EU feed trade body FEFAC has published a position statement the European Commission’s proposals to revise the EU Renewable Energy Directive. It says a consistent approach that maintains the supply of protein feed materials and adheres to the strict implementation of waste hierarchy principles is necessary.

The original Renewable Energy Directive (RED) sought to produce 20% of the EU’s energy from renewable sources by 2020 through a series of national member state plans. The revised RED seeks to make 27% of the EU’s energy form renewables by 2030, but also implements a series of sustainability criteria, to ensure biofuels are not grown on land of high biodiversity value and produce 35% less emissions than fossil fuels.  The Indirect Land-Use Change (ILUC) rules introduce a ceiling for the contribution of food crop-based biofuels, such as cereals, maize, oilseeds and beet. This starts at 7% of the target in 2021, reducing progressively to 3.8% in 2030.

FEFAC states that EU biofuel production from agricultural raw materials generates “significant quantities of protein-rich co-products that are used in animal nutrition”, such as oilseed meals and dried distiller’s grains. These help reduce the EU feed protein deficit.

The trade association believes the EU crop-based biofuels ceiling should remain in place, to “mitigate the potential adverse effects of first generation biofuels linked to competition for land and water use while maintaining the availability of protein-rich co-products”.  But it adds that dual use crops such as rapeseed meal make a positive contribution to the EU by providing protein-rich feed materials with a broad amino acid profile.

Therefore, FEFAC calls for the impact of the revision of EU biofuel-related policies on the EU protein supply to be assessed and monitored comprehensively. The analysis should cover the availability of EU protein sources by using the recently published EU protein balance sheet at the upcoming EU market observatory on cereals and oilseeds.

Turning to advanced or second generation biofuels, which largely comprise crop residues such as straw and haulms, FEFAC raises concern over the listing of feedstocks that are suitable for feed and food use, such as molasses. It says the proposed blending obligation would “provide a subsidised incentive distorting agricultural markets, while going against the principles of the waste hierarchy which prioritizes feed and food use over energy use”.