1st Plenary Meeting, 17th-18th November 2021, Online
Session 1: Lessons learned: RED1 experiences, opportunities and challenges and its influence on the RED2 implementation
The Netherlands will be the chair of the CT5 transport sessions for the upcoming period and started with the introduction of the new team. After that a representative of the European Commission provided an extensive update about the proposed revision of the RED II (RED III) in the Fit for 55 package and the state of play of the RED II implementation. The presentation of DG ENERGY was followed by an in-depth discussion and question and answer session to reach a common understanding of the complex provisions set out in the RED II, clarify on the status of the various acts and share information on the proposed revision in relation to other parts of the Fit for 55 package. This concerned in particular, targets and target calculation, feedstock-specific questions and sustainability certification guidelines. The session ended with sharing takeaways of experiences with RED I and the implementation of RED II. Member states discussed in breakout rooms on subjects that stood out in the responses to the questionnaire. This concerned, among others, cost efficiency, exchange of data (EU database), interpretation Annex IXA feedstocks.
Session 7: Promoting renewables in international mobility sectors (aviation/sea shipping/inland shipping); Interaction between sectors within the RED and possibly other (upcoming EU) legislation
This session focused on international sectors. Pioneer for sustainable aviation fuel SkyNRG gave a presentation about the role of aviation in the Dutch system, about the importance of renewables in aviation and their view on the effects the Fit for 55 package will have on the share of aviation fuels in the obligation and on feedstock usage. Consultancy bureau Studio Gear Up presented on the recent role of marine fuels as an opt-in in the Dutch obligation system and explained the specific characteristics for decarbonizing the maritime sector with regard to the Fit for 55 package. The session concluded with breakout rooms in which member states discussed their findings on the possibility of valuing marine and aviation fuels within the obligation. Although quite a few Member States have included international sectors in their national policies, only visions could be shared. It turned out to be too early to exchange experiences about implementation.
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2nd Plenary Meeting, 18th-19th May 2022, Online
Session 1: Possiblities for integrating electricity for transport into national systems to contribute to the national RED transport target
In the first session, the European Commission provided an update on recent policy developments regarding the REPowerEU Plan, a proposal to rapidly reduce dependence on Russian fossil fuels and fast forward the green transition. The presentation by DG ENERGY was followed by an in-depth discussion and a Q&A-session to reach a common understanding of the implications of REPowerEU for the use of renewable energy in mobility. Thereafter the session focussed in particular on targets and target calculation, and accounting renewable electricity. Three member states, Croatia, Luxembourgand Germany held presentations on their strategies for electrifying road transport. The discussion highlighted that most member states are still developing different policy instruments to stimulate electric mobility. During this discussion most attention went to the design of a crediting system for accounting renewable electricity in transport. Furthermore, several Member States indicated to need more clarification/guidance on how the use of renewable electricity can be attributed to the transport target.
Session 7: Assessing the possiblities and challenges to the incorporation of RFNBOs into national systems as contributor to the RED transport target
The second session of CT5 focused on RFNBOs in transport. The session started with an overview of the results from the questionnaire. Seventeen member states completed the questionnaire, which yielded interesting results. The presentation by DG ENERGY focussed on the increased RFNBO targets in the REPowerEU proposal to replace Russian fossil fuels and accelerate decarbonization. The presentation showed the need to ramp up RFNBO production. The presentation by the European Commission was followed by an extensive presentation from ISCC. In their presentation ISCC elaborated on the different trajectories that are currently in place to develop a certification system for renewable hydrogen. ISCC expects that in the coming years, renewable hydrogen will mainly be used as an intermediate product. The discussion made clear that the certification of renewable hydrogen and RFNBO can be developed quickly within Member States by voluntary schemes like ISCC, but no legal framework is set by RED II (yet?)
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3rd Plenary Meeting, 09th-10th November 2022, Greece, Athens
Session 1: Feedstock definitions and the effect on fuel availability
This CT5 session started with an informative presentation by a representative of the European Commission. This provided an extensive update on the recast of the REDII, the progress of the negotiations and ongoing work on REDII (a.o. update REDII Annex IX list, of which a draft proposal is expected before the end of the year). A subsequent presentation from Guidehouse on the assessment of EU27 reports on biomass use for 2020, revealed an EU wide growing use of Annex IX materials.
The presentations were followed by an Q&A-session and an in-depth discussion to share successes on the one hand and problems on the other regarding various feedstocks when implementing the REDII. It was striking that the outcome showed that there is need for more guidance on feedstock definitions and clear distinguishing criteria for both the feedstocks included in REDII Annex IX and intermediate crops to better unlock the potential. Concern was expressed about the possible consequences for different transport modes of the RED Annex IXB CAP within the FitFor55 package. A subject that awaits further developments.
