Technical assistance in realisation of the 5th report on progress of renewable energy in the EU : analysis of bioenergy supply and demand in the EU (Task 3) : final report.
Date: 2020-10-12
Institutions: Directorate-General for Energy
Subjects: Community certification, bioenergy, biofuel, directive (EU), energy consumption, energy production, renewable energy, report, supply and demand, sustainable development, technical cooperation

ENER/C2/2016-501 
28 June 201 

Technical assistance in realisation  

of the 5th report on  

progress of renewable energy in the EU  

Task 3 

State of play of bioenergy consumption in the EU and assesses the compliance of 
biofuels and bioliquids with the EU biofuel sustainability criteria through national 
certification or by voluntary schemes that have been recognised by the 
Commission. 

ENER/C1/2019-478 

October 2020 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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EUROPEAN COMMISSION 

DIRECTORATE C  

Renewables, Research and Innovation, Energy Efficiency 

European Commission 

B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Technical assistance in realisation of the 
5th report on progress of renewable 
energy in the EU 

Analysis of bioenergy supply and demand in the EU (Task 3) 

– Final report –   

By: Navigant – A Guidehouse Company 

Date: 5 October 2020 

Project number: 210248 

“The information and views set out in this report are those of the author(s) and do not necessarily 
reflect the official opinion of the Commission. The Commission does not guarantee the accuracy of 
the data included in this study. Neither the Commission nor any person acting on the Commission’s 
behalf may be held responsible for the use which may be made of the information contained therein.” 

© Navigant – A Guidehouse Company 2020 by order of: European Commission DG ENER 

 
 
 
 
 
 
 
 
 
 
 
 
Technical assistance in realisation of the 5th report on progress 
of renewable energy in the EU 

Executive summary 

Scope 

The Renewable Energy Directive requires the Commission to report on the progress of renewable 
energy and on the sustainability of biofuels consumed in the EU. To assist the Commission in this 
task, this report provides insights into the development of biofuels, biomass and biogas for renewable 
energy in the EU from 2010 to 2018 (with a focus on the most recent years). Specifically, the report 
assesses the production, consumption and trade of bioenergy, and quantifies the sustainability 
impacts of EU consumption of biofuels. The analysis is based on Member State Renewable Energy 
Progress Reports submitted in 20191, Eurostat SHARES and other Eurostat statistics, other reports, 
studies and databases, and additional original research. 

Overview of bioenergy in the EU, and its main applications 

In 2018, bioenergy represented the largest source of renewable energy in the EU, with a gross 
consumption of 145 Mtoe or 60% as shown in Figure S 1. The most important use of bioenergy is in 
the heating and cooling sector (84.6 Mtoe final energy), followed by electricity generation (16.2 Mtoe 
final energy) and transport (16.6 Mtoe fuels delivered).2 The majority of liquid bioenergy comes from 
the use of biodiesel (75%).  

Figure S 1. Gross EU consumption3 of renewable energy per type (2018, % and Mtoe). Source: Eurostat nrg_bal_c 

Figure S 2 compares this consumption per sector to the indicative targets for bioenergy use in those 
sectors as laid out in the Member States’ National Renewable Energy Action Plans (NREAPs). The 
generation of heat from biomass is close to the indicative NREAP targets. The gap is larger for 
electricity in relative terms (though smaller in absolute values). For biofuels, the gap is larger in both 
relative and absolute terms. Specifically, in the case of biofuels, the large gap does not per se imply 
that the 2020 indicative NREAP targets may be difficult to meet since the international production 
capacity for biofuels is larger than the target requires. Sufficient biofuel volumes can be bought on the 
market to fulfil the targets and, unlike electricity and heat production, no build-up of capacity is 
required.  

1 These reports have been published online and can be found here: https://ec.europa.eu/energy/en/topics/renewable-energy/progress-reports  
2 The difference between the total of final bio-energy consumption (117 Mtoe) and gross bio-energy consumption (140 Mtoe) is mainly due to the efficiency of 
electricity generation, while biofuel and bioheat retain most of the energy from the original biomass. 
3 Here, “consumption” is measured at the moment the biomass is consumed, e.g. in the production of heat or power, or as a fuel in transport. 

 
 
 
 
 
                                                      
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Figure S 2. Bioenergy consumption by end use in 2018 versus 2020 NREAPs targets (Mtoe)4  

In the heating and cooling sector, by far the largest part of the bioenergy is produced from solid 
biomass, followed by biogas and a small amount of bioliquids. Solid biomass is also the main energy 
carrier in the electricity sector, followed by biogas, the renewable fraction of municipal solid waste 
(MSW) and a small amount of bioliquids. For the transport sector, mainly biofuels are used as the 
energy carrier. 

Main bioenergy carriers 

Solid biomass is the major bioenergy carrier used in the EU for bioenergy production (99 Mtoe gross 
consumption, delivering 88.6 Mtoe in final energy carriers). The main feedstock for solid biomass is 
forest biomass (91%, including fuelwood, 5 wood residues and by-products, wood pellets and black 
liquor 6). Germany, France, Italy, Sweden, Finland and Poland show the largest consumption of 
fuelwood, wood residues and by-products. The consumption of black liquor is considerable in Sweden 
and Finland, which have large pulp industries. In some countries, energy crops and agricultural 
residues also play a significant role. Note that the available statistics do not give insight into which 
feedstock is exactly used in the production of bioenergy in each end-use sector. 

The vast majority (90%) of solid biomass consumed in Europe’s heat and power generation is 
sourced from within the EU. In 2018, the largest importer of wood pellets was the UK, responsible for 
almost 64% of EU imports. The most important third countries supplying wood pellets to the EU were 
the USA (almost 60%), Canada (17%) and Russia (13%). 

Liquid bioenergy carriers form the second largest bioenergy carrier in the EU (18 Mtoe gross 
consumption, delivering 17.5 Mtoe in final energy carriers) represents 13% of all bioenergy, or 8% of 
all renewable energy (in all sectors). Liquid bioenergy mostly consists of biofuels in transport 
(13.5 Mtoe biodiesel and 3.0 Mtoe bioethanol), but also accounts for a small amount of so-called 

4 Sources: Bioenergy in electricity generation based on Eurostat nrg_bal_c, bioenergy in transport based on Eurostat SHARES and nrg_bal_c, bioenergy in 
heating and cooling based on 2019 Member State reports and indicative NREAP targets based on analysis by ECN. 
5 Fuelwood (also known as wood fuel) is defined by the European Commission as “Roundwood being used as fuel for purposes such as cooking, heating or 
power production. It includes wood harvested from main stems, branches and other parts of trees (where these are harvested for fuel) and wood that is used 
for the production of charcoal (e.g. in pit kilns and portable ovens), wood pellets and other agglomerates. It also includes wood chips to be used for fuel that 
are made directly (i.e. in the forest) from roundwood. It excludes wood charcoal, pellets and other agglomerates.” (see 
https://ec.europa.eu/knowledge4policy/glossary/wood-fuel_en). 
6 Eurostat includes black liquor in the category of solid biomass. 

 
 
 
 
                                                      
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‘bioliquids’, i.e. liquid forms of bioenergy used for power production. These bioliquids are thought to 
mostly consist of vegetable oils and pyrolysis oil. 

Biogas is the third largest bioenergy carrier in the EU (16.8 Mtoe gross consumption, delivering 
9.3 Mtoe in final energy). It is mainly used for the generation of renewable electricity and heat. 

The renewable fraction of municipal solid waste (MSW, 10.4 Mtoe gross consumption) is also a 
significant source of bioenergy, especially in the electricity sector (2.0 Mtoe final energy). Overall, the 
EU has experienced an increase in the use of MSW for bioelectricity generation since 2010. In 2018, 
Germany was by far the largest consumer of MSW for power generation, accounting for 27% of the 
EU consumption, followed by the UK (16%), Italy (10%), France (10%), the Netherlands (9%) and 
Sweden (7%). 

Renewables in transport 

For the transport sector, the share of renewable energy in 2018 reached 8.0%,7 consisting of: 
•  3,905 ktoe of Annex IX biofuels (double counted  2.5%)8 
•  12,692 ktoe of other compliant biofuels (single counted  4.1%) 
•  52 ktoe of renewable electricity in road transport (five times counted  0.1%) 
•  1,618 ktoe of renewable electricity in rail transport (two and half-time counted  1.3%) 
•  291 ktoe of renewable electricity in other transport modes (single counted  0.1%) 
•  0.04 ktoe of other renewable energy (single counted; <0.0%) 

The largest part of renewable energy in transport is supplied by biofuels. About 35% of EU biofuel 
consumption is in France and Germany. The contribution of renewable electricity in rail (and other 
transport modes) has been growing slowly, mainly because of an increasing share of renewable 
electricity in the electricity mix. Electricity in road transport is small, but slowly increasing. The role of 
other forms of renewable energy in transport, for example in the form of hydrogen, is small. 

After the strong growth in biodiesel consumption in the decade to 2010, consumption in the EU has 
been stable from 2011 to 2016, at between 11 and 12 Mtoe, with only a temporary dip in 2013. In 
2017 and 2018, we again see an increase in biodiesel, with a consumption of 14.2 Mtoe in the EU in 
2018. France, Germany, Spain, followed by Sweden and Italy are the largest consumers of biodiesel 
in the EU.  

In 2016, 41% of biodiesel volume consumed in the EU market came from feedstocks that were 
produced in the EU, mainly from EU rapeseed (26%), UCO (8%), animal fat (5%), soybean (1%) and 
a small fraction that remains unknown. UCO biodiesel also originated from China, South East Asia, 
the USA and other countries. The UCO market has been dynamic and in 2017, China started playing 
an important role as a source of UCO biodiesel consumed in the EU. In addition, about 23% of the EU 
biodiesel volume stemmed from Indonesian (15%) and Malaysian (7%) palm oil. 

EU bioethanol consumption showed a declining trend in the EU from 2011 to 2016 but picked up from 
2016 to 2018. The largest consumers of bioethanol are Germany, France and the UK. About 73% of 
the bioethanol consumed in the EU in 2018 stems from feedstocks that are produced in the EU, 
mainly wheat (34%), maize (24%) and sugar beet (14%) and only a small amount from cellulosic 
ethanol. Non-EU origin feedstocks account for about 27% of the EU bioethanol market, mainly based 
on maize originating from Ukraine, Brazil, the USA and Canada.  

All of the 28 Member States have implemented the Directive’s sustainability criteria in their national 
legislation. Fifteen Member States reported that they have implemented the ILUC Directive already in 
national legislation (see Table 10). One Member State, Bulgaria, mentions that the implementation of 

7 Following the accounting method of the Renewable Energy Directive. 
8 Note that biofuels for transport, as defined in the Renewable Energy Directive, also include biogas. 

 
 
 
                                                      
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the ILUC Directive has started in 2018. The other twelve Member States have not mentioned the 
ILUC Directive, or its national implementation, in their Progress Reports. They have however reported 
to the Commission that the ILUC Directive has been implemented.   

Land used for biofuel production 

Based on a statistical analysis, the land required for the production of EU consumed biofuels in 2018 
is around 3.4 Mha within the EU and 3.8 Mha outside of the EU. This figure is likely higher than the 
actual area used, because conservative data has been used for the conversion efficiencies and 
yields. The 3.4 Mha of cropland used for the production of agricultural raw materials for biofuels 
consumed in the EU in 2018 equals 3% of the total EU cropland of 117 Mha. Rapeseed was the main 
crop used for biofuel production in the EU and represented 72% of the share of the total land used for 
biofuels production.  

On a global level the share of cropland that was estimated to be used for feedstock production for EU 
biofuels is around 0.5%. For the main third countries providing feedstock for EU biofuel consumption 
(Indonesia, Malaysia and Argentina) it is estimated that their share of total cropland used for the 
extraction of feedstocks that were used in the production of biofuels produced or consumed in the EU 
is small. For Indonesia this was just over 1% of their total cropland, while for Malaysia and Argentina 
the land used to produce feedstock for biofuels produced or consumed in the EU, makes up 3.3% of 
the total cropland of these countries. As shown in section 4.4.2, Argentina is the largest exporter of 
biodiesel to the EU in 2018. 

In contrast to these estimates, the Member State Progress Reports indicate a land use of about 
17 Mha used for the production of crops for biofuels, about 59 Mha for short rotation trees and about 
61 Mha for other energy crops. The difference is explained by the facts that  

a)  The land use reported by Member States covers crop production dedicated to total bioenergy use 
including solid, gaseous and liquid biofuels that are consumed in the electricity, heating & cooling 
and transport sectors combined, not just biofuels. 
 Responses sometimes included all land used for these categories of crops, not the share 
specifically dedicated to bioenergy purposes  

b) 

c)  There is not always a direct link to the extent the reported feedstocks are actually used for 

bioenergy purposes within the Member States. Therefore, the combined numbers as reported by 
the Member States are likely to be too high. 

Environmental and socio-economic impacts of biofuels 

The Member State Progress Reports indicate a total greenhouse gas emission saving of 45 Mtonne 
CO2eq in 2018, which is a 14% increase in savings as compared to 2017. Independent analysis 
suggests a slightly smaller total greenhouse gas emission saving of 48.6 MtCO2eq based on the 
consumption of 17,200 ktoe of biofuels displacing the same amount of energy from fossil fuels. None 
of the Member States indicate if the reported greenhouse gas emission savings include or exclude 
ILUC emissions. It is impossible to accurately calculate the ILUC emissions per Member State, 
because this would require an exact insight into the feedstock composition per country, and in 
changing feedstock patterns over time (because ILUC is caused by additional demand and the exact 
impact changes over time). When the 2018 crop feedstock volumes are multiplied with the 
corresponding mean ILUC values from the ILUC Directive, this suggests that the emission savings 
from renewable energy in transport are reduced to 24.0 Mtonne CO2eq (with a range of 18.8-33.8 
Mtonne CO2eq when using the ranges from the ILUC Directive). This is however an underestimation 
of savings, caused by an overestimation of ILUC. The 2000-2010 (historic) ILUC emissions from EU 
grown crops are significantly lower than those for 2010-2020 reported in the ILUC Directive.  

Most Member States ascertain that due to limited domestic feedstock production no significant 
environmental impacts are expected. Those Member States that produce the majority of EU biofuels 

 
 
 
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affirm that the environmental impacts of crop production are expected to be the same regardless of 
the final end use sector, and that these impacts are regulated through horizontal environmental 
legislation (e.g. valid for the whole agricultural sector). Several Member States also refer to the 
voluntary schemes or national systems used to safeguard sustainability impacts, and therefore 
indicate limited sustainability impacts. 

Additional analysis of possible direct environmental impacts related to biofuel feedstock production in 
the main third countries of supply shows that the geographical contexts covered in this report are 
quite heterogeneous and agricultural supply chains tend to be characterised by a high degree of site-
specificity. This means that it is not always possible to say with certainty whether identified risks are 
present in the specific supply chains delivering feedstock for EU biofuels. However, the fact that crops 
used for EU biofuel feedstock must adhere to the sustainability criteria of the Renewable Energy 
Directive should mean that the risks of direct land use change are minimised. Indirect impacts are not 
addressed by the voluntary schemes. 

In recent years no correlation has been observed between food prices and biofuel demand, and any 
impact is likely to be small compared to other dynamics in the global food market. Most Member 
States did not observe any impacts on prices due to increased bioenergy demand within their 
countries. In literature there are causes other than biofuel production identified for increased food 
prices in the period of the food price spikes in 2006–2008 and 2011.  

IRENA estimates that globally, liquid biofuels employed 2 million in 2018, with the majority of jobs in 
planting and harvesting biomass feedstocks. For the EU, it is estimated that the biofuel industry 
employed 208,000 in 2018, making biofuels the third largest renewable energy job creator after wind 
energy and solid biomass (314,000 and 387,000). The countries with the greatest employment related 
to biofuels are Romania (40,000 jobs) and Poland (41,200 jobs) due to their large agricultural land 
area. France is the third largest (29,100 jobs) as it has both biofuel production facilities and feedstock 
production. 

 
 
 
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Table of contents 

1  Introduction 

2. Bioenergy in the EU 

Key findings 
2.1 Overview 
2.2 Progress towards the indicative 2020 NREAP targets 
2.3 Progress towards the 2020 targets for renewable energy in transport 

3. Bioenergy supply 
3.1 Solid biomass 
3.2 Biogas 
3.3 Bioliquids 
3.4 Liquid biofuels 
3.5 Renewable fraction of municipal solid waste 

4. Feedstock for biofuels and their origin 
4.1 Biofuels consumption in the EU 
4.2 Biofuels production in the EU 
4.3 Annex IX biofuels 
4.4 Origin of feedstock used for biofuels consumed in the EU 

5. Environmental impacts related to biofuels 

5.1 Measures taken to respect the sustainability criteria for biofuels 
5.2 Land use and land use changes 
5.3 Greenhouse gas emission savings 
5.4 Local environmental impacts 
5.5 Relevant international conventions 

6. Economic, and social impacts related to biomass 

6.1 Food prices and affordability 
6.2 Labor and (local) employment 
6.3 Impact on other biomass using sectors 

Appendix A. Share of biodegradable fraction of waste 

Appendix B. Availability and use of biomass resources 

Appendix C. Local environmental impacts related to biofuels 

Appendix D. Underlying numbers for graphs in Chapter 3 

Appendix E. Underlying numbers for graphs in Chapter 4 

1 

3 
3 
3 
4 
14 

20 
20 
27 
30 
30 
31 

33 
33 
37 
39 
41 

45 
46 
47 
54 
59 
63 

66 
66 
68 
69 

74 

77 

81 

92 

93 

 
 
 
 
 
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Abbreviations 

CHP  

DME 

EC 

Combined Heat and Power 

Dimethyl Ether 

European Commission  

ETBE 

Ethyl Tert-butyl Ether 

FAME   

Fatty Acid Methyl Ester 

GHG 

HVO 

ILUC 

Greenhouse Gas  

Hydrogenated Vegetable Oil  

Indirect Land Use Change  

ILUC Directive  DIRECTIVE (EU) 2015/1513  

MS 

MSW 

NGO 

Member State  

Municipal Solid Waste 

Non-Governmental Organisation 

NREAP  

National Renewable Energy Action Plan  

RES Directive  Renewable Energy Directive (DIRECTIVE 2009/28/EC)  

REDII 

Recast of the Renewable Energy Directive (DIRECTIVE (EU) 2018/2001) 

RES 

Renewable Energy Sources  

RES-H&C 

Renewable Energy Share in Heating and Cooling sector  

RES-E   

Renewable Energy Share in Electricity sector  

RES-T   

Renewable Energy Share in Transport sector 

Toe  

UCO 

Tonne of oil equivalent 

Used cooking oil 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Terminology for biofuels and their feedstocks 

A large part of this report is about the sustainability of biofuels. Biofuels exist in many sorts 
and can be produced from many types of feedstocks. They can be produced via various 
technologies that already exist for centuries or that are invented rather recently. Biofuels are 
not automatically sustainable. In an effort to distinguish between different types of biofuels, 
stakeholders and individual organisations have applied some definitions that can be useful in 
casual discussions but that often lead to confusion. This is partially because these definitions 
are not mutually exclusive and collectively exhaustive. In other words, some types of biofuels 
could fall in multiple definitions and others fall in none. More importantly, the definitions 
suggest a level of sustainability quality, but the definitions are not suitable for this purpose. It 
is effectively impossible to classify types of biofuels or feedstocks and at the same time rank 
their sustainability performance. 

Advanced biofuels versus conventional biofuels 
These terms should be avoided. Most stakeholders relate the terms to the novelty of 
technology. However, some stakeholders relate these definitions to the type of feedstock and 
consider food crop-based biofuels as conventional. The 2015 ILUC Directive and the recast of 
the Renewable Energy Directive apply a feedstock-based definition and considers both waste 
and algae-based biofuels to be “advanced”. Stakeholders may assume that advanced biofuels 
are more sustainable than conventional biofuels, which is not necessarily correct. 

First generation, second generation, etc. 
These terms should also be avoided. Again, there is confusion over whether the terms should 
relate to the technology or the feedstocks. Following the trend, some emerging conversion 
technologies or feedstocks have been coined third or fourth generation. This causes further 
erosion of the already unclear definitions. 

Definitions in this report 
In this report, we apply the classifications and definitions that are specified by the European 
Renewable Energy Directive of 2009, because this report serves to assist the EC in their 
reporting obligations vis-à-vis this Directive. The Renewable Energy Directive has been 
amended by the ILUC Directive in 2015, which, in response to concerns about Indirect Land 
Use Change (ILUC) introduced new categories and definitions. 

 
 
 
 
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On the one hand, the ILUC Directive limits the contribution of biofuels that are often 
associated with Indirect Land Use Change. On the other hand, the ILUC Directive sets a 
specific sub target for biofuels that are assumed to have a low risk to cause ILUC. The 2018 
recast of the Renewable Energy Directive (REDII) applies similar categories and a sub target. 
Note that (again) the categories cannot be used to understand the true sustainability 
performance, they merely indicate a high or low risk and a subsequent preference of the 
policy makers.  

Therefore, the following categories are used throughout the report: 

•  The ILUC Directive states that “biofuels produced from cereal and other starch-rich crops, 
sugars and oil crops and from crops grown as main crops primarily for energy purposes 
on agricultural land shall be no more than 7% of the final consumption of energy in 
transport in the Member States in 2020.” In the frame of this report, we abbreviate this 
category to “Crop based biofuels”. Their contribution is limited to 7% points of the 
overall 10% target in 2020. Note that the recast of the Renewable Energy Directive  
simplifies this category to “food or feed crops” and at the same time makes the limitation 
dependent on the 2020 achievement per Member State, while low ILUC risk biofuels can 
contribute outside the 7% cap. 

•  The contribution of biofuels produced from feedstocks listed in Annex IX is not limited for 
the reporting until 2020. The recitals of the preamble of the ILUC Directive clarify that 
these biofuels are considered to be “advanced” and that they “provide high greenhouse 
gas emission savings with a low risk of causing indirect land-use change, and do not 
compete directly for agricultural land for the food and feed markets.” Biofuels produced 
from feedstocks listed in Annex IX count twice towards the target and are commonly 
called “double counting biofuels”. Annex IX consists of two parts: 
o  Annex IX A contains a long and diverse list of feedstocks that are considered to be 

more advanced and the Directive sets an indicative target of 0.5% points for 2020. In 
the frame of this report we abbreviate biofuels produced from feedstocks in this 
category to “Annex IX A biofuels”. Note that the recast of the Renewable Energy 
Directive sets a lower initial target of 0.2% in 2022, increasing to 1% in 2025 and at 
least 3.5% by 2030 (after optional double counting). 

o  Annex IX B concerns used cooking oil and animal fats categories 1 and 2. In the 

frame of this report we abbreviate biofuels produced from feedstocks in this category 
to “Annex IX B biofuels”. Note that the recast of the Renewable Energy Directive 
introduces a cap of 1.7% for this category (except for Cyprus and Malta). 

•  Feedstocks not listed in Annex IX that are “determined to be wastes, residues, non-food 

cellulosic material or ligno-cellulosic material by the competent national authorities and 
are used in existing installations prior to the adoption of [the ILUC] Directive” may also be 
counted towards the national target. This implies some additional freedom in the 
interpretation of this category. 

 
 
 
 
 
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Terminology for biomass for all energy purposes 

Some forms of biomass can be used to produce multiple forms of energy. In this report, the 
following definitions apply: 

•  Solid biomass covers solid organic materials of biological origin and relates to the 

physical state before conversion. Solid biomass can include both forest and agricultural 
products, by-products and wastes. In this report, solid biomass is a product aggregate 
covering fuelwood (such as firewood, chips, pellets, logs), wood residues and by-
products, black liquor, bagasse, animal waste and other vegetal materials excluding 
charcoal and the renewable fraction of municipal solid waste (MSW). This report only 
concerns solid biomass that is used as fuel for heat (and possibly cooling) production or 
electricity generation. Energy statistics of Eurostat uses “solid biofuels” term for 
presenting solid biomass. Since “biofuels” in the frame of the Renewable Energy Directive 
are associated with liquid fuels for transport this term should be avoided. 

•  Biogas is gas produced from biomass, mostly via anaerobic digestion and possibly (in 
future) via gasification and methanisation. Biogas also covers (pure) biomethane. This 
gas is currently used either for the generation of heat and power, or it is upgraded to 
natural gas quality and injected into the gas grid. There is increasing interest to use this 
biogas as a fuel for transport. In the statistical reporting of biofuels for transport in this 
report, biogas is inherently included, see below. We aim to clarify this were relevant. 

•  Bioliquids relates to the physical state of a biomass energy carrier. The term is only used 
for liquid biomass that is used to produce power and heat (and possibly cooling). It is 
likely to include vegetable oil, or pyrolysis oil. From a chemical and physical point of view, 
these materials could also be biofuels. Hence, the application is essential in the definition 
of bioliquids.  

•  Biofuels are liquid and gaseous types of bioenergy, for use in the transport sector, 

thereby replacing fossil gasoline, diesel or other fossil energy carriers. 

Terminology for renewable energy in transport 

According to the Renewable Energy Directive, the following energy carriers (when used in 
transport) count towards achieving the 2020 10% target for renewable energy in transport: 

•  Biofuels, with different types as explained above. 
•  Renewable hydrogen, that is hydrogen originating from renewable sources and it 

virtually does not exist yet in the EU. The two main production pathways are electrolysis 
based on renewable electricity and gasification of biomass. 

•  Renewable electricity. 
•  Biogas, as explained above is considered to be a biofuel by the Renewable Energy 

Directive. Please note that this is no longer the case for the REDII.  

•  Fuels produced from renewable electricity (via power-to-gas or power-to-fuels 

technologies) are not specifically mentioned in the Renewable Energy Directive, but in 
principle allowed. They hardly exist yet.  

The renewable energy can be applied in all forms of transport (road, rail, shipping and 
aviation). In practice, most of the biofuels are still applied in the road sector. 

 
 
 
 
 
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1  Introduction 

In 2009, the European Union adopted the first Renewable Energy Directive (also known as the RES 
Directive, or RED I). This Directive established an overall renewable energy target of at least 20% in 
final energy consumption for the EU (which is broken down in national targets) and a 10% target of 
renewable energy in transport for 2020 (which is the same for each Member State). The Directive 
requires Member States to implement policies and measures to reach these targets, and it includes 
EU binding sustainability criteria for biofuels and bioliquids. Member States were required to 
transpose the Directive into national legislation by 5th December 2010.  

The Renewable Energy Directive (Article 22) requires Member States to report every two years to the 
European Commission on progress in the promotion and use of renewable energy and on the 
sustainability of biofuels. The reports cover, amongst others, the aspects listed in Article 22 of the 
Renewable Energy Directive. Member States are also required to deliver other information to the 
Commission, for example Article 18(3) requires that Member States submit aggregated information 
based on the data submitted by economic operators (compliance with sustainability criteria, and 
methods of verification). 

Subsequently, Article 23 requires the Commission to report on the progress in renewable energy and 
on the sustainability of biofuels consumed in the EU. This report should be based amongst others on 
the information submitted by the Member States. The Commission is also required to monitor the 
origin of biofuels and their feedstock and several upstream sustainability effects, as well as 
displacement of land use, impacts on commodity prices and on food security. This 2020 report on 
renewable energy is the next report under this reporting obligation.  

The current report aims to provide technical assistance to the Commission in realisation of the 2020 
report on renewable energy. This report presents data collected and results of analysis on the EU 
biofuel, biomass and biogas markets and on impacts of the EU consumption of biofuels, biomass and 
biogas. This analysis is based on Member State’s Progress Reports submitted in 2019, SHARES and 
other Eurostat statistics, other reports and studies, and additional research.  

The Renewable Energy Directive has been amended by the ILUC Directive (Directive 2015/2013) in 
2015 in response to concerns about Indirect Land Use Change (ILUC) impacts associated with food 
and feed crop-based biofuels. The ILUC Directive introduced new categories related to renewable 
energy in transport and limitations to the contribution of some types of biofuels. In 2018, the 
Renewable Energy Directive (REDII) was recast, now covering the period 2021-2030. In the transport 
sector, this recast Directive, for instance, promotes the deployment of advanced biofuels (defined on 
basis of feedstock listed in Annex IX A of that Directive). Although the recast Directive is not directly 
relevant for the 2017-2018 reporting period, it already starts to impact the market because producers, 
national policymakers and other stakeholders consider the post 2020 regulatory situation for their 
actions in the current market.  

Chapter 2 presents an overview of bioenergy consumption in the EU in the main end-use sectors, 
with insights into the main feedstock categories. The bioenergy consumption in each sector is 
compared to the indicative targets as laid down in the National Renewable Energy Action Plans 
(NREAPs). Also, the role of biofuels in the frame of the 2020 target for renewable energy in transport 
is evaluated.  

In Chapter 3, the supply of bioenergy, including the main forms of bioenergy and their origin, are 
assessed, except for biofuels. 

The feedstocks of biofuels and their geographical origin are assessed in more detail in Chapter 4. 

Building amongst others on the understanding of the geographical origin of biofuels and their 
feedstocks, Chapter 5 analyses the environmental impacts related to biofuels consumed in the EU. 

 
 
 
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The chapter presents details on land use, greenhouse gas emission savings and impacts on air, soil 
and water. This chapter also discusses how sustainability is safeguarded.  

In Chapter 6, the economic and social impacts related to biofuels consumed in the EU are assessed, 
including the impact on food security, employment and impacts on other biomass using sectors.  

6.3Appendix A and 6.3Appendix B present information as reported by Member States in their 
Progress Reports 9, on the biodegradable fraction of municipal solid waste and on the availability and 
use of biomass.  

In 6.3Appendix C, more details are provided on the local environmental impacts from the main crop-
country combinations that supply to the EU biofuels market.  

Appendix D and E give an overview of the numbers underlying the graphs in respectively chapter 
three and four. 

9 Available at https://ec.europa.eu/energy/en/topics/renewable-energy/progress-reports  

 
 
 
                                                      
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2. Bioenergy in the EU 

Key findings 

Bioenergy represents 60% of the 2018 EU gross renewable energy consumption. The 145 Mtoe of 
gross bioenergy delivers a net 85 Mtoe of heat, 16 Mtoe of electricity and 14 Mtoe of biofuels for 
transport. 

Bioheat is mainly generated from solid biomass, including residues from forest management and by-
products and waste from forest-based industries. Over half of the bioelectricity is also generated from 
solid biomass, while biogas delivers about 32%. In contrast, bioenergy in transport is primarily 
generated from biofuels, including biodiesel and a smaller fraction of bioethanol. 

The generation of heat from biomass is quite close to the indicative national sectoral targets set out in 
the National Renewable Energy Plans (NREAPs), while the gap for electricity is smaller in absolute 
numbers, but larger in a relative sense. The gap towards reaching the NREAPs observed for 
bioenergy in transport has decreased from 15.8 Mtoe in 2016 to 13.3 Mtoe in 2018, but still remains 
large. In principle, a sufficient volume of biofuels can be obtained from the (global) market, and the 
gap could be closed quickly if demand was stimulated.  

2.1 Overview 

The majority of gross renewable energy consumption in the EU in 2018 consists of bioenergy 
(145 Mtoe or 60%), followed by hydropower (13%), wind (12%) and solar (6%), see Figure 110. 

The fraction of bioenergy in final renewable energy consumption is smaller because the conversion 
efficiency to electricity is less than 100%. This is further explained in Section 2.2. Although the 
consumption of biomass and renewable waste in 2018 has grown by 4% compared to 2016 in 
absolute terms, its share of gross renewable energy consumption has decreased. This is caused by 
solar and wind energy growing at a faster rate. In addition, in the 2018 version of this report, ambient 
heat was not included in the total renewable energy consumption. Since data on ambient heat 
consumption is now available in Eurostat and consumption is significant at 5% of the gross renewable 
energy consumption, this has been included in Figure 1.  

The growth of renewable energy consumption in the category ‘biomass and renewable waste’ is 
mainly caused by the growth in liquid biofuels, of which biodiesels have shown the fastest growth.  

10 Data in this section is based on Eurostat nrg_bal_c, unless specified otherwise. 

 
 
 
                                                      
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Figure 1. Gross EU consumption11 of renewable energy per type (2018, % and Mtoe).  12 Source: Eurostat nrg_bal_c 

Approximately 58% of the EU gross bioenergy consumption served to generate heat, followed by 11% 
to generate power, while 11% was consumed in the form of biofuels for transport (see Figure 2).13 
Germany was the largest consumer of bioenergy (27.1 Mtoe) followed by France (18.4 Mtoe), Italy 
(16.0 Mtoe), Sweden (13.6 Mtoe) and the UK (13.5 Mtoe).14 

The progress of these sectors (heat, power, transport) compared to the combined indicative targets in 
the National Renewable Energy Action Plans (NREAPs) is discussed in Section 2.2. 

2.2 Progress towards the indicative 2020 NREAP targets 

Figure 2 presents the forms of bioenergy contributing to each of the three end-use sectors of heat, 
power and transport at an EU level in more detail. It compares bioenergy generation in 2018 to the 
sum of 2020 indicative targets set out in all Member States NREAPs. The 145 Mtoe of gross 
bioenergy delivers net 85 Mtoe of heat, 16 Mtoe of electricity and 17 Mtoe energy in transport. The 
total of this net energy is 117 Mtoe. Note that the difference is mainly driven by the efficiency of 
electricity production, as the efficiency of producing heat is close to 100%, and the gross bioenergy 
consumption in transport is expressed as fuels delivered to vehicles. 

The figure shows that the generation of heat from biomass is rather close to the sum of the 2020 
indicative national sectoral targets set out in the National Renewable Energy Plans (NREAPs), while 
the gap is relatively larger for electricity. For biofuels in the transport sector, the gap is large in both 
relative and absolute terms, however, the large gap does not imply per se that the 2020 indicative 
NREAP targets may be difficult to meet. In fact, the EU has more production capacity than necessary 
to bridge the gap, and an even larger supply potential exists in the global market. Therefore, the 
additional volume could in principle be delivered within a year. 

11 Here, “consumption” is measured at the moment the biomass is consumed, e.g. in the production of heat or power, or as a fuel in transport. 
12 The definitions of materials in this dataset slightly differ from those in the Renewable Energy Directive. Eurostat nrg_bal_c provides annual data on the 
“Supply, transformation and consumption of renewable energies”. The category “solid biofuels” (excluding charcoal)” in the Eurostat data coincides with 
“solid biomass” (term consistent with the terminology used by the Directive). Further note that biogas is partially produced from the wet organic (and 
renewable) fraction of municipal solid waste. In that case it is included in the biogas category, and not (anymore) in the waste category. Also, it is important 
to understand that the rightmost category of biofuels does not contain biogas, while part of the biogas in reality can be used for transport. Finally, the 
category “other liquid biofuels” largely overlaps with what the Directive calls “bioliquids”, i.e. liquid bioenergy carriers used for heat or power (not used in 
transport), but also contains a tiny fraction that is being used in transport. More precise insights into the use of bioenergy (and other forms of renewable 
energy) in transport are presented later in the report. 
13 The remaining 19% is due to losses along the supply chain and due to transformation efficiencies. 
14 Eurostat nrg_bal_c. 

