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Allowing a biofuels loophole in the EU 2035 cars law would bring total European demand to 2-9 times what can be sustainably sourced, new T&E research finds.
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The EU’s CO₂ regulation for cars is the backbone of Europe’s automotive climate and industrial policy and the key driver for the supply of zero-emission cars. Changing the law to allow biofuels would be a disaster – here’s why:
The shift from environmentally damaging crop-based biofuels to waste-based biofuels has maintained a high reliance on imports: Today, 60% of biofuels are imported from non-EU countries. For used cooking oil, >80% is imported.
Reliance on imports comes with growing concerns over fraud risks: Previous investigations by T&E strongly suggests that fraud is occurring. As demand from aviation and shipping grows and supply remains limited in Europe, dependency on imports will only grow, further increasing the risk and level of fraud.
The current EU biofuel mix is delivering limited to non-existent CO2 savings (only 20%-40% CO2e savings vs. fossil fuels on average), and potential waste oil fraud would erase any emissions savings achieved at all.
Limited biofuels can’t cover planes and ships, let alone cars: Allowing a biofuels loophole in the EU 2035 cars law would add 30% to aviation and shipping biofuel demand and bring total EU demand to 2-9 times what can be sustainably sourced.
Sustainable sources of waste feedstocks are extremely limited; e.g. a car running on animal fats would require the equivalent of 120 pigs a year while a car running on used cooking oil would need 25 kg of fries per day.
Allowing biofuels to count as CO2 neutral fuels would risk increasing 2050 emissions by up to 23%. Europe faces a decisive choice: to either lead the global BEV race or fall behind by diverting to false solutions.
Since 2009, EU policies promoting food-based biofuels as fossil-fuel alternatives have led to inefficient land use compared with solar power and EVs. Using farmland for fuel crops causes indirect land-use change such as deforestation, which undermines emissions benefits and increases pressure on food security
Despite 15+ years of favourable policies: ~7% of total road fuel demand in 2024
60% Percentage of biofuels imported from non-EU countries (used in IT, ES, DE, FR)
The EU has seen increased reliance on dubious imports, in particular from Asian countries
Alarming mismatches in UCO imports strongly suggesting fraud is occurring: In 2023, Malaysia exported three times more UCO that it can collect
High increase of EU imports of POME, a residue from the processing of palm oil, reaching a quarter of EU hydrotreated vegetable oil (HVO) in 2023
9% Percentage of International Sustainability and Carbon Certification (ISCC)-certified UCO collectors in China, Malaysia, and Indonesia verified through an on-site audit
~60% Typical CO₂ savings of food and feed biofuels, compared to fossil fuels. But emissions can exceed that of fossil fuels when accounting for indirect emissions like deforestation (ILUC)
Many new 'advanced' biofuels require advanced technologies not yet fully commercialised and without strict sustainability safeguards, these could also cause negative environmental impacts
20% CO2 savings of bio-based diesel vs. fossil fuels
40% CO2 savings of bioethanol vs. fossil fuels
20% of new cars running on advanced biofuels after 2035 could add 30% to the existing potential demand in 2050 from aviation and shipping
Keep biofuels out of the cars CO2 regulation: The EU must reject options that include biofuels in the car CO2 regulation (as carbon correction factor or post-2035 exemption) to protect the integrity of the car CO2 regulation and broader climate policy framework. If exemptions for ‘CO2-neutral fuels’ post 2035 are considered, they should be strictly limited: 5% sales cap, limited to vehicles powered exclusively by 100% climate-neutral e-fuels, with no biofuels allowed.
Prioritise advanced biofuels for hard to abate sectors like aviation & shipping: Projected availability of sustainable biofuels will not even be enough to decarbonise ships and planes. Any biofuels going in new cars will increase reliance on fraud-prone imports and even fossil fuels use.
Maintain 2030–2035 car CO2 targets and tailpipe approach Fake alternative like biofuels lead to regulatory ambiguity, undermine company, investor and consumer confidence, and put jobs and EV momentum at risk.
Car, aviation and shipping industries would require 2-9 times the advanced biofuels that can be sustainably sourced in 2050.
Priority must be placed on tackling bottlenecks in cross-border rail infrastructure and supporting domestic clean fuel production.
‘STIP’ diagnoses the problems for decarbonising planes and ships, but there is an urgency to act now, says T&E.
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