EBB publishes position on how to strengthen EU industrial leadership in biobased SAF

The European Biodiesel Board published its policy priorities April 28 to accelerate investments, scale up production and increase the competitiveness of biobased sustainable aviation fuel (SAF) in the EU.

EBB represents European producers of biodiesel (FAME), renewable diesel (HVO) and biobased SAF produced via the hydroprocessed esters and fatty acids (HEFA) pathway.

The association stresses that maintaining the overall ambition of EU aviation-decarbonization policies is essential to ensure investment certainty and deliver emissions reductions, but that improvements can be made—particularly to the ReFuelEU aviation regulation.

SAF mandates trajectory

In its paper, EBB advocates for a framework that provides regulatory certainty for the years to come.

SAF production requires substantial upfront capital, long lead times and a stable framework to reach final-investment decisions (FID).

SAF projects are highly capital-intensive industrial undertakings, EBB noted.

Large jumps in the SAF mandate trajectory (such as from 6 percent in 2030-’34 to 20 percent in 2035) do not reflect the industrial reality of how SAF capacity is planned and developed, the organization stated.

“Therefore, the current five-year steps risk creating periods of temporary oversupply followed by abrupt compliance pressure, misaligning capacity and demand and complicating offtake planning,” EBB stated.

For this reason, EBB proposes to  complement the existing milestone five-year targets with a predictable and incremental annual trajectory.

This would not alter the overall ambition of the regulation, it said, but would create a smoother and more investable curve for both producers and airlines.

Beyond the minimum

To grant greater flexibility, EBB proposes to introduce what it calls the “SAF surplus and prefulfillment” mechanism within ReFuelEU in addition to an annual incremental increase of SAF targets.

Furthermore, the proposal touches on the EU Emissions Trading Scheme for aviation and how it can support EU-produced SAF uptake, on the need to address the risk of carbon leakage, and on the recognition of coproduction of electro SAF (eSAF) with biobased SAF.

It also stresses that the ambition and scope of the ETS aviation should be maintained, and provides ideas on how collected ETS revenues should be reinvested in the EU aviation sector.

Feedstocks paradox

In many applications of biofuels, including aviation, EBB said it observes a feedstock paradox.

“While the targets keep increasing—and rightly so—the EU’s feedstock-eligibility rules have become a patchwork,” EBB stated. “Instead, the Renewable Energy Directive, including its sustainability and greenhouse-gas emission-saving criteria, should be the only regulatory reference for feedstock eligibility.”

To download EBB’s position paper on biobased SAF, click here.