 
 
 
 
 
                                                      
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Figure 2. Bioenergy consumption by end use in 2018 versus 2020 NREAPs targets (Mtoe)15 

15 Heating and cooling are reported as final consumption, i.e. the amount of heat and cold effectively delivered. Electricity is reported as gross electricity 
generated. Fuels in transport are reported as final consumption, which implies the energy contained in the biofuels and biogas delivered to vehicles. 
Sources: Bioenergy in electricity generation is based on Eurostat nrg_bal_c, bioenergy in transport is based on Eurostat SHARES and nrg_bal_c. Note that 
Eurostat nrg_ reports on the supply, transformation and consumption of renewable energies, and contains details on the use in transport, distinguishing 
technical variations: biogas, biogasoline, biodiesels, other liquid biofuels and bio jet kerosene. However, these definitions do not comply with the Renewable 
Energy Directive, and it is unclear in how far these fuels comply with the Directive’s requirements. On the other hand, Eurostat SHARES specifically reports 
on the deployment of renewable energy in the frame of the Renewable Energy Directive. SHARES gives details on the deployment of biofuels in transport, 
distinguishing between compliant biofuels and non-compliant biofuels (and some subcategories), but this dataset does not distinguish between technical 
variations. In this chart the total of compliant biofuels reported in SHARES has been combined with the technical fractions reported in nrg_bal_c. Bioenergy 
in heating and cooling is based on 2019 Member State Reports. Eurostat nrg_bal_c reports on the Supply, transformation and consumption of heat. It reports 
a total gross heat production from solid biofuels, biogases, biodiesels, other bioliquids and from the renewable fraction of MSW of only 14.8 Mtoe in 2018. 
This is much lower than what is reported by the Member States in their renewable energy Progress Reports (85 Mtoe in 2018). We do not know the reason 
for the large difference between Eurostat and what Member States report. It is also instructive to consider the Eurostat SHARES dataset, which reports on 
renewable energy in the frame of the Renewable Energy Directive. For heating and cooling, it does not specify the contribution of bioenergy, but reports that 
the final consumption of renewable energy in heating and cooling is 75.9 Mtoe and the amount of (additionally) “derived heat” is 15.1 Mtoe (and heat pumps 
amount to 12.0 Mtoe). Understanding that renewable heating and cooling mainly concerns bioenergy and that other options are largely limited to solar 
heating, we think the total of bioenergy in heating and cooling can be expected to be close to the 91.0 Mtoe total in SHARES. Hence, in this chart, the 
amount of bioenergy for heating and cooling has been based on the Member State Progress Reports. Indicative NREAP targets are based on ECN collection 
of data provided in the Member State National Renewable Energy Action Plans (NREAPs) available via www.ecn.nl/nreap (update 2011). 

 
 
 
 
 
                                                      
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The development of bioenergy in the three sectors over time is shown in Figure 3, where it is 
compared to the sum of indicative sectoral NREAP trajectories. The development of bioenergy for 
heating in the EU has been continuously ahead of the trajectory, but the volume has stabilized since 
2017, decreasing the gap with the trajectory. To reach the 2020 NREAP target for bioheat, a 
compound annual growth rate of 3.2% is needed, while the annual growth rate over the period 2014-
2018 has been 3.8%. The development of biobased electricity generation has been on track, but 
since 2015, the growth has been too slow to keep up with the trajectory. In 2018, 16.2 Mtoe of 
electricity was produced from bioenergy, while the indicative sectoral NREAP trajectory lies at 17.6 
Mtoe. To reach the 2020 NREAP targets for bioelectricity, a compound annual growth rate of 11.1% is 
needed, while the annual growth rate over the period 2014-2018 has only been 3.1%. The 
development of biofuels in transport has been continuously behind trajectory. Therefore, the total 
contribution of bioenergy does not reach the sum of the sectoral trajectories. To reach the 2020 
NREAP target, a compound annual growth rate for bioenergy in the transport sector of 34% is 
needed, while this rate has been 7.9% over the period 2014-2018. 

Figure 3. Development of bioenergy consumption per subsector in the EU (bars for the years 2010-2018) and 
compared to the sum of indicative NREAP trajectories (lines) and 2020 NREAP targets (bar)16 

2.2.1 Bioenergy in Heating and Cooling 

In practice, bioenergy for heating and cooling concerns only heating. 17 This heating is mainly 
produced from solid biomass (95%), as indicated in Figure 2 (Section 2.2). There was also a small 
contribution from biogas (4.7%), and an even smaller one from bioliquids (0.7%). Figure 4 shows 
details per Member State.  

16 Note that bioenergy in heating and cooling and transport are reported as “final consumption”, in electricity is reported as “gross electricity generation” 
Sources: Bioenergy in electricity generation based on Eurostat nrg_bal_c, bioenergy in transport based on Eurostat SHARES and nrg_bal_c, bioenergy in 
heating and cooling based on 2019 Member State reports, and indicative NREAP targets based on analysis by ECN. See footnotes at the caption of Figure 2 
for more information on these sources. 
17 The generation of cooling based on bioenergy was not observed, although trigeneration systems can use biomass combustion. Cooling on basis of 
renewable electricity can of course involve bioenergy. 

 
 
 
 
 
 
                                                      
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Germany (14% of EU total) and France (12%) consume the most heating from bioenergy, followed by 
Sweden, Italy and Finland (all 9%). In most Member States, the deployment of bioenergy in heating in 
2018 is already close to their 2020 indicative NREAP sectoral targets. France and Sweden, however, 
still face a large gap between the 2018 achievement and their indicative NREAP sectoral target. For 
the EU as a whole, a compound annual growth rate of 3.2% is needed for the period 2018-2020 to 
reach the 2020 NREAP target. This is slightly below the 3.8% compound annual growth rate seen for 
bioenergy in the heating and cooling sector in the period 2014-2018, but growth will have to pick up 
again as volumes have stabilised from 2017 to 2018. 

Figure 4. Bioenergy consumption in heating versus NREAP 18 (2018, ktoe). Source: MS Progress Reports, ECN19 

As bioenergy for heating is mainly produced from solid biomass, the largest consumers of biobased 
heating are also the largest consumers of solid biomass: Germany, France, Sweden, Italy and 
Finland. All of these five countries rely on more than 80% domestic production of solid biomass 
consumed for heat and power generation. For the total EU, domestic production of solid biomass is 
90% of the total market, which is discussed in more detail in Section 3.1.2. It is not possible to provide 
separate insights into the sourcing for both applications (heat and power). The largest biomass 
importer was the UK, responsible for 64% of EU wood pellet imports (8.5 million tonnes), of which the 
majority (7.8 million tonnes) was for power production at Drax and Lynemouth power plants.20 

The most important third countries supplying wood pellets to the EU were the USA (close to 60% of 
imports), Canada and Russia (about 15% of imports each). A more detailed analysis of the EU 
production and consumption of solid biomass, feedstocks and their origins is presented in Section 3.1. 

Biogas in the EU is primarily produced by anaerobic digestion of waste streams. Almost half of the 
heating based on biogas occurs in Germany and is mainly generated by farm based anaerobic 
digestion. Crops such as maize, sugar beet and cereals are used as co-digestate at farm level. It is 

18 2020 indicative NREAP sectoral targets for bioenergy in heating. 
19 www.ecn.nl/nreap (update 2011). 
20 Bioenergy Europe Statistical Report (Pellet) 2019 – Bioenergy Europe and European Pellet Council 

 
 
 
 
 
                                                      
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also possible to produce biogas via gasification of solid biomass, but this was not done at a 
commercial scale in 2018.  

There is insufficient data to understand the origin of the feedstock for digestion. However, it is not 
economic to transport feedstock for digestion over large distances and therefore it can be assumed 
that all feedstock was sourced from the EU. 21 In terms of consumption, all the biogas produced in the 
EU was consumed domestically. A more detailed analysis of biogas is given in Section 3.2. 

The small use of bioliquids for heating is mainly located in France (43%), Germany (31%) The 
Netherlands (15%) and Italy (8%). The exact nature of these bioliquids is unknown. They likely 
concern mainly vegetable oils and crop-based biofuels similar to those used in transport, and some 
pyrolysis oil. 

2.2.2 Bioenergy in Electricity generation 

At the EU level, the contribution of bioenergy to renewable electricity has increased in absolute terms, 
but slightly decreased in relative terms to approximately 18% in 2018, after remaining stable around 
19% between 2012 and 2016 (see Table 1). This is caused by the faster growth of the total renewable 
electricity generation, driven by the strong growth in solar and wind power.  

Until 2015, the total bioelectricity consumption grew with annual growth rates above 6%. In the years 
following, growth slowed to rates below 3%, with 2.6% in 2018. To reach the 2020 NREAP target of 
20 Mtoe, 22 a compound annual growth rate of 11% is needed for the period 2018-2020.  

In 2018, bioenergy was the third largest contributor of all forms of renewable electricity, behind 
hydropower (36%) and wind energy (36%), and ahead of solar power (12%). The share of bioenergy 
in total power production increased between 2012 and 2018. This was primarily caused by an 
increase in bioelectricity production, combined with a decrease in overall power production. Although 
total power generation has been increasing since reaching a lowest point in 2014, the generation of 
bioelectricity has grown faster in comparison. 

Bioelectricity is sourced primarily from solid biomass (8.6 Mtoe in 2018) and biogas (5.2 Mtoe). The 
renewable fraction of municipal solid waste (MSW) has a smaller role (1.0 Mtoe) and bioliquids are 
negligible (0.4 Mtoe). The following table shows that both in absolute and in relative terms, biogas and 
solid biomass were the main drivers of growth in bioelectricity. 

21 Part of the feedstock for biogas production is considered to be waste (such as manure) and it is not economically attractive to import. The original 
commodities from which the waste was ultimately produced may have been imported, but this is not relevant for the current analysis. Note that co-digestion 
of crops could in principle be done with imported crops, but this is highly unlikely since anaerobic digestion takes place decentral, for instance at farms and it 
would not be competitive to bring imported crops “back” to farms for biogas production. 
22 Indicative NREAP target based on ECN collection of data provided in the Member State National Renewable Energy Action Plans (NREAPs) available via 
www.ecn.nl/nreap (update 2011). 

 
 
 
 
                                                      
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Table 1. Bioelectricity consumption (2012 - 2018, ktoe). Source: Eurostat SHARES, Eurostat nrg_bal_c23 

Solid biomass 

Biogas 
Renewable fraction of MSW1 
Bioliquids2 

Total bioelectricity 

Total of renewable electricity 

Total generated power  

2012 

6,758  

4,048  

1,577  

303  

2013 

6,906  

4,629  

1,600  

369  

2014 

7,270  

4,969  

1,694  

414  

2015 

7,867  

5,181  

1,771  

473  

2016 

7,905  

5,280  

1,818  

455  

2017 

8,150  

5,306  

1,908  

429  

2018 

8,555  

5,247  

1,973  

423  

12,686  

13,504  

14,348  

15,291  

15,459  

15,793  

16,198  

66,430  

70,997  

75,074  

79,966  

82,562  

86,476  

90,285  

282,937   280,325   273,745   277,718   279,863   281,648   281,598  

Share of renewable energy in power sector (%) 

Share of bioenergy in renewables total (%) 

Share of bioenergy in power sector total (%) 

Growth from previous year (%) 

23.5% 

19.1% 

4.5% 

11.5% 

25.3% 

19.0% 

4.8% 

6.4% 

27.4% 

19.1% 

5.2% 

6.2% 

28.8% 

19.1% 

5.5% 

6.6% 

29.5% 

18.7% 

5.5% 

1.1% 

30.7% 

18.3% 

5.6% 

2.2% 

32.1% 

17.9% 

5.8% 

2.6% 

1 MSW: Municipal Solid Wastes 
2 Sum of biodiesel and “other bioliquids” (presumably this includes raw vegetable oil and pyrolysis oil). 

Figure 5 shows the total bioelectricity consumption by Member State. Germany (27% of EU total) is 
the largest consumer of bioelectricity, followed by UK (17%) and Italy (10%). These Member States 
have already achieved their 2020 indicative NREAP targets, however, many others still face a large 
gap between the 2018 achievement these targets. The largest absolute gaps between the 2018 
achievement and the indicative 2020 sectoral NREAP targets are seen in The Netherlands, France 
and Poland. However, in the Netherlands, solid biomass for bioenergy production (wood chips and 
pellets) is expected to increase by 500,000 tonnes from 2018 to 2020 based on allocated national 
subsidies.24  

Some biomass power plants that have been granted subsidies have not yet started bioelectricity 
production due to delays caused by public opinion. In the first four months of 2020 bioelectricity 
production was approximately 190 ktoe25. If extrapolated to the remaining eight months, this would 
imply 570 ktoe in 2020, which is well below the NREAP projection. In Poland’s NREAP projections, 
biogas needs to grow 168% from 2017-2020 compared to only 8% for solid biomass.26 Although there 
are quite some current developments in Poland in the field of biogas and the use of solid biomass in 
former coal power plants 27, these projects are not expected to come online by 2020. Therefore, it can 
be expected that it will be difficult for Poland to fulfil its NREAP projections for bioelectricity.28  

Based on France’s NREAP projections, it appears that solid biomass for bioelectricity production is 
lagging, as it was projected to produce four times more bioelectricity than from biogas. Recent market 
developments show that one biomass power plant has come online in 2019, and a second is 
expected in 2022, but it is unsure if this will be sufficient to fill the gap towards NREAP projected 
bioelectricity production by 2020.29 

23 Data for total renewable and total generated power are based on Eurostat SHARES; data for solid biofuels, biogas, renewable MSW, bioliquids and total 
bioenergy are based on Eurostat nrg_bal_c. 
24https://apps.fas.usda.gov/newgainapi/api/report/downloadreportbyfilename?filename=The%20Dutch%20Industrial%20Market%20for%20Biomass_The%20
Hague_Netherlands_2-5-2019.pdf 
25 https://opendata.cbs.nl/statline/#/CBS/nl/dataset/84575NED/table?ts=1595416251791 
26 Poland National Renewable Energy Plan, Table 10a (2010). 
27 https://bioenergyinternational.com/heat-power/ze-pak-selects-valmet-to-convert-lignite-fired-boiler-to-biomass 
28 To note that both the Polish Progress Report comments on actions taken to reduce barriers for the production of renewable energy such as optimisation of 
support schemes.   
29 http://biomassmagazine.com/articles/15900/france-considers-biomass-conversion-of-cordemais-power-plant 

 
 
 
  
 
                                                      
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Figure 5. Bioenergy consumption for electricity versus NREAP 30 (2018, ktoe). Source: Eurostat nrg_bal_c, ECN31 

As discussed in the previous section, most of the solid biomass consumed in the EU originates from 
the EU, with only approximately 10% being imported.32 Solid biomass is traded within Europe and the 
market and details for feedstocks are discussed in Section 3.1. In the previous section, it was also 
explained that it is likely that all biogas feedstocks originate from the EU since it is uncommon to trade 
these types of feedstock over larger distances. 

The third largest source for bioelectricity generation after solid biomass and biogas is the renewable 
fraction of Municipal Solid Waste (MSW). Overall, the EU has experienced an increasing trend in the 
use of MSW for bioelectricity generation (see Table 1). In 2018, Germany was by far the largest 
consumer of MSW for power generation, accounting for 27% of the EU consumption followed by the 
UK (16%), Italy (10%), France (10%), the Netherlands (9%) and Sweden (7%). Most of this feedstock 
is domestically produced, although some countries such as Sweden, Germany, and the Netherlands 
with overcapacity of waste-to-energy plants import waste from other EU Member States, primarily the 
UK which exported 3.13 million tonnes of solid recovered fuels (SRF) or refuse derived fuels (RDF).33 
The Netherlands, however, has imposed a tax on imported waste as of 1 January 2020 which is 
expected to increasingly diminish waste imports in the coming years. 34 

Bioliquids only have a small role in the generation of bioelectricity compared to solid biomass, biogas 
and MSW. Their deployment is almost limited to Italy and mainly concerns vegetable oils, including 
some imported palm oil. 

Figure 6 shows the role of biomass in electricity consumption for each Member State in 2017 and 
2018. Typically, the share of bioelectricity in total electricity production is above average in more 
northern located countries (Denmark, Finland, Estonia, Latvia, the UK, Germany and Sweden), 

30 2020 indicative NREAP sectoral targets for bioenergy in power. 
31 www.ecn.nl/nreap (update 2011). 
32 Note that the 10% is based on total imports. Net import would be 5%. 
33 https://www.letsrecycle.com/news/latest-news/rdf-exports-plateau-2017/ 
34 https://www.euwid-recycling.com/news/policy/single/Artikel/netherlands-will-apply-hefty-tax-to-rdf-imports-as-of-2020.html 

 
 
 
 
 
                                                      
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whereas several southern located countries sparsely use biomass in renewable electricity production 
(Malta, Greece, Cyprus, Romania). In some countries, this relates to the domestic resource base, 
such as the large forestry industry in countries such as Finland, Estonia, and Latvia and the extensive 
use of straw from the agricultural sector in Denmark. However, other factors, such as the deployment 
of combined heat and power or the phasing out of coal could trigger the use of biomass for electricity 
production. The UK does not have a large solid biomass resource basis, and as we will see in Section 
3.1, mostly relies on imports in order to fuel the Drax and Lynmouth biomass power plants.35 Bulgaria 
has seen a large increase between 2017 and 2018, mainly caused by a large increase in solid 
biomass use for electricity. As indicated in their Progress Report, this was due to the transition of 
existing plants from conventional fuels to solid biomass.  

Figure 6. Bioelectricity share in total electricity production (2017-2018, %). Source: Eurostat nrg_bal_c and SHARES 36 

2.2.3 Bioenergy in Transport 

Bioenergy in transport is discussed in Section 2.3, where the progress towards the 2020 10% target 
for all Member States for renewable energy in transport is assessed. This analysis takes into account 
the other forms of renewable energy and the multiple counting options as specified in the Renewable 
Energy Directive. Section 2.3 is mainly based on the Eurostat SHARES dataset as this was 
specifically developed for the renewable energy reporting in the framework of the Directive. In this 
section, the absolute amounts of bioenergy are discussed based on a different Eurostat dataset 

35 Bioenergy Europe Statistical Report – Pellet 2019 – European Pellet Council. 
36 Eurostat SHARES reports the production of electricity from solid biofuels, but it does not give information about the other subcategories. These other 
categories are reported by Eurostat nrg_bal_c. Note that Eurostat nrg_bal_c and SHARES report similar values for solid biofuels and for the total RES-E 
denominator, which suggests that nrg_bal_c is a reliable source for renewable energy in electricity generation. Bioliquids (the term used in the Renewable 
Energy Directive) is taken as the total of the categories “biodiesels” and “other liquid biofuels”. Solid biomass equals the category solid biofuels in nrg_bal_c. 

 
 
 
 
 
 
                                                      
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(nrg_bal_c), which does not distinguish between the different sustainability categories, but does 
provide more insight into the material forms of bioenergy.37 

Table 2 below shows the final bioenergy consumption in the EU transport sector in 2018. Over 99% of 
this bioenergy was consumed in road transport. There is a small use of biodiesel in rail transport (12 
ktoe in Germany, 5 ktoe in Czechia) and a smaller use of biogasoline 38 and biodiesel in domestic 
navigation. Although the use of bioenergy in domestic aviation is reported to be zero, multiple airlines 
are trialling biojet fuels. IATA Environment estimates that 30 million litres of sustainable aviation fuel 
(SAF) was consumed globally in 2019. No details are available for the share of this consumption 
taking place in the EU.39 The majority of this is biojet fuel and only a very small fraction is produced 
from non-biomass feedstocks such as industrial off-gasses. From 2020 onwards, Member States will 
be asked to separately report on biofuel consumption in aviation. 

The majority (99%) of the bioenergy consumption in transport is from liquid biofuels, mainly 
biogasoline and biodiesel. A small amount of biogas is consumed in road transport in Sweden (118 
ktoe), Germany (33 ktoe) and Norway (18 ktoe). 

Table 2. Total final bioenergy consumption in EU transport sub-sectors (2018, ktoe). Source: [Eurostat nrg_bal_c]1)  

d

i
l

o
S

s
l
e
u
f
o
b

i

s
a
g
o
B

i

e
n

i
l

o
s
a
g
o
B

i

l
e
s
e
i
d
o
B

i

i

d
u
q

i
l

r
e
h
t
O

s
l
e
u
f
o
b

i

t
e
j

i

o
B

e
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o
r
e
k

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d
u
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L

i

l
a
t
o
T

s
l
e
u
f
o
b

i

l
a
t
o
T

Road 
Rail 
Domestic aviation 
Domestic navigation2) 
Non-specified transport 
Total 

2,997.2  
0.0  
0.0  
2.0  
0.0  
2,999.2  
1) Eurostat categories “charcoal” and “municipal solid waste” are excluded from the table, as they are not consumed in transport according to Eurostat 
nrg_bal_c. Eurostat category “consumption in pipeline transport” consumes no biofuels and has been excluded from the table. Total of liquid biofuels is the 
total of biogasoline, biodiesels, other liquid biofuels and bio jet kerosene. Unlikely combinations (e.g. solid biofuels in aviation) are indicated with “-”. 
2) Domestic navigation includes all the quantities delivered to vessels of all flags within Europe as well as inland navigation and yachting.  

13,629.9  
26.3  
0.0  
5.0  
5.6  
13,666.7  

16,627.8  
26.3  
0.0  
6.9  
5.6  
16,666.6  

153.8  
0.0  
- 
0.0  
0.0  
153.8  

0.7  
0.0  
0.0  
0.0  
0.0  
0.7  

- 
- 
0.0  
- 
0.0  
0.0  

- 
0.0  
- 
- 
- 
0.0  

16,781.7  
26.3  
0.0  
6.9  
5.6  
16,820.5  

Figure 7 shows the 2018 consumption of bioenergy in transport by Member State and fuel type 
compared to the 2020 NREAP targets. In absolute volumes, France and Germany are the largest 
consumers of bioenergy in transport, followed by Spain, Sweden, the UK and Italy.  

For most Member States, 2018 volumes of bioenergy used in transport have not yet reached the level 
of the 2020 indicative targets set in their NREAPs. Some Member States like the UK, Spain, Italy and 
Poland are still far from their indicative 2020 NREAP targets, while others may reach their targets 
within the next few years. Sweden and especially Germany have surpassed the level of their original 
NREAP targets by far.  

37 Eurostat nrg_bal_c reports on the Supply, transformation and consumption of renewable energies. For transport it only reports contributions from biomass, 
and the results of other forms of renewable energy are reported to be zero. From the specific reporting on the share of renewable energy in transport in the 
SHARES Eurostat dataset it is clear that renewable electricity plays some role. However, this is not recognised in set nrg_bal_c. 
38 Eurostat nrg_bal_c reports amongst others on biogasoline. Eurostat definitions and glossary do not give insight into what exactly is included in biogasoline. 
Market insights make clear this must mainly concern bioethanol. 
39 Personal communication with IATA Environment, May 2020.  

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
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It should be noted that although Member States have set indicative sectoral trajectories for the 
introduction of bioethanol, biodiesel and other biofuels in their NREAPs, their policies for the reporting 
years were rather driven by the 10% overall target for renewable energy in transport, as well as the 
anticipation of de facto lower targets in the REDII, as is analysed in the next section. 

Figure 7. National consumption of bioenergy in transport in 2018 versus 2020 NREAP targets. Source: ECN40, Eurostat 
nrg_bal_c 

40 www.ecn.nl/nreap (update 2011). 

 
 
 
 
 
                                                      
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2.3 Progress towards the 2020 targets for renewable energy in 

transport 

Renewable energy use in transport, known as RES-T, reached an 8.0%41 share in 2018, having 
continuously increased since 2004 (apart from an accounting decline registered in 2011-201247).  

As shown in Table 3, biofuels 42 represent most of the renewable energy consumed in transport, 
largely in the form of biodiesel43 (81%), followed by bioethanol (18%) - directly replacing fossil diesel 
and gasoline respectively. Gaseous biofuels represent only a minor share (1%). 

Table 3. Share of renewable energy in transport (2018). Source: Eurostat SHARES1) 

Annex IX biofuels 
Other compliant biofuels2) 
Non-compliant biofuels 
Renewable electricity in road transport 
Renewable electricity in rail transport 
Renewable electricity in other transport modes 
Other renewable energy 
Total RES-T numerator 
Total RES-T denominator 

Real 
deployment 
(ktoe) 

Multiplication 
factor 

Administrative 
contribution 
(ktoe) 

Resulting  
RES-T share 

3,905  
12,692  
88  
52  
1,618  
291  
0.04  

2 x 
1 x 

5 x 
2.5 x 
1 x 
1 x 

7,810  
12,692  
0  
260  
4,045  
291  
0.04  
25,098  
312,706  

2.5% 
4.1% 
0.0% 
0.1% 
1.3% 
0.1% 
0.0% 
8.0% 

1) 

2) 

Numbers for real deployment and administrative contribution (after applying multiplication factors) towards the 2020 sum of 10% Member States 
target of the Renewable Energy Directive. 
 “Other compliant biofuels” includes biofuels that fulfil the sustainability criteria but that are not categorized as “Annex IX” by the ILUC Directive. 

The share of renewable energy in transport has grown from 6.9% in 2016 to 8.0% in 2018. To meet 
the 2020 sum of Member States targets of 10% renewable energy in transport, the share needs to 
increase at a rate of 12% in the coming years, which is higher than the growth rate of 8% over the 
past two years.  

In the Renewable Energy Directive, the concept of double counting biofuels was introduced. Initially 
this concerned “wastes, residues, non-food cellulosic material, and ligno-cellulosic material” while the 
2015 ILUC Directive introduced a list of specific feedstocks in what became Annex IX of the 
Renewable Energy Directive. Most Member States have by now adopted legislation to increase the 
market value of double counting biofuels, 44 and this has triggered a strong increase in the sales of 
these fuels, in particular for biodiesel from used cooking oil, tall oil, and waste-based biogas (see 
Section 4.3). The share of these fuels has again grown in the period 2016-2018 and now represents 
2.5% of the RES-T, after double counting.  

Today, these Annex IX biofuels account for over one third of the biofuel share (after double counting). 
The “other compliant biofuels” concern biofuels that fulfil the sustainability criteria, but that are not 
categorised as “Annex IX”. It includes biofuels from a range of feedstocks according to Article 3(4)d 
and e of the ILUC Directive.45 

41 Following the accounting method of the 2009 Renewable Energy Directive, the share of renewable energy in transport is established by dividing the total 
amount of renewable energy in transport (numerator) by the total amount of all energy in transport (denominator). The numerator concerns all types of 
energy from renewable sources consumed in all forms of transport. The denominator concerns only petrol, diesel and biofuels consumed in road and rail 
transport, plus electricity in all transport. This means the scope of the numerator and denominator is slightly different. Furthermore, a multiplicator is applied 
to some forms of renewable energy: biofuels produced from waste feedstocks count double, electricity in rail counts 2.5 times, and electricity in road 
transport counts 5 times. 
42 Note that biofuels for transport, as defined in the Renewable Energy Directive, also includes biogas. 
43 Note that hydrotreated vegetable oil (HVO) and hydrotreated crude tall oil (HCTO) are included in the biodiesel category. 
44 It is necessary to distinguish between the double counting rule in the Renewable Energy Directive and support measures in national legislation. The former 
implies that Member States may double count the contribution of these fuels towards the national targets (and in their bi-annual reporting to the EC). Member 
States can translate this double counting possibility to incentives, for instance by allowing economic operators to double count Annex IX fuels towards their 
blending mandates. Note that Member States do not have to support this type of fuels, as long as the national targets are met.  
45 Article 3(4)d: […] “biofuels produced from cereal and other starch-rich crops, sugars and oil crops and from crops grown as main crops primarily for energy 
purposes on agricultural land” […]. Article 3(4)e: […] ” biofuels made from feedstocks not listed in Annex IX that were determined to be wastes, residues, 
non-food cellulosic material or ligno-cellulosic material by the competent national authorities” […]. 

 
 
 
  
  
  
  
  
  
  
 
                                                      
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Figure 8. Historical overview of renewable energy in EU transport. 46 Source: Eurostat SHARES 47 

The contribution of renewable electricity in rail (and other transport modes) has been growing slowly, 
mainly due to an increasing share of renewable electricity. In  Figure 8, the contribution is 
considerable, but note that electricity in rail is counted 2.5 times. Renewable electricity in road 
transport is negligible, but slowly increasing (further discussed below).  

After years of strong growth between 2005 and 2010 (0.6 percentage point per year on average), 
since 2012 the share of renewable energy in transport grew at a slower pace (0.4 percentage point 
annually on average), with a higher growth in 2018. In the former period, the development was mainly 
driven by attractive tax support policies. In the latter period, the development slowed down, mainly 
because national blending mandates were set just above what was already achieved. In the largest 
market, Germany, the support instrument changed from a blending mandate to a CO2 emission 
reduction mandate, which de facto led to the use of biofuels with higher greenhouse gas savings, 
while requiring less volumes to achieve the same savings.48  

In 2015, the ILUC Directive came into force, amending the Renewable Energy Directive and 
introducing a 7% cap on the share of food and feed crop-based biofuels and a non-binding national 
target for advanced biofuels of 0.5% by 2020 (sources from feedstock lister in Annex IX, part A49). In 
some Member States, this 7% limit was already almost reached in 2016 (Bulgaria, France, Austria 

46 Numbers after application of multipliers for renewable electricity and Annex IX biofuels in line with the ILUC Directive. 
47 Note that data for Annex IX biofuels is only available from 2010 onwards. The dip in 2011 (and to a lesser extend 2012) is mainly caused by the change in 
reporting requirements. Until 2010, all biofuels were counted towards the RES and RES-T shares. From 2011 onwards, Member States are only allowed to 
report biofuels and bioliquids that are compliant with the sustainability criteria set out in Article 17 and 18 of the Directive 2009/28/EC. Many Member States 
(Bulgaria, the Czechia, Estonia, Spain, France, Croatia, Cyprus, Finland, Portugal and Romania) were late in their late transposition and implementation of 
Directive 2009/28/EC and therefore not able to verify or administrate the compliance of the biofuels in their markets with the sustainability requirements. As a 
result, they could only report non-compliant biofuels which are not shown in the graph. 
48 The total volume of compliant biofuels in Germany decreased from 2,939 ktoe in 2012 to 2,548 ktoe in 2016, and this is not compensated by the increase 
in Annex IX double counting biofuels (from 412 ktoe to 623 ktoe) [Eurostat SHARES]. From 2014 to 2016, the average greenhouse gas emission per unit of 
biofuels has decreased from 41 g/MJ to 19 g/MJ. This is not only caused by the partial switch to waste based biofuels. For instance, in 2016, 82% of all corn 
ethanol sold in the German market achieved >65% emission reduction in comparison to the old fossil comparator of 83,8 g CO2eq/MJ. Even 95% of all 
rapeseed biodiesel sold in the German market achieved >65% emission reduction [BLE 2016, Evaluations und Erfahrungsbericht für das Jahr 2015, 
Biomassestrom-Nachhaltigkeitsverordnung & Biokraftstoff-Nachhaltigkeitsverordnung, Bundesanstalt für Landwirtschaft und Ernährung, Bonn Germany]. In 
2018, the total volume of compliant biofuels increased to 2686 ktoe, of which the Annex IX biofuels have increased to 792 ktoe [Eurostat SHARES]. 
49 The term “advanced biofuels” is often used to indicate types of biofuels that are either produced via technologically more advanced production pathways 
(compared to traditional fermentation of sugars or starch, or to the (trans) esterification of vegetable oils), or that are produced from non-food crop biomass. 
The definition is ambiguous and often disputed. In the frame of the current report, we use “advanced biofuels” to indicate biofuels made from feedstock as 
listed in Annex IX A of the ILUC Directive EU 2015/1513.  

 
 
 
 
 
                                                      
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and Slovakia) and these countries did not further raise their demand for these crop-based biofuels 
above the 7%. Please note that in the REDII, additionally a cap on Annex IX B biofuels was added, 
but it is not valid for this 2020 reporting period. 

Support measures for Annex IX A biofuels still largely need to be developed. The supply of Annex IX 
A biofuels still comes from a limited number of producers. One of the reasons for this is that it is 
technically more difficult and consequently costly to develop new production capacity. The progress of 
these Annex IX A biofuels is discussed in Section 4.3. 

Used cooking oil (UCO) is one of the feedstocks included in the double counting list of Annex IX 
(specifically in the capped amount of Annex IX B feedstocks). There has been concern that the 
attractiveness of double counting biofuels would stimulate the production of waste oils beyond their 
autonomous potential. The EC identified a risk of fraud50 in situations where the value of double 
counting biofuels would become very high, and the value of used cooking oil could become higher 
than that of fresh vegetable oil. This could drive operators to fraudulently relabel fresh oil to used 
cooking oil without cooking it. There is also a risk of fraud further down the supply chain as the 
material price increases and larger volumes are traded. This includes, for example, selling non-
sustainable material as sustainable or the relabelling of material.  

In addition, used cooking oils are not always considered to be a waste material in all the countries 
where it is sourced from. For instance, in the USA, UCO is used in animal feed, and its use in EU 
biofuels could lead to fresh vegetable oil replacing this UCO. To address these concerns on stretching 
the demand for UCO, the REDII limits the contribution of fuels from Annex IX B feedstocks to a 
maximum of 1.7%.51 The global potential for waste oils is sufficient to provide feedstock for EU 
biofuels up to this limit. Within Europe, the potential from restaurants is around 800 ktonne per year, 
of which over 80% is already collected. Germany, the UK, Spain and Italy are key markets, 
collectively representing over 50% of the potential. Currently, the potential of UCO from European 
households is estimated to be around 850 ktonne per year, however only about 6% (less than 50 
ktonne) of this is currently being collected.52 

The feedstocks for biofuels and their geographical origin are discussed in more detail in Section 4.4. 

Figure 9 gives more detail on the application of renewable energy in transport in the Member States. 
It shows that some countries have already achieved the level of their RES-T targets and the RES-T 
increased in most Member States from 2017 to 2018, but that many Member States still have a large 
gap to fill to reach the 2020 target.  

