Proposal for ReFuelEU:
November 2022
Animal fats category 3 are not suitable for Sustainable Aviation Fuels – Views of the Oleochemical, Pet Food and Animal Feed industries
The European associations representing the Oleochemicals, Pet Food and Animal Feed industries welcome the efforts to decarbonise the aviation sector. We support the original proposal by the European Commission regarding the definition of eligible biofuels for sustainable aviation fuels (SAFs), and urge the co-legislators to revert to this original proposal.
Proposed changes will lead to shortages of animal fats category 3 for traditional users
Extending eligible sustainable aviation fuel (SAF) feedstocks beyond those listed in the Renewable Energy Directive Annex IX parts A and B will lead to significant shortages of animal fats category 3 for its traditional users. While the biofuels sector can thrive on other types of feedstock, the oleochemical, pet food and animal feed industries cannot function sustainably without access to sufficient quantities of animal fats category 3. An increase in demand, from any mode of transport, but in particular the aviation sector, would deviate animal fats category 3 from pet food, animal feed and oleochemical uses.
What are animal fats category 3?
Animal fats category 3 are highly valuable by-products from the animal processing industry (see page 3 for details). They can be used in a variety of applications, and have historically been used by the Animal Feed, Pet Food and Oleochemical Industries. They can only be sourced from Europe. Our sectors use rendered animal fats category 3 to manufacture various high-quality products, pet food and feedstuff, offering European bio- based solutions.
Why can we only source animal fats category 3 from Europe?
Animal fats from outside of Europe, cannot be used by our sectors due to stringent sanitary European rules regarding animal by-products.1 We are therefore dependent on animal fats category 3 produced in Europe. The availability of rendered animal fats category 3 is highly impacted by the declining meat consumption in Europe, the demand for animal fats category 3 for biofuel production has grown by 88% between 2018 and 2020.2
To feed pets and farm animals and to safeguard the European Oleochemical Industry exclude animal fats category 3 from eligible feedstocks for SAFs
We strongly support limiting the production of biofuel SAFs to feedstocks listed in RED II Annex IX A and B to ensure the aviation sector decarbonises on waste-based biofuel feedstocks. Animal fats category 3 are not waste. We appreciate the proposed time limit by the European Parliament, but during this transitional period our industries will struggle to access sufficient animal fats category 3. In light of the very limited availability of animal fats category 3, of about 2.54 MT per year, we urge the co-legislators and the European Commission in their trialogue negotiations to ensure that decarbonising the aviation sector does not sacrifice our industries.
You can download the full statement here.