Making the most of EU renewable energy policy: ePURE’s feedback to the REDII revision roadmap


As the EU is once again moving towards a new revision of the Renewable Energy Directive, it is critical that the European Commission takes stock of the failures of the approach that has been taken on renewables in transport and crop-based biofuels in particular. The design of RED II puts renewables against each other, pursuing the approach initiated by the ILUC Directive, thereby hindering greater renewable energy incorporation.

In response to the RED II revision roadmap, ePURE has provided recommendations to make the most out of this upcoming revision of the main policy instrument fostering the uptake of renewable energy. This is in order to significantly increase renewable energy quantity in Europe, reduce reliance on fossil energy and support the European Green Deal ambitions.

  • It is time to do better: the EU cannot afford to dismiss what has been the nearly sole contributor to renewable
    energy incorporation in transport. In light of the Green Deal ambitions, it would be wise to reassess the current
    cap on crop-based biofuels put in place in response to ILUC concerns which have now been fully addressed in the
    Delegated Act on high ILUC-risk biofuels. The existence of a crop-based biofuel cap simply hinders greater
    renewable energy incorporation in transport by penalising some high environmentally performing biofuels such
    as European renewable ethanol.
  • RED II targets and sub-targets should only be revised upwards, without the possibility to reduce them, as is
    presently the case through reduced crop-based biofuels cap and the use of artificial multipliers. The target of at
    least 14% represents an absolute minimum, which may not be sufficient to achieve the ambitions set out in the
    European Green Deal and the 2030 Climate target plan.
  • As illustrated by the launch of this process less than 20 months after the adoption of the RED II, the EU renewable
    energy policy framework has been highly unstable and inconsistent, hindering the development of innovative
    renewable energy such as Annex IX-A biofuels. This instability has triggered investors certainty and delayed the
    necessary deployment of renewable energy in transport. These biofuels require a level of support not currently
    offered by the RED.

Read our full response to the European Commission consultation here.

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