The CO2 savings provided by sustainable biofuels They have become one of the hot topics of the European climate debate. While the technology is available and widespread on the market, the EU regulatory framework offers very limited recognition of its real contribution to the decarbonization of transport.
In this context, APPA Renovables, the leading voice of clean energy in SpainThe association has intensified its pressure to ensure that these savings are fully factored into emissions targets for new passenger cars and vans. The association believes that the rules proposed by the European Commission fall short and fail to take advantage of a tool that could already be reducing emissions much more ambitiously.
What the sector is asking for regarding CO2 savings from biofuels
APPA Renovables' position stems from a simple idea: each ton of CO2 avoided thanks to sustainable biofuels, it must be fully accounted for in the European targets for reducing road transport emissions. And, moreover, it must do so now, without waiting more than a decade.
Specifically, the association claims that CO2 emission savings derived from the use of sustainable biofuels and other renewable fuels can be used without restrictions to meet the targets set in Regulation (EU) 2019/631, which regulates emissions from new passenger cars and light commercial vehicles in the European Union.
This would imply that carbon-neutral renewable fuelsWhen used in cars and vans, these fuels would directly contribute to lowering the average emissions that manufacturers must meet. For the sector, this represents taking advantage of a solution already deployed at gas stations, eliminating the need to wait for the entire fleet to be electric.
APPA's request has been formally forwarded to Ministry for the Ecological Transition and the Demographic Challenge (MITECO) within the framework of the public consultation on the amendment to the European emissions regulation. The objective is to influence the position that Spain will defend in the negotiations in the Council and the European Parliament.
The European Commission's proposal: loans and strict limitations
The European Commission has proposed introducing a credit system for sustainable biofuels and other renewable fuels in Regulation (EU) 2019/631. The idea is that the CO2 savings over the life cycle of these fuels will serve to offset some of the emissions from new vehicles.
According to the proposed text, only from 2035 These savings would begin to be counted, and with a very tight limit: at most 3% of the CO2 emissions of the reference year 2021In other words, even from that date onwards, the contribution of biofuels would be limited to a small portion of total emissions.
The proposal also excludes from the calculation first-generation biofuels (produced from conventional agricultural crops) and limits to 1% the contribution of biofuels made from certain waste listed in Part B of Annex IX of the Renewable Energy Directive (DER III), such as used cooking oil.
If applied as written, The regulations would exclude or barely allow a small portion to be counted. of the biofuels that today meet the sustainability criteria of the European renewables directive itself, despite their ability to reduce transport emissions.
Why the sector considers the recognition of CO2 savings insufficient
For APPA Renovables, the Commission's approach means, in practice, postponing the decarbonization potential of biofuels until well into the 2030sThe association argues that delaying the calculation to 2035 and setting a 3% ceiling almost completely eliminates the effectiveness of a mechanism that could be serving climate objectives from now on.
The president of APPA's Biofuels section, Álvaro Mitjans, admits that the community initiative It is a step in the right direction by recognizing these savings for the first time.However, he emphasizes that it does so in such a limited way that its real impact would be very small. In his opinion, all time and quantity limits should be eliminated.
The sector argues that Sustainable biofuels are already generating tangible CO2 savings In cars and vans, by directly replacing fossil fuels in the tanks. The fact that these savings are not fully reflected in official emissions reports, the association argues, underestimates their climate contribution.
Furthermore, the exclusion of first-generation biofuels and the additional restriction on those produced from waste included in Part B of Annex IX of DER III are considered limitations lacking a solid technical justificationThese products are already subject to sustainability and monitoring criteria in European regulations, so their ban or significant reduction is perceived as inconsistent.
The role of first-generation biofuels and waste
One of the most controversial points of the community's approach is the total exclusion of first-generation biofuels from the credit systemThese are biofuels made, for example, from oilseed crops, cereals or sugars, which have been the basis of the initial development of the sector in many European countries.
For APPA Renovables, leaving these technologies out means unnecessarily cutting a significant part of the CO2 saving potentialprecisely at a time when the European Union needs to accelerate its energy transformation to meet climate commitments.