• 

In 2018, Sweden and Finland already achieved the level of their 2020 RES-T target by 
achieving shares of 30% and 15% of renewable energy in transport, respectively. In Finland, most 
of the RES-T was from Annex IX biofuels (double counted biofuels, including the multiplicators) 
and in Sweden it stemmed mainly from use of other compliant biofuels (single counted biofuels). 
o  After a strong dip in 2016, Finland recovered to target level in 2017 and 2018. The dip in 
2016 was probably caused by a new law that caps the options for transferring surpluses 
(administratively) to the following years (making it less attractive to surpass the mandated 
volumes). In 2016, the government announced to increase the share of biofuels in road 
transport fuels to 30% by 2030. 53 Also, the Act on promoting the use of biofuels for transport 
in Finland sets an obligation of 20% in 2020. The 2017 and 2018 values (respectively 19% 
and 15%) show a recovery and achievement above target, although they still demonstrate 
fluctuations.  

50 The European Commission letter, on the 10th October 2014, to Voluntary Schemes have been recognised by the Commission for demonstrating 
compliance with the sustainability criteria for biofuels https://ec.europa.eu/energy/sites/ener/files/documents/2014_letter_wastes_residues.pdf 
51 Member States can individually modify this limit, subject to the approval of the Commission. 
52 Analysis of the current development of household UCO collection systems in the EU, Greenea, 2016. 
53 Reuters, 2016 November 24, Finnish government lifts biofuel targets. 

 
 
 
                                                      
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o  Finland is also the country with the largest share of Annex IX biofuels, which mainly include 

HVO biodiesel produced from waste oils and residues.54 

o  Since 2016, Sweden remained relatively stable at 30% of RES-T. The major part comes 
from the use of other compliant biofuels (18%) and Annex IX biofuels (7%). The use of 
renewable electricity in trains contributes 5% (all numbers administratively, i.e. after the 
multiple counting). 

•  From 2017 to 2018, RES-T increased in most Member States, which is mainly caused by an 

increase in the use of Annex IX type biofuels that are double counted and other compliant biofuels 
(single counted biofuels).  
o  The Netherlands showed a significant increase in RES-T. This was driven by an increase in 
the use of double counting Annex IX biofuels. According to the Dutch Progress Report, this 
was primarily caused by a ‘sharpening’ of national regulation on renewables in transport. 

•  However, many Member States still have a large gap to fill to reach to 2020 target. 

o  Despite an increase from 2017 to 2018, the UK has the largest gap in absolute terms to reach 
the 2020 target. The target still has the potential to be met due to the updates made to the 
Renewable Transport Fuel Obligation (RTFO) Order in 2018, which significantly increased the 
target levels for fuel suppliers. The biofuel volume target was more than doubled from 4.75% 
biofuels in transport fuels to 9.75% in 2020. The increase of this mandate is expected to 
increase biofuel consumption in the UK to 2020 and onwards. 55 

o  Spain also has a considerable gap to fill in the coming years despite an increase from 2017 to 
2018. Spain similarly has increasing biofuel mandates, and biofuel shares in transport fuels 
will increase from 6% in 2018 to 8.5% in 2020 and subsequently increase consumption. In 
addition, waste-based biofuels (Annex IX) began to be double counted as of January 1, 2019 
which will stimulate the consumption of these fuels.56 These two factors have the potential for 
Spain to reach the 10% target in 2020.  
Italy also remains far from the 2020 target in absolute terms, but also has an increasing 
national biofuel target. The share of biofuels in transport fuels mandate will increase from 7% 
in 2018 to 9% in 2020, with a sub target for advanced biofuels from 0.1 to 1.0% (double 
counted).57 Additionally, both Annex IX and other compliant biofuels production will increase 
with the opening of a new biorefinery producing HVO (600-700 ktonne annually) from both 
palm oil and UCO.58 If this output is used domestically rather than exported, there is potential 
for meeting the target. 

o 

54 UPM produces HVO from crude tall oil, which is listed in Annex IX A. The HVO verification scheme (www.hvoscheme.com/certificates/) shows that the 
Porvoo facility produces HVO based on amongst others animal fat cat 1, 2 and 3, UCO, and PFAD. Note that PFAD is not recognized as a waste feedstock 
by the ILUC Directive, but Finland grandfathered its application as a waste feedstock, which is allowed by the ILUC Directive. 
55 https://www.gov.uk/government/news/new-regulations-to-double-the-use-of-sustainable-renewable-fuels-by-2020 
56 USDA, Biofuel Mandates in the EU by Member State in 2019. 
57 USDA, Biofuel Mandates in the EU by Member State in 2019. 
58 https://www.ofimagazine.com/news/eni-gela-biorefinery-due-to-start-commercial-operations 

 
 
 
 
 
                                                      
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Figure 9. National share of renewable energy in transport (2017-2018). 59 Source: Eurostat SHARES 

The contribution of renewable electricity in transport mainly concerns electricity in rail transport (1,618 
ktoe) and other non-road transport (291 ktoe). Only a few countries show significant amounts of 
renewable electricity for road transport, most notably Latvia. This mainly includes the use of electricity 
in trams and trolleybuses. 

The use of renewable electricity in passenger cars is small. This is mainly because the share of 
electric passenger vehicles in the total fleet is still small. The sales (new registration) of electric 
passenger cars 60 in the EU has grown sharply from 50,000 in 2013 to 217,000 in 2017 and 461,000 in 
2019.61 But even if all new vehicles would be electric, it would take decades to replace all the existing 
vehicles, and the electricity that the vehicles use is only partially renewable. 

Biogas and biomethane derived from biogas accounts for only a small fraction (<1%, or 154 ktoe) of 
the total bioenergy used in transport. In fact, there are only a few Member States including Sweden, 
Germany, Finland, Denmark and Austria using biogas in transport. Sweden and Germany together 
account for over 98% (77% Sweden and 22% Germany) of the total EU biogas consumption in 
transport.62 

Hydrogen falls in the category of “other renewable energies”, which contribute less than 0.001%, as 
shown in Table 3. Table 4 provides a detailed historical overview of biofuels and other renewable 
energies used in transport in the EU. 

59 Categories and accounting are according to the methodology set out in Directive 2015/1513. 
60 pure electric and plug-in hybrids.  
61 European Alternative Fuels Observatory, eafo: http://www.eafo.eu/  
62 Eurostat database, nrg_bal_c. 

 
 
 
 
 
                                                      
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Table 4. Renewable energy consumption in all transport in the EU28 (2011-2018, ktoe).63 Source: Eurostat SHARES 

Product/time 
Renewable electricity in road 
Renewable electricity in rail  
Renewable electricity in other 
modes 
Compliant biofuels 
Annex IX 
Other compliant biofuels1) 

Non-compliant biofuels2) 
Other renewable energies 
Total renewable energy in 
transport (including multipliers) 
Total fuels used in transport3) 
RES-T Share (%) 

2011 
11  
1,077  

2012 
11  
1,101  

2013 
15  
1,205  

2014 
18  
1,268  

2015 
24  
1,368  

2016 
33  
1,501  

2017 
42  
1,575  

2018 
52  
1,618  

201  

198  

216  

231  

267  

281  

288  

291  

8,424  
584  
7,840  

5,326  
0.0  

11,037  
1,289  
9,748  

3,358  
0.0  

11,183  
1,506  
9,678  

1,901  
0.3  

12,238  
1,726  
10,512  

1,953  
0.3  

12,830  
2,739  
10,092  

1,129  
0.1  

13,575  
3,277  
10,298  

14,758  
3,017  
11,741  

16,597  
3,905  
12,692  

182  
0.2  

109  
0.1  

88  
0.0  

11,956  

15,332  

15,992  

17,457  

19,327  

21,049  

22,212  

25,098  

302,974   293,932   290,269   294,245   299,551   306,174   311,635   312,706  
8.0% 

5.2% 

5.5% 

5.9% 

7.1% 

3.9% 

6.5% 

6.9% 

1) Other compliant biofuels and biofuels include in the first and third paragraphs of article 3(4)d of the Directive 2015/1513  
2) “Non-compliant” biofuels are biofuels that do not meet criteria of sustainability (Articles 17 and 18 of the Renewable Energy Directive). This means that 
they can be either non-sustainable or that they cannot be certified as sustainable. The latter especially occurred in 2011 and 2012 when the certification 
scheme was not operational in some Member States.  
3) Total electricity, diesel, gasoline and biofuels used in the transport; biofuels included with multiplicators. 

63 All calculations follow the rules set out in the ILUC Directive. 

 
 
 
                                                      
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3. Bioenergy supply 

The use of bioenergy in heating and cooling, in power production and in transport was discussed in 
Chapter 2. This chapter provides additional detail on bioenergy supply, including bioenergy carriers 
and their origin. Bioenergy can be produced from many types of agriculture, forest and waste 
feedstock, that can be categorised in material forms in different ways. The categorisations used by 
Eurostat of solid biomass, biogas, bioliquids, biofuels and the renewable fraction of municipal solid 
waste provide more insight into the nature of the feedstock.64 

Solid biomass is the main form of biomass for energy in the EU, as it represents 95% of the bioenergy 
in heating (which in turn represents 72% of all primary bioenergy), and 53% of bioenergy in electricity 
generation (14% of all primary bioenergy). Most of this solid biomass (90%) originates from the EU 
and mainly consists of forestry and forest industry products and residues (74%). The USA, Canada 
and Russia are together responsible for supplying 89% of the EU import of wood pellets. The UK is 
the largest importer of wood pellets, mainly from the USA and Canada.  

Biogas is the second largest form of bioenergy in the EU representing a 12% share of all primary 
bioenergy, or 16.8 Mtoe. It produces 5.2 Mtoe of power and 3.9 Mtoe of heat. Germany is by far the 
largest producer and consumer of biogas. Most of the biogas is produced from crops, agricultural 
residues, manure and food-industry residues. Furthermore, the UK has significant biogas production 
from landfills, with also a large share in France. Most, if not all, the feedstock for biogas consumed in 
the EU originates from the EU, and often from the same country as it is consumed. 

Bioliquids represent only 3% of bioelectricity and less than 1% of total bioenergy consumption. It is 
mainly consumed in Italy, where it consists of palm and rapeseed oil, UCO and animal fat. 

The contribution of the renewable fraction of municipal solid waste (MSW) to the total gross bioenergy 
consumption was 7% in 2018. All this MSW originates from the EU, but some is traded between 
Member States. 

3.1 Solid biomass 

3.1.1 Consumption of solid biomass for energy in the EU 

Almost all bioenergy consumed in heating and cooling in the EU in 2018 was based on solid biomass 
(95% of the total, equivalent to 80.1 Mtoe) as indicated in Figure 2. The major EU consumers of solid 
biomass for heat production were France (9,792 ktoe), Germany (9,623 ktoe), Sweden (7,584 ktoe), 
Italy (7,264 ktoe) and Finland (7,115 ktoe). These countries accounted for more than 50% of the total 
solid biomass consumed in 2018 (see Figure 4). 

Also, more than half of the bioelectricity is produced from solid biomass (again, see Figure 2). By far 
the largest consumer of solid biomass for power production was the UK (2,023 ktoe), representing 
24% of the EU total, followed by Finland (1,016 ktoe), Germany (931 ktoe) and Sweden (877 ktoe). 

The total consumption of solid biomass in both heat and power production in the EU in 2016 is 
estimated to be 88.6 Mtoe on the basis of a combination of Eurostat and Member State Progress 
Reports (see Section 2.2 and specifically Figure 2). Note that this is less than the total reported 
consumption of “solid biofuels” of 99.4 Mtoe, reported by Eurostat, as both shown in Table 6 later in 
this section. This discrepancy cannot be explained from the available data. 

64 These categories are used in Eurostat in several datasets used in the current study. 

 
 
 
                                                      
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Solid biomass can include wood directly supplied from forests and other wooded land, residues and 
co-products from the forest-based industry (e.g. wood processing or pulp and paper industry), energy 
crops and short rotation trees, and agricultural and food industry wastes and by-products. For major 
EU consumers of solid biomass (Germany, Sweden, Italy and Finland 65), the nature of the solid 
biomass used for heat and power generation is given in Table 5.66 In Sweden and Finland, residues 
and by-products from wood industry was the main source of solid biomass for heat and power 
generation, while in Italy and Germany, forest biomass from forest and other wooded lands was the 
main source.  

For instance, in Finland, a country with a large forest industry, bioelectricity is mainly sourced from 
wood products: about 30% comes directly from the forest and 70% concerns residues from forest-
based industry. Also, in Sweden, by far the majority of bioelectricity comes from wood products: 21% 
directly from the forest and 77% from forest-based industry. The remainder comes from agricultural 
by-products, processing residues and fishery by-products. In Germany, 60% of the solid biomass 
concerns wood products from forests and 30% concerns wood processing (industry) residues, while 
agricultural by-products are mainly used for biogas production (Section 3.2). 

Table 5. Solid biomass supply for heat & electricity in major EU consumers (2018, ktoe). Source: MS Progress Reports 

Feedstock 

Wood biomass from forest and other wooded 
lands for energy generation 

Wood biomass residues and by-products from 
wood industry 
Energy crops and short rotation trees 

Agricultural by-products/processed residues and 
fishery by-products 
Total 

Germany  

Sweden 

Italy 

Finland 

c
i
t
s
e
m
o
D

t
r
o
p
m

I

c
i
t
s
e
m
o
D

c
i
t
s
e
m
o
D

t
r
o
p
m

I

c
i
t
s
e
m
o
D

t
r
o
p
m

I

t
r
o
p
m

I

5,947 

256 

2,020  

9   5,468  

379   2,718  

1  

2,590 

470 

6,532  

783  

543   1,064   6,232  

66  

- 

1,013 

0 

0 

13  

60  

0   1,336  

596  

60   1,126  

0  

- 

- 

0  

0  

9,550 

726 

8,625  

852   8,473   2,039   8,950  

66  

The table also shows that these Member States mainly relied on the supply of domestic raw materials 
with imports accounting for less than 20% of their total consumption. Italy imported 19% of their total 
consumption (fraction of import in sum of import and domestic supply), Germany, Finland and 
Sweden imported less than 10% of their consumption. International trade is discussed later in this 
section. 

3.1.2 Production of solid biomass for energy in the EU 

Figure 10 shows how the solid biomass production for energy purposes in the EU gradually increased 
between 2014 and 2017 with a compound annual growth rate of 2.4% and stabilized over the period 
2017-2018. This trend is mainly driven by the increasing demand for both renewable heat and 
renewable electricity in the EU, as was discussed in Section 2.2. The link between the demand for 
and the production of solid biomass for energy becomes especially clear from the overview given in 
Table 6.  

Germany is the largest EU producer of solid biomass for energy in 2018, followed by France, Sweden 
and Finland. 

65 The French Member State Progress Report did not cover the supply of solid biomass. 
66 Data are from Member State’s reports. Note that Member States did not split the solid biomass consumption between the electricity and heat sectors. 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
                                                      
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Figure 10. Solid biomass primary production (2010 – 2018)67. Source: Eurostat nrg_bal_c 

Table 6 shows solid biomass production, import, export and consumption in the EU between 2010 
and 2018. The major feedstocks for solid biomass have been forms of wood (~77%, including 
fuelwood68, wood residues and by-products as well as wood pellets) followed by black liquor 
(~14%) 69.  

Table 6. Solid biomass production, import, export and consumption in the EU (ktoe). Source: Eurostat nrg_bal_c 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

Total EU solid biomass production 
Total import of solid biomass 
Total market (EU production + import) 
Total export of solid biomass 
Change in stock 
Total consumption of solid biomass 

6,239  

5,771  

6,099  

88,989   84,148   92,314   93,362   88,122   92,253   93,144   94,659   94,353  
9,400   10,245  
9,014  
94,760   90,247   98,554   101,044   97,136   101,107   102,403   104,059   104,599  
4,926  
4,446  
-228  
-67  
92,168   86,885   94,833   97,129   92,623   96,357   97,740   99,567   99,444  

4,698  
-52  

3,176  
-186  

3,644  
-77  

4,653  
161  

4,672  
9  

4,041  
126  

2,699  
107  

8,854  

9,259  

7,682  

The import of solid biomass, as total market share, has slowly increased from 6.1% in 2010 to 9.8% 70 
in 2018 as can be seen from Table 6. The origin of imported solid biomass is further discussed later in 
this section. The total market (EU production + import) has been growing with a compound annual 
growth rate of 1.9% over the period 2014-2018, but growth from 2017 to 2019 was only 0.5%. The 
majority of solid biomass is used in the heating & cooling sector, where the bioenergy consumption 
needs to grow by 3.2% in the coming years to reach the 2020 NREAP target, as described in section 
2.2.1. 

67 Data are shown for the 10 Member States with the largest production volume in 2018; The other Member States are aggregated. Data on ‘primary solid 
biofuels'. Note that Eurostat does not give statistics on “solid biomass”, but rather on “primary solid biofuels”. We presume these terms effectively cover the 
same material scope. 
68 Definition of fuelwood (also known as wood fuel) by the European Commission: “Roundwood being used as fuel for purposes such as cooking, heating or 
power production. It includes wood harvested from main stems, branches and other parts of trees (where these are harvested for fuel) and wood that is used 
for the production of charcoal (e.g. in pit kilns and portable ovens), wood pellets and other agglomerates. It also includes wood chips to be used for fuel that 
are made directly (i.e. in the forest) from roundwood. It excludes wood charcoal, pellets and other agglomerates.” It can be accessed via the link: 
https://ec.europa.eu/knowledge4policy/glossary/wood-fuel_en  
69 Eurostat categorises black liquor as a solid biofuel, while it is technically a viscous liquid. 
70 Note that the 9.8% is based on total imports. Net import would be 5%. In the same year the EU export of solid biomass was about 5 Mtoe (Eurostat 
nrg_bal_c). Please note that the export is not necessary a proportion of the domestic production. All or part of the export can be from imported solid biomass. 

 
 
 
 
 
 
 
                                                      
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Figure 11 shows the primary solid biomass supply by Member State. German solid biomass 
production amounted to 12,608 ktoe in 2018, 91% of which was from forest biomass71 (fuelwood, 
wood residues and other by-products as well as wood pellets). The increasing demand for solid 
biomass in France is primarily attributed to increasing demand for collective residential heat and 
industrial power.72 Similar to Germany, the majority (89%) of solid biomass in France concerns wood-
based products (Figure 11). In Sweden and Finland, a significant amount of solid biomass (43% and 
44% respectively, Figure 11) is sourced from domestically produced black liquor – a by-product of the 
Kraft wood pulping process.73 These two countries are the largest producers of black liquor in the EU 
and together account for about ~60% of the EU production,74 followed by Portugal,75 Austria, France, 
Spain and Germany. In Italy, all solid biomass is sourced from fuelwood, wood residues and by-
products according to Eurostat nrg_cb_rw. However, in its Member State Progress Report, Italy 
reports 18% of energy crops and short rotation trees and 11% of agricultural by-products, processed 
residues and fishery by-products, next to a majority of 71% of wood biomass (Table 5).  

Figure 11. National primary solid biomass supply (2018, ktoe). Source: Eurostat nrg_cb_rw data on ‘solid biofuels’ 76 

3.1.2.1 Origin of solid biomass 

As discussed above, most of the solid biomass consumed for energy production in the EU originates 
from the EU. The import of solid biomass represented only about 10% (10 Mtoe) of the total 
consumption in 2018. 77 A trade analysis approach, described below, based on Eurostat International 
Trade statistics 78 is used to identify the origin of the imported solid biomass. 

71 Note that the term “forest biomass” is used in the recast of the Renewable Energy Directive, and in the frame of that Directive such biomass shall meet 
certain additional sustainability criteria. Eurostat does not specifically cover “forest biomass”. Some material forms reported by Eurostat are assumed to fall in 
the “forest biomass” category, as further explained under Table 6. 
72 Pellet market country report France, ADEME: https://pelletsatlas.info/wp-content/uploads/2015/09/France_CR.pdf  
73 Eurostat includes “black liquor” in its definition of “solid biofuels”. Technically, black liquor is a liquid, albeit very viscous. 
74 Eurostat database, energy statistics, nrg_cb_rw. 
75 http://ec.europa.eu/DocsRoom/documents/10271/attachments/10/translations/en/renditions/pdf  
76 Note that Eurostat does not give statistics on “solid biomass”, but rather on “primary solid biofuels”. We presume these terms effectively cover the same 
material scope. 
77 Note that the 10% is based on total imports. Net import would be 5%. In the same year the EU export of solid biomass was about 5 Mtoe (Eurostat 
nrg_bal_c). Please note that the export is not necessary a proportion of the domestic production. All, or part of, the export can be from imported solid 
biomass.  
78 Figures were obtained from Eurostat, Database by Themes, International Trades, International Trades in goods - detailed data, the dataset “EU trade 
since 1988 by HS 2, 4, 6 and CN8” and can be found at https://ec.europa.eu/eurostat/data/database  

 
 
 
 
 
 
                                                      
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In the following section we provide additional detail on imports of wood pellets and wood chips to the 
EU28. On the types of solid biomass listed in Table 6, Eurostat provides international trade data for 
wood pellets and wood chips (as part of the ‘fuelwood, wood residues and by-products’ category) in 
disaggregated forms. Disaggregated trade data for bagasse, black liquor, other vegetal materials and 
residues and animal waste are not included in the Eurostat International Trade statistics.  

Wood pellets import 

Wood pellets accounted for 5% of solid biomass production in the EU in 2018, as shown in Figure 11 
in the previous section. Imports made up 50% of the total wood pellet market in the EU. Wood pellets 
make up 46% of the total solid biomass import.79  

Figure 12 shows the EU wood pellets imports between 2016 and 2018. The EU imported 10,355 
ktonne of wood pellets for energy use in 201880. This represents an increase of almost 28% 
compared to 2016. Figure 12 also shows the EU’s main trade partners between 2016 and 2018: The 
USA, Canada, Russia, Ukraine, Belarus and Brazil. These six countries account for more than 95% of 
the wood pellet imports to the EU since 2016. The overall composition of the EU’s main trade partners 
in this period remains the same with some changes in the import trend.  

The USA has been the largest exporter to the EU (accounting for almost 60% of the import in each 
year), followed by Canada (over 15% in each year) and Russia. Imports from Russia increased by 
about 64% from 834 ktonne in 2016 to 1,365 ktonne in 2018. Other changes in the import trend can 
be seen in imports from Ukraine (increased by 130% from 165 ktonne in 2016 to 380 ktonne in 2018).  

Figure 12. EU wood pellets imports from the main EU trade partners (2016 – 2018, ktonne). Source: Eurostat81 

79 Based on energetic value of wood pellet production and import in Eurostat nrg_cb_rw, Eurostat trade statistics on wood pellets (CN 44013100) and a LHV 
of wood pallets of 19 MJ/kg dry (https://publications.jrc.ec.europa.eu/repository/bitstream/JRC104759/ld1a27215enn.pdf) 
80 This information excludes intra-EU imports and indicates only imports from outside the EU28 borders.  
81 Trade statistics on wood pellets CN 44013100. This Commodity Number includes wood pellets only. Please note that the Commodity Number of wood 
pellets in Eurostat has changed since 2012. In 2008, the Commodity Number used was 44013090 (“Wood waste and scrap, whether or not agglomerated in 
logs, briquettes, pellets or similar forms, excl. sawdust”). Due to changes made by Eurostat, data between 2009 and 2011 used the Commodity Number 
44013020 (“Sawdust and wood waste and scrap, agglomerated in pellets”). From 2012 and onwards, these data were reclassified into Commodity Number 
44013100 (“Wood pellets”). 

 
 
 
 
                                                      
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Figure 13 presents the top Member States of wood pellets imports in 2018. The UK has been the 
most significant importer of wood pellets in the EU in 2018. In 2018, the UK accounted for 64% of the 
total EU import followed by Denmark (11%), Belgium (8%) and Italy (5%) (Figure 13). Countries such 
as Germany, France, Italy and Sweden represented only a small share of the EU import (collectively 
less than 8%) while these countries were the largest consumers of solid biomass.  

The demand in these countries was mainly met by domestically produced solid biomass.82 This is in 
line with the information reported by the Member States in their Progress Reports (see Appendix B). 

The UK Progress Report does not give details on the sources of biomass for heat and electricity 
production. The Ofgem Biomass Sustainability Dataset for 2017-1883 shows that around 25% of the 
solid biomass was imported from the USA and around 9% from Canada.84 Note that 58% of the solid 
biomass used in the UK still originated from the UK and the remainder largely from other EU Member 
States. 

Figure 13. EU top importers of wood pellets (2018). 85 Source: Eurostat trade statistics on wood pellets CN 44013100 

Wood chips import 

Wood chips make up 28% of the total import of solid biomass. Figure 14 presents the EU import of 
wood chips in the period 2016 to 2018. The figure shows that the EU imported 6,338 ktonne of wood 
chips in 201886. This represents an increase of 39% compared to 2016. The figure also shows the 
EU’s main trade partners between 2016 and 2018, of which Russia and Belarus are the most 
significant in terms of volume. The six countries identified in the figure account for more than 94% of 
the wood chips imports to the EU since 2016.  

The overall composition of the EU’s main trade partners on wood chips in this period remained the 
same with some smaller changes in the import trends. Russia was the largest exporter to the EU in 
2016 and 2017. As of 2018, Belarus is the main source of imported wood chips. Imports from Belarus, 
as the largest EU wood chips trade partner, increased by about 63% from 1,480 ktonne in 2016 to 
2,419 ktonne in 2018, exceeding the overall trend of an increase in wood chips imports to Europe. 

82 Eurostat database, nrg_bal_c. 
83 https://www.ofgem.gov.uk/publications-and-updates/biomass-sustainability-dataset-2017-18 
84 The ranges represent values found in the 2015-16 and in the 2016-17 Biomass Sustainability Datasets, published by Ofgem.  
85 Top 4 importers and rest of EU28 based on percentage as EU total import. 
86 We cannot verify whether the entire imported wood chips were used for energy production since wood chips could also be used for other purposes such as 
producing wood pulp, as an organic mulch in gardening and landscape, etc. 

 
 
 
 
 
                                                      
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Figure 14. EU wood chips imports from the main EU trade partners (2016 – 2018, ktonne). Source: Eurostat87 

Figure 15 shows the Member States who imported the largest volumes of wood chips in 2018. 90% of 
the total amount of wood chips imported to the EU took place through six Member States, namely 
Finland, Poland, Portugal, Lithuania, Sweden and Latvia. Finland was the largest importer of wood 
chips and accounted for 25% of the total EU wood chips imports in 2018. Between 2016 and 2018 
Latvia showed the most notable increase of the top importers, going from 1% of total EU wood chips 
import to 9%, making it the sixth largest importer in the EU. Lithuania was the fourth largest importer 
in 2018, after Finland, Poland and Portugal (Figure 15). 

87 Eurostat trade statistics on wood chips CN 44012100 and CN 44012200. For this analysis we combined two Commodity Numbers: CN 44012100 
representing coniferous wood in chips or particles (excluding those of a kind used particularly for dying or tanning purposes) and CN 44012200 representing 
wood in chips or particles (excluding those of kind used particularly for dying and tanning purposes, excluding coniferous wood). 

 
 
 
 
 
                                                      
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Figure 15. EU top importers of wood chips (2018). Source: Eurostat trade statistics on wood chips88  

3.2 Biogas 

3.2.1 Consumption of biogas for energy in the EU 

In 2018, biogas was the third largest form of bioenergy in the EU representing a 12% share of all 
primary bioenergy, or 16.8 Mtoe. It is used to produce 5.2 Mtoe of electricity, 3.9 Mtoe of heat and 0.2 
Mtoe of energy in transport (see Figure 2 in Chapter 2). The difference between these numbers, of 
7.5 Mtoe, are losses, especially due to the efficiency of power production. In 2018, biogas is usually 
consumed (for heat or power production) close to its production location. The heat can be transferred 
directly to heat buildings and agricultural units or used in a district heating network. Alternatively, 
biogas can be upgraded to natural gas quality (biomethane) to be injected to the gas grid, or used 
directly as a fuel in the transport sector. Approximately 10% of biogas produced is currently upgraded 
to biomethane (2 bcm of 18 bcm).89 In 2018, the EU consumed 154 ktoe of biogas in transport, of 
which 118.5 ktoe was used in Sweden and 33.4 ktoe in Germany. The high consumption in Sweden 
was driven by energy and CO2 tax exemptions for biomethane in transport. 

3.2.2 Production and origin of biogas for energy in the EU 

Anaerobic digestion is a commercially available and widely used biological process for converting 
biomass into biogas in the absence of oxygen. The end-products of the process are biogas (a gas 
containing around 50-70% methane and 25-50% carbon dioxide,90 water vapour and trace amounts of 
other gases such as oxygen, nitrogen and hydrogen sulphide) and a solid fraction called digestate. 
Biogas can be used to generate electricity or heat, or both outputs in a CHP system. Biogas can also 
be upgraded to biomethane,91 a process in which the carbon dioxide, water and other trace gas 

88 CN 44012100 and CN 44012200. 
89 Gas for Climate, Gas Decarbonisation Pathways 2020-2050, https://gasforclimate2050.eu/publications. 
90 Biogas from sewage digesters usually contains from 55 to 65% methane, 35 to 45% carbon dioxide and <1% nitrogen, biogas from organic waste 
digesters usually contains from 60 to 70% methane, 30 to 40% carbon dioxide and <1% nitrogen, while in landfills methane content is usually from 45 to 
55%, carbon dioxide from 30 to 40% and nitrogen from 5 to 15% [Rasi S 2009, Biogas composition and upgrading to biomethane, University of Jyväskylä 
Finland]. 
91 Biomethane is a purified form of biogas, with higher methane content. The exact methane content may depend on the location and application. In the 
Netherlands, biogas with at least 85% methane can be injected in the gas grid, and could thus be called biomethane, while in Sweden, over 97% purity is 
required [Rasi S 2009, Biogas composition and upgrading to biomethane, University of Jyväskylä Finland]. 

 
 
 
 
 
 
                                                      
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impurities are removed. Biomethane has an additional advantage, namely that it can be injected into 
existing gas infrastructure, or used as a transport fuel. 

Figure 16. EU biogas production (2010 – 2018, ktoe).92 Source: Eurostat nrg_bal_c 

Biogas production in the EU has two main purposes: it is either seen as a method for waste treatment 
or a way of energy production. It can also be used for a combination of the two purposes. Germany 
has been the frontrunner in biogas production to date accounting for 45% of the total EU production in 
2018, followed by the UK (17%), Italy (11%), France (5%) and Czechia (4%).  

The number of biogas plants in the EU increased from 12,397 installations in 2011 to 17,439 in 2016 
to 18,202 in 2018, with biogas production following this growth trend.93 As shown in Figure 16, biogas 
production experienced a significant growth of 56% from 2011 to 2016 with production then flattening 
from 2016 to 2018, with Germany as strongest driver for this change in trend. In Germany several 
incentives, including the Renewable Energy Act (EEG), Renewable Energy Bonus, CHP bonus, 
technology bonus and KfW renewable energies programme, have been in place to support 
investments in biogas anaerobic digesters.94 The most effective driver for the production of 
biogas/biomethane was the Renewable Energy Act, which originally came into force in 2000 and has 
since then been modified several times. It includes a guaranteed feed-in tariff for the generated 
electricity from biogas, which was initially set higher than that of electricity generated from other 
renewable sources. However, amendments made to the Renewable Energy Act in 2014 cancelled 
specific biogas related targets for 2020 and 2030 and as a result, there was a slowdown in the 
construction of new biogas plants.  

92 Data are shown for the 10 Member States with the largest production volume in 2018. The other Member States are aggregated. 
93 European Biogas Association (EBA): https://www.europeanbiogas.eu/eba-statistical-report-2019/ 
94 Biogas & biomethane in Europe, European Biomass Association: https://ec.europa.eu/energy/intelligent/projects/sites/iee-
projects/files/projects/documents/agriforenergy_2_international_biogas_and_methane_report_en.pdf  

 
 
 
 
 
                                                      
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In the UK, the most effective incentives for production of biogas/biomethane since 2011 are the Feed-
in Tariffs scheme for electricity (2010) and the Renewable Heat Incentive (2011). These incentives 
have resulted in a significant growth of the UK biogas sector, in particular between 2011 and 2013. In 
Italy and Czechia, the most important driver has also been a feed-in tariff. Notably though, biogas 
production in Italy has decreased since 2014 due to the reduction of the feed-in tariff.95 Italy could see 
an increase in the coming years because a subsidy was introduced for biomethane used as a 
transport fuel in the beginning of 2018. The subsidy is for plants beginning operations between 2018 
and 2022 and has a total budget of 4.7 billion euro. 96 

The production of biogas is assessed in more detail in Figure 17. With 45% of all biogas production, 
Germany is the largest EU biogas producer. 92% of German biogas is produced from anaerobic 
digestion of agriculture wastes, residues and crops (manure, maize and hay silage and sugar beet). In 
the UK, the second largest EU biogas producer with 17%, around 45% of biogas is produced from 
agricultural products and the biggest share (around 55%) comes from landfill and sewage sludge 
gases. The potential of landfill gas in the UK will depend on how waste trade is handled with the 
withdrawal of the UK from the EU. Although historically there has been a reduction in landfills and 
therefore landfill gas, the UK currently exports waste to other Member States such as Germany and 
the Netherlands. If this trade is affected or disrupted by ‘Brexit’, the UK could be forced to increase 
the volume of waste landfilled.97 Italy follows with 11% of biogas production, mainly from manure and 
energy crops, with a small contribution from landfill gas.  

Figure 17. National biogas production per sources (2017 – 2018, ktoe).98 Source: Eurostat nrg_cb_rw 

Table 7 shows biogas production in the EU between 2010 and 2018, differentiated by feedstock 
types.99 The amount of biogas produced from landfill has decreased since 2013 as the share of waste 
disposed to landfill decreased due to several Member States imposing higher landfill taxes. On the 

95 Optimal use of biogas from waste streams, European Commission, 2016: 
https://ec.europa.eu/energy/sites/ener/files/documents/ce_delft_3g84_biogas_beyond_2020_final_report.pdf   
96 Gas for Climate, Gas Decarbonisation Pathways 2020-2050, Table 1, https://gasforclimate2050.eu/publications. 
97 https://www.bbc.com/news/business-49440290 
98 “Other biogases from anaerobic fermentation” mainly represents biogas from manure and energy crops like corn silage. 
99 These data are from Eurostat and are given in rather aggregated forms since information of specific feedstock use for biogas production is often not easy 
to obtain. 

 
 
 
 
 
 
                                                      
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other hand, biogas production from anaerobic digestion and thermal processes increased. In 2018, 
biogas from farm-based plants (mainly silage maize), manure and other agro/industrial organic wastes 
had a share of 75%, whereas biogas from landfill had a share of 14%, biogas production from sewage 
sludge had a share of 9% and biogas from thermal processes had a share of 2%.  

The share of biogas from thermal processes is negligible, but shows a relatively steep growth, since 
these technologies are still in the development stage. 

