UFOP recommendations for the practical application of the sustainability directive to oilseeds for biofuel production

Effective 1 July 2010, biofuels will only be considered for blending purposes or tax relief if the prescribed sustainability certificate has been issued. Precondition for the sustainability certificate is that comprehensive documentation of the complete chain to farm level is available. The basis is a statement by the farmer to make sure that, nationally, the crop has not been grown on protected areas and, internationally, that rain forest has not been cleared.

BLE and Deutscher Bauernverband, the German Farmers’ Association, are preparing information material because it was found that all market participants still have a number of questions as to how the sustainability directive should be handled practically. As regards oilseeds, UFOP suggests the following recommendations and notes:

To ensure that the entire biomass production of a farm can be used as input for biofuel later, the simplified self-declaration should be made for all available arable land; a sample of the simplified self-declaration is contained in the guideline document published by BLE. The purpose of the self-declaration is to make sure that all biomass in fact is only coming from areas that comply with the requirements of the sustainability directive.

The self-declaration is issued once and addressed to the market partner obliged to maintain the documentation. More information will probably be issued to the farmers’ market partners by their certification system in May. By that time, it will also be clear what needs to be documented in case of grassland being ploughed up in conformity with the directive after 1 August 2008.

From the time the raw goods are registered, it suffices to document additions and withdrawals under a mass balance system and updated it for type and quantity. Mixing with goods not conforming to the directive, i.e., deliveries without grower’s statement (e.g., from imports), is possible. In this case, the non-conforming goods must not be declared to be sustainable goods. It must be possible to keep sustainable goods and non-sustainable goods apart in the balance sheet. A balance must be struck every day, every month or every quarter year. The amount of goods delivered in that period must not exceed the amount of goods received in the same period.

Biofuel producers existing since 23 January 2008 are exempted from the greenhouse gas reduction potential until 1 April 2013; in Germany, this is the rule, at present. Even though, it is recommended to document - both in the farmer’s self-declaration and for further delivery and processing - that the standard value as per the directive should be applied. This also makes use of the plant oil in cogeneration units possible. No right of continuance is granted for the bonus for renewable raw materials and the greenhouse gas reduction potential (at least 35 per cent) must be proved with effect of 1 July 2010.

Certification on the basis of the directive is required for businesses and production facilities, oil mills and biofuel producers registered for the first time. BLE has accepted temporarily a certification system and several certification bodies. REDcert, a certification system supported by 10 major industry associations across the complete goods chain, can start auditing the large number of traders and cooperative societies probably from in May. All these businesses are already certified feedstuff suppliers, which will facilitate the REDcert audit.

Even if biodiesel from rapeseed oil with a standard value of 38 per cent has a greenhouse gas reduction potential better than the current minimum requirement of 35 per cent, the conversion to the climate protection quota on 1 January 2015 will require a reduction of greenhouse gas emissions both during conversion and in cultivation. Latest from that time, the competitiveness of rapeseed biodiesel and its preliminary products in the market will decisively depend on the respective contribution to the greenhouse gas reduction and the cost for this. Therefore, researchers are working with concentration on the development of solutions for practical