???? EU | Multiple counting back in RED3

This article has been published on February, 21 2023 on our?platform.

The EC and Parliament (EP) wanted to get rid of it; multiple counting of waste-based biofuels and electricity is, however, on good track to come back in the final text. We picked other relevant themes as we follow the trilogues about RED3 and FuelEU Maritime.

Council insists on maintaining DC

We consulted the latest version of the RED3 draft being negotiated in Brussels. It now clearly mentions in the column “Draft Agreement” the version of the Council that maintains the RED2 multiplicator for waste-based biofuels (2), electricity supplied to the rail (1.5), and to the road (4). The use of multiplicators allows to inflate the renewable shares communicated by the MS, a practice logically praised by the Council executives.

On one hand, this status quo would be good news for the biofuels industry as it maintains the advantage of 9A+9B over crop, on which less pressure would apply to cut the cap.?On the other hand, the multiplicator 4 applied to road electricity is a massive threat to the survival of other compliance options. Without any cap or compensation mechanism (as it exists in Germany), the massive generation of electricity tickets could in the medium-term constitute a big hurdle to non-advanced biofuels growth.

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Exception for 1.7% 9B cap also back

The latest version of the draft reintegrates the Council version copy/past from RED2, allowing MS to modify the 1.7% e.c limit “taking into account the availability of the feedstock”. Few months after the EC proposed to increase the number of 9B feedstocks to a staggering 14, this outcome is logical: MS must optimize the use of available 9B to reach their decarbonization objectives.

Crucial other arbitrages on RED3 features have yet to be agreed upon regarding the main objectives, including the revision of the RED Article 25 with the 2030 share of renewable in transport. The EC proposed 13% GHG, the EP 16% GHG, and the Council 16% GHG + 29% e.c working in parallel. Also, the level of the advanced and RFNBOS targets by 2030 is still under negotiation. The EC proposed 2.2% and 2.6% (no DC for both), the EP 2.2% and 5.7% (no DC for both) and the Council 4% (with DC) and 5.2% (no DC).

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FuelEU Maritime at the same stage

A trilogue meeting occurred last Thursday about FuelEU Maritime but did not lead to significant progress. Positions are still frozen on the GHG reduction targets from 2025, sub-targets for RFNBOs. and the level of the penalties in case of non-compliance. There is no schedule available for the next meetings.