Grow renewables by preserving the effective mass balance system

Read the letter below.

Eurogas, together with seven industry associations representing the EU renewable and low-carbon fuel value chain, welcomes the European Commission’s continued efforts to strengthen the EU sustainability certification framework for renewable and low-carbon fuels. A robust, trusted and practicable system is essential to achieving the Union’s climate and energy goals and ensuring a well-functioning market.

As discussions on the future implementation of sustainability certification and the definition of the post-2030 framework continue, including the ongoing review of Implementing Regulation (EU) 2022/9961, the foundational principles of the Renewable Energy Directive (RED), notably the mass balance system, must be preserved and built upon. Improvements to the framework must safeguard the pragmatism that has enabled renewable fuels to move efficiently through EU infrastructure while ensuring robust sustainability assurance and traceability.

Redefining the RED’s mass balance system could represent a total upheaval of the EU fuels market’s operations at a time when energy security and the competitiveness of the EU industrial base are key concerns, while providing no improvement in sustainability assurance downstream of a manufacturing facility. We therefore urge the Commission to preserve the core principles of the mass balance system. In particular:

• Product groups should continue to be defined by fuels with similar rather than identical characteristics.
• Existing provisions on the physical mixing of raw materials and fuels, as well as the allocation of sustainability attributes, should be maintained.
• Fuels in the same product group should remain eligible for mass balancing within the infrastructure and systems recognised under the RED framework.
• The current three-month mass balance period should be maintained
• The Commission should use this review to drive broader consistency across the framework.