Ensuring Progress and Innovation in the Revision of RED Annexes V and VI
Read the full recommendations here.
Eurogas welcomes the opportunity to contribute to the public consultation on the revision of Annexes V and VI of the Renewable Energy Directive. Regular updates to these annexes are essential to ensure that the regulatory framework keeps pace with technological progress and innovation across the biofuels, bioliquids, and biomass fuels value chains. While Eurogas supports this objective, we would like to draw attention to some elements of the proposed revisions that could have negative repercussions in the market.
Recommendations concerning the proposed text for Annex V:
- Provide visibility to all co-products sold in the market
Recommendations concerning the proposed text for Annex V/VI:
- Recognise the better performance of electricity consumed in the liquid, solid or gaseous fuel supply chains
- Include methanol and Fischer-Tropsch liquid fuels in the list of recognised production pathways
Recommendations concerning the proposed text for Annex VI:
- Recognise all liquefaction pathways as viable enablers for decarbonisation
- Foresee an approach to co-digestion that allows biomethane producers the flexibility to choose between the averaging methodology and a feedstock-specific calculation
- Ensure that the eme,I factor accurately reflects the performance of best available technologies
- Clarify the meaning of Cstor factor in the GHG emissions calculation for biomass fuels
- Include a definition of biowaste aligned with the existing EU regulatory framework
- Ensure that typical and default values are applicable to all biogas/biomethane produced
- Distinguish between EU and third-country production in the accounting of the Etd factor
Clarifying questions for the European Commission:
- Clarify how solid and liquid biomass can be combined in Annex VI, Table A3, p.17
- Explain the rationale behind the inclusion of the new fossil fuel comparator for grid-injected biomethane
- Clarify the impact of the 75% conversion efficiency to heat and cold on existing provisions of Annex VI
Read the full recommendations below for more details:
