodiesel in the EU: how did
everything start?
1992: EU mandatory set-aside in the framework of the
Common Agriculture Policy (CAP) to address agricultural
production surplus and regularly depressed global prices;
the non-food production on these set-aside lands allowed
the production of proteins and biodiesel to reduce the need
to import it, maintaining the producers revenues while
simultaneously controlling the supply of cereals;
2003: Directive 2003/30/EC on the promotion of biofuels,
setting a voluntary objective of 5.75% renewable energy in
transport for 2010;
2003: Directive 2003/96/EC restructuring the taxation of
energy products and electricity, giving a common EU legal
basis for the tax exemptions for biofuels (although limited
in time up to 2020) especially important for Germanys
restructuring of its own national legislation;
2009: RED I (2009/28/EC) the Renewable Energy
Directive, setting a 10% target of renewable energy in
transport for 2020, aiming at reducing GHG emissions,
enhancing EU Energy independence and supporting the
EU agricultural sector;
20132015: debate around the ILUC Directive (2015/
1513/EC) which impacted negatively the perception of the
biofuel sector and led to a shift in the European biofuel
policies towards advanced biofuels and electrication. EU
production did not progress since then. Crop-based
biofuels have been capped at 7% in all member states;
20162018: debate on the recast of the Renewable
Energy Directive is dominated by the palm oil issue.
RED II (2018/2001/EC) compromise allows for stabilisa-
tion of biodiesel and plans the elimination of palm oil by
2030. After intense negotiations, the cap of crop-based
biofuels for each member state is maintained at the
consumption level of 2020, with a maximum of 7%,
allowing the prospect of a stabilisation of biodiesel.
The debates on ILUC as well as on palm oil are concluded
by the introduction of a category of ILUC-risk feedstocks
dened as those with a signicant expansion on high carbon-
stock land which will be progressively eliminated by 2030 a
Delegated Act has determined that palm oil as the only
feedstock classied as such. RED II thus cuts the link of crop-
biofuels with the deforestation and effectively mitigates the
risk of ILUC.
In parallel, the only targets provided by RED II are
specically directed at second generation biofuels and
electricity, conrming the direction of the energy policy
toward advanced biofuels and e-mobility.
Appendix D Biodiesel EU Rapeseed EUs
protein decit
1 The bioenergy outlet is crucial for the
EU oil and protein sector and specially
for EU rapeseed
Rapeseed is the major oilseed involved in bioenergy, as
around 70% of EU rapeseed oil is used in biodiesel production
(Fig. 4).
Today, the production of the rapeseed is closely linked to
the demand for biodiesel which historically has supported the
growth of EU rapeseed area: from the early 1990s with the
cultivation on set-aside, to the blending mandates introduced
since the mid 2010s that triggered a doubling of the rapeseed
production since 2004 (Fig. 5).
Fig. 3. Feedstock shares in EU biodiesel. (Source: Oilworld).
Page 7 of 9
P. Dusser: OCL 2019, 26, 51
Fig. 4. Rapeseed oil use in food, biodiesel & industry EU 28. (Source: Oil World & Avril).
Fig. 5. Rapeseed area evolution in EU28, in former & new Member States.
Page 8 of 9
P. Dusser: OCL 2019, 26, 51
It is important to underline the protein co-production
linked to the development of the rapeseed production (around
60% of rapeseed meal co-produced for 40% rapeseed oil), and
to remember the major contribution of rapeseed and other
oilseeds to mitigating the EU protein decit (Fig. 6).
Appendix E Rapeseed biodiesel: a major
contribution to the Renewable Energy in EU
According to the 2019 Renewable Energy Progress report
(COM 2019 225 nal), in 2016 biodiesel represented 80% of
the renewable energy from biofuels consumed in the European
Union (11 Mtoe vs. 13.8 Mtoe). As vegetable oils in 2016 made
up to around 70% of it, and used cooking oil and animal fats
another 26%, rapeseed oil was still the major feedstock with
around 45%, while palm oil reached 20% (to which could be
added palm products as PFAD not clearly registered for around
5% to 7%) and soy oil for less than 5%.
References
Accompanying Report. 2019. COM(2019) 142 nal: Report on the status
of production expansion of relevant food and feed crops worldwide.
Availablefrom https://ec.europa.eu/transparency/regdoc/rep/1/2019/
EN/COM-2019-142-F1-EN-MAIN-PART-1.PDF.
Delegated Act Commission Delegated Regulation (EU) 2019/807.
2019. Commission Delegated Regulation (EU) 2019/807 of 13
March 2019 supplementing Directive (EU) 2018/2001 of the
European Parliament and of the Council as regards the determina-
tion of high indirect land-use change-risk feedstock for which a
signicant expansion of the production area into land with high
carbon stock is observed and the certication of low indirect land-
use change-risk biofuels, bioliquids and biomass fuels. Available
from http://data.europa.eu/eli/reg_del/2019/807/oj.
Directive 2003/30/EC. 2003. Directive 2003/30/EC of the European
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the use of biofuels or other renewable fuels for transport.
Available from https://eur-lex.europa.eu/legal-content/EN/TXT/
PDF/?uri=CELEX:32003L0030&from=EN.
ILUC Directive (EU) 2015/1513. 2015. Directive (EU) 2015/1513 of
the European Parliament and of the Council of 9 September 2015
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legal-content/EN/TXT/?uri=CELEX%3A32015L1513.
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Fig. 6. EU rapeseed biodiesel vs. EU protein imports.
Cite this article as: Dusser P. 2019. The European Energy Policy for 20202030 RED II: what future for vegetable oil as a
source of bioenergy?. OCL 26: 51.
Page 9 of 9
P. Dusser: OCL 2019, 26, 51
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Directive (EU) 2015/1513 of the European Parliament and of the Council of 9 September 2015 amending Directive 98/70/EC relating to the quality of petrol and diesel fuels and amending Directive 2009/28/EC on the promotion of the use of energy from renewable sources (Text with EEA relevance)
  • Iluc Directive
ILUC Directive (EU) 2015/1513. 2015. Directive (EU) 2015/1513 of the European Parliament and of the Council of 9 September 2015 amending Directive 98/70/EC relating to the quality of petrol and diesel fuels and amending Directive 2009/28/EC on the promotion of the use of energy from renewable sources (Text with EEA relevance). Available from https://eur-lex.europa.eu/ legal-content/EN/TXT/?uri=CELEX%3A32015L1513.
Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of the use of energy from renewable source
  • Red Ii - Directive
on the promotion of the use of energy from renewable sources and amending and subsequently repealing Directives 2001/77/EC and 2003/30/EC (Text with EEA relevance)
  • Red Ii -Directive
RED II -Directive (EU) 2018/2001. 2018. Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of the use of energy from renewable source. Available from https://eur-lex.europa.eu/legal-content/ EN/TXT/?uri=uriserv:OJ.L_.2018.328.01.0082.01.ENG. The Renewable Energy Directive (2009/28/EC -RED I). 2009. Directive 2009/28/EC of the European Parliament and of the Council of 23 April 2009 on the promotion of the use of energy from renewable sources and amending and subsequently repealing Directives 2001/77/EC and 2003/30/EC (Text with EEA relevance). Available from https://eur-lex.europa.eu/LexUr iServ/LexUriServ.do?uri=OJ:L:2009:140:0016:0062:en:PDF.