. /.  WORLD TRADE  
ORGANIZATION   
G/TBT/W/337 
8 June 2011 
 (11-2834) 
Committee on Technical Barriers to Trade Original:   English 
  
 
INDONESIAN CONCERNS REGARDING THE EUROPEAN UNION'S  
RENEWABLE ENERGY DIRECTIVE (EU - RED) 
 
 
The following communication, dated 7 June 2011, is  being circulated at the request of the 
delegation of Indonesia. 
 
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 I. INTRODUCTION 
1. The purpose of the implementation of these regulations is to replace the use of petroleum-
based fuels with renewable ener gy fuels in order to reduce vehicle emissions containing carbon 
dioxide (CO
2) which caused the increase of greenhouse gas emissions.  The EU-RED requires criteria 
for environmentally sustainable biofuel production process. 
2. Indonesia fully understands that the purposes behind this draft regulation are to reduce vehicle 
emissions containing carbon dioxide (CO 2) which caused the increase of greenhouse gas emissions 
and the environmental sustainability. 
3.  As one of main supplier of Crude Palm Oil (CPO) to the European Union (EU), Indonesia is 
much concerned about the draft EU-RED Regulation. 
4. Therefore, Indonesia would like to request clar ification from the EU on a number of issues.  
II. QUESTION RAISED 
(a) Article 17, paragraph 4 and 5 allows for the revision of default values based on 
scientific evidence which is compiled by independent experts at the Joint Research Center (JRC).  Could the EU confirm wh ether default values have already been 
revised, how long does the process take and what are the procedures including 
decision-making?  
(b) It is noted that the EU sustainability  sch eme also allows altern ative methods to the 
default values to be used to show comp liance with the sustainability criterion for 
minimum greenhouse gas savings.  Could th e Commission also confirm whether this 
alternative data has been presented and accep ted, the duration of this process from 
submissions being made, and the decisions making process? 
(c) It is understood that the  independent e xperts referred to are part of the JEC 
consortium financed by the EU.  In or der to ensure independence, would the 
Commission include  experts from outside the
 Community? G/TBT/W/337 
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  (d) While the Commission has explained that the RED Directive does not restrict imports 
of palm oil, Indonesia is of the view that the biofuel market in Europe is shaped by 
the RED Directive in terms of default valu es and financial support provided and that 
there is no meaningful market outside of the mandatory targets being set for the use 
of biofuels.  In this respect, could the Commission confirm, based an independent 
market information, that there is a EU bi ofuel market outside of the market created 
 and shaped by the RED Directive? 
(e) In accordance to article 16.4, would the Commission explain the number of voluntary 
schemes that have been rec ognized to demonstrate compliance to the sustainability 
criteria set out?  Could the Commission furt her explain the duration of the assessment 
process before a Commission decision is made? 
(f) In accordance to article 16.4, would th e Commission explain whether bilateral 
agreements are being negotiate d and/or have been concluded with third countries to 
meet the sustainability criteria? 
(g) Based on the article 19 paragraph 6, the Commission shall, by 31 December 2010, 
submit a report to the European Parliament  and to the Council reviewing the impact 
of indirect land-use change on greenhou se gas emissions and addressing ways to 
minimize that impact by 31 December 2010.  Indonesia would like to know about the 
report and ask whether the report is open to the public? 
 
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