FEDIOL and the European Biodiesel Board (EBB), consider that reducing the proportion of crop-based biodiesel would have short-term effects on prices and availability, but it sends the wrong signal to farmers and producers , which discourages long-term production. Ultimately, the market would find a new equilibrium at much lower volume without any price advantage.

The existence of a market for crop-based biofuels leads to crop production that exceeds the demand for food. However, during food crises this surplus can be diverted to the food market, but eliminating or reducing the market for crop-based biofuels would leave our food system more vulnerable, with less flexibility to respond immediately to food crises.

On the other hand, the demand for crop-based biofuels increases the production of protein-rich co-products while increasing and diversifying farm incomes, thus increasing food security.

In addition, crop-based biodiesel also has real advantages for the climate and the environment. Higher crop production increases the availability of co-products used to replace fossil chemicals in cosmetics and other uses. Additionally, crop-based biofuels offer GHG emissions savings of more than 50% compared to fossil fuels, while waste and residue-based biofuels offer reductions of up to 90%.

Since the beginning of the Ukraine crisis, market operators have diverted volumes of vegetable oils initially intended for processing into biodiesel to food uses. The food market was able to cover the shortage of basic products in extraordinary circumstances thanks to the existence of a market for biofuels based on crops, the production of which maintained a critical reserve of vegetable oil. Crop-based biofuels maintained crop availability beyond those needed to meet food demand, which was redirected towards the food sector when the food crisis hit. Without crop-based biofuels, total crop production would have been lower, reducing our ability to respond to and mitigate food crises. The retail supply problems that occurred in the EU as a result of the Ukraine crisis were not related to actual shortages but to overstocking by consumers.

The expected decline in demand for vegetable oil for biodiesel in the EU would make oil crop production less attractive as it would reduce the price a farmer would expect to get for his crops. This would decrease oil crop production, possibly leading to higher consumer prices.

Contrary to popular belief, biodiesel production does not divert oil crops from food. In fact, experience has shown that even when rapeseed production increases by including it in crop rotation, the demand for food per rapeseed remains stable. As a general rule, only vegetable oil that is not used in food or specialized uses such as oleochemistry is used for biodiesel production.

The production of vegetable oils for biodiesel feedstock also produces around 10 million tonnes of protein-rich meals critical to reducing the EU's protein deficit. Reducing blending obligations would reduce the availability of European protein-rich raw materials and increase the need for imports.

EU biodiesel incentives boosted European oilseed production by stimulating demand for rapeseed-based biodiesel. Higher oilseed crushing followed higher oilseed production, which increased the availability of important protein by-products. By offsetting imports of such products, the EU incentives strengthened Europe's food security without disrupting the food market. In a nutshell, while demand for rapeseed oil in the food sector remained stable, biodiesel mandates under the EU Renewable Energy Directive have led to a steady increase in oilseed production over the last 20 years.

In general, the proportion of oilseed crush used for biodiesel production ranges from just under 7% for soybeans to 25% for rapeseed, with the main products being feed and food. In addition, the co-products of biodiesel production in biorefineries are increasingly replacing fossil chemicals in cosmetics and other uses. Around 83% of the crops grown in the EU are used nationally for food, feed, drink and non-fuel industrial uses. Almost 11% is exported and around 6% is used as fuel. The integration of animal feed production with biodiesel production makes oilseed crushing economically viable in the EU; oil from oilseeds is a by-product and is mainly used for the production of biodiesel since there is not enough demand from the food sector.

Altering the existing legislative and regulatory frameworks through bans, restrictions, changes in mandates or other forms of public intervention in the biodiesel market would exacerbate the already tense situation in the energy market. Such actions would put more pressure on energy prices and increase the demand for fossil fuels. These actions run counter to the EU's goals of addressing vulnerabilities in its energy supply and becoming less dependent on fossil fuel imports. Therefore, any reduction in renewable fuel blending obligations in the transport sector should be avoided.

The EU is highly dependent on imported oil. In 2020, the EU imported 23 million tonnes of oil equivalent (Mtoe) of diesel and gas oil and 440 Mtoe of crude oil. Together, diesel and gas oil accounted for 70% of all vehicle fuel consumed in Europe. In the same year, the EU used 13 Mtoe of biodiesel, the largest source of renewable energy used in transport, a sector where fossil fuels dominate with a market share of 93%. With an increasing share of European biodiesel production coming from waste and residue, giving up this production would severely hamper the EU's climate goals. Furthermore, on average, GHG emissions from biofuels based on sustainable crops are less than 50% of those from fossil fuels; waste and residue-based biofuels offer reductions of up to 90%.

Therefore, from FEDIOL and the European Biodiesel Board, they consider that supporting the reduction of the biofuel mixture sends the wrong signal and is a short-sighted measure with potentially devastating consequences for the biofuel value chain without perceptible benefits.

As European farmers are being asked to produce more in order to improve food security, reducing the biofuel mix will severely and negatively affect EU production in the medium and long term. Without the production of biofuels, the European production of high-protein meals for our European livestock sector will no longer be economically viable. Reducing the biofuel mix will discourage the planting of oilseeds, especially rapeseed, reduce the EU harvest, compromise the EU crushing industry and thus lead to more imports of the end product, the high-carbon meals. proteins. Likewise, biorefineries that produce biodiesel and its co-products (glycerin, naphtha) will also be compromised.