Session 11: Joint Session CT5/TF-GO: Implemenation issues regarding streamlining data on (1) biofuels and (2) RFNBOs
This joint CT5/Task Force GO session focussed on implementation issues regarding streamlining data on (1) biofuels and (2) RFNBOs and started with an update by a representative of the European Commission on status, implementation and expected operation in practice of the Union Database (UDB). This was particularly important for Member States with a national transport fuel database, given the approaching implementation date (foreseen 1 January 2023) and the importance of a good connection of the national databases to the UDB. Discussions on both the UDB to support supervision by Member States on sustainability claims and on guarantees of origin (GOs) as an option to transfer renewability information on RFNBOs (including hydrogen) along the chain-of-custody, raised a lot of questions by Member States.
Participants strongly advised the European Commission and Member States to elaborate as soon as possible on: 1. interconnection of national databases (e.g. on different interpretations on feedstock, legal problems etc); 2. use, integration, timeline GO information on RFNBOs with GO bodies.
Session 15: Joint Session CT4/CT5: Verification of compliance sustainability biomass
This joint CT4/CT5 session was on supervision of certification bodies by Member States. A representative of the European Commission started this session with an update on voluntary schemes for forest biomass. Up till now 2 voluntary schemes are recognised by the commission.
Due to art 30-9 (RED) and art 17 (Implementing Regulation) the role of Member States with regards to supervision is going to change. Main questions listed on this topic were: 1. Certification Bodies (CBs) can ask which Member State is the lead-supervisor. How to appoint the lead-supervisor between Member States? 2. Who is supervising the CB when controlling raw materials from outside EU? 3. How to deal with differences between Member States with regards to energy mix (import/export/feedstock etc.)? These questions were already further elaborated upon by a task force consisting of several Member States. Results of the task force were presented an discussed on the basis of the following questions: 1. cooperate with REFUREC (group regulators of biofuels) on these issues? 2. What steps do require formal decision? 3. Who is the best party to do so? Participants concluded that cooperation between all Member States is preferred, for instance in CA-RES an via an EC Expert Group.
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4th Plenary Meeting, 24th-25th May 2023, Vienna
Session 1: EC policy update on transport related issues
The Commission started with a policy update on the revision of the RED. New targets are under negotiation for all modes of transport. Member States will be able to choose between either an energy-based or emissions-based target. In the presentation DGENER also provided more clarity on the new calculation methodology of GHG-savings including the maritime and aviation sectors. The aim of the system based on emissions-reduction, is to incentivize renewable energy that reduces the most CO2. Next, the Commission elaborated on the interplay between the RED and the FUEL-regulations and the different accounting rules. Finally, DGENER gave an update on the Delegated Acts concerning RFNBOs. More specifically, there were new insights on additionality, GHG-calculations and the procedure for recognition of voluntary schemes.
This presentation was followed by a Q&A and an in-depth discussion on several themes including the interplay between Fit-for-55 and RED, feedstock categorization, co-processing. There were also many questions regarding the Union Database and sustainability criteria, however there was no room during the session to discuss these. The outcome of this session makes clear that there is a need for more guidance, especially on the harmonization between RED and de FF55-regulations, but also on remaining questions on the UDB and feedstock categorization. These topics require further attention.
Session 9: Potential impacts of RFNBO legislation on decarbonizing transport: RED versus sector regulations (FF55)
The lion’s share of this session was devoted to five enlightening presentations by Lithuania, Estonia, Denmark, Germany and Portugal. These Member States all presented a different, but relevant approach to the adoption of RFNBOs for transport in their national systems. The focus of the presentations ranged from (preliminary) analyses on the uptake of RFNBOs and the needed investments, to an elaboration on the use of GOs, and a detailed description on the use of RFNBOs in the intermediate route. These presentations provided many useful insights on the challenges and successes these Member States had encountered so far. Moreover, the presentations yielded concrete examples on how to approach the adoption of RFNBOs in transport.
Furthermore there was a Q&A and discussion on the policy update by the Commission on the progress of the Delegated Acts concerning RFNBOs. During this discussion, the main focus was on the GHG-calculations and on the implementation of an intermediate route. What stood out were the difficulties that Member States encountered with accounting RFNBOs used as intermediate product. Given the concerns on this topic, it was proposed to establish a task force on intermediate products. Several Member States indicated that they were interested in joining. Therefore, this subject awaits further developments.