The other major restriction concerns biofuels produced from certain waste materials listed in Part B of Annex IX of the RED III. These include materials such as used cooking oil, which is already commonly used in the manufacture of biodiesel and other advanced biofuels.
The Commission argues that, even while complying with the renewables directive, the contribution of these biofuels made from waste is limited to 1% in the calculation of CO2 savings for light transport. The Spanish association rejects this limitation, considering that it penalizes solutions that, in addition to reducing emissions, help to valorize waste that would otherwise be more complex to manage.
Zero-emission vehicles powered by renewable fuels
Beyond simply accounting for CO2 savings, the sector is proposing a significant change in how vehicles are classified. APPA Renovables argues that Cars and vans with combustion engines approved to run exclusively on sustainable biofuels or other CO2-neutral renewable fuels should be officially considered as "zero emission" vehicles.
The technical reasoning is that The CO2 emitted from the exhaust pipe of these vehicles is equivalent to that absorbed by the biomass during its growth.so the net balance of emissions into the atmosphere is neutral. It's not about eliminating the physical emissions from the exhaust, but about ensuring that those gases had already been captured beforehand.
Recognizing these vehicles as zero-emission would have direct implications for the automotive industry: This would open an additional avenue for meeting fleet CO2 limits. beyond pure electrification, incorporating advanced thermal engines powered solely by certified renewable fuels.
According to the industry, this option would offer greater technological and cost flexibilityby allowing the combination of battery electric vehicles, plug-in hybrids and combustion models powered by sustainable biofuels, while still maintaining the decarbonization path required by European regulations.
Impact on climate goals and the European energy transition
The discussion about how to account for CO2 savings from biofuels is not an isolated legal debate, but rather It directly affects the decarbonization strategy for transport in Europe.The automotive and logistics sectors account for a substantial portion of emissions, and their transformation is one of the most complex challenges of the energy transition.
For APPA Renewables, A broader recognition of sustainable biofuels would accelerate emissions reductions in the short and medium term, taking advantage of the existing infrastructure and without waiting for the complete renewal of the vehicle fleet.
The association insists that renewable fuels should not be seen as rivals to electrification, but as a complementary tool that can provide additional reductions in segments where full electrification is still complicated, such as certain delivery vans or vehicles that travel many kilometers per year.
In parallel, the development of these fuels favors the technological and energy supply diversificationThis reduces dependence on imported fossil fuels and improves the resilience of the European energy system. For a country like Spain, with a large renewable energy business sector, this also means industrial and employment opportunities.
Spain's position and the weight of the renewable sector
APPA Renovables wanted to guarantee that Spain's position in European negotiations reflects the importance of biofuels. in the transport decarbonization strategy. For this reason, it has actively participated in the MITECO consultation on the emissions regulations for passenger cars and vans.
The organization, founded in 1987, brings together more than 500 companies and entities linked to renewable energies In Spain, this includes everything from biofuels, biogas, and biomass to wind, hydropower, self-consumption, and solar photovoltaics. Its role as an intermediary with government agencies allows it to channel the sector's vision into regulatory frameworks.
Within that vision, the full and immediate accounting of CO2 savings from biofuels This is considered key to ensuring that European regulations are consistent with technological realities and climate objectives. The association points out that these fuels already have sustainability certifications and traceability schemes that allow for verification of their environmental contribution.
The debate now opening in the Council and the European Parliament will determine if the Union chooses to take full advantage of these emissions savings or if, on the contrary, it maintains a more restrictive approach that limits its recognition to a reduced proportion and in a distant time horizon.
Overall, the discussion on CO2 savings from biofuels under Regulation (EU) 2019/631 reflects the tension between the available technical potential and the safeguards of the regulatory designThe Spanish renewable energy sector argues that opening the door more decisively to these fuels, without delays or such strict limits, would allow for faster emissions cuts, diversification of solutions, and a strengthening of Europe's role in an energy transition that cannot wait until 2035 to take advantage of all the tools already available.