Table 7. Feedstock for biogas production in the EU (ktoe). Source: Eurostat, nrg_cb_rw 

2011 

2010 

Product 
Other biogases from anaerobic fermentation1) 
Landfill gas 
Sewage sludge gas 
Biogases from thermal processes 
Total biogas 
1) Eurostat nrg_cb_rw includes the category “Other biogases from anaerobic fermentation” as third (but largest) category after “Landfill Gas” and “Sewage 
Sludge Gas”. This includes biogas on basis of manure, agriculture/food/industry waste and field crops such as corn silage. 

4,881   6,441   8,082   9,522   10,506   11,317   12,039   12,473   12,575  
2,840   2,924   2,912   2,971   2,906   2,837   2,742   2,585   2,429  
1,114   1,220   1,262   1,378   1,371   1,369   1,439   1,469   1,509  
326  
8,835   10,607   12,284   13,932   14,868   15,622   16,379   16,786   16,839  

260  

160  

28  

99  

85  

61  

22  

0  

2015 

2016 

2018 

2012 

2017 

2013 

2014 

Nearly all the biogas that was produced in the EU has been consumed domestically. 100 The precise 
geographical origin of the materials from which the biogas has been produced could not be assessed. 
Most of these materials are wastes with a high moisture content and are costly to transport over a 
long distance. The energy crops that have been used (often as a co-digestate) in anaerobic digestion 
are generally produced on or near the farm where the biogas production takes place, since it is not 
economically attractive to procure such crops from further away. 

3.3 Bioliquids 

Electricity from bioliquids accounts for a small share (3%) of the total bioelectricity generated in the 
EU and less than 1% of all bioenergy. Table 1 in Chapter 2 showed that bioliquid use in the EU in 
2018 is at the same level as in 2010, with lower use in 2011-2014 and higher use in 2015-2017. 
Bioliquids for electricity generation were mainly deployed in five Member States: Italy (369 ktoe), 
Germany (41 ktoe), Belgium (6 ktoe), Sweden (4 ktoe) and Spain (1 ktoe).101 Whereas in Italy 
bioliquids account for a large share of domestically produced bioelectricity (22%), in Germany, 
Belgium and Austria they only account for a very small fraction (<3% in each Member State).  

Since bioliquids have a small share in bioelectricity (as well as in heat) generation, the information on 
the type of bioliquids is limited. The Member States’ Progress Reports do not differentiate between 
feedstock used for biofuels and bioliquids, presenting both of these feedstocks under the same 
category. 

3.4 Liquid biofuels 

The consumption of liquid bioenergy carriers in the EU accounts for 16.8 Mtoe, or 13% of all 
bioenergy and 8% of all renewable energy (in all sectors). Liquid bioenergy largely concerns biofuels 
in transport (16.7 Mtoe) and for a smaller part bioliquids, i.e. liquid forms of bioenergy used for power 
production in conventional thermal power stations and of heat and power in CHP stations (as 
described above in Section 3.3). Because the sustainability of bioenergy in the frame of the 
Renewable Energy Directive especially concerns biofuels in transport, their feedstock and origin are 
assessed in more detail in Chapter 4. 

100 Eurostat nrg_bal_c. 
101 Eurostat nrg_bal_c.  

 
 
 
 
 
                                                      
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3.5 Renewable fraction of municipal solid waste 

The contribution of the renewable fraction of municipal solid waste (MSW) to the gross bioenergy 
consumption was 7% in 2018, see Figure 1 in Chapter 2. The contribution of the renewable fraction of 
MSW in the energy sector has slowly increased over the past decade, from 7.4 Mtoe in 2007 to 10.4 
Mtoe in 2018. MSW is currently only used to produce heat (3 Mtoe according to Eurostat,102 although 
not reported by all Member States in their Progress Reports) and power (net 2 Mtoe renewable 
electricity). Germany, France and the Netherlands have continuously been the main users of MSW for 
energy generation since 2007.  

Figure 18 shows the historical trend of the main EU consumers of MSW (renewable fraction) in the 
power sector. The figure indicates a growing trend since 2010 in all main Member States, except in 
Sweden where the amount remained relatively stable. Germany shows a constant and rapid growth 
over time (30% between 2010 and 2018) and the UK shows a steady increase from 2014 as a result 
of high landfill charges and increase in incineration capacity. In 2018, Germany was by far the largest 
consumer of MSW for power generation, accounting for 27% of the EU consumption followed by the 
UK (16%), Italy (10%), France (10%), the Netherlands (9%) and Sweden (7%). 

Figure 18. Consumption of the organic fraction of Municipal Solid Waste (MSW) in the power sector in selected MS. 
Source: Eurostat nrg_bal_c 

Table 21 in Appendix A, gives an overview of the information reported by the Member States on the 
share of renewable waste in the waste used for energy production. Also included are any remarks 
provided by Member States on the methodologies applied for estimation and any steps taken to 
improve these estimates. As indicated, several Member States did not report the actual share they 
applied in 2017 and 2018. Additionally, several Member States did not report any renewable energy 
produced from MSW (e.g. Austria, Cyprus, Chechia, France, Ireland, Latvia, Lithuania, Slovenia and 
the UK), while others did report renewable energy produced from MSW, but not the fraction applied 

102 Eurostat nrg_bal_c reports that the gross heat production from the renewable fraction of municipal solid waste in the EU in 2018 was 3 Mtoe. This is not 
visible in Figure 2, since heat in Figure 2 is based on Member State reports as explained in Footnote15. 

 
 
 
 
 
                                                      
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(e.g. Bulgaria and Greece). For the Member States that did report the renewable fraction in their 
Progress Reports, most indicated a share between 50-60%. Several Member States refer to 
regulation, or online documentation, in which methodologies to assess the renewable fraction are 
detailed.  

Many Member States use measurements or sampling in a selection of processing facilities to 
determine the renewable fraction of MSW, elaborate on methodologies applied to determine (e.g. C14 
method) and mention regular assessments on this. 

MSW consumed in EU bioenergy production originates almost exclusively from the EU. 103 As 
mentioned in Section 2.2, MSW and (actually mostly) its derivatives RDF/SRF are however traded 
within the EU between Member States.  

103 In 2017 and 2018, the import of municipal waste from third countries to the EU customs union represented less than 0.01% of the EU internal waste 
production. Moreover, over 95% of this import was from Gibraltar [Eurostat trade statistics on wood pellets HS 382510]. 

 
 
 
                                                      
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4. Feedstock for biofuels and their origin 

4.1 Biofuels consumption in the EU 

Figure 19 shows biofuel consumption per fuel type for the period 2010-2018. Most biofuels consumed 
in the EU constitute of biodiesel (77%, FAME or HVO) or bioethanol (16%).104 Other liquid biofuels 
(6%) are not specified. Almost all biofuels are consumed in the road transport sector, while the use in 
aviation and shipping is negligible. About 35% of all the biofuels are consumed in just two Member 
States, Germany and France.  

Over the period 2011-2016, the consumption of biodiesel has been rather stable, between 11 and 12 
Mtoe. The consumption of bioethanol shows a slow decrease over the same period. After this period 
of slight decline, consumption of both biodiesel and bioethanol has increased from 2016-2018, driving 
a compound annual growth rate of 10% in the period 2016-2018.  

About 41% of the biodiesel consumed in the EU in 2018 comes from EU feedstock, mainly from 
rapeseed (26%), UCO (8%) and animal fat (5%). The main third countries of origin are Indonesia 
(17%) and Malaysia (8%), whose palm oil ends up in EU consumed biodiesel, and Argentina (9%) 
which exports biodiesel made from soybeans. 

Around 73% of the bioethanol consumed in the EU in 2016 comes from EU feedstock. This mainly 
concerns wheat (34%), maize (24%) and sugar beet (14%). 

Figure 19. Liquid biofuel consumption per fuel type (2010 – 2018, ktoe). Source: Eurostat nrg_bal_c 

4.1.1 Biodiesel (FAME and HVO) 

Biodiesel represents the majority of biofuels consumed in the EU, with a share of about 77% of the 
total transport biofuel market (compare Figure 20 and Figure 21).105 Figure 20 presents biodiesel 
consumption in the EU between 2010 and 2018. Based on the available data, one cannot distinguish 
between HVO and FAME consumption in the EU market, although based on the production capacities 
in the EU and major third country producers (see Section 4.4), it could be estimated that in 2018 81% 
concerns FAME and 19% concerns HVO. 106 

With increasing HVO production in France (Total) and Italy (ENI) this figure is expected to shift to 

104 Source: Eurostat nrg_bal_c. The terms biodiesel and bioethanol refer to the physical appearance of the fuel. Biodiesel is a type of fuel that can be 
blended with diesel. The main types of biodiesel are Fatty Acid Methyl Ester (FAME) and Hydrotreated Vegetable Oil (HVO). Ethanol is the chemical name of 
what is commonly known as alcohol. It can be blended with gasoline. These terms have no relation to the sustainability of biofuels, and are also unrelated to 
the categories “compliant biofuels” or “Annex IX biofuels”. 
105 Eurostat data, nrg_bal_c 
106 USDA GAINS Report, EU Biofuels Annual 2019. Table 9. 

 
 
 
 
 
 
                                                      
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70/30 in the coming years. Figure 20 presents the ten largest EU consumer markets, while the figures 
for the other Member States are aggregated. After the strong growth in biodiesel consumption in the 
first decade, the consumption in the EU has been rather stable from 2012 to 2016, between 11 and 
12 Mtoe, with only a temporary dip in 2013. The stabilisation relates to the introduction of double 
counting biofuels, which allowed for an increasing RES-T share over the same period, while the 
biofuels volume in total hardly increased. This was discussed in Section 2.3. In 2017 and 2018, we 
again see an increase in the biodiesel consumption. 

The following trends can be observed from Figure 20:  

•  A rapid biodiesel uptake is observed between 2011 and 2012 in most of the key markets. This 

increase was mainly due to an increase in mandates in some Member States. The largest growth 
was observed in Spain where the biodiesel specific mandates increased from 3.9% to 7%.107  
•  A 10% decline is observed in 2013. This can largely be explained by two factors: double counting 
and reduced mandates in some Member States. Double counting of advanced biofuels was 
applied in Germany (2011-2014), Italy (2012 until early 2014), the Netherlands, Belgium, the UK, 
Portugal and Austria. Double counting reduces the physical biofuels volume that is required to 
meet the mandates. In addition, Spain reduced its consumption mandates from 7% down to 4.1% 
at the beginning of 2013.107  

•  From 2013 through 2014, the overall consumption of biodiesel in the EU increased, largely due to 

increases in France, Germany, Sweden, the UK and Austria. 

•  From 2014 through 2016 biodiesel consumption fluctuated as mandate increases in some 

Member States107 were off-set by consumption decreases in other Member States. During this 
period, the biodiesel consumption decreased in Germany, the UK, and Czechia and increased in 
Sweden and several other Member States. The decrease in Germany is due to the transition from 
an energy-based consumption mandate to greenhouse gas reduction mandates in 2015. Based 
on this new regulation, companies are encouraged to calculate actual greenhouse gas values 
rather than using default values and to use biofuels with higher emission savings. This reduces 
the physical volume of biofuels required to reach the mandates. In Czechia an increase in the 
excise tax for biofuels made biodiesel more expensive compared to fossil diesel. 108 In Sweden, 
biodiesel consumption benefitted from tax exemptions and higher mandates for biofuels in diesel 
(19.3% on energy basis).109 

•  A rapid biodiesel uptake is observed between 2016 and 2018. The strongest growth comes from 
Spain (559 ktoe), Sweden (484 ktoe) and Poland (450 ktoe). The relative growth has been 
strongest in the Netherlands and Poland, where biodiesel consumption more than doubled since 
2016.  

•  From 2017 to 2018 there is an increase in consumption due to national mandate increases in 

Finland, the Netherlands, Poland, Spain and the UK. 

Biodiesel (FAME and HVO) consumption is driven almost exclusively by Member State mandates and 
less so by tax incentives.110 With increasing mandates to 2020 and onwards, this triggers the 
increasing biodiesel consumption observed in recent years.  

107 Overview of the biofuel policies and markets across the EU-28, ePURE, 2016. 
108 Czech Republic case study, European Environment Agency: 
109 https://green-budget.eu/green-overhaul-of-swedish-fuel-and-vehicle-taxation/  
110 See ‘Technical assistance in realisation of the 4th report on progress of renewable energy in the EU’, Navigant, a Guidehouse company, 2020. 

 
 
 
                                                      
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Figure 20. Biodiesel consumption in the EU28 (2010 – 2018, ktoe). Source: Eurostat nrg_bal_c.111 

4.1.2 Bioethanol (Ethanol and ETBE) 

Figure 21 shows bioethanol consumption in the EU between 2010 and 2018. The figure shows the ten 
largest EU consumers and separates them from the rest of the Member States. As can be seen from 
this figure, bioethanol consumption shows a declining trend in the EU between 2010 and 2016. This 
can mainly be explained by the double counting of bioethanol, which reduces the physical volume of 
bioethanol required to reach the mandate, lower gasoline consumption in the EU 112 (115 million litres 
in 2011 versus 102 million litres in 2016) and the adjustment of national bioethanol specific blending 
mandates. From 2016 to 2018, the bioethanol consumption increased. Similar to biodiesel, this can 
be explained by the increasing biofuel mandates in many Member States. In addition, bioethanol was 
more competitive with gasoline prices and imports from the USA increased (463 million litres in 2018 
compared to only 45 million litres in 2016).113 

111 Data are shown for the 10 Member States with the largest consumption volume in 2018; The other Member States are aggregated. 
112 Eurostat database. 
113 USDA GAINS Report, EU Biofuels Annual 2019. 

 
 
 
 
 
 
                                                      
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Figure 21. Bioethanol consumption in the EU28 (2010 – 2018, ktoe).114 Source: Eurostat nrg_bal_c  

114 Data are shown for the 10 Member States with the largest consumption volume in 2018; The other Member States are aggregated. Note: Eurostat reports 
the consumption of biogasoline. The largest part of this product is bioethanol or its derivative bio-ETBE. 

 
 
 
 
 
 
 
                                                      
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4.2 Biofuels production in the EU 

4.2.1 Biodiesel (FAME and HVO) 

Figure 22 shows biodiesel production (FAME and HVO) in the EU between 2010 and 2018, including 
the ten largest producing Member States. In 2018, about 81% (on mass basis) of the biodiesel 
produced in the EU was FAME biodiesel, and the remainder was HVO biodiesel. 115  

Biodiesel production in the EU had an increasing trend between 2011-2014, followed by a slow 
decrease towards 2016 and an increasing trend again from 2016 onwards. In 2014, EU biodiesel 
production benefited from higher domestic consumption and higher exports. 116 As a result, biodiesel 
production increased in most of the Member States, most significantly in Spain, Belgium, the 
Netherlands, Germany and France.117 The slight production decline in 2016 as compared to 2014 is 
mainly attributed to the decline in biodiesel consumption and competition from imports (import to the 
EU was 6.7 Mtonne in 2016 versus 6.6 Mtonne in 2014).118 

From 2016 to 2018, the increase in biodiesel production is mainly attributed to the increase in FAME 
production, while HVO production remained stable. However, HVO production will increase in 2019 
with the opening of a biorefinery producing HVO in France and another one in Italy. The slight 
increase in production in Spain could be explained by the increase in biofuel mandates which 
increase from 2016 to 2020, creating further demand.119 

The EU biodiesel market is mainly driven by domestic consumption and import competition. While 
HVO is not imported (or at least negligible amounts according to industry traders), import competition 
does influence FAME production. In 2018, 42% of imported biodiesel came from Argentina (soy) and 
27% from Indonesia (palm). These cheap imports rapidly increased from 2017 to 2018 which drove 
down EU production. This was due to the removal of anti-dumping duties from Argentina in 
September 2017 and Indonesia in March 2018, which had been imposed since March 2013. 120 

FAME is produced in all Member States except for Finland, Luxembourg and Malta while HVO is only 
produced in the following six Member States: the Netherlands, Finland, Spain, Italy, Sweden, France 
and Portugal. Although Germany was the largest total biodiesel producer in 2018, France was the 
largest biodiesel consumer in the same year (compare Figure 20 and Figure 22).  

115 USDA GAINS Report, EU Biofuels Annual 2019. Table 9. 
116 Eurostat, nrg_cb_rw. 
117 Eurostat, nrg_bal_c. 
118 Eurostat, nrg_t. 
119 http://agriexchange.apeda.gov.in/MarketReport/Reports/Spain%E2%80%99s_Biodiesel_Renewable_Diesel_Overview%20_Madrid_Spain_6-27-2017.pdf 

120 USDA GAINS Report, EU Biofuels Annual 2019. 

 
 
 
                                                      
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Figure 22. Biodiesel production in the EU28 (2010 – 2018, ktoe).121 Source: Eurostat nrg_bal_c 

4.2.2 Bioethanol (ethanol and ETBE) 

Although the EU is today the third largest bioethanol producer in the world, it remains a modest player 
with only 0.8% of the total global ethanol production in 2018. The USA and Brazil are the two largest 
producers, representing 92% and 7% respectively of global production. 122 Figure 23 shows 
bioethanol (ethanol and ETBE) production in the EU from 2010 through to 2018. The figure displays 
the ten largest EU producers and separates them from the rest of Member States (which are 
presented aggregated). While EU bioethanol consumption has declined from 2011 to 2016 (Figure 
21), the production has shown an increasing trend with a peak in 2013. In 2013, EU ethanol 
production benefitted from lower feedstock prices and more stringent import measures, thus 
bioethanol production reached more than 2,500 ktoe (equal to about 5 billion litre). The import 
measures included both tariff (€ 0.19/litre) and non-tariff measures. Implementation of non-tariff 
measures such as sustainability criteria have significant potential to limit the bioethanol imports to the 
EU.  

The decline from 2013 through 2015 is due to a shrinking domestic market caused by the competition 
of double-counting of waste-stream biodiesel, high import duties, and changes to blending mandates 
in some Member States (e.g. the introduction of E10). The production dropped most significantly in 
the UK, Belgium, the Netherlands and France.  

Overall, from 2016 to 2018, EU bioethanol production increased because of the increasing demands 
of Member States as they attempt to meet their 2020 RES-T targets. Some Member States however 

121 Data are shown for the 10 Member States with the largest production volume in 2018. The other Member States are aggregated. 
122 https://www.statista.com/statistics/281606/ethanol-production-in-selected-countries/ 

 
 
 
 
 
 
                                                      
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experienced a decrease in production from 2017 to 2018, most notably Germany and the UK. The 
German Bioethanol Industry Association attributes the decline in production to the increase in crop 
prices caused by the drought experienced in 2018. In the UK, the decline could be explained by 
competition with waste-based biodiesels and the gradual decline of the cap on crop-based fuels.123  

Figure 23. Bioethanol production in the EU28 (2010 – 2018, ktoe). 124 Source: Eurostat nrg_bal_c 

4.3 Annex IX biofuels 

The use of waste streams or residues as feedstocks for biofuels are likely to cause less sustainability 
impacts than traditional agricultural crops. Likewise, lignocellulose feedstocks such as energy grasses 
could be produced with less sustainability impacts. These so called “advanced” biofuels, based on 
biomass waste and residues, typically have high greenhouse gas emissions savings (compared to the 
fossil comparator) and a low indirect land use change (ILUC) impact125. For this reason, the 
Renewable Energy Directive sets separate goals for biofuels produced from these types of feedstock 
or attributes a higher value in the form of double counting. Two types of feedstock are examined in 
this section: 

•  Annex IX A type biofuels, which are produced from a range of very different feedstocks (including 

gaseous fuels).  

•  Annex IX B type biofuels, which are produced from used cooking oil (UCO) or animal fat. 

123 USDA GAINS Report, EU Biofuels Annual 2019. 
124 Data are shown for the 10 Member States with the largest consumption volume in 2018; The other Member States are aggregated. Note: Eurostat reports 
the consumption of biogasoline. The majority of this product is bioethanol or its derivative bio-ETBE. 
125 See detailed results in the GLOBIOM studies, available from the EC website: 
https://ec.europa.eu/energy/sites/ener/files/documents/Final%20Report_GLOBIOM_publication.pdf and 
https://ec.europa.eu/energy/sites/ener/files/documents/globiom_complimentary_2016_published.pdf  

 
 
 
 
 
                                                      
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The ILUC Directive includes a national sub target of 0.5% for biofuels produced from Annex IX Part A 
feedstocks.126 Part B of Annex IX includes a separate list of waste feedstocks (namely UCO and 
animal fats categories 1 and 2). Biofuels produced from both Part A and Part B Annex IX feedstocks 
count twice towards a Member State’s 10% RES-T target. In addition, the ILUC Directive also sets a 
cap of 7% on the use of food and feed crop-based biofuels in transport.  

In December 2018, the recast of the Renewable Energy Directive (REDII) was published, covering the 
period 2021-2030. The new Directive specifically promotes the consumption of advanced biofuels with 
the following provisions 127:  

•  Biofuels produced with feedstocks listed in Part A of Annex IX shall at least have a share of final 
consumption of energy in the transport sector of 0.2% in 2022, rising to 1% in 2025 and 3.5% by 
2030. 

•  Biofuels produced with feedstocks listed in Parts A or B of Annex IX may be double counted 

towards a Member State RES-T target. 

•  With the exception of fuels produced from food and feed crops the share of fuels used for aviation 

and maritime are counted 1.2 times. 

•  The share of food and feed crop-based biofuels in transport shall be no more than 1% higher than 

the share of such fuels in the final consumption of energy in the road and rail transport sectors in 
2020 in that Member State, with a maximum of 7% of final consumption of energy in the road and 
rail transport sectors in that Member State.128  

Based on the above proposed elements and the EC support programs for the commercialization of 
Annex IX A biofuels 129, the production and consumption of advanced biofuels in the EU are expected 
to increase beyond 2020. 

Increasingly, biofuels are produced from waste and residues as demonstrated by the increased 
consumption of double counting biofuels, as discussed in Section 2.3 and shown in Figure 8. In the 
biodiesel sector, this can be both FAME and HVO on the basis of UCO or animal fats or HVO on the 
basis of tall oil. Other types of Annex IX A feedstock are not yet widely used in biodiesel.  

Cellulosic bioethanol is an advanced biofuel that has been promoted by several companies in the EU. 
However, the market has been slow to develop due to various reasons (technical and/or financial) and 
some previously operational plants have ceased operation. Beta Renewables, for example, closed 
operations of its cellulosic ethanol plant in 2017 due to the bankruptcy of its parent company130 and 
Abengoa similarly sold their assets in a plant in Spain in 2016.131 Also outside the EU some 
operational plants have had to cease operation. 132 

There are still, however, several cellulosic ethanol projects underway, including the St1 Biofuels Oy 
demonstration plant in Kajaani Finland (10 million litres annual capacity) which began in 2017 to use 
residual sawdust from the forestry sector and test the profitability of cellulosic ethanol production. 133 
Clariant is also very active in this space and has signed several license agreements for its Sunliquid 
technology for cellulosic ethanol plants from agricultural residues (such as straw) in Slovakia and 
Romania (annual capacity 50,000 tonnes each), and most recently in Poland (annual capacity 25,000 
tonnes).134 

126 Member States shall endeavour to achieve the target and can also set a lower target if justified. 
127 Please note that the REDII further introduces a cap on the use of Part B Annex IX fuels.  
128 Member States can set a lower target “taking into account best available evidence on ILUC impact” and differentiate by crop type. 
129 E.g. Innovating for sustainable growth: a bioeconomy for Europe; Bio-based industries joint undertaking.  
130 http://www.biofuelsdigest.com/bdigest/2017/10/30/beta-renewables-in-cellulosic-ethanol-crisis-as-grupo-mg-parent-files-for-restructuring/  
131 USDA GAINS Report, EU Biofuels Annual 2019. 
132 For example POET-DSM in the US: https://cen.acs.org/business/biobased-chemicals/POET-DSM-pause-cellulosic-ethanol/97/i46 
133 https://forest.fi/article/st1-aims-to-increase-its-production-of-wood-based-bioethanol-15-fold-by-products-of-forest-industry-replace-fossil-raw-materials-
and-increase-carbon-sink-in-agricultural-lands/ 
134 https://www.chemanager-online.com/en/news-opinions/headlines/clariant-licenses-second-sunliquid-plant 

 
 
 
 
                                                      
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4.4 Origin of feedstock used for biofuels consumed in the EU 

4.4.1 Origin of biofuel feedstock 

This section presents the estimated origin of the main feedstocks used to produce biodiesel and 
bioethanol consumed within the EU. This information is estimated by combining the biofuel trade 
statistics from Eurostat with statistics and estimations of feedstock for biofuels in all biofuel producing 
countries, as well as trade statistics of the major feedstocks.  

Table 8 shows the origin of feedstock used for EU biodiesel consumption in 2018. The largest part of 
biodiesel by volume (41%) is estimated to be based on domestic feedstocks, mainly from rapeseed 
(26%), UCO 135 (8%) and animal fat (5%). In 2018, additional UCO was imported from South East Asia 
(in particular China), the USA and multiple other countries. Over 20% of the EU biodiesel volume 
originates from palm oil, mainly from Indonesia (11% of the EU consumed biodiesel) and Malaysia 
(4%). A smaller fraction is imported in the form of biodiesel from Indonesia (4% of the EU consumed 
biodiesel) and Malaysia (2% of the EU consumed biodiesel).  

In comparison, in 2016136 similar analysis indicated over 60% of the biodiesel to be based on EU 
feedstocks. Also, in absolute terms (5,871 ktoe in 2018 versus 7,062 in 2016), the share of the EU 
feedstocks went down. The main increase in share (both percentage as well as absolute) comes from 
palm oil (both from Indonesia and Malaysia) and soybean (Argentina). The use of rapeseed for 
biodiesel is in absolute terms similar to the values from 2016, with the increases mainly caused by 
biodiesel produced from palm oil, soybean and UCO.  

Table 8. Origin of feedstock for biodiesel as consumed within the EU (2018, % and ktoe). Source: Navigant analysis 

EU 
Australia 
Ukraine 
Canada 
Indonesia 

Malaysia 
USA 
Brazil 
China 
Argentina 
Other 
Unknown 
Total (%) 
Total (ktoe) 

Rapeseed  Palm oil  Soybean  UCO 

26% 
2% 
2% 
0% 

0% 
0% 
0% 
0% 
0% 
1%1) 
32% 
4,502  

0% 

15% 

7% 
0% 
0% 
0% 

1%2) 

1% 

0% 
0% 
0% 

0% 
3% 
2% 
0% 
9% 
0% 

23% 
3,208  

15% 
2,193  

8% 
0% 
0% 
0% 
2% 

1% 
1% 
0% 
4% 
0% 
3%3) 
0% 
19% 
2,678  

Animal 
fat 

5% 

5% 
693  

Other, pine/tall 
oils, fatty acids, 
sunflower oil 

Total 
(%) 

Total 
(ktoe) 

1% 

0% 

0% 

1% 
4% 
6% 
921  

41% 
2% 
3% 
1% 
17% 

8% 
4% 
2% 
4% 
9% 
5% 
5% 
100% 

5,871  
308  
362  
96  
2,382  

1,082  
580  
266  
527  
1,342  
707  
671  

14,194  

1) Small fraction of rapeseed imports is reported in the Eurostat [EU trade since 1988 by CN8 [DS-016890]] as import from countries and territories not 
specified for commercial or military reasons 
2) Smaller fractions of palm oil-based biodiesel are estimated to originate from amongst others Honduras (0.3%), Guatemala (0.1%) and Colombia (0.1%) 
3) Smaller fractions of UCO biodiesel are estimated to originate from amongst others Saudi Arabia (0.5%), Japan (0.3%), Russia (0.3%) 

Table 9 shows the origin of feedstock used for EU bioethanol consumption in 2018. About 73% of the 
bioethanol consumed in the EU in 2018 is estimated to stem from feedstocks produced in the EU, 
mainly wheat (34%), maize (24%) and sugar beet (14%) and only a small amount (0.3%) from 

135 Investigations into suspected fraud cases regarding UCO are currently ongoing (Transport & Environment 2020, Letter from the Dutch Ministry of 
Infrastructure and Water Management to the The President of the House of Representatives of the States General, June 2020). Outcomes of this 
assessment are solely based on statistics. 
136 Ecofys, A Navigant company, 2019, Technical assistance in realisation of the 2018 report on biofuels sustainability Biofuels, biomass & biogas used for 
renewable energy generation:  
https://ec.europa.eu/energy/sites/ener/files/documents/technical_assistance_in_realisation_of_the_2018_report_on_biomass_sustainability-final_report.pdf 

 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
                                                      
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cellulosic ethanol. In reality, this number is possibly higher, as the origin of barley, rye and triticale 
was not assessed, but can be expected to originate partially from the EU. Non-EU origin feedstocks 
account for about 27% of the EU bioethanol market, mainly maize originating from Ukraine, USA, 
Pakistan, Russia, Brazil and Canada. 

In comparison, in 2016137 similar analysis indicated that 65% of the bioethanol was based on EU 
feedstocks. Also, in absolute terms (2,199 ktoe in 2018 versus 1,700 in 2016), the share of the EU 
feedstocks increased. The main increase in share (both percentage as well as absolute) comes from 
European wheat-based ethanol. This is now also the largest feedstock used for ethanol, while in 2016 
this was maize (whose share in absolute terms remained stable).  

Table 9. Origin of feedstock for bioethanol as consumed within the EU (2018, % and ktoe). Source: Navigant analysis 

Wheat  Maize  Barley  Rye 

34% 
0% 
0% 
0% 
0% 

1% 
0% 
0% 
0% 
37% 

24% 
4% 
2% 
1% 
2% 

0% 
0% 
1% 
0% 
34% 

0% 
0% 
0% 
0% 
0% 

0% 
0% 
0% 
2% 
2% 

0% 
0% 
0% 
0% 
0% 

0% 
0% 
0% 
3% 
3% 

Triticale 
0% 
0% 
0% 
0% 
0% 

0% 
0% 
0% 
5% 
5% 

Sugar 
beet 

Sugar 
cane 

14% 
0% 
0% 
0% 
0% 

0% 
0% 
0% 
0% 
14% 

0% 
0% 
1% 
0% 
0% 

0% 
2% 
1% 
0% 
4% 

Cellulosic 
0% 
0% 
0% 
0% 
0% 

0% 
0% 
0% 
0% 
0% 

Unknown/ 
other 

Total 
(%) 

0% 
0% 
0% 
0% 
0% 

0% 
0% 
2% 
0% 
2% 

73% 
4.5% 
2.6% 
0.8% 
2.2% 

1.6% 
1.6% 
4.0% 
9% 
100% 

Total 
(ktoe) 
2,199 
134  
79  
24  
68  

50  
49  
119  
285  

1,101  

1,016  

70  

79  

136  

425  

116  

8  

54  

3,006  

EU 
Ukraine 
Brazil 
Canada 
USA 

Russia 
Pakistan 
Other 
Unknown 
Total (%) 
Total 
(ktoe) 

4.4.2 Global biofuels trade 

Figure 24 shows the global biodiesel trade in 2018. In 2018, a total of 24,805 ktonne of biodiesel was 
imported by EU countries, of which 13% (3,259 ktonne) was imported from countries outside the EU. 
The most notable observation from this figure is the return of import flows from Indonesia and 
Argentina. In 2011 and 2012, Indonesia and Argentina were the major exporters of biodiesel to the 
EU, with a combined export volume of more than 2,500 ktonne per year (>88% of the total import to 
the EU). After enforcement of the EC anti-dumping tariffs on biodiesel imports from Argentina and 
Indonesia, the biodiesel imports from these two countries dropped significantly since 2013 (combined 
volume of 820 ktonne in 2013 and 430 ktonne in 2014) and almost ceased in 2015 and 2016.  

Since then the void was partially filled with domestic EU production and with an increase of imports 
from countries not impacted by the EC anti-dumping tariffs such as Brazil, China, India, Malaysia and 
South Korea. In 2018, Argentina and Indonesia regained their positions as major exporters of 
biodiesel to the EU, with exports from 1,648 ktonne and 785 ktonne respectively. This was due to the 
removal of anti-dumping duties from Argentina in September 2017 and Indonesia in March 2018. 138 

Next to that, trade within the EU increased significantly from 8,734 ktonne in 2016 to 21,545 ktonne in 
2018 139. Also, exports to the USA increased to 575 ktonne in 2018. In 2016, the USA mainly imported 

137 Ecofys, A Navigant company, 2019, Technical assistance in realisation of the 2018 report on biofuels sustainability Biofuels, biomass & biogas used for 
renewable energy generation:  
https://ec.europa.eu/energy/sites/ener/files/documents/technical_assistance_in_realisation_of_the_2018_report_on_biomass_sustainability-final_report.pdf 
138 USDA GAINS Report, EU Biofuels Annual 2019. 
139 Please note that we have not been able to identify the reason behind this quite drastic increase. It could just be regular trade fluctuations, but no specific 
reason in the market has been identified so far. The import from outside the EU has increased a lot (from 467 ktonne in 2016 to 3159 ktonne in 2018), which 
probably enters through a limited number of major ports/entry points and then gets distributed to other EU countries. It could be that the increased import 
from outside the EU is thus the main reason for increased inter-EU trade. 

 
 
 
  
  
  
 
 
                                                      
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from Argentina and the Pacific region, while in 2018 the highest share of biodiesel import was from 
the EU. This is most likely linked to the increase of export tax on biodiesel from 8 to 15% in Argentina, 
effective as of July 2018. 140 

Figure 24. Global biodiesel trade (2018, ktonne). 141 Source: Eurostat, Comtrade 

Figure 25 shows the global ethanol trade in 2018. In 2018, a total of 5,238 ktonne of ethanol was 
imported by EU countries, of which 9.5% (497 ktonne) was imported from countries outside the EU. 
The main suppliers were Pakistan (100 ktonne), the USA (91 ktonne), Russia (73 ktonne), Guatemala 
(67 ktonne) and Brazil (58 ktonne). Although Pakistan and Guatemala are not large bioethanol 
producers from a global perspective, the EU has zero duty trade relationships with both countries 
which makes for a favourable import setting. 142  

The EU ethanol import landscape has seen important changes since 2012. In 2012, imports 
accounted for 21% of the EU ethanol market, half of which was imported from the USA because of 
low EU import duties for high ethanol blends combined with the Volumetric Ethanol Excise Tax Credit 
(VEETC) in the USA. This resulted in the dumping of USA bioethanol in the EU market which 
subsequently reduced the market share of domestically produced bioethanol. As of February 2013, 
the EC imposed a five-year anti-dumping tariff of €49.20 per 1,000 litres in addition to the already 
imposed import tariff of €102 per 1,000 litres on the bioethanol import from the US. This rate 
significantly cut USA exports of ethanol to the EU from 522 ktonne in 2012 to 91 ktonne in 2018.  

EU ethanol export to destinations outside of the EU was marginal, at only 107 ktonne in 2018. 