Session 13: Combined Session CT4/CT5: Verification of compliance with the REDII criteria - Final results of the Task Force on supervision by MS
The joint CT4/CT5 session was devoted to the supervision of certification bodies by Member States. During this session, the results of the Task Force on this topic, launched a year ago, were presented. The Task Force concluded that (1) several issues could be resolved via an addendum to the CIR 996/2022 clarifying the role that Member States should play in the registration of voluntary schemes, the appointment of a lead supervisor and establishing basic rules of supervision procedure / guidance to achieve harmonization ; (2) it is important, for supervision in third countries, to address the necessary access of supervisors more explicitly in the regulation ; (3) it should be possible to address tasks to Member States through a group of experts in charge of the coordination that has a formal position to the Member States and the EC; (4) a timeframe is required for the tasks of coordination and their interaction and (5) there is enough to discuss at future CA-RES meetings (the role of biomass fuels, biomethane or RFNBO’s in this framework, etc.). Most priority in time is given to the addendum to the CIR 996/2022 by the attending policy makers. The task force's work is now complete, and it will be up to the existing parties to continue the process on the basis of the priorities and actions defined by the task force.
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5th Plenary Meeting, 18th-19th October 2023, Lisbon
Session 1: Interactions between Fit-for-55-policies related to transport
DGENER started with a policy update on the revision of the RED. In the presentation DGENER elaborated on the new rules for biofuels and the accompanying sustainability criteria, and how these are regulated under the RED recast. Next, the Commission provided more details on the accounting rules for aviation and maritime shipping. Furthermore, DGENER presented plans for a credit mechanism aimed at better facilitating e-mobility based on renewable electricity. Finally, DGENER gave an update and timeline on ongoing work on RED II implementation.
This presentation was followed by contributions of several representatives of the Commission, (specifically DGMOVE, DGCLIMA (limited by technical issues) and DGTAXUD) a panel discussion and Q&A. The goal of this discussion was to provide more insight at the interlinkages between the RED and the different regulations of the Fit-for-55 package. The presentations of the Commission focused on various topics, ranging from specific sector regulations like FuelEU-Maritime and ReFuel-Aviation, to ETS and the ETD.
During the session it became clear that there is a need for further guidance from the Commission on the interaction between different transport related policy areas. Particularly when it comes to the mutual contribution to the different obligations for the different transport objectives, many pressing issues remain. Both the participants from the Member States, as well as the Commission representatives acknowledged that a clear picture is urgently needed on interlinkages for successful implementation of the RED recast and related legislation from the Fit-for-55 package. DGMOVE indicated its intention to include a Q&A about implementation questions on their website. This was generally seen by participants as a good starting point to support the implementation processes. It was proposed to share the questions from the Member States collected during CA-RES with the DGs so that they could serve as input for these Q&As.
Session 7: (1) Accounting of RFNBOs and renewable electricity in transport in national RED implementation; (2) UDB
The first part of this session was devoted to an elaborate presentation of Eurostat on the functioning of the SHARES-tool. Eurostat explained the benefits of SHARES and how the methodology is set up. This gave more insight in, for example, data collection via questionnaires and presentation in various sheets and tables. Additionally, Eurostat provided more insight on how the different renewable energy carriers are being counted and reported in SHARES, and how this differs from other energy statistics. Furthermore, special attention was devoted to the incorporation of accounting and reporting hydrogen and E-fuels in SHARES. The main conclusion of this part was that ideally, the numerator would be calculated in SHARES and the denominator imported from energy statistics. However, the main challenge is that definitions of hydrogen/RFNBOs differ between different frameworks. To support this a reporting instruction is being developed for H2 reporting in E-statistics.
Furthermore, DGENER provided a policy update on the recently adopted Delegated Acts related to RFNBOs. The Commission covered several topics, including the creation of a framework for harmonized certification of RFNBOs with regard to additionality, an elaboration on the accounting rules for RFNBOs and how to count them towards the RES-targets, and the approach for accounting RFNBOs during co-processing. This presentation was followed by two pitches from Member States, Germany and Norway, which yielded valuable insights on how their crediting system of renewable electricity is organized. Finally, The Netherlands and Germany shared their thoughts on how the different options in the RED could be organized to account RFNBOs in the transport objective. As a follow up, it was proposed to start a Task Force specifically aimed at the contribution of the use of renewable H2 in the intermediate route to the transport goal (Art. 25). Several Member States expressed interest in participating.
