REDII – Taking a look at the Impact Assessment


With its revised Renewable Energy Directive (RED II) the European Commission wants to phase out all conventional biofuels in the EU. But in making its proposal the Commission has ignored many of its own guidelines for Impact Assessments, including on evidence-based policy making and the proportionality of its policy choices. The Commission provides no scientific evidence or rational arguments to justify the proposed end of policy support for sustainable conventional ethanol post-2020 – a move that would severely restrict biofuels’ contribution towards renewable energy targets.

In the attached policy briefing ePURE highlights three concrete examples demonstrating how the Commission has failed to respect essential procedural requirements in its conduct of the Impact Assessment to the detriment of the EU renewable ethanol industry. The Impact Assessment:

  1. Fails to compile robust evidence and wrongly applies available science. The most carbon-abatement-cost-effective solution to decarbonise transport – continuing Article 7a of the Fuel Quality Directive beyond 2020 – was never given due consideration in the Impact Assessment, yet was dismissed as a viable policy option.
  2. Fails to demonstrate how the proposal addresses the identified problem in a proportional manner. The Impact Assessment never received approval from the Regulatory Scrutiny Board. One of the key reasons for the rejection was precisely the Commission’s undifferentiated and unsubstantiated treatment of conventional biofuels.
  3. Fails to provide credible and transparent evidence for conclusions drawn. The Impact Assessment misrepresents the impact of the proposal on investments in conventional renewable ethanol by wrongfully assumes that existing biorefineries will be easily converted into advanced ethanol facilities.

ePURE believes the Commission has acted contrary to the Treaty by failing to respect essential procedural requirements in its conduct of the Impact Assessment to the detriment of the EU renewable ethanol industry. Moreover, its proposal to phase out conventional bioethanol is in direct conflict with Article 194(2) of the Treaty which expressly limits the legislative powers of the Commission by guaranteeing the sovereign right of Member States to determine their energy mix.

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