The USA and Brazil were the largest global exporters of ethanol in 2018, and collectively exported 
more than 9,000 ktonne of ethanol. Aside from intra-trade between the two nations and export to 
Canada from the USA, the majority of the USA and Brazil ethanol found its way to the Asian market, 
mainly in India (867 ktonne from the USA and 9 ktonne from Brazil), South Korea (432 ktonne from 
Brazil and 328 ktonne from the USA), Japan (430 ktonne from Brazil and 110 ktonne from the USA), 

140 USDA GAINS Report, EU Biofuels Annual 2018. 
141 Trade flows larger than 100 ktonne are shown. Trade based on codes 38260010 and 38260090 (Biodiesel and mixtures thereof, not containing or 
containing less than 70% by weight of petroleum oils or oils obtained from bituminous minerals) including both FAME biodiesel and other biodiesel such as 
HVO.  
142 USDA GAINS Report, EU Biofuels Annual 2019. 

 
 
 
 
 
 
                                                      
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Philippines (464 ktonne from the USA and 7 ktonne from Brazil), and China (464 ktonne from the 
USA). In 2016, the combined export of the USA and Brazil was just above 3,200 ktonne of ethanol 
and these countries have significantly scaled up their export since then. 

It can be concluded that the international biofuel market is quite dynamic and trade routes change 
continuously. The production side is volatile in particular because of weather impacts and the 
influences from other agricultural commodity markets. Changes in international biofuels policy and 
trade barriers such as import tariffs are other important factors that influence the international biofuel 
market. 

Figure 25. Global ethanol trade (2018, ktonne). 143 Source: Eurostat, Comtrade 

143 Trade flows larger than 100 ktonne are shown. Trade based on codes 22072000 (Ethyl alcohol and other spirits, denatured, of any strength) and 2207100 
(Undenatured ethyl alcohol of an alcoholic strength by volume of 80% vol or higher). 

 
 
 
 
                                                      
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5. Environmental impacts related to biofuels 

The Renewable Energy Directive requires Member States and the European Commission to report on 
various local and global sustainability aspects of biofuels consumed in the national markets and in the 
EU as a whole. This includes both environmental aspects (this chapter) and socio-economic aspects 
(Chapter 6). Environmental impacts related to biofuels consumed in the EU are assessed on the basis 
of the Member State Progress Reports and additional analysis of literature and statistics. All Member 
States have implemented measures to safeguard sustainability criteria in line with the criteria set out 
in the Directive.  

The land use, around the world, for biofuels consumed in the EU has been estimated on the basis of 
the breakdown of biofuels volume from crops and countries of origin presented in Chapter 4. Overall, 
it is estimated that7.4 Mha of cropland globally (close to the total land area of Ireland), of which 3.4 
Mha in the EU (comparable to the total land area of the Netherlands), has been used for the 
production of crops for EU biofuel consumption. Member States have also reported on crop area for 
biofuels feedstock, but they often report on the whole crop area, without specifying the (small) part 
used for the biofuel feedstocks. Member States also do not cover the impact in third countries related 
to imported feedstocks. 

On the basis of the crop-fuel volumes estimated in the previous chapter, the total greenhouse gas 
emission reduction from EU consumed biofuels in 2018 is estimated to be 48.6 Mtonne CO2eq, which 
is comparable to the annual emissions of 10.5 million cars. In their Progress Reports, Member States 
report a total emission reduction of 45.6 Mtonne CO2eq (uncertain if this includes or excludes ILUC 
values).  

When the 2018 crop feedstock volumes are multiplied by the corresponding mean ILUC values from 
the ILUC Directive, the total emission savings from renewable energy in transport is reduced to 24.0 
Mtonne of CO2 savings (within a range of 18.8-33.8 Mtonne of CO2 savings).   

In recent years, several new studies on ILUC have been published (see review in Section 5.3.1). They 
confirm the understanding that the ILUC impact depends on many factors. Gradually, less research is 
focusing on quantification of ILUC, while more studies focus on ILUC mitigation.  

Feedstock production for all types of EU consumed biofuels can have local environmental impacts. 
These impacts are site specific and depend on the agricultural practices applied on that specific farm 
or region. Voluntary schemes help to ensure that biofuels are sustainably produced and comply with 
the EU sustainability criteria. Several schemes, recognised by the EC, also consider additional 
sustainability aspects such as soil, water, air protection and social criteria. However, this may not 
completely avoid impacts, and a continued effort is needed to decrease impact and increase insights 
in the size of these impacts.  

The majority of countries (Member States and main third countries) have ratified all relevant 
conventions on biodiversity and labour. Malaysia has accepted/ratified the majority of the relevant 
conventions. The USA, however, has ratified or accepted only two of the relevant conventions. 
Globally, there have been very limited changes in ratification and acceptance of conventions by the 
countries relevant for EU biofuel feedstock production since 2010. Thus, although coverage is 
reasonable over the amount of countries providing feedstock, very little improvements can be shown 
since 2010, as discussed in Section 5.5.  

 
 
 
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5.1 Measures taken to respect the sustainability criteria for biofuels 

National implementation of Renewable Energy Directive sustainability criteria and the ILUC Directive 
are presented in Table 10. All of the 28 Member States have implemented the Renewable Energy 
Directive’s sustainability criteria in their national legislation. 

Fourteen Member States reported that they have implemented the ILUC Directive already in national 
legislation (see Table 10). One Member State, Bulgaria, mentions that the implementation of the ILUC 
Directive has started in 2018. The other thirteen Member States have not mentioned the ILUC 
Directive, or its national implementation, in their Progress Reports. They have however reported to 
the Commission that the ILUC Directive has been implemented.   

Table 10. National implementation measures to respect biofuel sustainability criteria. Source: MS Progress Reports 
and communication by EC 

Member State 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 
Czech Republic 

Denmark 

Estonia 

Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
UK 

National implementation of RED 
sustainability criteria 
Yes 

Yes 

Yes 
Yes144  
Yes 
Yes 

Yes 

Yes 

Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 

National implementation of ILUC Directive 

Reported as ‘existing’ amendment 

Implemented 2019 

Started implementing into national law in 2018 

Reported to EC as implemented 

Reported to EC as implemented 
Reported to EC as implemented 

Reported to EC as implemented 

Reported to EC as implemented 

Implemented July 2017 
Reported to EC as implemented 
Implemented 2017 
Implemented 2018 
Reported to EC as implemented 
Implemented 2016 
Implemented March 2017 
Reported to EC as implemented 
Implemented July 2017 
Implemented 2017 
Reported to EC as implemented 
Implemented 2018 
Implemented January 2018 
Reported to EC as implemented 
Implemented 2015 
Reported to EC as implemented 
Reported to EC as implemented 
Implemented 2018 
Implemented 
Reported to EC as implemented 

144 Please note that national implementation of the Renewable Energy Directive has not been explicitly mentioned in the Progress Report. However, 
obligations and related biofuel quotas are set through the Biofuel Action Plan, which therefore seems to cover the implementation of the Directive.  

 
 
 
 
                                                      
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5.2 Land use and land use changes 

This section analysis the changes in land use associated to the production of EU biofuels 
consumption, on the basis of the following two types of data sources:  

1.  A statistical analysis: The total amount of land that is used to produce the feedstocks is calculated 
by combining the results about the type and origins of feedstocks, with associated yields per 
country of origin. This also gives insights into land use for EU biofuel consumption in the main 
countries of supply. 

2.  The data reported in the Member State Progress Reports. 

5.2.1 Statistical analysis 

Most of the feedstocks for biofuels consumed in the EU originate from food/feed crops such as sugar, 
starch or vegetable oil crops. Therefore, it is important to understand how biofuel consumption in the 
EU impacts the land used for this part of food/feed crop production both domestically and globally. In 
this section the total land use for the production of biodiesel and bioethanol, as the main fuel 
additives/replacement to diesel and gasoline, in the EU transport sector in 2018 is estimated based 
on statistical analysis. This estimate covers, separately, lands that are used within the EU and in third 
countries, for the production of biofuels consumed in the EU.  

To model the land use, this report applies a methodology145 based on combining the origin of 
feedstocks for biofuels production (as developed in Section 4.4) with country specific crop yields. Co-
products were accounted for by means of energy allocation in line with the greenhouse gas 
accounting rules of the Renewable Energy Directive.146 The method does not deliver an exact insight 
into where feedstock for EU biofuels has been originally produced, because there are many 
unknowns in the supply chain. However, it can estimate land use, based on market averages, insights 
into the trade of main biofuels and main feedstock. 

145 This methodology is based on the methodology as developed by Ecofys for the use in the Ecofys report for the European Commission on renewable 
energy progress and biofuels sustainability, published in November 2014. 
146 This means that only part of the land used to grow a crop is really for the main product, as another part can be allocated to the co-product. Therefore, the 
amount of land that is really needed for a biofuel is less than what would be expected if one would multiply the crop yield with conversion efficiencies. 

 
 
 
 
 
 
                                                      
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Methodology for land use modelling 

The land use for crops used as feedstock for biodiesel and bioethanol is modelled based on the 
types and origin of feedstock, as assessed in Section 4.4.1. Land use is assessed for the most 
relevant crop-country combinations: 

•  Land use for rapeseed, wheat, maize and sugar beet in the EU 
•  Land use for soybeans in Argentina 
•  Land use for oil palm fruit in Malaysia and Indonesia 

As reference, we indicate the breakdown of all land in these countries, based on the FAO 
database: 

•  Non-agricultural land 
•  Meadows and Pastures 
•  Land use for the assessed crops and all other crops 

The land used for the biofuel production for a specific crop-country combination is estimated 
based on: 

•  The total biofuel production of that country 
•  Export of biofuel from that country to the EU 
•  The share of the assessed crop as feedstock for biofuel production in the assessed 

country 

•  The conversion factor of the assessed crop to biodiesel 
•  The crop yield per area of land for the assessed crop-country combination 

Figure 26 shows how the land use for biofuel crops relates to other agricultural land use and the total 
land area of the country, for a selection of the main crop/country combinations used for the production 
of EU consumed biofuels in 2018. It is expected that these figures are higher than the actual land 
area used for biofuel crops, because conservative data has been used for the conversion efficiencies 
and yields.147  

Within the EU, 3.4 Mha of land is used for crops which are converted to biofuels in the EU and 
consumed within the EU. This equals 3% of the total cropland, which is 117 Mha in the EU. 0.1 Mha 
of land within the EU is used for crops which are converted to biofuels in the EU and exported to 
countries outside the EU. Rapeseed was the main crop used for biofuels production in the EU and 
represented 72% of the share of the total European land used for biofuels production.  

147 Efficiencies are taken from the BioGrace tool, which was developed to mimic the greenhouse gas performance as tabulated in the Renewable Energy 
Directive in 2009. It should be expected that supply chain efficiency has improved in the meantime. Yield data is taken from FAOstat, even though the most 
recent year is taken as reference, it is expected that part of the data is outdated. Moreover, it does not take into account options of multi-cropping and 
advantages following from crop rotation. 

 
 
 
 
                                                      
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Land use for production of Rapeseed for Biodiesel in EU in 2018

Meadow s and 
pastures

Land use for 
other crops

Other 
Purposes

Rapeseed

Non - agricultural 
land

Fuel 
consumed in 
the EU

Fuel consumed 
outside the EU

Total land area
Non - agricultural land

423,796 kha
242,150 kha

Meadow s and pastures

64,227 kha

Total land use for Rapeseed
Land use for other crops

6,891 kha
110,526 kha

Land for Rapeseed
Rapeseed for Biodiesel produced in the EU - 
          consumed in the EU
Rapeseed for Biodiesel produced in the EU - 
          consumed outside of the EU
Rapeseed for other purposes

6,891 kha
2,440 kha

100 kha

4,351 kha

Land use for production of Wheat for Bioethanol in EU in 2018

Meadow s and 
pastures

Land use for 
other crops

Wheat

Non - agricultural 
land

Other 
Purposes

Fuel 
consumed in 
the EU

Fuel consumed 
outside the EU

Total land area
Non - agricultural land

423,796 kha
242,150 kha

Meadow s and pastures

64,227 kha

Total land use for Wheat
Land use for other crops

25,496 kha
91,922 kha

Land for Wheat
Wheat for Bioethanol produced in the EU - 
          consumed in the EU
Wheat for Bioethanol produced in the EU - 
          consumed outside of the EU
Wheat for other purposes

25,496 kha
563 kha

26 kha

24,907 kha

Land use for production of Maize for Bioethanol in EU in 2018

Meadow s and 
pastures

Land use for 
other crops

Maize

Other 
Purposes

Non - agricultural 
land

Fuel 
consumed in 
the EU

Fuel consumed 
outside the EU

Total land area
Non - agricultural land

423,796 kha
242,150 kha

Meadow s and pastures

64,227 kha

Total land use for Maize
Land use for other crops

8,246 kha
109,171 kha

Land for Maize
Maize for Bioethanol produced in the EU - 
          consumed in the EU
Maize for Bioethanol produced in the EU - 
          consumed outside of the EU
Maize for other purposes

8,246 kha
210 kha

10 kha

8,027 kha

 
 
 
 
 
 
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Land use for production of Sugar beet for Bioethanol in EU in 2018

Meadow s and 
pastures

Land use for 
other crops

Sugar beet

Other 
Purposes

Non - agricultural 
land

Fuel 
consumed in 
the EU

Fuel consumed 
outside the EU

Total land area
Non - agricultural land

423,796 kha
242,150 kha

Meadow s and pastures

64,227 kha

Total land use for Sugar beet
Land use for other crops

1,746 kha
115,671 kha

Land for Sugar beet
Sugar beet for Bioethanol produced in the EU - 
          consumed in the EU
Sugar beet for Bioethanol produced in the EU - 
          consumed outside of the EU
Sugar beet for other purposes

1,746 kha
83 kha

4 kha

1,660 kha

Figure 26. Land use for production dedicated to EU biofuel production versus other land uses, for major crops in the 
EU (2018). Source: Navigant analysis 

Out of the 7.4 Mha land used for biofuels feedstock in 2018, 3.4 Mha (46%) is located within the EU 
and 3.8 Mha (51%) is located outside the EU.148 For the main feedstock supplying countries outside 
the EU (see Figure 27), the share of cropland that was estimated to be used for feedstock for EU 
biofuels is likely small. For Indonesia it is estimated that less than 1% of their total cropland was used 
for the extraction of feedstocks that were used in the production of biofuels produced or consumed in 
the EU. For Argentina (for soybean production for biofuels produced or consumed in the EU) and 
Malaysia (for palm oil for biofuels consumed or produced in the EU) the share of land estimated to be 
used for feedstock for EU biofuels makes up 3.3% of the total cropland. As shown in Section 4.4.2, 
Argentina is the largest exporter of biodiesel to the EU in 2018. 

Indonesia was estimated to use 9.8% of its palm oil cultivated land for biofuels that were produced or 
consumed in the EU in 2018. This is higher than in 2016 (5.2%) and 2012 (6.5%).149 The drop from 
2012 to 2016 is likely to be a result of the combination of the considerable increase in total land used 
for palm oil cultivation and the implementation of the EC anti-dumping tariffs on biodiesel imports from 
Indonesia since 2013 (please refer to Section 4.4 for details). This did not impact the import of palm 
oil and EU producers could still use imported palm oil. The increase observed from 2016 to 2018 is 
likely driven by the increase of palm-oil export from Indonesia to the EU after the removal of anti-
dumping duties from Indonesia in March 2018. 150 As shown in Figure 27, the majority of land used for 
palm oil production (95%) is used for production of palm oil for other purposes than biodiesel 
production. Around half of all palm oil exported by Indonesia is exported to India (23%), China (13%), 
Pakistan (9%) and Bangladesh (5%). Palm oil use in these countries includes consumption in the food 
market.151  

Malaysia, the third largest biodiesel exporter to the EU in 2016, used 1.2% of its total palm oil 
cultivated land for biofuels that were produced or consumed in the EU.  

148 The remaining 0.2 Mha (3%) of feedstock concerns barley, rye and triticale sourced from unknown countries. 
149 Values for 2016 and 2012 were estimated based on a similar analysis based on FAO data for those years.   
150 USDA GAINS Report, EU Biofuels Annual 2019. 
151 UN Comtrade Database 

 
 
 
 
 
                                                      
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Land use for production of Soybeans for Biodiesel in Argentina in 2018

Meadow s and 
pastures

Land use for 
other crops

Soybeans

Non-agricultural 
land

Other purposes

Fuel produced in 
Argentina consumed 
in EU

Fuel produced in 
Argentina consumed 
outside EU

Total land area
Non - agricultural land
Meadow s and pastures

273,669 kha
124,969 kha
108,500 kha

Total land use for Soybeans

16,318 kha

Land for Soybeans
Soybeans for Biodiesel produced in the EU
Soybeans for Biodiesel produced in Argentina - 
   consumed in the EU
Soybeans for Biodiesel produced in Argentina - 
   consumed outside of the EU

16,318 kha
0 kha
1,340 kha

680 kha

Land use for other crops

23,882 kha

Soybeans for other purposes

15,638 kha

Land use for production of Oil palm fruit for Biodiesel in Indonesia in 2018

Land use for 
other crops

Meadows and 
pastures

Oil palm fruit

Other purposes

Non-agricultural 
land

Fuel produced in 
Indonesia consumed 
in EU
Fuel produced in 
Indonesia consumed 
outside EU

Total land area
Non - agricultural land
Meadows and pastures

187,752 kha
125,452 kha
11,000 kha

Total land use for Oil palm fruit

6,777 kha

Land for Oil palm fruit
Oil palm fruit for Biodiesel produced in the EU
Oil palm fruit for Biodiesel produced in Indonesia - 
   consumed in the EU
Oil palm fruit for Biodiesel produced in Indonesia - 
   consumed outside of the EU

Land use for other crops

44,523 kha

Oil palm fruit for other purposes

6,777 kha
446 kha
219 kha

1,186 kha

5,146 kha

Figure 27. Land use for crop production dedicated to EU biofuels versus other land uses, for major crop-country 
combinations (2018). Source: Navigant analysis 

 
 
 
 
 
 
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To put the global land use for crops used for biofuels consumed in Europe in perspective, the 
following table shows the land use for biofuels consumed in Europe as percentage of total land used 
for the production of that crop.  

 Table 11. Land use for crops used for biofuels consumed in the EU in comparison to global land use for production of 
those crops in 2018. Source: FAOstat and Navigant analysis 

Crops 
Rapeseed 
Palm oil 
Soybean 
Wheat 
Maize 
Sugar beet 
Sugar cane 
Other (barley, rye, triticale) 
Land for EU biofuels crops 
compared to global total cropland 

Land for biofuels 
consumed in EU (kha) 

Global land used for crop 
production (kha) 

Share of global 
land use  
(%) 

3,201  
981  
1,908  
652  
309  
84  
44  
245  

7,424 

37,580  
18,917  
124,922  
214,292  
194,904  
4,809  
26,270  
55,855  

1,423,329  

8.5% 
5.2% 
1.5% 
0.3% 
0.2% 
1.8% 
0.2% 
0.4% 

0.5% 

5.2.2 Member States reported land use for production of crops for energy use 

Member States are required to every two years report any changes in land use associated with the 
increased use of biomass or other sources of renewable energy in their Progress Reports 152. 

At the time of writing this report, all 28 Member States submitted their 2019 Progress Reports to the 
Commission. Of these, ten Member States (Croatia, Cyprus, Estonia, Finland, France, Malta, 
Slovenia, Spain, Sweden and the UK) did not report land used for crops dedicated to bioenergy. The 
other Member States reported land use in the following three general categories: 

•  Land used for common arable crops (including starch, sugar and oilseeds) 
•  Land used for short rotation trees 
•  Land used for other energy crops such as grasses 

Please note that the land use reported by Member States covers crop production dedicated to total 
bioenergy use including solid, gaseous and liquid biofuels that are consumed in the electricity, heating 
& cooling and transport sectors combined. The method for reporting land use differs per Member 
State and sometimes concerns all land used for a crop, not limited to the share used for bioenergy 
production.  

Most Member States reported limited, or no impact, on land use within their territory (Austria, 
Denmark, Bulgaria, Hungary, the Netherlands, Poland, Spain and Sweden). These Member States 
refer to land use statistics to support the conclusion that increased use of biomass and renewable 
energy has limited impact on land use in their Member State. Other Member States (Belgium, Cyprus, 
the Czechia, Estonia, Finland, Lithuania, Norway and Portugal) estimate the impact without providing 
further quantitative evidence or clarifications on the methodology applied. However, in general, the 
data quality is poor: definitions vary per Member State, and different methods have been used for 
data collection. Twelve Member States report data on land used for energy crops with the by largest 
amounts in Italy. Some only report the data for a certain land use type but not for others (e.g. 
Bulgaria, Greece and Lithuania). One Member State, Slovakia, reported the total crop land and 
showed the share of crops dedicated to bioenergy. 

In some of the Progress Reports, it is not clear whether the data represent total cropland or only 
cropland dedicated to bioenergy (e.g. this is the case for Bulgaria, Greece, Ireland, Italy and Latvia). It 
is therefore difficult to draw any overall conclusions based on the data provided. This is also shown 
when the total area reported by Member States (17 Mha) is compared to the calculated amount of 

152 Available at https://ec.europa.eu/energy/en/topics/renewable-energy/progress-reports  

 
 
 
 
 
                                                      
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land required in Europe to produce the total amount of biofuels consumed in the EU in 2018 (3.4 Mha, 
see previous section on statistical analysis). 

Table 12 shows the amount of land used in the EU for the production of crops used for bioenergy 
purposes, as reported in the Member States Progress Reports. As can be seen from the table, the 
overall growth of land use over the period 2017-2018 has been negative. Both the land used for short 
rotation trees as well as the land used for other energy crops reduced substantially (by 7.2% and 
5.7%), which occurred mainly in Finland, Latvia, the Netherlands, Slovakia, Belgium and Poland. The 
land used for the cultivation of common arable crops and oilseeds shows significant expansion in 
some Member States (Belgium 49%, Luxembourg 41%, Hungary 11%, Slovakia and Poland 9%, 
Lithuania 8%, the Netherlands 8%) with an overall reduction of about 1% across the EU between 
2017 and 2018. A slight decrease can be seen in the period from 2015-2018. This is mainly due to 
land use reductions in Bulgaria, Denmark, Germany, Ireland, Italy and Poland and due to France not 
reporting on land use in 2017 and 2018. Yet, over 99% of the reported land in 2018 is land used for 
the cultivation of common arable crops and oilseeds. 

Again, note that in some of the Progress Reports, it is not clear whether the data represents total crop 
land or only crop land dedicated to bioenergy. This makes it difficult to draw conclusions on the 
significant expansion noted (which could also relate to overall crop production, price developments or 
surpluses in other markets etc.). The largest amounts of land reported in relation to bioenergy 
production are found in Romania (37%), Italy (20%), Bulgaria (13%) and Germany (12%) in 2018 (as 
a percentage of the total reported land by all Member States).  

Table 12. Land use for crops dedicated to energy production (ha) – common arable crops and oilseeds. Source: MS 
Progress Reports 

Member 
State 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

Common arable crops and oilseeds 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czechia 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
UK 
EU-28 
1) 
2) 

67,300 
16,674 
-  
-  
-  
172,426 
70,000 
-  
n/a 
1,230,073 
2,147,400 
67,389 
197,000 
315,000 
-  
693,424 
177,320 
581 
-  
4,000 
n/a 
4,357 
6,125 
153,000 
5,141 
n/a 
n/a 
14,942 

45,500 
7,197 
2,193,323 
0 
0 
123,662 
120,000 
0 
n/a 
- 
2,149,300 
86,059 
272,307 
288,494 
3,436,075 
569,834 
178,000 
1,014 
0 
2,600 
925 
302,049 
6,365,000 
145,521 
-1 
-2 
n/a 
- 
5,342,152  10,667,372  12,119,972  20,833,613  20,638,862  17,260,5563  17,210,6353 

51,400 
-  
2,864,916 
0 
0 
134,551 
130,000 
-  
0 
1,158,600 
2,396,700 
77,483 
0 
299,453 
3,677,980 
620,300 
139,000 
848 
-  
2,300 
2,560,021 
1,797 
6,396,500 
117,946 
3,156 
-  
0 
5,911 

71,500 
20,634 
-  
-  
-  
164,463 
125,000 
-  
n/a 
1,162,799 
2,211,300 
80,491 
300,000 
318,042 
-  
556,600 
- 
591 
-  
800 
553,975 
- 
6,248,300 
187,914 
5,563 
- 
n/a 
112,000 

77,500 
23,453 
-  
-  
-  
159,745 
130,000 
-  
n/a 
- 
1,979,700 
78,460 
300,000 
320,599 
-  
549,500 
- 
531 
-  
800 
601,370 
- 
6,176,900 
220,683 
6,131 
- 
n/a 
42,000 

38,100 
-  
2,886,137 
0 
0 
159,797 
150,000 
-  
0 
1,375,450 
2,431,800 
102,545 
0 
311,787 
3,665,076 
574,600 
137,000 
932 
-  
3,000 
2,612,581 
1,287 
6,248,700 
127,308 
1,629 
-  
0 
5,885 

52,200 
4,816 
2,223,342 
0 
0 
159,904 
140,000 
0 
n/a 
- 
2,163,600 
86,009 
245,751 
292,529 
3,558,622 
628,298 
165,000 
720 
0 
2,400 
848 
336,637 
6,218,800 
134,028 
-1 
-2 
n/a 
- 

The Slovenian member state Progress Report only provides the statement that there was no domestic production of biofuels in Slovenia. 
The member state Progress Report of Spain indicates that data on land use for crops dedicated to energy production is not available, but states that 
feedstock for biodiesel, HVO and bioethanol is grown in Spain for respectively 0.35%, 0.0% and 15.81%. 
Assuming numbers for Poland are 1.000 times larger than reported. The Polish Member State Progress Report, reported numbers in ha for 2017-
2018. Comparing their numbers to historical values and values of other countries it seems likely that these numbers were actually in kha. 

3) 

 
 
 
 
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Table 13. Land use for crops dedicated to energy production (ha) – short rotation trees and other energy crops. 

Source: MS Progress Reports 

Short rotation trees 

Other energy crops 

Member 
State 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

1,500 

1,500 

1,500 

1,240 

1,221  1,221   1,195  

1,214 

1,179 

1,173 

1,075 

1,078  1,125   1,071  

165 

100 

91 

-  

-  

-  

1584 

1595 

-  

-  

-  

-  

-  

0 

0 

-  

-  

122 

122 

0 

0 

-  

- 

0 

0 

- 

0 

0 

Czechia 

1,292 

1,589 

2,086 

2,838 

2,869 

2,850 

2,738 

Denmark 

4,000 

9,014 

9,518 

9,088 

8,896 

8,780 

8,651 

138 

n/a 

- 

-  

n/a 

50 

-  

- 

-  

n/a 

85 

- 

-  

n/a 

80 

43 

47 

-  

-  

509 

408 

-   6,821 

3,286 

0 

-  

0 

78 

-  

0 

-  

0 

66 

-  

- 

0 

0 

- 

78 

0 

- 

0 

0 

- 

86 

0 

Estonia 

Finland 

France 

-  

36 

-  

42 

-  

24 

4,508 

4,062 

5,539 

-  

23 

0 

-  

26 

0 

0 

34 

-  

0 

-  

-  

-  

29  14,949 

8,549 

7,501 

5,776 

5,452 

965 

829 

-  

n/a 

- 

- 

0 

0 

-  

- 

Germany 

4,900 

6,000 

6,000 

6,600 

6,600  6,630  

6,630 

2,000 

3,200 

4,900 

4,900 

5,400  6,400 

7,600 

- 

n/a 

839 

- 

n/a 

- 

0 

0 

- 

- 

n/a 

4,082 

4,104 

4,104 

4,104 

- 

n/a 

- 

n/a 

- 

n/a 

0 

0 

72 

0 

914 

1,033 

1,052 

1,046 

830 

843 

2,349 

2,055 

1,612 

1,285 

1,100 

- 

n/a 

973 

- 

n/a 

863 

6000 

5000 

5000 

321 

6,628 

- 

- 

n/a 

-  

20 

Lithuania 

2,000 

Luxembourg 

n/a 

Malta 

Netherlands 

-  

6 

- 

n/a 

-  

7 

Poland 

10344  11,486  13,499 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

n/a 

n/a 

n/a 

n/a 

n/a 

- 

n/a 

590 

-  

- 

- 

n/a 

650 

-  

- 

0 

0 

0 

0 

- 

- 

810 

700 

3,436 

4,063 

0 

-  

33 

276 

0 

0 

-  

13 

804 

0 

- 

n/a 

0  

14 

22  

n/a  

- 

n/a 

0 

8 

20 

n/a 

300 

3,200 

4,600 

4,420 

0 

0 

-  

0 

0 

-  

1,020 

145 

- 

- 

- 

- 

n/a 

884 

n/a 

84 

- 

- 

- 

- 

- 

- 

0 

0 

0 

0  40,901  39,596 

0 

0 

258 

252 

- 

- 

187 

92 

215 

211 

244 

295 

-  

-  

-  

-  

-  

124 

191 

190 

280 

245 

0  

242 

11  

0  

262 

8 

n/a 

-  18,406  10,000 

- 

0 

- 

- 

- 

0 

0 

0 

0 

-  

0 

n/a  

1,200 

970 

1,040 

0 

0 

-  

- 

- 

- 

- 

- 

- 

n/a 

n/a 

0 

n/a 

n/a 

n/a 

- 

- 

0 

- 

- 

- 

Sweden 

11861  11825  11637  11102  10193  10,246 

9,389 

912 

906 

646 

661 

669 

643 

691 

UK 

EU-28 

2,551 

3,000 

3,000 

10 

10 

- 

- 

8,075 

7,000 

7,000  11,046  11,222 

- 

- 

50,323  63,341  61,192  40,080  43,045  63,6521  59,0741  30,779  23,395  23,241  50,543  40,001  64,7081  60,9931 

1) 

Assuming numbers for Poland are 1.000 times larger than reported. The Polish Member State Progress Report, reported numbers in ha for 
2017-2018. Comparing their numbers to historical values and values of other countries it seems likely that these numbers were actually in kha. 

5.3 Greenhouse gas emission savings 

Since biofuels account for 89% of the renewables used in transport (without the multipliers of the total 
renewable energy in transport), the assessment of greenhouse gas performance related to renewable 
energy in transport focuses on understanding the greenhouse gas performance of biofuels. First, the 
greenhouse gas emission reductions estimated by Member States are reported as they are included 
in their Progress Reports 153. Second, the total savings are calculated from combining insights into the 
biofuel consumption and origin with reported savings.  

The EU Member States reported on the greenhouse gas emissions savings resulting from the use of 
renewable energy in transport in their Progress Reports. At the time of writing, all 28 Member States 
submitted their Progress Reports. Of these, one Member State did not report on the greenhouse gas 

153 Available at https://ec.europa.eu/energy/en/topics/renewable-energy/progress-reports  

 
 
 
 
                                                      
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emission savings (Belgium), and one other Member State (Estonia) only reported on greenhouse gas 
emissions savings per unit of fuel consumed. The reports indicate total greenhouse gas emission 
savings from transport and do not explain the roles of renewable electricity and (different types of) 
biofuels. However, given the overwhelming share of biofuels in the total amount of the renewables 
used in transport (89%), it can be expected that the emission savings largely result from the use of 
biofuels. In some Member States 154 a significant fraction is expected to come from the use of 
renewable electricity in transport, particularly in rail transport.  

Table 14 presents the emission savings reported by the Member States. The reported savings 
indicate a total greenhouse gas emission savings of 45.6 Mtonne CO2eq in 2018, which is a 14% 
increase in savings as compared to 2017. This is line with expectations as the share of renewable 
energy in the EU transport sector increased over the period of 2017-2018 (it was 7.1% in 2017 and 
8.0% in 2018).155 As mentioned, the emission savings in the transport sector are expected to be 
largely due to the use of biofuels. The amount of biofuels in EU transport increased by 12% between 
2017 and 2018. In contrast to the 2015-2016 Progress Reports, in which Sweden was the only 
Member State reporting substantial year-on-year increases in emission savings, the 2017-2018 
Progress Reports show many more Member States reporting substantial year-on-year increases in 
emission savings. These include Croatia (growing from 2 to 84ktCO2eq), Latvia (203% growth), 
Slovenia (201% growth), the Netherlands (70% growth), Poland (46% growth), the UK (41% growth) 
and Hungary (36% growth). This could be attributed to the growth in biofuel consumption, as shown in 
Chapter 4.1. 

None of the Member States indicate if the reported greenhouse gas emission savings include or 
exclude ILUC emissions. It is expected that Member States did not report ILUC emissions, since this 
was not required from the Member States for reporting in 2018. It is impossible to calculate the ILUC 
emissions per Member State, because this would require an exact insight in the feedstock 
composition per country, and in changing feedstock patterns over time: since ILUC occurs as a result 
of increasing feedstock consumption, the impact differs per time period.  

154 Countries with high share of renewable electricity in transport such as Austria (46%), Croatia (32%), Latvia (28%), Romania (25%). Share of renewable 
electricity in all renewable energy in transport, including multiplication factors. Source: SHARES database 
155 SHARES dataset, RES-T value including multiplicators. 

 
 
 
                                                      
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Table 14. GHG emission savings from the use of RE in transport (ktonne CO2eq). Source: MS Progress Reports 

EU GHG savings (ktCO2eq) 

Member States 
Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czechia 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
United Kingdom 
EU 

2017 
1,600 
n/a 
229 
2 
30 
887 
1 
n/a 
760 
7,600 
7,400 
331 
522 
473 
3,000 
22 
294 
331 
23 
874 
2,411 
819 
1,165 
338 
74 
3,403 
4,700 
2,639 
39,927 

2018 
1,600 
n/a 
272 
84 
30 
876 
1 
n/a 
720 
7,600 
7,700 
336 
710 
471 
3,400 
67 
330 
360 
29 
1482 
3,511 
944 
1,246 
366 
223 
4,318 
5,200 
3,726 
45,600 

The greenhouse gas emission savings can also be estimated on the basis of the insights into biofuels 
feedstock and their origin (see Section 4.4) in combination with the greenhouse gas emissions for 
biofuel pathways (see Table 15).156 This approach is limited to the greenhouse gas savings from the 
use of liquid biofuels (bioethanol and biodiesel) in transport and does not consider the savings related 
to the use of other types of renewable energy (gaseous biofuels and electricity). Therefore, the 
emission savings might be underestimated as in some Member States significant savings may come 
from use of renewable electricity in transport, especially in rail transport. In this exercise we use the 
information provided by the Commission   

Without taking ILUC factors into account, a total greenhouse gas emission savings of 48.6 Mtonne 
CO2eq (72% savings) was achieved through consuming 720,112 TJ of biofuels, compared to the 
situation where only fossil fuels would have been used.  