A Q&A regarding the interpretation of target-setting, GHG-calculations and accounting of renewable electricity and RFNBOs (both as intermediate and end-use product), made up the end of this part of the session. The questions comprised remaining questions and issues that pose a challenge to RED III implementation. As in session 1, these questions will be shared with DGENER so that they can serve as input for a Q&A to support the implementation of the RED.
Finally, at the end of this session, the joint inventory of CT4, CT5 and Task Force GO with questions and pending issues about the UDB was presented to DGENER. DGENER provided an initial response to a selection of the points from the inventory. Start of operation of the UDB will be January 2024.
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6th Plenary Meeting, 22nd-23rd May 2024, Budapest
Session 1: Transport related crediting systems (RED Art. 25.4)
The Commission started with a policy update on the recent publication of the updated Annex IX. In the presentation, DGENER elaborated on the new feedstocks added to part A and B of the Annex, as well as on the pathways for intermediate crops. The Commission also outlined the implementation process as part of the RED III transposition and indicated that more guidance on the certification of feedstocks will follow in due time. Additionally, DGENER provided more insight in the coverage of aviation and maritime under the RED obligation. It was confirmed that it is not possible to impose specific obligations on the aviation sector, apart from ReFuel. A fuel supplier that only supplies to aviation, cannot be obliged under the RED. However, fuel suppliers who also supply to other sectors are allowed to be imposed an obligation under the RED.
The second part of the session consisted of several insightful presentations by Member States, the United Kingdom and the State of California. These presentations yielded valuable information on how the different (Member) States have organized their transport crediting systems. California and the UK have implemented a crediting system based on emission reduction and volumes of renewable energy respectively, and both stated that they achieved good results. Furthermore Germany, Ireland, Belgium, France and the Netherlands presented their considerations on their national crediting systems. These presentations touched upon several important topics, for example the consideration for setting energy- or emission-based targets, the inclusion of public and private charging, the accounting of different feedstocks and the administrative process of incorporating different users generating different kind of credits.
The session made clear that many challenges remain regarding the implementation of functioning crediting systems. However, many countries are well underway with creating smooth functioning crediting systems for transport.
Session 14: Counting RFNBOs to transport targets
The first part of the session was devoted to a policy update from DGENER on the accounting of RFNBOs within the RED III obligation. The Commission provided insight in the RFNBO targets and multipliers. Furthermore, the rules for accounting RFNBOs as either direct or indirect use (intermediate route) were made clear. DGENER elaborated on the allocation of renewable hydrogen in refineries and the approach for the assessment of amounts used.
The second part of the session consisted of a detailed presentation by ISCC. The basic principles of RFNBO certification were outlined and used to explain various scenarios for the use of electricity for the production of RFNBOs. ISCC showed a simplified representation of a supply chain to determine the scope and certification applied in the process. This showed how RFNBOs are traced. ISCC continued with an explanation of the PPA and GOs and also gave an explanation of the audits. This way the certification process for actual GHG emission values was further made clear.
In the extension of this presentation the Task Force on ‘the intermediate use of renewable hydrogen’ presented its results. Several collected questions were presented, ranging from topics like for example the methodology for assigning and allocating renewable hydrogen utilized in the refinery processes, the accounting of renewable hydrogen to targets of Art. 22 and Art. 25, an tracking of renewable hydrogen in the UDB. The Task Force also requested additional guidance from DGENER on these same subjects. Finally, to conclude the session, there was a discussion in small groups of participants that debated the considerations of the intermediate route with direct and indirect use of renewable hydrogen, and the requirements of a robust certification system to ensure compliance.
Session 9: Combined Session CT4/CT5/TF-GO: Union Database
The goal of this session was to provide a clear demonstration of the functioning of the Union Database from the perspective of the Member States (supervisor). The session started with a presentation by DGENER's UDB team on the Union Database for biofuels. The team explained the current state of affairs in broad terms and what the plan is for the coming months. The team explained that there are various types of users for the UDB, including the roles for Member States. The demonstrations focused on the operation of the UDB for Member States, using the previously prepared case studies. The demonstration was performed in the test environment (not yet available to users) and mock-ups/screenshots are shown for functionalities that have not yet been set up/programmed. All transactions made by Economic Operator's (EO) can be seen by the EO itself. In short, all detailed information from the PoS can be entered. The Member State can see which EOs are active in the country. In addition, a Member State can see which materials are available/registered in aggregated total.
Furthermore, the gas value chain was also presented, where mass balance systems are assumed. The UDB team proposed to set up a link with the national GO system for this purpose. It is explained that it will be possible to link a PoS and a GO in the UDB. DG ENER added that an EO is linked to a PoS and GO, so that they can easily be followed. The demonstration proved to be very insightful as it gave the Member States a first glimpse into the functioning of the UDB and how to operate the new system.
