iEthanol’s position paper on European Commission’s support for reducing biofuels’ blending proportion

Brussels, May 2022

With this position paper, iEthanol opposes the unfounded statements suggesting that biofuels are a threat to food supply security, and hereby kindly asks the European Commission to carry out an impact assessment to determine the real implications of this initiative on the energy and food security in the EU and at the global level.

For background, the European Commission’s Communication of 23rd March 2022 on Food Security, expresses Commission’s support for Member States’ actions to reduce the blending proportion of biofuels, which could lead to a reduction of EU agricultural land used for production of biofuel feedstocks, thus easing pressure on the markets for food and feed commodities. Moreover, demands to reduce or ban crop-based biofuels emerged from other stakeholders in the midst of the war in Ukraine, with NGOs calling the production of crop-based biofuels “immoral” and the European Parliament asking that agricultural land is primarily used only for the purpose of producing food and feed to ensure food security.

Given the significant impact these actions would have, not only on the ethanol market, but most importantly on the environment and the EU’s progress towards greener energy, iEthanol strongly encourages the European Commission to carry out an impact assessment before any change in blending mandates is considered.

iEthanol would like to bring to the attention of the European Commission the below arguments that support the continuous use of biofuels in Europe.

1. “Biofuels” is a misleading denomination. iEthanol strongly recommends having differentiated individual assessments for Biogas, Biodiesel and Bioethanol. Bioethanol has by far the lowest impact in terms of soil and crop occupation, and the highest benefit in terms of GHG savings in transport.

Bioethanol is not impacting grain availability, as less than 1% of EU cropland used for biofuels, goes to the production of bioethanol. Additionally, only a small portion of EU cropland is used for biofuels production. It amounts only to 3,4 million hectares out of 117 million hectares cropland in the EU, which in percentages is equal to 3%3 of the total EU cropland being used to produce biofuels. Of this, more than 72% goes to the production of biodiesel and less than 25% for bioethanol.

2. In terms of soil occupation and competition with food crops, biogas is by far using the most land compared to what is needed to produce biodiesel and bioethanol together

In Germany, which is at the forefront of biogas production, the land used to produce biogas is six times more than the land used to produce bioethanol and three times more than the land used to produce biodiesel (see annex 1). The cultivation of crops used in the production of bioethanol is therefore very limited compared to the crops used in the production of biodiesel and biogas and even more limited compared to the total agricultural commodities available in the EU. It is therefore not reasonable to encourage a reduction of the blending proportions for bioethanol without specifically targeting biogas and biodiesel.

3. Bioethanol industry is important for Europe’s food and energy security

By generating, through the production process, high purity ethanol, food ingredients, animal feed and fuel blending components, bioethanol diminishes the need to import crucial pharmaceutical components, key industrial solvents and chemicals, animal feed and reduces the use of crude oil in transport. As a fuel component, bioethanol is used only in gasoline, which will continue to power cars for the next 20 years at least. This is more important now than ever, given that the EU is dependent on imports of animal feed which has become excessively expensive, with Russia and Ukraine accounting for a large share of the world’s wheat and maize exports, 30% and 20% respectively.

4. Commission’s support for reducing the blending proportion for biofuels goes against the goals set in the Commission Communication on RePowerEU and against the overall EU environmental and climate goals

In the RePowerEU Communication, the Commission seeks to diversify gas supplies, speed up the roll-out of renewable gases and replace gas in heating and power generation. This has the potential to make Europe independent from Russian gas by two-thirds before the end of the year. This is an important step towards Europe’s energy independence. Using less biofuel would result in higher imports of crude oil, including from Russia. Not only would this imply a rise in greenhouse gas emissions from transport but it could also delay the EU’s independence from Russia’ s crude oil, putting at risk the EU’s energy independence and its environmental goals.

5. There are ways to grow EU and global food security, without sacrificing EU’s environmental goals and energy security

There is no risk to food security in the EU, as the Union is largely self-sufficient in key agricultural products, as well as in most animal products. In the latest Commission’s trade outlook6, the new measures such as increasing agricultural production by using fallow land and reducing and diversifying imports of resources such as energy, fertilizer and animal feed, should increase usable land for growing grains, positively affecting the EU’s output for arable crops and addressing the issue of global food security.

To help third countries, the Commission has already foreseen in its Communication a number of financial, agricultural and logistical measures to ensure food security at the global level, which we consider more appropriate to tackle the food security problem than reducing crop-based biofuels.

In conclusion, iEthanol recommends to the Commission to keep the ethanol blending mandates at their current levels and targets. A change should only be considered based on an impact assessment and clearly distinguishing between biogas, biodiesel, and bioethanol impact on land in the EU.

Annex 1: Land use for the cultivation of renewables feedstock in Germany 2019-2021 (in hectares)

Source: FNR, BMEL (2021)