FEFAC considers that the capping of the contribution of crop-based biofuels to the renewable energy targets should remain in place as an effective instrument to mitigate the potential adverse effects of 1st generation biofuels linked to competition for land and water use while maintaining the availability of protein-rich co-products. Dual use crops such as rapeseed meal make a more positive contribution by providing protein-rich feed materials with a broad amino acid profile. The impact of future adaptations of biofuel-related EU policies on the EU protein supply should be assessed and monitored comprehensively, covering availability of EU protein sources, by using the recently published EU protein balance sheet at the upcoming EU market observatory on cereals and oilseeds.
On “advanced” or “2nd generation” biofuels, FEFAC is concerned with the listing of feedstocks that are suitable for feed and food use (such as molasses). The proposed blending obligation would provide a subsidized incentive distorting agricultural markets, while going against the principles of the waste hierarchy which prioritizes feed and food use over energy use.