156 In previous progress reports, we have used the ‘typical’ greenhouse gas emissions from the Renewable Energy Directive for this analysis. In this edition, 
we have used the emissions for biofuels as reported by MS to the EEA. This information should be published by the EEA end of 2020.These emissions are a 
combination of actual emissions or typical default values as used by fuel suppliers to report to their MS.     

 
 
 
 
 
                                                      
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Table 15. GHG savings related to EU biofuel consumption (2018). Source: Navigant analysis 157  

Total 
consumption 

Fuel 

(ktoe) 

(TJ) 

ILUC factors not included 

ILUC factors included (mean values) 

GHG 
Emissions 
(gCO2e/MJ) 

 GHG 
Savings 
(gCO2e/MJ) 

Total GHG 
Savings 
(MtonneCO2e) 

GHG 
Emissions 
(gCO2e/MJ) 

 GHG 
Savings  
(gCO2e/MJ) 

Total GHG 
Savings 
(MtonneCO2e) 

Biodiesel 

14,194 

594,275 

Bioethanol 

3,006 

125,837 

26.7 

25.4 

67.3 

68.6 

40.0 

8.6 

65.6 

37.5 

Total 
1 The fossil fuel comparator is 94 g CO2eq/MJ fuel according to Directive (EU) 2015/652. 158 

720,112 

17,200 

67.5 

26.5 

48.6 

60.7 

28.4 

56.5 

33.3 

16.9 

7.1 

24.0 

The right half of Table 15 shows the resulting greenhouse gas emission savings when taking into 
account ILUC factors. The resulting emission savings are 24.0 Mtonne CO2eq, a 50% decrease from 
the 48.6 Mtonne CO2eq without ILUC factors. This decrease is mostly driven by the relatively high 
ILUC factors for most common biodiesel feedstocks, such as rapeseed, oil palm fruit and soybean (all 
55 gCO2eq/MJ).159 The ILUC factors used in to come to the values in the table above are the mean 
values as presented in the ILUC Directive. When taking into account the ranges in ILUC emissions as 
presented in the same ILUC Directive, the resulting greenhouse gas emission savings related to the 
consumption of biofuels are ranging between 18.8 Mt CO2eq to 33.8 Mt CO2eq, with the 24.0 Mt 
CO2eq as the ‘mean’ value.  

Biodiesel is particularly susceptible to ILUC factors because of the adjusted emissions savings of its 
feedstocks. 70% of biodiesel consumed in the EU comes from three feedstocks with a high ILUC 
factor: rapeseed, oil palm fruit and soybean, with respective shares of 32%, 23% and 15%. The ILUC 
factors for each of these are so high that the use of biodiesel made from these feedstocks could even 
be more emissions-intensive than the fossil fuel comparator benchmark (94 gCO2eq/MJ), in effect 
creating “negative” savings. This happens when using the high range of the ILUC emissions (rather 
than the mean) or when using the ‘default’ emissions savings as indicated in the RED (instead of the 
actual reported emissions savings related to biofuels consumed).  

5.3.1 ILUC science update 

The concept of ILUC was brought into biofuel discussions over a decade ago, and since then new 
research has continuously been added to the growing body of knowledge on this topic. This section 
provides an overview of notable ILUC research literature that has been published since 2018. These 
studies are formative for developing new tools to measure ILUC impacts, performing updated regional 
ILUC assessments, and showcasing the potential impacts of different ILUC policies if implemented. 
They serve as a basis for discussion on the ILUC topic for policymakers, academics, and other 
stakeholders in the biofuel community.  

Calculating the ILUC impact is a challenging exercise and methodologies are constantly evolving with 
new research, policy, and literature. ILUC impacts are typically calculated using large and complex 
models such as GLOBIOM160 and GTAP-BIO 161 and ILUC outcomes are dictated by input data and 
methodological choices in these models. As ILUC criteria are being increasingly integrated into policy 
quantitatively, it is important that methodologies are continuously critically assessed, refined, and 
improved. A recent example of ILUC in policy is the Carbon Offsetting and Reduction Scheme for 
International Aviation (CORSIA). In June 2019, the International Civil Aviation Organization (ICAO) 

157 The typical savings are an aggregate result from combining the estimated feedstock shares with typical greenhouse gas saving values reported in the 
Renewable Energy Directive. 
158 Similar to the REDII, the simple average of the fossil fuel comparators for diesel and petrol was used: https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32015L0652&from=IT 

159 Source: Directive (EU) 2015/1513. 
160 GLOBIOM is a partial-equilibrium model developed by International Institute for Applied Systems Analysis (IIASA) that analyses the competition for land 
use between agriculture, forestry, and bioenergy. It has been used for the EC to quantify the land area and GHG impacts of ILUC from biofuels consumed in 
the EU. https://ec.europa.eu/energy/sites/ener/files/documents/Final%20Report_GLOBIOM_publication.pdf  
161 Global Trade Analysis Project (GTAP) is a computable general equilibrium model that evaluates costs of abatement and to assess the spill-over effects of 
greenhouse gases (GHG) abatement policies via international trade and sectoral interaction. The GTAP-BIO is an extension of this model to analyse biofuels 
and global land use. https://www.gtap.agecon.purdue.edu/models/energy/default.asp 

 
 
 
 
                                                      
 
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released their methodology for calculating the default lifecycle emission values for CORSIA eligible 
fuels. 

Indirect Land use Change (ILUC) can occur when land previously devoted to food or feed 
production is converted to produce biofuels, bioliquids and biomass fuels. In that case, food and 
feed demand still needs to be satisfied, which may lead to the extension of agricultural land into 
areas with high carbon stock such as forests, wetlands and peat land, causing additional 
greenhouse gas emissions. (Source: Commission delegated regulation (EU) 2019/807) 

The methodology uses ILUC values from the GLOBIOM and GTAP-BIO models for various 
sustainable aviation fuel (SAF) pathways that differ by technology, region, and feedstock. Where the 
models have a discrepancy of greater than 10% of baseline GHG intensity for fossil kerosene, the 
lower value plus an adjustment factor of 4.45 gCO2e/MJ is taken.162 Cerulogy criticizes this 
methodological choice for calculating ILUC and argues that it introduces optimism bias, and more 
importantly is not analytically justified.163 Malins, Plevin and Edwards looked at the recent adjustments 
to the GTAP-BIO model and its effects on lowering ILUC values. This study argues that the new 
adjustments to the model systematically underestimate ILUC emissions because the role of 
productivity increases has been increased as compared to land use changes in meeting feedstock 
demand.164 

In contrast to large global models, other studies have focused on measuring ILUC impacts on a more 
localised and regional level, and new tools have also been developed to do so. Di Lucia  et al. 
developed a causal
ASsessment Tool (ILUC PAST). The approach was tested with a case study in Sardinia on cellulosic 
ethanol production. The authors concluded that combining quantitative estimates of ILUC with the 
cause
project level and local decision

effect dynamics from ILUC PAST are “sufficiently credible, salient and legitimate to support 

descriptive approach for project level assessment of ILUC called ILUC Project 

making”. 165 

and

‐

‐

‐

‐

Elobeid, et al. showed that for regional assessments, there is a need to frequently evaluate and 
update land use change assessments as agricultural activities evolve in a region. 166 This paper first 
provided an overview of direct and indirect land use change, considerations of land use change for 
policy implementation, and used Brazil as evidence to illustrate factors relevant for the analysis of 
land use change. These factors included agricultural production trends, observed land use change 
based on land intensification (double cropping, increased yields), and extensification (land expansion) 
in response to price signals. The case study demonstrated that regional ILUC assessments need to 
be regularly updated as factors in Brazil including zoning restrictions, possibilities for double cropping, 
and stricter enforcement of policies can change over short periods. 

Another area of recent ILUC research has focused on assessing the potential impacts of different 
policies on ILUC. The effects of these policies are then typically tested with a regional case study. 
Recent examples include: 

•  Brinkman, et al. performed a case study for Romania in which they calculated the rapeseed 

biodiesel potential and the GHG emissions of four measures to make surplus land available in 
2020. The study found that low-ILUC-risk rapeseed biodiesel produced from surplus land has a 

162 CORSIA Eligible Fuels – Life Cycle Assessment Methodology, June 2019. 
https://www.icao.int/environmentalprotection/CORSIA/Documents/CORSIA%20Supporting%20Document_CORSIA%20Eligible%20Fuels_LCA%20Methodol
ogy.pdf 
163 Malins, Understanding the indirect land use change analysis for CORSIA (2019). 
https://www.transportenvironment.org/sites/te/files/publications/2019_12_Cerulogy_ILUC-in-CORSIA.pdf  
164 Malins, Chris, Richard Plevin, and Robert Edwards. "How robust are reductions in modeled estimates from GTAP-BIO of the indirect land use change 
induced by conventional biofuels?." Journal of Cleaner Production 258 (2020): 120716. 
165 Di Lucia, Lorenzo, et al. "Project level assessment of indirect land use changes arising from biofuel production." GCB Bioenergy 11.11 (2019): 1361-1375. 
166 Elobeid, Amani, et al. "Implications of biofuel production on direct and indirect land use change: Evidence from Brazil." Biofuels, Bioenergy and Food 
Security. Academic Press, 2019. 125-143. 

 
 
 
 
                                                      
 
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potential of meeting 1-28% of the projected Romanian transport diesel consumption, mainly due 
to yield improvements in crop and livestock production167. 

•  Van der Hilst, et al. spatiotemporally assessed the potential direct and indirect LUC dynamics 

from increased biofuel demand and the resulting GHG emissions, focusing on Brazil. They also 
analysed the potential effect of direct and indirect LUC mitigation measures such as increased 
agricultural productivity, shift to second
study found that all LUC mitigation measures reduce the LUC
from ethanol production, ranging from a 7-60% reduction.168 

generation ethanol, and strict conservation policies. The 

related GHG impact emissions 

‐

‐

Other ILUC studies assess ILUC impacts by specific feedstock type as certain feedstocks have a 
larger concern for ILUC than others. Recent notable examples include:  

•  Strapasson, et al. assessed the land use changes from 1990 to the present for the major 

biodiesel crops, soybean, oil palm and oilseed rape in a study commissioned by the French 
vegetable oil and proteins sector. The study concluded that the emissions associated with ILUC 
for palm and soy are significant. For oilseed rape, there was no evidence found that this crop had 
high ILUC risk as the assessed countries showed net afforestation/reforestation in the past 
decade.169 

•  Dumortier, Elobeid and Carriguiry assessed the GHG emissions from LUC of corn ethanol in the 
US. Some have the concern that higher commodity prices from additional corn-based ethanol 
demand in the USA leads to LUC in the USA and globally, and subsequently increases overall 
GHG emissions. Others argue that this increased demand also leads to increased yields and can 
actually reduce LUC. This study concluded that a 15% increase in USA ethanol production results 
in a total expansion of global crop area by 1.2 million ha (0.25% compared to baseline). While 
some countries have a high yield gap and potential to increase yields with increasing commodity 
prices, others like the US, Brazil and EU countries are closer to the yield potential and less likely 
to have price-induced yield increase.170 

•  Pavlenko and Searle performed a review of 5 studies focused on the ILUC impact of energy 

crops. Although there was variance between studies which used different models with differing 
inputs (e.g. crop yields or share of land categories), nearly all the studies concluded that energy 
crop ILUC emissions are lower than those of food crops. However, energy cropping is still a 
nascent industry with limited empirical data, and improvements to modelling need to be made with 
more field data. 171 

While the relevance of ILUC has been established and there is evidence that ILUC can be avoided at 
a project basis, measuring of concrete ILUC factors remains complex despite new literature and 
research. 

5.4 Local environmental impacts 

Local environmental impacts related to biofuel production are addressed by Member States in their 
Progress Reports. Typical risks related to the most important crop country combinations are 
separately discussed at the end of this section. 

167 Brinkman, Marnix LJ, et al. "Low-ILUC-risk rapeseed biodiesel: potential and indirect GHG emission effects in Eastern Romania." Biofuels (2018): 1-16. 
168 Van Der Hilst, Floor, et al. "Mapping land use changes resulting from biofuel production and the effect of mitigation measures." Gcb Bioenergy 10.11 
(2018): 804-824. 
169 Strapasson, Alexandre, et al. "Land Use Change and the European Biofuels Policy: The expansion of oilseed feedstocks on lands with high carbon 
stocks." OCL 26 (2019): 39. 
170 Dumortier, Jerome, Amani Elobeid, and Miguel Carriquiry. "Assessing the possibility of price-induced yield improvements to reduce land-use change 
emissions from ethanol." Biofuels, Bioenergy and Food Security. Academic Press, 2019. 193-207. 
171 Pavlenko and Searle (2018). The International Council on Clean Transportataion. A Comparison of Induced Landuse Change Emissions Estimates from 
Energy Crops. https://theicct.org/sites/default/files/publications/ILUC-energy-crops_ICCT-White-Paper_06022018_vF1.pdf 

 
 
 
 
                                                      
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5.4.1 Member States Progress Reports172 

Most Member States indicated that within their country there is only limited domestic feedstock 
production for biofuels compared to total agricultural activities, and therefore consider that biofuel 
production causes no significant environmental impacts. Several Member States indicate that all 
agricultural production is regulated with respect to environmental impacts and therefore impacts of 
biofuel crop production are expected to be the same as those of other crop production. Several 
Member States also report that biofuels consumed in their country use voluntary schemes or national 
systems to provide proof that they originate from sustainable production. Detailed information per 
Member State is provided in Table 16.  

Table 16. Information provided in MS Progress Reports to question 9.173 Source: MS Progress Reports  

Member State 

Information reported on environmental impacts related to biofuel/bioliquid production 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czechia 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Evidence of source materials for biofuels produced sustainably in Austria is provided by means of a 
voluntary scheme or Agrarmarkt Austria’s national sustainability system (AACS). Certification systems 
that demonstrate the sustainability of biofuels are listed in the elNa register. In the case of biodiesel, the 
voluntary system ISCC EU is used most (54%). For bioethanol, ISCC DE and ISCC EU have a combined 
market share of 64%. Austria developed a biofuels database and web-based platform to monitor trade 
flows and sustainability information of biofuels counted towards the national targets. 
The Belgium Progress Report only states that ‘There are no known negative impacts on biodiversity, 
water and soil quality specifically due to the cultivation of biofuels.’ No other information is provided. 
Bulgaria indicates that regional inspectorates for the environment and water prepare regional annual 
reports on the state of the environment and that for the reporting period, do not contain any information 
about ascertained harmful impacts or new circumstances relating to impact on biodiversity as a result of 
the production of biofuels for transport and other liquid fuels from biomass. 
The Croatian Progress Report reports no environmental impacts, as no agricultural land in Croatia is 
used for growing energy crops. Since 2015 there has been no biofuel production in Croatia. 
Cyprus states that in 2017 and 2018 there was no significant domestic production and therefore that 
there are no impacts on biodiversity, water resources, water quality and soil quality in Cyprus.  
The Czech Progress Report indicates that all agricultural production within the Czech Republic is 
controlled within the framework of Good Agricultural and Environmental Conditions (GAEC). For this 
reason, they state that no impact is expected during the cultivation period. Also, it is mentioned that 
environmental impacts related to agriculture are routinely monitored and have not changed considerably 
over the past years. In the Progress Report extensive details are provided on the evidence to be 
provided for compliance with sustainability criteria by all actors in the supply chain.  
Denmark only states that domestic production has been so limited that, in the opinion of the Danish 
Energy Agency, there has not been significant impact related to biofuel/bioliquid production.  
The Estonian Progress Report only states that ‘no biofuels are produced in Estonia, and as a result there 
are no impacts.’ It also states that ‘other agricultural activities are not known to have become more 
environment-intensive than usual.’ 
Finland indicates that biofuel production in Finland is based on material from domestic and imported 
waste and residues. They further state that monitoring is carried out within the framework of the national 
sustainability scheme. Finally, they mention that the production of biofuels cannot be assessed to have 
had an impact on any of these factors in Finland.  
The French Progress Report only states that ‘the impact of biofuel production on these natural resources 
has not been assessed in the last two years.’ 
The German Progress Report indicates that it is difficult to link impacts of biofuel production to the overall 
agricultural system. It also indicates that more intensive utilisation of agricultural land in Germany 
essentially increases risks to biodiversity, water resources, water and soil quality and the state of 
terrestrial ecosystems. The report mentions that several risks are linked to the more intensive use of 
agricultural land (e.g. nitrogen leakage to water, bird loss). The report specifically mentions the 
importance of leaving rapeseed straw on the field for humus balance, stating that the use of rapeseed 
straw for biofuels presents a significant risk to the humus balance of the soil.  
Greece indicates that no specific study has been performed on this topic so far. The final statement in 
the report is that no significant impact is expected due to the small-scale energy crops cultivated in the 
country and the appropriate legislation issued and applied.  
Hungary provides details on land use for different crops in the country and conclude that the production 
of raw materials in Hungary for the implementation of the Renewable Energy Directive had no effect on 
biodiversity, water resources, water quality or soil quality. 
Ireland indicates that all feedstock for domestic biofuel production was waste products or residues from 
meat processing, which do not have an impact on food or feed or on soil and the ecosystem.  

172 Available at https://ec.europa.eu/energy/en/topics/renewable-energy/progress-reports  
173 Question 9: ‘please provide information on the estimated impacts of biofuels and bioliquids on biodiversity, water resources, water quality and soil quality 
within your country in the preceding two years’. 

 
 
 
                                                      
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Member State 

Information reported on environmental impacts related to biofuel/bioliquid production 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

UK 

They indicate that there were no detectable impacts on biodiversity, water resources, water quality, and 
soil quality. In an annex they provide information on the voluntary schemes used to demonstrate 
compliance.  
The Italian Progress Report states that land use for energy crop production is limited, and therefore that 
its impact on biodiversity, water resources and soil quality - is negligible. They finally state that the 
growing focus on the sustainability of bioliquids and biofuels has entailed a constant commitment to 
guarantee an ecological balance and protect biodiversity. 
The Latvian Progress Report indicates that no studies were conducted to assess these impacts. They 
provide some more details on the type of crops used for biofuel production and the recent fluctuations in 
amounts of biofuels produced and land used for crop production. No other information is provided.  
Lithuania states that the Lithuanian Ministry of the Environment did not provide any information on the 
estimated impacts of the production of biofuels and bioliquids on biodiversity, water resources, water 
quality and soil quality.  
Luxembourg indicates that compared to the last two progress report there is no change to information on 
the expected impacts. No other information is provided.  
Malta indicates that local biofuel production derived mainly from waste cooking oil waste streams. Thus, 
there was minimal, if any, negative impact on biodiversity, water resources, water quality and soil quality. 
The sole local manufacturer of biofuels had to abide to Integrated Pollution Prevention and Control 
regulations. This local production was considered to have a positive impact on the environment as it 
reused its waste. The local production ceased its operations in December of 2017, and as of currently, all 
biofuels contributing to the RES share are being imported. 
The Dutch report states that hardly any raw materials for biofuels are grown in the Netherlands. In 
addition, practically no new agricultural land has been brought into use. For this reason, the impact on 
biodiversity, water resources, water quality and soil quality as a result of growing crops for the production 
of biofuels is immaterial in the Netherlands. 
The Polish Progress Report indicates that the environmental impacts have been analysed and addresses 
the possible environmental impacts related to biomass cultivation, biofuel production and biofuel use. 
The report states that the analysis showed that the cultivation of crops intended for biofuel production 
does not have a greater impact on soil quality and water resources than the cultivation of the same crops 
for food purposes. The report further indicates that the production of biofuel components in Poland does 
not adversely affect the environment as it mentions that this is based on “high security and environmental 
standards”. Finally, regarding the use of biofuels, the report indicates that biofuel use reduces the 
emission of pollutants into the environment, except for nitrogen oxides, whose share in exhaust gases 
increases. 
Portugal states that given the low levels of endogenous agricultural material used in the production of 
biofuels, it does not appear that at national level, there is any impact on biodiversity, water resources or 
soil quality. 
The Romanian Progress Report provides a detailed description of how the sustainability criteria were 
implemented within Romania. It does not provide any additional information on actual environmental 
impacts related to biofuel consumption.  
Slovakia indicates that farmers/suppliers of biomass have to be able to provide a declaration stating that 
the requirement for good agricultural and environmental condition has been met. The report adds that at 
the moment, there is no relevant data on the adverse impact of producing biofuels on biodiversity, water 
resources, water quality or soil quality. The report assumes that these impacts are negligible, since the 
area of crops cultivated for biofuels in 2010 to 2018 in Slovakia did not increase significantly compared to 
the previous period. 
The Slovenian Progress Report only provides the statement that there was no domestic production of 
biofuels in Slovenia. 
Spain states that environmental impacts are negligible due to the limited use of domestic feedstocks for 
biofuel production. The report indicates that no specific reporting on these types of impacts is done by 
economic operators. No additional information is provided. 
The Swedish Progress Report indicates that at an aggregated level there is no reason to believe that the 
cultivation of raw materials for biofuels is leading to the use of land of high natural value. Also, the report 
indicates that impacts on water are not relevant for the Swedish case, since cereals and other crops that 
are used to produce biofuels are not irrigated, not even in years when there is a drought. Regarding soil 
and water quality, the report states that since no new agricultural land is deemed to have been given 
over to the current production of crops for biofuels, it is assumed that these crops do not contribute to 
any direct changes in stored carbon in the soil that need to be taken into account in this context. 
However, as is the case for food production, the production of biofuels results in emissions of acidifying 
and eutrophying substances, which in turn affect land and water quality. 
The UK Progress Report indicates that the Joint Nature Conservation Committee has published a report 
on the potential impacts related to biofuel production in 2013. The report also states that a recent update 
was published on broader biodiversity indicators. No conclusions of these reports are summarized in the 
Progress Report.  

 
 
 
 
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5.4.2 Analysis of local environmental risks in a selection of countries of 

production 

The risks of local environmental impacts have been assessed for the main crop/country combinations 
that are representative of biofuel consumption in the EU in 2018. For each of the impact categories 
(soil, water, air and biodiversity), an assessment was done of typical environmental risks associated 
with the feedstock in a specific country. The analysis shows that the geographical contexts covered in 
this report are quite heterogeneous and agricultural supply chains tend to be characterised by a high 
degree of site-specificity. This means that it is not always possible to say with certainty whether 
identified risks are present in the specific supply chains delivering feedstock to EU biofuels.  

The implementation of the EU biofuel sustainability criteria minimizes environmental impacts 
associated to agricultural feedstock for biofuel production. Voluntary schemes help to ensure that 
biofuels comply with the EU sustainability criteria, checking that; production of biofuel feedstock does 
not take place on land with high biodiversity, land with a high amount of carbon has not been 
converted for biofuel feedstock production, and the production of biofuels leads to sufficient 
greenhouse gas emissions savings. Several voluntary schemes also consider additional sustainability 
aspects such as soil, water, air protection and social criteria. However, this does not completely avoid 
impacts, and a continued effort is needed to decrease impact and increase insights in the size of 
these impacts. 

Agricultural intensification and growing demand for food and fuels pose great pressures on the 
environment. The analysis shows that for all crop-country combinations, serious impacts on water, 
soil and air have to be taken into account. These environmental impacts are often closely 
interconnected, therefore one pressure can have a cascading effect on the whole agro-ecosystem. 
Ecosystem functioning and biodiversity is of great importance for agriculture. For example, processes 
such as of pollination by insects, biological pest control, maintenance of soil quality by soil organisms, 
and nutrient cycling by microorganisms can play a significant role in achieving good yields. It is 
expected that agriculture will face more challenges in the future due to a changing climate, increasing 
levels of water scarcity and limited availability of arable land.  

All these aspects and challenges differ per feedstocks and regions of origin as shown inTable 17. A 
detailed exploration of potential local environmental risks can be found in Appendix C. 

 
 
 
 
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Table 17. Relevant environmental risks and impacts per crop-country combination 

EU 

Indonesia & Malaysia 

Rapeseed, wheat, maize, 

Palm oil 

Argentina 

Soy 

sugar beet 
•  Eutrophication of water 

bodies through run-off and 
leaching of nitrogen-based 
fertilisers 

•  Water abstraction leading to 

water scarcity 

•  Leaching of nutrients and organic 
matter through soil erosion and 
sedimentation 

•  Water pollution through discarded 

wastewater from palm oil mills (palm oil 
mill effluent) 

•  Soil erosion through wind, 
water or harvest losses 
•  Soil compaction as a result 
from heavy machinery use 

•  Soil organic carbon loss 
through erosion, climate 
change and drainage of soils 

•  Soil contamination through 
accumulation of pesticide 
residues 

•  High soil erosion rates leading to river 

constriction, increased flooding, 
threatened aquatic habitats, leaching of 
nutrients and organic matter and silt 
deposits in rivers and ports 
•  Soil compaction due to heavy 

machinery use related to increased size 
of plantations 

•  Eutrophication of water 

bodies through run-off and 
leaching of nitrogen-based 
fertilisers (especially 
glyphosate) 

•  Unsustainable water use and 
contamination straining the 
Guarani Aquifer 

•  Soil erosion and deterioration 
through soybean cultivation 
on fragile soils 

•  Soil contamination through 
increased application of 
herbicides 

•  Air pollution through 

•  Air pollution through haze related to 

spreading of fertilisers and 
pesticides 

burning as land preparation, 
agrochemical application and 
processing emissions 

•  Air pollution through burning 
of crop residues and other 
waste 

•  Eutrophication of aquatic and 
terrestrial ecosystems leading 
to decrease in biodiversity 
and invasion of species 
•  Decline in soil organisms 

through decreased soil quality 

•  Habitat and biodiversity loss through 

•  Habitat and biodiversity loss 

indirect displacement effects 

•  Decreasing soil biodiversity due to 

extensive use of herbicides 

through indirect displacement 
effects 

•  Loss of local biodiversity 
through intensification of 
farming 

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5.5 Relevant international conventions 

The Renewable Energy Directive requires insight into whether countries that supply a significant 
source of raw material for biofuels consumed within the Community, have ratified and implemented 
each of the following Conventions of the International Labour Organization, and international 
conventions related to biodiversity: 

•  Forced Labour Convention 1930 (ILO 29). 
•  Freedom of Association and Protection of the Right to Organize (ILO 87). 
•  Application of the Principles of the Right to Organize and to Bargain Collectively (ILO 98). 
•  Equal Remuneration of Men and Women Workers for Work of Equal Value (ILO 100). 
•  Abolition of Forced Labour (ILO 105). 
•  Discrimination in Respect of Employment and Occupation (ILO 111). 
•  Minimum Age for Admission to Employment (ILO 138). 
•  The Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour (ILO 

182). 

•  Cartagena Protocol on Biosafety to the Convention on Biological Diversity (CPB). 
•  Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). 

In the following tables and paragraphs, we provide insights in the status of ratification of the different 
conventions and the comments ILO provided to the country on enforcement of the ratified 
conventions.  

 
 
 
 
 
 
 
 
 
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Table 18. Ratification of international conventions as appear in the Renewable Energy Directive 2010 (changes from 
2008 cited below) in main countries providing EU biofuels1) 2) 

ILO 
29 
Argentina  √ 

Indonesia  √ 

Malaysia 

Ukraine 

USA 

EU 28 

√ 

√ 

√ 

ILO 
87 
√ 

ILO 
98 
√ 

ILO 
100 
√ 

ILO 
105 
√ 

ILO 
111 
√ 

ILO 
138 
√ 

ILO 
182 
√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

CPB 2) 

CITES 3) 

-174 

R 

R 

ACS 

- 

See Table 19 

R 

ACS 

ACS 

ACS 

R 

1) Sources: ILO web site http://www.ilo.org/dyn/normlex/en/f?p=1000:11400:3969178755425480::NO:::, CPB website : http://bch.cbd.int/protocol/parties/  
and CITES website: http://www.cites.org/eng/disc/parties/alphabet.php 
2) Abbreviations stand for the various administrative options: R= Ratified, A= Accepted, ACS = Accession, AP= Approval, S = Succession, C=Continuation. √ 
stands for ratified.  
3) Cartagena Protocol on Biosafety. 
4) Convention on International Trade in Endangered Species of Wild Fauna and Flora. 

Table 19. Ratification of biodiversity conventions as mentioned in the Renewable Energy Directive for EU281) 2) 

Country 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Ireland 

Italy 

CPB 

CITES 

R 

R 

R 

R 

ACS 

R 

R 

R 

R 

AP 

R 

R 

R 

R 

ACS 

R 

ACS 

ACS 

R 

S 

R 

ACS 

ACS 

AP 

R 

ACS 

R 

R 

Country 

Latvia 

Lithuania 

Luxembourg 

Hungary 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

UK 

CPB 

ACS 

R 

R 

R 

ACS 

A 

R 

A 

R 

R 

R 

R 

R 

R 

CITES 

ACS 

ACS 

R 

ACS 

ACS 

R 

R 

R 

ACS 

S 

ACS 

ACS 

R 

R 

1) Sources: CPB website: http://bch.cbd.int/protocol/parties/  and CITES website: http://www.cites.org/eng/disc/parties/alphabet.php 
2) Abbreviations stand for the various administrative options: R= Ratified, A= Accepted, ACS = Accession, AP= Approval, S = Succession, C=Continuation. 

Table 18 shows that ILO conventions have been ratified in several of the countries important for 
providing the EU biofuels feedstock. Only the USA has not ratified most of the ILO conventions. Also, 
Malaysia has not ratified some of them. Compared to previous assessment in 2018, the progress in 
these countries is limited and not resulting in any changes in ratifications. An overall argument given 
by the USA is that they have difficulty of imposing legislation through their federal structure and can 
therefore not ratify or implement many of the ILO conventions.  

The ratification of ILO conventions alone says little regarding their enforcement. The ILO committee 
monitors the ratification of the conventions and also their integration into existing or future legislation. 
The committee provides countries with comments, feedback and questions regarding elements they 
do not fully see as enforced or implemented in national legislation or programmes.  

Several European countries received comments, mostly on ILO 29 (forced labour especially related to 
migrant workers) ILO 87 (issues with trade unions) and ILO 98 (collective bargaining/agreements), 
ILO 100 (equal remuneration) and ILO 111 (discrimination). Only Finland, Italy, Latvia, Lithuania, 

174 Argentina has signed the protocol on 24th of May 2000, but has not ratified or implemented the protocol.  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
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Luxembourg, the Netherlands and Sweden did not receive any comments on the selection of ILO 
conventions under review here.  

For the countries outside the EU, no comments were provided for Indonesia and Ukraine by the ILO 
committee on any of the conventions named in Table 18. For Argentina comments were provided on 
ILO 87 (issues with trade unions and right to strikes) and ILO 98 (potential restrictions on collective 
bargaining). For Malaysia comments were provided on ILO 100 (equal remuneration). For the USA 
comments are provided on ILO 182 (protection of child agricultural workers from hazardous work).  

For some countries, international NGOs claim practices like forced labour or child labour are taking 
place on agricultural plantations which is not signalled by ILO. The ILAB (Bureau of International 
Labour Affairs) published a report (published 2018175) of goods where child or forced labour 
sometimes occurs in their production. Examples on that list are Indonesian oil palm (child labour) and 
Malaysian oil palm (child labour and forced labour). In the frame of the current study it is impossible to 
verify whether this is correct or has taken place at the plantations producing feedstock for biofuels 
supply chains. 

Due to the relatively slow ratification of ILO conventions, few changes in the past period (2014-2020) 
and recurring concerns raised about the enforcement, ILO conventions have only limited power in 
safeguarding the sustainability of biofuels. We have not assessed in detail whether conventions are 
implemented in the national legislative and regulatory frameworks.  

Table 18 shows that countries outside the EU have mostly ratified or are in the process of ratifying 
CITES. However, the Cartagena Protocol on Biosafety (CPB) is less commonly ratified. Argentina and 
the USA have neither ratified nor accepted the convention. Table 19 shows that all Member States 
have accepted or ratified the CPB and CITES conventions. 

175 https://www.dol.gov/sites/dolgov/files/ILAB/ListofGoods.pdf  

 
 
 
                                                      
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6. Economic, and social impacts related to biomass 

The Renewable Energy Directive requires the Commission to report on a range of socio-economic 
impacts in the Community and in third countries related to an increased demand for biofuels. This 
includes the availability of foodstuffs at affordable prices, in particular for people living in developing 
countries, and wider development issues. 

In this chapter we analyse several economic and social impacts related to biofuels consumption in the 
EU. Firstly, we analyse possible impacts on food prices and food affordability; secondly, we analyse 
impacts on labour and employment and finally we discuss impacts on other sectors that use the same 
biomass feedstocks. The Commission is also required to report on ratification and implementation of 
Conventions of the International Labour Organisation. These were addressed in Section 5.5, together 
with conventions on biodiversity.  

In terms of the influence of biofuels on food prices, studies have historically shown that increased 
demand in biofuels in the EU did not directly cause the food price spikes observed in 2008. Recent 
studies have confirmed this conclusion and find that biofuels are not a main leading source of 
increased food prices, rather they are linked more so to energy prices. Regardless, this is a topic that 
should be continued to be researched and monitored, especially in developing countries. 

In regard to employment, it is estimated that the biofuel industry in Europe employed 248,200 in 2018. 
Most of the employment is observed in Romania, Poland, and France. Although some employment is 
temporary construction jobs for biofuel production facilities, roughly a third are permanent biofuel 
facility or agricultural jobs. 

A wide range of different biomass feedstocks can be used for biofuel and bioenergy production (e.g. 
in the heat and power sector). Several of these feedstocks are also used in other sectors for material, 
animal feed or other applications. Increased use of biomass for energy applications can potentially 
lead to negative impacts for these other sectors that also use biomass. At the moment, this is not 
likely, as for many feedstocks there is surplus biomass available which can be used for bioenergy. 
However, just like food prices, this is a topic which should continue to be monitored to avoid 
unsustainable practices. Biorefineries could be a potential solution to using biomass more efficiently 
and reduce competition with other sectors.  

6.1 Food prices and affordability 

As most biofuels are produced from food crops, stakeholders are concerned that biofuels compete 
with food production and that this competition drives up food prices and price volatility and causes 
hunger.  

To understand the true impact, the following elements are most relevant: 
•  Factors influencing international/global food prices, and of other related commodities 
• 
•  Local food affordability, and food prices 

Interaction between global and local food/agricultural markets 

6.1.1 Global food prices 

Concerns about the impact of biofuels on food security follow from the argument that an increasing 
application of basic agricultural commodities for biofuels production leads to crop shortages and 
increasing food commodity prices.  

Figure 28 shows a composite food price index and annual biofuels production volumes. The price 
surge up to the July 2008 climax coincides with increasing growth in global biofuels production. Over 
the next half year however, biofuel production continues to increase while crop prices drop. This 
counters the idea that increased biofuel production leads to crop shortages, which eventually lead to 

 
 
 
 
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increasing food commodity prices. The graph also shows that biofuel production is fairly stable from 
2010-2011, while another price spike in crop prices occurs in 2011. In the past few years, biofuel 
production has continued to increase while crop prices have been stable or are even slightly 
declining. This suggests that there is no direct, or even indirect, correlation between crop prices and 
increasing biofuel production over the assessed period. 