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CA-RES4_PM6_Highlights Joint Session CT4/CT5/TF-GO
7th Plenary Meeting, 23rd-24th October 2024, Brussels
Session 2: Feedstock Differentiation in Transport Fuels
DGENER started with a policy update on new additions to the RED III. The Commission presented updates on the adoption of guidance on the implementation of RFNBO-targets in industry and transport. 3 new schemes can be used for RFNBO-certification, although still awaiting formal recognition. With regard to biofuels, the Commission made changes to the Annex IX list. The revised list is now in force and Member States have until September 2025 to implement the changes. Furthermore, DGENER also provided a draft methodology for low carbon fuels. This emphasizes consistency with the RFNBOs and RCFs methodology: it will consider life-cycle emissions and indirect emissions. Lastly, process for delegated act on low carbon fuels has also started. Consultation on methodology of emission calculation is ongoing.
The second part of the session consisted of three interesting debates. The first discussion concerned feedstock definitions; we talked about chemical categorization of feedstocks, about ambiguity in interpretations of Annex IX, waste classification regarding the Waste Framework Directive, and need for harmonization. The second discussion reviewed the possible need for adjustment of the Annex IX-B cap. We discussed the concerns about the cap being too low with new feedstocks on the list, the impact of the increased denominator under RED III, and challenges about deployment for achieving renewable energy goals. The third discussion was about intermediate crops and crops from degraded lands; we discussed if definitions are clear enough to distinguish them from food and feed crops.
Session 8: Robustness of system requirements in transport
The session consisted of multiple presentations by Member States on potential fraud and supervision. In the first presentation France noted an increase in UCO from Asia, but questioned the sustainability claims of the feedstocks. In response France set up a national supervision system (CarbuRe), to increase supervision and robustness. During the second presentation, Ireland made clear that it observed an exponential increase in POME-use, which caused suspicion of fraud. A non-paper was presented to the Commission with request for thorough investigation. In response the Commission will establish a working group within the Sustainability Committee (established under the RED) to strengthen the functioning of the Implementing Regulation on certification. In the third presentation, the Dutch Emissions Authority (NEa) called for public supervision on economic operators instead of just on certifying bodies, and also for increased cooperation with other enforcement agencies. NEa also gave insight in their supervision practices, for example the use of cross-checks for biofuels and sustainability analyses (C14-method). NEa emphasized a need to focus on transparency of prices and greenhouse gas reduction claims. The fourth and last presentation was by the European Commission. DGENER presented the UDB as a tool where harmonized data should lead to improved traceability, by use of statistical analysis. Accordingly, the design of the UDB should minimize fraud risks, because it labels raw material, signals irregularities at economic operator-level throughout member states and production chains.
The final part of the session was devoted to discussion about the topics covered by the presentation. The debate showed that many member states are improving national supervision systems to tackle (potential) fraud and answer to political questions in their home states. The UDB can contribute to that, however its launch is pending.
Session 5: Combined Session CT4/CT5: Annex V and VI on Greenhouse Gas Emission Calculations
This session focused on the revision of the annex V and annex VI of Directive 2018/2001, providing rules for calculating the greenhouse gas impact of biofuels, bioliquids (annex V) and biomass fuels (annex VI) and their fossil fuel comparators. The revised annexes have not been adopted yet: a public consultation still need to be organised to end the drafting process by the first quarter of 2025 and see the revised annexes be published by the end of June 2025 (under the form of a delegated directive). A transposition deadline of 18 months from its entry into force will probably be fixed. DG-ENER gave a first overview of the draft version of the revised annexes. No values have been shared during the session. At this stage, Annex V introduces new supply chains, excludes default values for some feedstocks and updates other values, considering – among others – the improvement of production processes and reduced impact of climate change. The scope of Annex V will also be enlarged to aviation and maritime transport. No change of methodology is expected. In Annex VI, values for some existing feedstocks have been updated and values have provided for a new feedstock (sewage sludge). Annex VI also revises its methodology and only refers to pathways in which electricity and heat required in the process are supplied by the CHP engine itself (“case 1”). The methodology also considers biomethane leakages which highly influences the values. It appears that majority of current installations will not be compliant with the proposed values, mainly because of that inclusion of biomethane leakages. Support schemes (financial and non-financial) are therefore crucial to promote the new investments in installations. Finally, DG-ENER introduced the possibility to publish a common EU tool to calculate GHG emissions based on the annexes.
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