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Biofuel production

Crops

Figure 28. Global crop commodity prices and the aggregated price of all commodities,176 versus global biofuels 
production volume,177 both normalised 

Ecofys 2013 reviewed several studies and found that biofuels did not cause the price spikes, but that 
their impact is likely more nuanced.178, A strong demand for crop-based biofuels could have an impact 
on the price of feedstock but this leads only to small variations on global agricultural commodity prices 
(which cover much larger volumes of crops), and thus a direct strong impact cannot be observed. 
Recent research has updated and confirmed this conclusion and also finds that price series data 
show that biofuels are not a main leading source of increased food prices (and consequently food 
shortages). 179 Food prices are more so linked to energy prices, as an increase in energy prices 
subsequently increases the production and transportation costs of food production. Despite a weak 
linkage between food prices and biofuel production, some criticise biofuel mandates as they create an 
inelastic demand and do not have the flexibility to respond to food price volatility. 180 

For the future, Thomson and Meyer, 2013 expect the strongest biofuel consumption growth in 
developing countries and even argue that second generation biofuels can help food security.181 The 
impacts depend on whether the feedstock competes with traditional crops or is a co-product; biofuel 
from crop residues such as corn stover and wheat straw can lead to more efficient land use (higher 
biofuel yield per hectare), potentially reducing food and feed prices. 

The discussion of biofuel production and food price volatility is a complex one as economies are 
shaped by a diverse and interconnected range of forces. The majority of current research argues that 

176 World Bank, 2013, World DataBank - Global Economic Monitor (GEM) Commodities, accessed June 2020. The food price index is derived by averaging 
all food/crop commodities in the World Bank monitor on commodity prices. 
177Statista, Global biofuel production from 2000 to 2018. 
178 For an overview and discussion of studies, see [Ecofys 2013, Biofuels and food security]. 
179 Filip, Ondrej, et al. "Food versus fuel: An updated and expanded evidence." Energy Economics 82 (2019): 152-166. 
180 Tadasse, Getaw, et al. "Drivers and triggers of international food price spikes and volatility." Food price volatility and its implications for food security and 
policy. Springer, Cham, 2016. 59-82. 
181 Thomson and Meyer, 2013, Second generation biofuels and food crops: Co-products or competitors?, Global Food Security 2(2):89-96]., Also see 
extensive work by FAO on their Bioenergy and Food Security (BEFS) approach. 

 
 
 
 
 
 
                                                      
 
 
 
 
 
 
 
 
 
 
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increasing biofuel production does not have a negative effect on food security or food prices, however 
this is a topic that should be continued to be researched and monitored. 

6.1.2 Food prices in Member State Progress Reports 

In the Member States Progress Reports 182 any changes in commodity prices associated with 
increased use of biomass within their Member State have to be reported. In the recent Progress 
Reports, most Member States report that they do not see a relation between commodity prices and 
biofuel production, or that they did not see any fluctuations in their domestic food prices related to 
biofuel production. Several Member States (e.g. Austria, Lithuania, Spain, Poland, Sweden) point to 
yield, availability of biomass or international commodity prices as reasons for fluctuations in food 
prices. Other Member States (Bulgaria, France, Hungary, Italy, Slovenia, Latvia, Greece, Sweden, 
Slovakia and the UK) provide overviews of prices for crops or woody biomass products, of which most 
give no analysis/conclusions or indicate that no link can be made based on the presented data. 
Luxembourg indicates that no robust data on raw material prices is available because most of the 
plants dedicated for energy purposes are internally used in the biogas plant attached to the farm. So, 
no real market exists. 

Germany presented an extensive analysis of a range of different biomass feedstock types (e.g. wood 
chips, logs, vegetable oils, biogas substrates). For most woody biomass, prices increased until 
2014/2015 and decreased until 2016. Since 2016 most prices increased, e.g. for wood pellets and 
briquettes by 7-10%. This development partly reflects the development in heating oil prices that 
strongly influence the price of wood pellets.  

For vegetable oils, Germany indicates that their prices are largely determined by the world market. In 
the reporting period, prices for palm oil and soy oil decreased due to a high supply of palm oil from 
Malaysia and Indonesia and a low demand as a result of the trading dispute between the USA and 
China. Nevertheless, the prices of rapeseed increased in the second half of 2018 as the drought in 
Europe and Australia led to low harvests. Prices of biogas substrates are less dependent on the world 
market and vary strongly, even between regions. Still, a positive trend in the prices of biogas 
substrates could be observed in 2018 because of the drought. 

6.2 Labor and (local) employment 

The biofuel industry plays an important role in employment in the EU as it creates many jobs along 
the supply chain, from feedstock cultivation to biofuel production facilities. IRENA estimates that 
globally, liquid biofuels employed 2 million in 2018, with the majority of jobs in planting and harvesting 
biomass feedstocks. Fuel processing facilities comprise a smaller share of employment, but tend to 
require more technical expertise, are higher paid, and create higher value in the supply chain. Brazil 
represents the largest share of the workforce, with 832,00 jobs in biofuel related industry and the USA 
the second largest with 311,000 jobs.183 

For the EU, it is estimated that the biofuel industry employed 248,200 in 2018, making biofuels the 
third largest renewable energy job creator after wind energy and solid biomass (314,000 and 
387,000). Based on modelling of the biofuel industry, including agricultural activities, the countries 
with the greatest employment are Romania (40,000 jobs) and Poland (41,200 jobs) due to their large 
agricultural land area. France is the third largest (29,100 jobs) as it has both biofuel production 
facilities and feedstock production. As biofuel mandates increase in MS and overall demand 

182 Available at https://ec.europa.eu/energy/en/topics/renewable-energy/progress-reports  
183 IRENA, Renewable Energy and Jobs Annual Review 2019. 

 
 
 
                                                      
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increases, this is expected to stabilise the important socioeconomic role of the biofuel industry in total 
employment in the EU.184  

One study estimated the potential jobs created if each Member State were to use the sustainable 
available waste feedstocks for advanced biofuel production.185 The countries with the highest job 
creation were France (38,000-78,000 jobs), Germany (32,000-70,000 jobs), and Romania (10,000-
18,000 jobs) as these are the countries with the greatest waste feedstock availability. While 70% of 
these are temporary construction jobs, 30% are permanent biofuel facility or agricultural jobs.  

Although there is a range in job quality (e.g. pay, permanency) and variance in number of biofuel jobs 
among MS, it is apparent that the biofuel industry can play a positive role for employment in the EU. 

6.3 Impact on other biomass using sectors 

A wide range of different biomass feedstocks can be used for biofuel and bioenergy production (e.g. 
in the heat and power sector). Several of these feedstocks are also used in other sectors for material, 
animal feed or other applications. Increased use of biomass for energy applications can potentially 
lead to negative impacts for these other sectors that also use biomass.  

Table 20 provides an overview of biomass feedstock types and their current uses in non-bioenergy 
sectors. Several of these feedstock types are included in Annex IX Part A of the ILUC Directive, like 
biomass residues from forestry and straw, while UCO and animal fats (Category 1 and 2) are included 
in Part B of Annex IX. 

Table 20. Biomass feedstock types and their possible uses 

Type of 
feedstock 

Raw 
material 

Existing use 

Left in forest 
X 

X 

X 

X 

Mulch 
X 

X 

Pulp, paper 
& panel 
board 
production 

X 

X 

Animal 
bedding 

Landscaping, 
playground 
surfacing 

Wood pellet 
or briquette 
production 

X 

X 

X 

X 

X 

X 

Incorporation in soil 
X 

Animal 
bedding & 
feed 

Mushroom 
& 
strawberry 
production 

Frost 
protection 
& thatching 

Building 
materials 

Paper & 
Pulp 

X 

X 

X 

X 

X 

Woody 
residues186  

Straw 

Bark 
Branches 
(incl. tops) 
Leaves 
(and 
needles) 
Sawdust 
from 
forestry 
operations 
Sawdust & 
cutter 
shavings 
from 
sawmills 

Any straw 
Cereal 
straw 

184 EurObserv’er, The State of Renewable Energies in Europe, 2019. https://www.eurobserv-er.org/category/all-annual-overview-barometers/ 

185 S.Y. Searle, C.J. Malins, Waste and residue availability for advanced biofuel production in EU Member States, Biomass and Bioenergy (2016), 
http://dx.doi.org/10.1016/j.biombioe.2016.01.008  
186 Including forestry residues from managed forests, arboricultural residues, woody farm residues, sawmill residues. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
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Raw 
material 

Existing use 

Animal feed (restricted in the EU & 
some 3rd countries) 
X 
Process fuel in the 
rendering facility for 
process heat and 
power 

Oleochemicals 
(detergents, soap, 
cosmetics etc.) 

Oleochemicals (detergents, soap, cosmetics, etc.) 

X 

Pet food and animal feed 

X 

X 

X 

Distilled into a variety 
of products (e.g. 
glues, primers) 

Process fuel in the pulp 
mill lime kiln 

Used as petroleum extraction drilling fluid 
or in phosphate mining 

X 

X 

X 

Animal feed 

X 

Activated carbon 

Oleochemical products 
(detergents, soap, 
cosmetics etc.) 

Recycled paper de-inking 

X 

X 

Livestock bedding & 
animal feed 

Industrial source of furfural 

Type of 
feedstock 
Used 
cooking 
oil187 

Animal 
fats 
(tallow) 

Crude tall 
oil 

Fatty acids 

Cobs 
cleaned of 
kernels of 
corn 

UCO 

Category 1 
animal fats 
Category 3 
animal fats 

Crude tall 
oil 

All fatty 
acids 
High quality 
fatty acids 

Corn cobs 

X 

X 

X 

For forestry biomass,  the level of competition varies by type of raw material, cultivation and 
extraction method, and sector. The forestry sector is a relatively complex economic sector, with 
various residue streams and recovered products that need to be considered in the balance. As 
displayed in Figure 29 which shows the woody biomass balance in the EU in 2015, woody biomass 
has demand from the construction, paper and paperboard, and bioenergy industries. Construction 
wood mainly relies on large diameter logs, meaning the sawn wood/sawmill subsector, and nearly half 
of this ends up as a residue going to the pulp or panel industry. Therefore, wood-based construction 
is an important driver for raw material availability for pulp and paper and for emerging industries, as 
sawmilling generates raw materials for these industries (wood chips, bark, sawdust, etc). For 
bioenergy, just under half of the woody biomass is by products from the pulp, sawmill, and panel 
industries, with the remainder from roundwood. This shows that there is potential competition for 
roundwood used for bioenergy and these other industries, but that bioenergy also works with them 
synergistically as it also relies on these industries’ by-products.  

Several studies have explored the growth and availability of wood from EU forests which allow us to 
further examine the competition between industries and potential for bioenergy. One potential woody 
biomass stream is forestry residues; a significant portion of these forestry residues (>90%) are 
currently left in forests and could (if harvested/extracted to a sustainable limit) be used for bioenergy 
purposes without competition. A sustainable limit refers to the fact that some residues need to be left 
in the forest to retain soil quality and forest productivity. 188  Searle and Malins estimate the availability 
of forestry residues at nearly 68 million tonnes (dry basis). While 46 million tonnes should be kept on 
soil to retain quality, 12.3 million tonnes are still available for heat and power and a remaining 9.2 
million tonnes for biofuel production. 189 If these resources were mobilised, this could potentially 
reduce competition between bioenergy and other sectors. European Forestry Institute (EFI) recently 
estimated that 44 Tg (44 million tonnes) a year of logging residues (branches and harvesting losses) 

187 Note that in some Asian countries UCO has historically been re-used as cooking oil (termed ‘Gutter oil’) by simple cleaning and mixing with virgin cooking 
oil. This practice is, however, illegal in some countries (notably in China) and therefore not included in the table.   
188 JRC, Biomass production, supply, uses and flows in the European Union, (2018). 
189 S.Y. Searle, C.J. Malins, Waste and residue availability for advanced biofuel production in EU Member States, Biomass and Bioenergy (2016), 
http://dx.doi.org/10.1016/j.biombioe.2016.01.008 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
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are available in Europe, however a large part of this is already used to produce materials and 
energy.190  

Figure 29. EU’s woody biomass balance in 2015 (units in Mm3)191 

190 Verkerk, P. J., Fitzgerald, J. B., Datta, P., Dees, M., Hengeveld, G. M., Lindner, M., & Zudin, S. (2019). Spatial distribution of the potential forest biomass 
availability in Europe. Forest Ecosystems, 6(1), 5. 
191 JRC (2019), ‘Sankey diagrams of woody biomass flows in the EU-28’, 
https://publications.jrc.ec.europa.eu/repository/bitstream/JRC115777/jrc_sankey_2019_online.pdf 

 
 
 
 
                                                      
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A share of straw can be sustainably removed from the field for use as bioenergy feedstock. However, 
some straw should be left in the field to maintain soil quality and soil carbon. The sustainable removal 
rate depends on local conditions as well as the soil management practices applied (e.g. low or no till 
agriculture, use of cover crops and crop rotation).192 Several Member States have a straw surplus (in 
particular France, Germany and Spain), that could sustainably be harvested and used for bioenergy 
production. According to Ecofys 2013,193 an estimated total of 21.4 Mtonne of low ILUC cereal 
straw194 was available in the EU (top 12 straw producing Member States) in 2013. Searle and Malins 
looked at a wider range of agricultural residues (including more crops, but also other residues). They 
estimated that of the available 316 million tonnes (dry basis), 196 million tonnes should not be 
removed to retain soil quality. There remain 9.8 million tonnes for heat, power, and biogas, 26.4 
million tonnes for other uses, and 84.6 million tonnes for biofuel production.  195 A study by JRC 
estimated slightly higher amounts and concluded that all agricultural residues in the EU amount to 
440 million tonnes. Of this, wheat residues represent 149 million tonnes and maize residues 80 million 
tonnes.196 

An estimated 90% of the currently collected EU supply of used cooking oil (UCO) is used for biofuel 
or bioenergy production,197 with the remainder used in the oleochemical industry.198 Importantly, use 
of UCO as animal feed has been restricted in the EU since 2002 as a reaction to the BSE199 crisis, 
and subsequent implementation of the Animal-By-Products Regulation EC 1774/2002. Only a few 
high-quality sources of vegetable oil UCO, such as from food manufacturing processes where the 
inputs are pure and uniform and the processes are well controlled, are permitted to be used for animal 
feed. Outside of the EU, biofuel production is the prevalent use for collected UCO, either directly 
within the country of collection, or for use in the EU. Use of UCO for animal feed is also restricted in 
some overseas markets, including in the USA as of 2017200 and China. There is room for increased 
use without severe competition with other current uses as in many markets there is still significant 
potential to scale up the collection of UCO. Within Europe, the main potential exists in the collection of 
UCO from households (as discussed in section 2.3).  

For animal fats,201 nearly 80% of the EU supply of 2.1 Mtonne Category 3 animal fats was used in 
the oleochemical industry or as animal feed and only 0.43 Mtonne (~20%) was used for biodiesel 
production in 2018.202 Competition will occur if increased volumes are diverted to biofuel or bioenergy 
production. Category 3 animal fats are not included in Annex IX part B (which only includes categories 
1 and 2), and thus not counted double towards the target for RES-T. Around 80% of the available 
Category 1 and 2 animal fats (0.62 Mtonne) is already used for biodiesel production (0.51 Mtonne), 
with the remainder being used as a process fuel at the rendering facility. Competition with other uses 
is very limited. Category 1 material needs to be disposed of, either by incineration or as a fuel for 
combustion, whereas the use of Category 2 animals fats is restricted to specific technical industrial 
uses (around 1.5 ktonne).  

192 REDIIBIO project, Technical Assistance to develop guidance for the implementation of the new bioenergy sustainability criteria set out in the revised 
Renewable Energy Directive 
193 Ecofys 2013, Low ILUC potential of wastes and residues for biofuels 
194 Based on wheat, barley, oat, rye and triticale. Rapeseed straw and sunflower straw are not typically collected in the EU. Additional potential could be 
realised from corn straw (commonly termed “corn stover”).  
195 S.Y. Searle, C.J. Malins, Waste and residue availability for advanced biofuel production in EU Member States, Biomass and Bioenergy (2016), 
http://dx.doi.org/10.1016/j.biombioe.2016.01.008 
196 JRC, Biomass production, supply, uses and flows in the European Union, (2018). 
197 Ecofys 2013, Low ILUC potential of wastes and residues for biofuels 
198 UCO is not a preferred feedstock for the oleochemical industry, which requires oils with a consistent carbon chain length and saturation. 
199 Bovine spongiform encephalopathy (BSE) is an animal disease also known as “mad cow” disease. 
200 International Magazine of Rendering, US Market Report, April 2019. 
201 The Animal By-product Regulation classifies materials into 3 categories according to their potential risk posed to human health. Category 1 material has 
the highest risk of spreading disease such as BSE and includes the bovine spinal cord, pet animals, zoo and circus animals, wild animals suspected of 
carrying a disease, and catering waste from international transport. Category 2 material is also high risk material, and includes fallen stock and digestive 
content. Category 2 is also the default status of any material that does not fall into Categories 1 or 3. Category 3 material is the lowest risk material. It 
represents parts of the animals that have been passed as fit for human consumption. However, it is generally not used for human food, either because it is 
made out of non-edible parts (e.g. hides, hair, feathers, bones) or for commercial reasons. When products of different categories are mixed, the entire mix is 
classified according to the lowest category in the mix. 

202 European Fat Processors and Renderers Association (EFPRA), June 2019, https://www.efpralabaule2019.com/docs/dobbelaere.pdf. 

 
 
 
                                                      
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Crude tall oil (CTO) is only available in limited supply as a by-product of the Kraft chemical wood 
pulping process (total potential CTO supply is around 2.6 Mtonne). Current demand is around 1.75 
Mtonne, of which an estimated 80% is distilled to derive a number of products203. This implies that 
there is a potential surplus of about 0.85 Mtonne of CTO that could be accessed (besides the 0.23 
Mtonne currently used for biofuel production). Accessing this potential will require modifications at 
some plants to process (acidulate) crude sulphate soap to CTO, rather than to burn it directly as a 
process fuel at the pulp plant. 204  

For fatty acids there is considerable current use in oleochemical and animal feed sectors.205 Of the 
estimated total available 3 Mtonne fatty acids in the EU, approximately 1.5 Mtonne is produced and 
directly used in the oleochemical sector and 1.5 Mtonne is traded in the market. Of this, around 0.5 
Mtonne is high quality fatty acid which is mostly used for animal feed production (some is also used 
for biofuel production). The remaining 1 Mtonne of lower quality is used in paper, heat or biofuel 
production.  

Besides the above-mentioned feedstock types, Searle and Malins also estimated the amount of 
biogenic waste available at 63 million tonnes a year. This is largely comprised of household and 
similar residues (46 Mtonne), sorting residues (6.9 Mtonne), and common sludges (3.5 Mtonne). The 
competing uses of biogenic wastes are composting for fertiliser production, backfilling as material 
used in landscaping or engineering, and incineration for power and heat production. 206 

From this analysis it is clear that bioenergy applications often compete with other sectors that use 
biomass. Many waste and residue streams have other applications besides bioenergy and could 
imply that it will become costlier for these other sectors to obtain the same material. Also, the 
environmental benefits of using waste streams for bioenergy application may in some cases be 
smaller if other sectors will be forced to use other feedstock with higher greenhouse gas impacts. 
However, it was not possible to establish the economic or environmental impacts from this 
competition, because the level of competition and how the market changes can only be understood by 
complex models. For policy makers, it is important to understand the real potential of each feedstock, 
and how this may change over time. Low ILUC approaches can help to increase the production of 
bioenergy crops without intensifying the impacts on other biomass using sectors. 

As biorefineries become more prevalent in the EU and technology matures in the coming years, there 
will be new sectors that increase competition for biomass, such as the bio-based chemicals and bio-
based material industries. However, in an integrated biorefinery approach, a biomass feedstock is 
used most efficiently and converted into a spectrum of valuable products. Power, heat, and biofuels 
can be synergistically co-produced with food, feed, pharmaceuticals, chemicals, materials, and 
minerals.207 Market forces will likely dictate which products are produced in which volumes and how 
these different sectors will compete.  

203 These include additives, adhesives, metal working fluids, resins and rubber emulsifiers. 
204 Ecofys 2017, Crude tall oil low ILUC risk assessment, available at https://www.upmbiofuels.com/siteassets/documents/other-publications/ecofys-crude-
tall-oil-low-iluc-risk-assessment-report.pdf 
205 Ecofys, 2016, Assessment of fatty acids, confidential report. 
206 S.Y. Searle, C.J. Malins, Waste and residue availability for advanced biofuel production in EU Member States, Biomass and Bioenergy (2016), 
http://dx.doi.org/10.1016/j.biombioe.2016.01.008  
207 IEA Task 42, Biorefining in a Future BioEconomy, Triennium 2016-2018. 

 
 
 
 
                                                      
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Appendix A. Share of biodegradable fraction of waste  

Table 21. Reported information by MS on the share of biodegradable fraction of waste used for energy production 

MS 

Austria 

Belgium 

Renewable 
fraction 

Manner used for estimation and any steps taken to improve estimates 

N/A  The share of biodegradable waste in waste is determined based on information from 

samples for which the geographical scope is to be expanded. No mention of actions to 
improve the estimation. 
Based on data from the 2006 local waste sorting campaign in Flanders. The method is 
described in the report “Determination of the renewable share of residual waste” (Vito, April 
2009)[2]. 
The share of incinerated waste of the intermunicipal waste mass is estimated based on 
ICEDD, energy balance 2013. 

47.78%  
(Flanders) 

47%  
(Wallonia) 

Bulgaria 

N/A  During the reporting period the Methodology for determining the morphological composition 

Croatia 
Cyprus 

Czech 
Republic 

of household waste was applied. The methodology has been published on the website of the 
MOSV [3] and ensures a single approach to determining and estimating the quantity and 
morphological composition of household waste. 

28.6%  The basis on which the share of municipal waste is estimated. 

N/A  The biomass fraction of specific alternative fuels was determined by analyses carried out by 

laboratories accredited according to EN ISO/IEC 17025. 

N/A  The proportion of biodegradable municipal waste specified in Decree No 477/2012, on 

determining the types and parameters of renewable sources supported for electricity, heat or 
biomethane production, and on the establishment and preservation of documents, is 
determined on the basis of consultation and information from the IEA, Eurostat, other EU 
countries, and information from local operators of municipal waste incinerators. 

Denmark 

55%  This proportion is determined on the basis of a study carried out in 2012. From 1 January 

2013 Denmark has decided to include 21 of the largest waste incineration plants in the CO2 
quota adjustment. These plants determine their annual emission of fossil CO2 by measuring 
the CO2 content of the flue gas. Two different methods are used for these measurements. 
These are a 14C method and a mass balance method (Bioma), which is based on a number 
of balances set up for the plant. No mention of actions to improve the estimation methods. 

Estonia 

65%  Estonia has regularly conducted studies on the sorting of mixed municipal waste (the 

Ministry of the Environment has commissioned such a study every two or three years), 
which provide a good overview of the share of biodegradable waste and also changes 
therein. No mention is made on the exact method used for estimating, nor are actions 
mentioned to improve estimation methods. 

Finland 

50%  The estimate is based on sampling. A national recommendation on composition analyses 

France 
Germany 

was issued to improve the quality of sampling in 2014, and the volume of sampling has 
increased. A composition database has been set up to record the data with the aim of 
collating and processing the results of qualitative testing and composition analyses for 
various types of waste. There is no clear indication of the method used by survey 
respondents for the estimation of the share.  

N/A  No information provided. 

 50%  This value comes from a study (UBA, 2011 [6]) which examines the waste flows from 
selected treatment methods in detail. The report further mentions that the methods of 
determining the biogenic fraction are being constantly improved and tested for practical 
viability (e.g. C14 method) without clear indication how these improvements are achieved. 

Greece 

N/A  The energy produced from waste (municipal, industrial etc.) corresponds exclusively to 

biogas primary production deriving from landfill and sewage sludge biogas plants. Until now, 
no RDF/SRF are exploited for electricity production in Greece and thus no requirement has 
arisen to estimate the share for biodegradable waste in the reported figures. 

Hungary  

~ 57%  The current methodology goes beyond the previous one, as it is not based on an estimate, 

Ireland 

but on the data transmitted by data providers. In statistical questionnaires, data providers 
must distinguish between the amounts of renewable and non-renewable waste. 

N/A  The renewable fraction of waste used in producing energy is calculated in accordance with 
the standard I.S. EN 15440:2011 "Solid Recovered Fuel, Methods for the Determination of 
Biomass Content". This standard specifies a number of methodologies that may be used i.e. 
the selective dissolution method, the manual sorting method and the Carbon 14 method. 
The data obtained in accordance with the standard may be combined with waste 
characterization survey data that is demonstrated to the satisfaction of the CRU 
(administrator of the PSO) to be representative of the waste composition at the generation 
facility, in order to determine the renewable fraction. 
Calculations of the renewable fraction must be verified by an independent third party on an 
annual basis. 

Italy 

50-51%  Under national law, the incentives for electricity from biodegradable waste are calculated two 

ways: 
- Fixed rates for certain categories of waste; 

 
 
 
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MS 

Renewable 
fraction 

Manner used for estimation and any steps taken to improve estimates 

- Analytical determination methods for the remaining waste. 
The share of electricity generated from renewable sources and eligible for the incentive is 
set at a fixed rate of 51% of net generation from sorted municipal waste and, under certain 
conditions, from other specific types of non-municipal waste. This fixed rate (very similar to 
the share considered for statistical purposes) was set by the legislator following a testing 
campaign conducted on the municipal waste used by a representative sample of waste-to-
energy plants. 

Latvia 

N/A  The amount of biodegradable waste and residues used for biogas production in Energy 
Statistics can be obtained by analyzing statistical data on the amount of biodegradable 
waste recycled in a given year that according to the type of recovery (R3D-Biogas extraction 
(excluding biogas from waste disposal))is used for deriving biogas in production. No 
measures were taken during the reporting period to improve or verify the estimates of the 
share of biodegradable waste in the waste for energy production. 

Lithuania 

N/A  Economic operations use the Lithuanian Standard LST EN 15440:2011 'Solid recovered 

fuels - Method for the determination of biomass content'. At least four times per year tests 
are to be done. No mention is made on the exact method used, nor are any actions 
mentioned to improve this estimation.  

Luxembourg 

N/A   The different shares in wet waste are determined on the basis of on-site surveys (from 1992, 

1994, 2001, 2004/2005 and 2009) and extrapolated to the total quantity of waste. 
The total quantity of wet waste is then converted into dry waste using wet waste coefficients. 
The quantity of energy is then calculated on the basis of the calorific value of the waste 
category concerned. The biodegradable carbon content is used to calculate the 
biodegradable fraction of the waste category in question. The renewable energy share of the 
waste, and consequently the renewable share of electricity production, is thus determined. 
This is the same method as applied in the previous report. 

Malta 

100%  Malta’s current waste-to-energy plants are based on an anaerobic digestion process and 

thus all processed waste is biodegradable. Shares of biodegradable content per waste 
stream are provided, e.g. mixed MSW 66%. No exact method for estimation of the share is 
mentioned, nor are actions to improve the estimation. 

Netherlands 

54%  The method of estimating the share of biodegradable waste in waste used for producing 

energy is described in the ‘Methodology report on the calculation of emissions to air from the 
sectors Energy, Industry and Waste’ (ENINA 2019).[1] The model for the calculation of the 
share of renewable energy is also used to calculate the emissions from waste incineration 
plants in the framework of the reports for UNFCCC and the Kyoto Protocol. ENINA 2019 
also describes the quality control. 
The estimate of the share of biodegradable waste is made annually by an independent 
organisation, the Rijkswaterstaat Environment, using various annual reports. The estimate is 
based on seven stages. The data from the years of research into the composition of waste in 
the Netherlands are used to form the basis. The data obtained from that are used to 
determine the energy and carbon content and associated share of biomass of the waste 
streams burned in waste incineration plants. The biomass share of energy is then used to 
calculate a ‘flat-rate percentage’ of renewable energy for all waste incineration plants in the 
Netherlands. 

Poland 

N/A  The share is based on ‘direct measurement’ by examining the share of biodegradable 

Portugal 

Romania 

Slovakia 

Slovenia 
Spain 

fractions (defined by harmonised standards for solid recovered fuel) or taking a flat rate 
value (based on an expert study – no reference provided). No actions are mentioned to 
improve the estimation. 

50%   The share is supplied on an annual base by electricity producers. No details on methodology 

for estimation nor on actions to improve such estimations are provided. 

55-60%  As regards the quantities of biodegradable waste generated in Romania, the National Waste 
Management Plan lists the quantities of municipal waste generated in Romania in the period 
2010-2014 and the composition of this waste. Biodegradable waste accounts for 
approximately 55-60% of the composition of household waste and waste similar to 
household waste collected by sanitation operators in the period 2010-2014.  The production 
of energy based on the biodegradable actions in waste was not reported in 2017 and 2018. 
50-55%   Renewable fraction is determined directly by companies involved in recovering energy from 

waste. These data are recorded and sent to the Statistical Office. As regards the incineration 
of municipal waste, only the biological portion of waste in municipal waste is supported, up 
to a maximum biodegradable-waste share of 55%. This also corresponds to analyses 
carried out, in which the share of biodegradable waste has been estimated at 50%. No 
details on methodology for estimation nor on actions to improve such estimations are 
provided. 

N/A  No information provided. 
 N/A  Share of waste comes from Biofuel Statistics published by the Biofuel Certification Entity of 
the CNMC. As the body responsible for certifying compliance with the biofuel consumption 
obligation, the ECB obtains data via the SICBIOS IT application. No details on methodology 
for estimation nor on actions to improve such estimations are provided. 

Sweden 

52%  This assumption has been made based on an investigation of the composition of waste 

published in 2017 [4]. A previous study dating from 2008 was updated with new input data 

 
 
 
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MS 

Renewable 
fraction 

Manner used for estimation and any steps taken to improve estimates 

as regards waste composition taking into account available measurement data from seven 
major waste incineration plants. Two types of methods are mentioned, namely the analyses 
of solid waste and the analyses of the flue gases formed during incineration. In 2008, it was 
shown that 60% of the waste was of renewable origin. The reduction since then is primarily 
explained by changes in the composition of the waste due to an increase in domestic sorting 
of waste at source and an increase in the proportion of imports. 

UK 

N/A  Waste with 10% or less of renewable content is regarded non-renewable waste. Fuel 

Metering and Sampling procedures are put in place by Ofgem[5] for assuring an accurate 
calculation of the proportion of biodegradable material. The testing and sampling is often 
done by independent accredited laboratories. Also, there is an audit programme in place 
with a selection of generation stations. No actions are mentioned to improve the estimation. 

[1] https://english.rvo.nl/sites/default/files/2019/05/ENINA%202019-0018.pdf  
[2] https://esites.vito.be/sites/reflabos/onderzoeksrapporten/Online%20documenten/rapport_aandeel_hernieuwbaar_maart%202011.pdf  
[3] http://www.moew.government.bg/bg/otpaduci/bitovi-otpaduci/  
[4] Profu, 2017. Analysis of the renewable energy fraction in waste for combustion. Swedish Energy Agency ref. No 2016-010523. 
[5] https://www.ofgem.gov.uk/publications-and-updates/renewables-obligation-fuel-measurement-and-sampling-guidance  
[6] UBA, 2011. Nutzung des Potenzials des biogenen Anteils im Abfall zur Energieerzeugung, IAA TU Dresden. 

 
 
 
Technical assistance in realisation of the 5th report on progress 
of renewable energy in the EU 

Appendix B. Availability and use of biomass resources 

The following tables present the information as provided by the Member States in their Progress 
Reports (‘Table 4 in Question 6’).  

Table 22. Biomass consumption for heating and electricity based on Table 4 in the Member States Progress Reports in ktoe unless 
otherwise specified 

MS 

Domestic 
vs import 

Direct supply of 
wood biomass from 
forests 

Indirect supply of 
wood biomass  

Energy crops and 
short rotation trees 

Agr by-products / 
processed residues 

2018 

2017 

2018 

Biomass from waste  

Others  

2017 
180  

2018 
198  

2017 
532  

2018 
518  

AT  Domestic 
AT  EU 
AT  Non-EU 
BE  Domestic 
BE  EU 
BE  Non-EU 

BG  Domestic 
BG  EU 
BG  Non-EU 
CY  Domestic 
CY  EU 
CY  Non-EU 
CZ  Domestic 
CZ  EU 
CZ  Non-EU 
DK  Domestic 
DK  EU 
DK  Non-EU 

EE  Domestic 
EE  EU 
EE  Non-EU 
FI  Domestic 
FI  EU 
FI  Non-EU 
FR  Domestic 
FR  EU 
FR  Non-EU 
DE  Domestic 
DE  EU 
DE  Non-EU 
EL  Domestic 
EL  EU 
EL  Non-EU 
HR  Domestic 
HR  EU 
HR  Non-EU 
HU  Domestic 
HU  EU 
HU  Non-EU 
IE  Domestic 
IE  EU 
IE  Non-EU 
IT  Domestic 
IT  EU 
IT  Non-EU 
LV  Domestic 
LV 

Import1 

LT  Domestic 
LT  EU 
LT  Non-EU 

2017 
1,582  
198  

2018 
1,602  
198  

- 

- 

2017 
1,575  
1,050  
51  

2018 
1,643  
1,084  - 
51  - 

2017 
13  

- 
- 

No information provided 

13  - 
- 
- 

4,565,264 
m³ 

4,357,710 
m³ 

- 

- 

256,411 
m³ 

275,827 
m³ 

- 

No information on imported biomass provided 

14  
0  
0  
1,791  
2  
2  
1,002  
149  
44  

16  
0  
0  
1,855  
2  
2  
1,065  
159  
53  

2  
0  
11  
1,053  
235  
7  
251  
828  
486  

2  
0  
10  
1,082  
200  
3  
283  - 
797  - 
468  - 

5,600,000 
m³ 

,.670,000 
m³ 

2,200,000 
m³ 

2,234,000 
m³ 

- 

No information on imported biomass provided 

2,704  
0  
0  

2,718  
0  
1  

5,962  
4  
55  

- 
- 
- 

- 
- 
- 

- 
- 
- 

6,165  
108  
161  
180  
40  
2  
1,208  
1  
12  
897  
5  
48  
56  
1  
0  
6,094  
234  
128  
1,199  
89  

5,947  
104  
152  
176  
40  
1  
1,110  
5  
10  
894  
6  
41  
58  
2  
0  
5,468  
257  
122  
1,435  
119  

- 
- 
- 

2,666  
404  
130  
16  
18  
11  
305  
10  
13  
10  
22  
17  
80  - 
0  
0  
693  
700  
152  
833  
34  

6,232  - 
8  - 
58  - 
- 
- 
- 
2,590  - 
352  - 
118  - 
17  - 
13  - 
8  - 
355  - 
13  - 
16  - 
8  - 
15  - 
17  - 

0  - 
0  - 

543  
834  
230  
1,006  - 
57  - 

929,600 
m³ 

886,100 
m³ 

- 

- 

- 

No information on imported biomass provided 

0  
0  
0  
152  
0  
0  

0  
0  
0  
133  
0  
0  

- 
- 
- 

- 

- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
3  - 
- 
- 

- 
- 

- 

- 
- 
- 
- 
- 
- 

- 
- 
- 
- 
- 
- 
- 
- 

- 

1,341  
75  
579  

1,336  

77  - 
519  - 

- 
- 

- 

- 

- 

- 
- 
- 

- 

- 
- 

- 

2  
0  
0  
541  
0  
0  
483  

2  
0  
0  
538  
0  
0  
421  

- 
- 

- 

- 
- 
- 
- 
- 
- 

- 

- 

- 
- 
- 
- 
- 

- 
- 

- 

2  
17  
0  
158  
0  
0  
468  
53  

- 

- 

327  

- 
- 
- 
- 
- 

- 
- 

- 

2  
27  
0  
153  
0  
0  
441  - 
64  - 
- 

- 

349  - 
- 
- 
- 
- 
- 

1,160  
0  
0  
604  

1,013  
0  
0  
577  

6,690  
331  
10  
0  

6,677  
288  
4  
0  

- 
- 
- 
- 
- 
- 
- 
- 

23  

- 

17  
1,113  

- 
- 

6  

- 

- 
- 

- 
- 

n/a 
n/a 

23  

- 
0  - 

- 
- 

14  

- 
- 

411  

n/a 
n/a 

158  

- 
- 

1,126  

1,558  

- 

5  
3  

2  - 

11  
0  

- 

7  

- 
- 
161  - 
- 
- 

201  

- 

1,598  - 
1  - 
- 

10  

0  - 

11,640  

10,089  - 

- 
- 

- 

9  
0  
0  
0  
0  
0  

- 
- 
- 

- 

- 
- 
- 
- 
- 
- 

154  
24  
1  
0  

- 

0  
64  

- 
- 
- 
- 
- 

12  

- 

12  

- 
- 
- 

9  
0  
0  
0  
0  
0  

150  
21  
0  
8  

1  
74  

12  

12  

83  

78  

- 

- 

0  

0  

No information on imported biomass provided 

0  
0  
322  

0  
0  
322  

4,877 t 
- 
- 

LU  Domestic  38,408 m³  40,768 m³  - 
- 
5,483 t 
LU  EU 
- 
- 
LU  Non-EU 
MT  Domestic 
- 
- 
MT  EU 
MT  Non-EU 
NL  Domestic 
NL  EU 
NL  Non-EU 
PL  Domestic 
PL  EU 
PL  Non-EU 
PT  Domestic 
PT  EU 
PT  Non-EU 
RO  Domestic 
RO  EU 
RO  Non-EU 
SK  Domestic 
SK  EU 

4,797  
49  
347  
1,093  
- 
- 

4,796  
52  
472  
1,144  
- 
- 

323  
2  

320  
2  

- 
- 
- 

- 
- 
- 

- 
- 
- 
- 

1  
1  
656  

13,709 
tTM 
- 
- 
- 
1  - 
1  - 

15,564 
tTM 
- 
- 
- 
- 
- 

- 
- 
- 
4,793 t 
- 
- 

- 
- 
- 
4,397 t 
- 
- 

- 
- 
- 

- 
- 

- 
- 
- 

1  

- 
- 

- 
- 
1  - 
- 
- 

- 
- 
- 
- 
- 

743  

3  

4  

437  

371  

1,319  

1,265  

0  

0  

- 
- 
- 
1,274  
24  
- 
3,447  
0  
0  
525  
0  

- 
- 
- 
1,256  
24  
- 
3,506  
0  
0  
522  
0  

29  
- 
- 
209  
- 
- 
3  
0  
0  
102  
0  

43  
- 
- 
194  
- 
- 
3  - 
0  - 
0  - 

99  
0  

283  
- 
- 
- 
- 
- 

- 
- 
- 

0  
0  

196  
- 
- 
- 
- 
- 

- 
- 
- 

0  
0  

905  
- 
- 
- 
- 
- 

- 
- 
- 

18  
0  

845  
- 
- 
- 
- 
- 

17  - 
0  - 

92  
- 
- 
77  
- 
- 
0  
0  
0  

- 
- 

98  
- 
- 
75  
- 
- 
0  
0  
0  

 
 
 
 
 
 
Technical assistance in realisation of the 5th report on progress 
of renewable energy in the EU 

Indirect supply of 
wood biomass  

Energy crops and 
short rotation trees 

Agr by-products / 
processed residues 

Biomass from waste  

Others  

MS 

Domestic 
vs import 

Direct supply of 
wood biomass from 
forests 
3  

0  

3  

0  

0  

11  

12  

1,606  

1,618  

No information provided  

No information on imported biomass provided 

SK  Non-EU 
SI  Domestic 
SI  EU 
SI  Non-EU 
ES  Domestic 
ES  EU 
ES  Non-EU 
SE  Domestic 
SE  EU 
SE  Non-EU 
UK  Domestic 
UK  EU 
UK  Non-EU 
[1] The Member State Progress Report of Latvia doesn’t distinguish between imports from within and outside of the EU 

No information provided  

2,020  
7  
2  

2,190  
9  
6  

6,837  
128  
342  

707  
97  
97  

141  - 
642  - 

60  
30  
30  

66  
24  
15  

1,851  - 

1,818  

6,532  

1,831  

1,864  

668  

13  

13  

- 
- 

0  

0  

- 

674  - 

625  
100  - 
100  - 

0  - 

- 

- 

707  

625  

- 
- 

 
 
 
 
 
 
 
Technical assistance in realisation of the 5th report on progress 
of renewable energy in the EU 

Table 23. Biomass consumption for transport based on Table 4 in the Member States Progress Reports 

MS 

Domestic 
vs import 

Common arable crops for 
biofuels 

Energy crops 

Others 

AT 
AT 
AT 
BE 
BE 
BE 
BG 
BG 
BG 
CY 
CY 
CY 
CZ 
CZ 
CZ 
DK 
DK 
DK 
EE 
EE 
EE 
FI 
FI 
FI 
FR 
FR 
FR 
DE 
DE 
DE 
EL 
EL 
EL 
HR 
HR 
HR 
HU 
HU 
HU 
IE 
IE 
IE 
IT 
IT 
IT 
LV 
LV 
LT 
LT 
LT 
LU 
LU 
LU 
MT 
MT 
MT 
NL 
NL 
NL 
PL 
PL 
PL 
PT 
PT 

Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
Import2 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic3 
EU 
Non-EU 
Domestic 
EU 

2017 
38  
359  
59  

2018 
43  
405  
57  

- 
- 

No information provided 

No information provided 

0  
0  
0  

- 
- 
- 

- 
- 
- 

0  
0  
0  

No information provided 

No information provided 

No information provided 

No information provided 

482  
772  
652  
100  
27  
7  
0.4  
29.2  
0.0  
288,000  

0  
0  
0  
0  
18  
275  

- 

- 
- 

- 
- 

- 
- 

- 
- 

398  
712  
732  
79  
17  
19  
0.3  
0.2  

368,000  

0  
0  
0  
0  
13  
64  

119  

151  

No information provided 

n/a 
- 
- 
- 
- 
- 

n/a 
- 
- 
- 
- 
- 

No information provided  

1323716 kt 

1308425 kt 

No information provided  

- 
- 

- 
- 

- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 

- 
- 
- 
- 
- 
- 

- 

- 
- 

2017 
13  

2018 
13  

0  
0  
0  
0  
0  
0  

0  
0  
0  

0  
0  
0  
0  
0  
0  

0  
0  
0  

- 
- 

- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 

- 
- 
- 
- 
- 
- 

- 

- 
- 

2017 

2018 

- 
- 
- 

- 
- 
- 
- 
- 
- 
- 

- 

- 
- 
- 
- 
- 
- 

0  
9  
0  
0  
0  
0  

190  
362  
242  
31  
0  

17  
0  
0  
81  
40  
82  
531  
10  

- 
- 
- 

- 
- 
- 
- 
- 
- 

- 

- 
- 
- 
- 
- 
- 

0  
9  
0  
0  
0  
0  

230  
408  
388  
43  
0  
0  

18  
0  
0  
83  
47  
202  
841  
26  

408682 kt  

426035 kt 

- 
- 

- 
- 

 
 
 
 
 
 
 
Technical assistance in realisation of the 5th report on progress 
of renewable energy in the EU 

MS 

PT 
RO 
RO 
RO 
SK 
SK 
SK 
SI 
SI 
SI 
ES 
ES 
ES 
SE 
SE 
SE 
UK 
UK 
UK 

Domestic 
vs import 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 
Domestic 
EU 
Non-EU 

Common arable crops for 
biofuels 

- 
- 
- 
- 

386  
0  
0  
72  

- 

- 

340  
0  
0  
73  

n/a 
n/a 

n/a 
n/a 

No information provided 

No information provided 

30  
277  
73  

40  
286  
109  

- 
- 
- 

No information provided 

Energy crops 

Others 

0  
0  
0  

- 
- 
- 
- 

- 
- 
- 

- 
- 
- 
- 
- 
- 
- 

0  
0  
0  

- 
- 
- 
- 
- 
- 
- 

165  
420  
709  

156  
486  
719  

[1] The Member State Progress Report of Latvia doesn’t provide information on feedstock. These numbers refer to primary energy of raw 
materials for the total of biodiesel and bioethanol. 
[2] The Member State Progress Report of Latvia doesn’t distinguish between imports from within and outside of the EU. 
[3] Numbers refer to amount of basic feedstocks of agricultural origin and products of feedstock processing used for production of esters and 
bioethanol in kilotonnes. Neither the energy content nor the origin are specified. 

 
 
 
 
 
Technical assistance in realisation of the 5th report on progress 
of renewable energy in the EU 

Appendix C. Local environmental impacts related to 

biofuels 

In the following section, the local environmental impacts for the main crop-country combinations 
supplying feedstock for biofuels consumed in the EU are analysed. Crops cultivated for bioethanol 
within the EU consist mainly of wheat, maize, and sugar beet. For biodiesel, rapeseed is the main 
cultivated crop. Non-EU biodiesel feedstock production is primarily produced through soybean 
cultivation in Argentina and oil palm cultivation in Malaysia and Indonesia. 

The local environmental impacts assessment differs between the crop-country combinations. For the 
crops produced within the EU (section EU biofuel crops) the analysis is based on the developments of 
the environmental status as described by the EEA and Eurostat. For the assessment of the non-EU 
crop-country combinations (section non-EU biofuel crops) the approach is based on reviews of 
scientific literature. 

A challenge in the analysis of local environmental impacts of biofuels is the lack of transparency in 
agricultural supply chains, making it difficult to trace the origin of the feedstock. To determine the 
actual local environmental impact of a biofuel crop, site-specific data is essential as impacts will vary 
widely between countries, farms, management practices, and fields.  

Another question specific to the EU is whether cultivation systems and management practices used 
for European biofuel crop production differ significantly from crop cultivation for food production. 
Feedstock for biofuels consumed in the EU must adhere to the sustainability criteria from the 2009 
Renewable Energy Directive. To ensure that the biofuels meet the criteria of the RED, biofuels need 
to be validated by national verification systems or by one of the 15 voluntary schemes approved by 
the EC. However, it is difficult to fully evaluate the effect of these schemes, as environmental impact 
criteria differ between schemes and total certified biofuel volumes lack transparency208. 

EU biofuel crops – rapeseed, wheat, maize and sugar beet 

Over half of the feedstock for crop-based biofuels is grown in the EU. As described in the Renewable 
Energy Directive, all EU Member States report every two years on their national renewable energy 
developments including the impact on biodiversity and air, soil and water quality (as described in 
section 5.4.1). Most Member States indicate that within their country there is either limited domestic 
biofuel feedstock production compared to all agricultural production, or that all their agricultural 
production is regulated with respect to environmental impacts. Therefore, impacts of biofuel crop 
production are expected to be the same as those of other crop production.  

The most common types of feedstock grown in the EU for biofuels are rapeseed, wheat, maize, and 
sugar beet. Many of the environmental impacts of the main biofuel crop production are generic to 
agriculture, however some distinct impacts can be related to the production of rapeseed, wheat, 
maize and sugar beet in Europe. The section below provides an overview and analysis of the current 
state and outlook of agriculture in the EU and provides specific insights for biofuel feedstocks.  

Background and current state 

In Europe grass- and cropland make up 43% of the landcover 209. Farming practices and structures 
differ significantly across and within the EU Member States, reflecting highly diverse biogeographic, 
economic and social conditions. The EU’s 7th Environment Action Programme210 set out the 2050 
vision of “living well, within the limits of our planet”, the EU is committed to multiple policy objectives 

208 ECA, 2016. The EU system for the certification of sustainable biofuels. Special Report No 18, 2016. European Court of Auditors. 
209 FAOstat, 2018 
210 EAP, 2014. General Union environment action programme to 2020. EU Publication by DG ENV. 

 
 
 
                                                      
Technical assistance in realisation of the 5th report on progress 
of renewable energy in the EU 

focussing on the environmental outcomes of agricultural activities. These include the objectives of the 
EU nature legislation, the 2020 biodiversity strategy, the National Emission Ceilings Directive on air 
pollution, the Effort Sharing Regulation on greenhouse gas (GHG) emissions, the LULUCF Regulation 
on land-use change and forestry and the Water Framework Directive and Nitrates Directive on water 
quality.  

Water quality 

The ecological status and quality of surface water ecosystems in Europe are assessed under the 
Water Framework Directive 211. Currently, 40% of Europe’s 111.000 water bodies achieve good 
ecological status 212. One of the main environmental pressures on water quality in Europe is diffuse 
pollution, affecting 38% of the surface water bodies and 35% of the groundwater bodies. Run-off and 
leaching of nitrogen-based fertilisers used on agricultural land have been identified as a primary 
cause213 . Excess nitrogen discharges to soil, water and air result in systemic environmental issues 
such as eutrophication in which a water body becomes overly enriched with nutrients and minerals, 
resulting in toxicity, oxygen depletion, decreased biodiversity and changes in species composition. 
Between 2000 and 2015 agricultural nitrogen surplus decreased by 18% in the EU212. However, the 
overall fertiliser application remains high. Under the Nitrates Directive, Member States are 
implementing multiple measures, many of which are compulsory in nitrate vulnerable zones, to reduce 
the impact and input of nitrogen. Measures include the management of nutrients on farm-level, 
standards for the timing of fertiliser application, appropriate tillage techniques, the use of nitrogen-
fixing catch crops, crop rotation, and uncultivated buffer strips along rivers and streams214. Risks 
related to pesticide and nutrient leaching are emphasized especially for maize, rapeseed and sugar 
beet. These crops have a high fertiliser demand and leaching risk due to soil erosion, harvesting 
residues, or water demand215. An important factor to take into account here is the impact per energy-
unit of biofuel, e.g. maize and wheat are comparatively low yielding meaning that the impact can still 
be quite high. 

40% of Europe’s water abstraction can be attributed to agricultural activities. Especially in southern 
Europe, this figure can exceed 80% in the summer months. Water scarcity arises as a consequence 
of the water demand and through reduced precipitation (e.g. rain, snow, fog). Between 2005 and 
2016, crop production in Europe became 12% less water intensive. Due to more efficient irrigation 
techniques, a clear trend for absolute decoupling of total water input and gross value added in crop 
production has been observed. The total water input to crops decreased from 5 m3 to 4.4 m3 for each 
unit of gross value added generated216. However, water scarcity is expected to become increasingly 
frequent and widespread in Europe in response to a changing climate, making this an important 
environmental pressure213.  

Crop based bioethanol and biodiesel have by far the largest water footprint of the EU renewable 
energy sources, partly due to their vast consumption of soil moisture217. Especially in southern Europe 
water consumption is linked to agriculture, where crops such as maize and sugar beet are often 
irrigated218. Rapeseed and wheat have less impact on water abstraction, as these crops are often 
dependent on seasonal patterns of precipitation. Water use improvements can be obtained by more 
efficient irrigation methods or through more resilient crop selection.  

211 EU Water Framework Directive (WFD), 2000. EU Publication by DG ENV. 
212 EEA, 2018. Chemicals in European waters — knowledge developments. 
213 EEA, 2019. The European environment – state and outlook 2020. 
214 EU Nitrates Directive, 1991. Council Directive 91/676/EEC concerning the protection of waters against pollution caused by nitrates from agricultural 
sources. EU publication. 
215 EU Biofuels baseline 2008, 2011.  
216 EEA, 2019. Water intensity of crop production in Europe. 
217 JRC newsletter, 2019. Water footprint of EU energy consumption: 1,301 litres per person per day. https://ec.europa.eu/jrc/en/news/water-footprint-eu-
energy-consumption 
218 Eurostat, 2018. Agri-environmental indicator - irrigation. 

 
 
 
 
 
                                                      
Technical assistance in realisation of the 5th report on progress 
of renewable energy in the EU 

Soil quality 

The 2018 mapping of Europe’s land cover assessed in the Corine Land Cover data sets 219, indicates 
that the proportion of Europe’s main land cover types is relatively stable. Around 9% of agricultural 
land is part of Natura 2000 sites 220 and around 30% is classified as high nature value farmland221. 
However, the high demand for agricultural output and trend towards intensification leads to various 
pressures on the land and soil, such as soil erosion, soil compaction, soil organic carbon loss and soil 
biodiversity decrease, creating cumulative impacts on ecosystems.  

Conversion of grasslands to croplands and increased fertilisation rates, create environmental 
pressures on erosion control, storage of soil carbon and soil biodiversity. Grasslands are one of the 
most species-rich vegetation types 222, conversing these lands lead to negative consequences for 
pollinators, other insects and birds. Erosion of soils is described by the loss of soil by water or wind, or 
through harvest losses. Soil adhering to harvested root-crops (such as sugar beet and potato) 
contributes to significant soil removal. Panagos et al. (2019) estimate that 4.2 million hectares of root-
crops contribute to 14.7 million tonnes of soil loss 223. Soil erosion leads to loss of productivity and soil 
function, and potential leakage of soil material and pollutants into water systems. Soil erosion is 
particularly for maize and sugar beet deemed a high risk, with significant soil removal through 
harvesting losses for sugar beets and soil erosion through wind for maize as a result of extensive 
periods where soils are left bare. Crops grown over winter such as winter-wheat and winter-rapeseed 
provide good crop cover, thereby reducing erosion risks. 

A precursor of erosion is soil compaction, resulting from heavy machinery use on agricultural lands, 
causing increased soil density and reduction of soil structure and porosity. This has a negative effect 
on root penetration and the habitat of soil organisms, lowering crop yields and water retention 
capacity224. About 23% of soils in the EU are estimated to have critically high densities in their 
subsoils 225. In some Member States guidelines exist on access to wet soils, however on EU level no 
regulations are in places. Especially sugar beet is accounted as a susceptible crop to soil 
compaction226.  

Soil organic carbon (SOC) is one of the primary sources of energy in the food pyramid. Losses of 
carbon through erosion, climate change and drainage impact the ecosystem and reduce 
biodiversity227. Decomposition of organic material is the fundamental process for building SOC pools 
which are important for the nutrient cycle and retention. SOC in mineral cropland soils in the EU have 
been broadly stable over time the past years, however much lower compared to SOC in other land 
cover categories. Mean SOC for permanent crops is 16.4 g/kg, compared to 90.4 g/kg in natural 
vegetation and 43.8 g/kg in permanent grassland228. The dynamics of SOC vary according to land use 
and specific management practices. SOC loss in wheat, maize and rapeseed can be partly prevented 
by the retention of crop residues on the agricultural soils (Stella et al., 2019). The RED II states 
additional sustainability criteria, which add a limit to crop residue extraction to ensure that soil quality 
and soil carbon are maintained or improved229. 

219 Corine Land Cover inventory, 2018. https://land.copernicus.eu/pan-european/corine-land-cover 
220 EU agricultural outlook for agricultural markets and income 2017-2030, European Commission. EU publication by DG AGRI. 
221 Paracchini et al., 2008. High nature value farmland in Europe — an estimate of the distribution patterns on the basis of land cover and biodiversity data. 
EUR - Scientific and Technical Research Report 
222 Silva et al., 2008. LIFE and Europe’s grasslands: restoring a forgotten habitat. Office for Official Publications of the European Communities, Luxembourg. 
223 Panagos, et al., 2019. ‘Soil loss due to crop harvesting in the European Union: a first estimation of an underrated geomorphic process’, Science of The 
Total Environment 664, pp. 487-498 
224 Brus and van den Akker, 2018. ‘How serious a problem is subsoil compaction in the Netherlands? A survey based on probability sampling’, SOIL 4(1), pp. 
37-45 
225 Schjønning, et al., 2015. ‘Soil compaction’, in: Soil threats in Europe: status, methods, drivers and effects on ecosystem services. RECARE project, JRC 
Technical Report, Joint Research Centre, pp. 92-101. 
226 Marinello et al., 2017. Traffic effects on soil compaction and sugar beet (Beta vulgaris L.) taproot quality parameters. Spanish Journal of Agricultural 
Research, Volume 15, Issue 1, e0201 
227 Stolte et al., 2016. Soil threats in Europe: status, methods, drivers and effects on ecosystem services. RECARE project, JRC Technical Report 
228 Hiederer, 2018. Data evaluation of LUCAS soil component laboratory data for soil organic carbon, JRC Technical Report, Luxembourg 
229 RED II, article 29.2. 

 
 
 
                                                      
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Several national studies done on pesticide residues in agricultural soils, indicate that contamination of 
soils is widespread in Europe230, 231. Concerns are raised on the accumulation of pesticide residues 
and their potential release mechanisms for example through acidification and wind erosion230. Due to 
high levels of pesticide use, leakage is deemed the most problematic for rapeseed and maize.  

Sustainable management can improve the many potential positive environmental impacts of land and 
soils. Soil can function as a carbon sink, a filter for water and nutrients, and a support system for 
biodiversity. Currently, there is no European legislation that focusses exclusively on soil, the lack 
thereof can have a potentially negative effect on soil protection in the EU. 

Air quality 

Air quality can have a direct effect on fauna and vegetation by affecting the soil and water quality. 
Intensively managed agricultural areas contribute to air pollution mainly via the spreading of animal 
manure or agro-chemicals on fields with no or little vegetation cover. This process increases the level 
of particulate matter in the air (PM). Precipitation can then lead to the atmospheric deposition of these 
nitrate and ammonium compounds, exceeding the critical load for eutrophication and disturbing 
terrestrial and aquatic ecosystems. Excessive amounts of the nutrient nitrogen can lead to changes in 
species diversity and invasion of new species.  

At the EU level, air pollution is a well-established environmental policy area, setting emission 
standards for the agricultural sector (e.g. Clean Air for Europe Programme, Ambient Air Quality 
Directives, Nitrate Directive). When legal limits for ambient concentrations of air pollutants are 
exceeded, Member States are obliged to implement reduction plans and measures. The cooperative 
program for monitoring and evaluation of the long-range transmission of air pollutants in Europe232 
shows that in 2016 lower emissions of air pollutants have contributed to fewer exceedances of 
acidification and eutrophication limits. However, in 2016, the critical loads for eutrophication were still 
exceeded in over 62% of the European ecosystem area. Air pollution risks are high for rapeseed, 
sugar beet, maize and wheat in the EU as the cultivation of these crops requires fertilization of the 
soil.  

Non-EU biofuel crops – palm oil and soy 

This section provides an overview of local environmental impacts related to the production of EU 
biofuels from palm oil cultivation in Indonesia and Malaysia, and soy cultivation in Argentina.  

Palm oil 

Palm fruit oil (Elaeis guineensis Jacq.) is a tropical oil. The ideal growing conditions for palm oil are 
found only within 10 degrees north or south of the equator, on the continents of Asia, Africa and South 
America. The common denominator of these areas is the vast areas of tropical rainforest rich in 
biodiversity they contain. In the recent decades the demand for edible vegetable oils has grown 
strongly and palm oil plantations have expanded rapidly in number and size to meet the global 
demand. This analysis will focus on the two countries with the largest production of palm oil; 
Indonesia and Malaysia. Palm fruit oil from these two countries is the feedstock for respectively 15% 
and 7% of all biodiesel consumed in the EU and covers 99% of all palm fruit oil used as feedstock for 
biodiesel consumed in the EU. 

Palm oil used for biofuels in the EU needs to adhere to the sustainability criteria in the Renewable 
Energy Directive. The Renewable Energy Directive forbids the use of feedstocks from deforested 

230 Silva et al., 2019. ‘Pesticide residues in European agricultural soils – a hidden reality unfolded’, Science of the Total Environment 653, pp. 1532-1545 
231 Swartjes et al., 2016. Appraisal of measures for the reduction of pesticide load in groundwater as drinking water resource, RIVM, Netherlands 
232 EMEP, 2018. Transboundary particulate matter, photo-oxidants, acidifying and eutrophying components, Status Report No 1/2018, Cooperative 
programme for monitoring and evaluation of the long-range transmission of air pollutants in Europe. 

 
 
 
                                                      
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lands (cut-off date 1st of January 2008), therefore recent deforestation can’t be directly linked to 
biofuels used in the EU. Additional restrictions have been put on biofuels counting towards the RES 
targets in the REDII for the time period 2021-2030. The Directive includes a phase-out of all “high 
ILUC risk” feedstock by 2030, and no expansion of these feedstocks beyond their 2019 levels 233 
unless this feedstock is certified as low ILUC risk. Currently, palm oil falls in this category of high ILUC 
risk feedstock and this could result in a  decline of palm oil biodiesel consumption in Europe towards 
2030. In the beginning of June 2020, Indonesia raised a complaint on the REDII, stating that it 
discriminates against biofuels from palm oil. They asked the dispute settlement body of the World 
Trade Organization (WTO) to establish a panel to examine the EU REDII on this point234.  

The analysis in this section will focus on environmental impacts related to existing palm oil 
plantations. It should be noted that tracking of palm oil sources for biofuel production is still 
challenging, with a lack of transparency of the supply chains. Therefore, standard practices and 
common environmental risks in palm oil production in Indonesia and Malaysia will be assessed.  

However, it should be noted that deforestation of rainforests through the development of new palm oil 
plantations and expansion of smallholder farms remains a serious concern as general palm oil 
demand is still expected to grow in the coming years. The removal of acres of rainforest threaten the 
rich biodiversity in these elaborate ecosystems and releases carbon into the atmosphere. Soil erosion 
is a big problem, when the rainforest root structure is removed and nutrient-rich soil washes away. 
Leading to increased use of fertilizers and pesticides, adding to the pressure on the soil, water, and 
air quality. A simple shift from palm oil to other crops is not deemed a solution as palm oil produces 
up to nine times more oil per unit area than other major oil crops. Shifting to other crops could result in 
diminished efforts to produce palm oil sustainably, and an increase in land used for producing other 
oils (mostly soy, sunflower and rapeseed) shifting environmental impacts to regions where those oils 
are produced235. 

Water quality 

Water and soil impacts are often closely interconnected, with soil problems often leading to water 
problems. Several water quality risks are related to palm oil production in Indonesia and Malaysia. An 
analysis on water quality impacts through soil erosion and leaching of nutrients and organic matter 
can be found in the paragraph below.  

The eastern part of Malaysia is affected by the monsoon between mid-October and the end of March 
every year. During the monsoon period, rainwater can wash off soil and debris from the land into the 
rivers. Oil palm plantations make up 77% of agricultural land in Malaysia, therefore a large part of 
river pollution in Malaysia is caused by palm oil plantations. Lack of fertilizing regulations in Malaysia 
may cause severe environmental damage and exposure of toxic chemicals to the surrounding236. 

Pollution of soil and water caused by wastewater is another major environmental impact. In Malaysia 
and especially Indonesia, water quality is in many places poor due to several different causes, among 
these oil palm cultivation and palm oil processing237. A by-product of palm oil processing is Palm Oil 
Mill Effluent (POME), an oily wastewater consisting of various suspended components. A palm oil mill 
generates 2.5 metric tons of effluent for every metric ton of palm oil it produces. POME is often 

233 EEAS, 2018. Palm Oil: Outcome of the Trilogue of the EU’s Renewable Energy Directive (RED II) - EEAS - European External Action Service - European 
Commission. European External Action Service. 
234 Argus, 15 June 2020. Indonesia’s palm oil dispute with EU set to continue. https://www.argusmedia.com/en/news/2114306-indonesias-palm-oil-dispute-
with-eu-set-to-continue  
235 Meijaard et al., 2018. Oil palm and biodiversity. A situation analysis by the IUCN Oil Palm Task Force. IUCN Oil Palm Task Force Gland, Switzerland: 
IUCN. 
236 Che Nadzi et al., 2019. Malaysian Journal of Fundamental and Applied Sciences Vol. 15, No. 1, 85-87 
237 Badan Pusat Statistik, 2018. Statistical yearbook of Indonesia 2017. Badan Pusat Statistik, Jakarta. 

 
 
 
                                                      
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discarded in disposal ponds, resulting in the leaching of contaminants that can pollute the soil, and 
surface- and groundwater affecting biodiversity and human health 238, 239. 

POME is considered as the main source of water pollution in Malaysia due to the high biochemical 
oxygen demand (BOD) and chemical oxygen demand (COD) that causes a reduction of the 
biodiversity and ability of aquatic ecosystem. Furthermore, the damages to the river cannot be 
undone easily. Since POME is generated in huge amounts at a time, it is very difficult to manage, and 
the treatment of this wastewater is expensive. Consequently, the cheapest and easiest way for this 
wastewater disposal that have been practiced in Malaysia is by discharging the treated POME to the 
nearby river or stream. However, even treated POME still poses negative effects on the 
environment240.  

In Malaysia, most industries are able to meet current BOD emission standards of 100 mg/l241 or the 
even stricter standards of 20mg/l applied to mills in Malaysian Borneo. These strict standards are in 
the process of becoming the nation-wide standard242. Most oil mills in Indonesia do not comply with 
discharge limits even though these are less strict than in Malaysia.  

Currently, promising research is done on wetland treatment systems using phytoremediation to clean 
the wastewater. Phytoremediation is one of the environmental-friendly and cost-effective systems, in 
which plants remove, transfer, stabilize, and/or destroy contaminants in the soil and groundwater. 
POME can be a source of nutrients for specific plants, increasing growth and creating a potential for 
biofuel production240. 

Soil quality 

Soil quality decline is prevalent in palm oil cultivation in Indonesia and Malaysia and can be impacted 
by multiple stressors. Under the Renewable Energy Directive, a couple of these impacts are 
mitigated, such as biodiversity loss through deforestation, soil organic carbon (SOC) losses and soil 
stability losses related to land use change of especially peatlands.  

Soil erosion and sedimentation are major issues in Indonesia and Malaysia and have a big impact on 
pollution and water quality. High soil erosion rate often leads to river constriction, increased flooding, 
threatened aquatic habitats, leaching of nutrients and organic matter and silt deposits in rivers and 
ports 243. Levels of soil erosion differ between plantations and the season, and depend on the tree 
arrangements, steepness of the slopes and soil management practices. Eroded areas require more 
fertilizer and other inputs, including repair of roads and other infrastructure239. Erosion rates in 
matured oil palm plantations in Malaysia range from 7.7 to 14.0 t/ha/yr, soil erosion rates in Indonesia 
are deemed similar. Cover crops or understory vegetation have shown that they could play a big 
potential role in mitigating soil erosion and increasing soil biodiversity243,244. 

Soil biodiversity plays a large part in the ecosystem functions, through nutrient cycling, soil carbon 
sequestration and nutrient uptake by plants, that help maintain soil sustainability. Understory 
vegetation management varies between plantations, but complete removal by using herbicides (such 
as paraquat, glufosinate ammonium, and glyphosphate) and weeding is common. Extensive use of 
herbicides has been related to increased water pollution, threatening ecosystems and impacting 
human health. Reduction in herbicide use and a greater coverage of understory vegetation has been 

238 Rusmawarni, 2020. Mathematical modelling of total suspended solid removal from pome via modified electrocoagulation. Journal of Critical Reviews, 7 
(8), 67-71. 
239 Wordwilfe.org, Sustainable Agriculture – Palm oil. WWF. 
240 Osman et al., 2020. The effect of Palm Oil Mill Effluent Final Discharge on the Characteristics of Pennisetum purpureum. Sci Rep 10, 6613 
241 Bello and Raman, 2017. Trend and current practices of palm oil mill effluent polishing: Application of advanced oxidation processes and their future 
perspectives. J. Environ. Manage. 198, 170–182 
242 Tabassum et al., 2015. An integrated method for palm oil mill effluent (POME) treatment for achieving zero liquid discharge - a pilot study. Journal of 
Cleaner Production 95, 148–155. 
243 Sahat et al., 2016. IOP Conference Series: Materials Science and Engineering. 136 
244 Ashton-Butt et al., 2018. Understory Vegetation in Oil Palm Plantations Benefits Soil Biodiversity and Decomposition Rates. Frontiers in Forests and 
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related to improved avian- and invertebrate biodiversity245. Understory vegetation does not seem to 
have a negative effect on palm oil yield. It could even increase the yield by improving soil quality and 
lowering operational costs for plantation owners244, 246.  

Another aspect influencing soil quality is compaction, as plantations become bigger the size and 
weight of machinery used also increases. Various machines have been introduced to reduce labour 
reliance, as well as to improve productivity. However, mechanised field operations could contribute to 
gradual degradation of soil’s physical properties leading to detrimental effects on crop productivity247. 
Furthermore, soil compaction is associated with a higher risk on floods and droughts as water 
infiltration capacity becomes lower 248. 

Air quality 

The main air quality impacts related to palm oil cultivation in Indonesia and Malaysia, come from haze 
related to burning as land preparation, agrochemical application and processing emissions in the form 
of soot and dust.  

The haze from fire as a land preparation will be mitigated mostly by adherence to the sustainability 
criteria as stated in the Renewable Energy Directive. However, haze continues to affect the Southeast 
Asian region and causes significant deterioration in air quality. Currently, it is difficult to determine 
exactly where the fires originate. The highly voluntary nature of reporting in Indonesia could perhaps 
explain the poor environmental management performance of plantation companies that has led to the 
haze problem. Abdullah et al. (2020) discovered that Malaysian companies provided slightly better 
disclosures compared to Indonesian companies, perhaps due to a better voluntary disclosure 
environment and increased environmental awareness among Malaysian communities. In Indonesia 
stakeholders often show no positive response to accountability249. 

Besides the contamination of soils and pollution of surface and ground water as described under the 
section water quality, POME can also have a negative effect on air quality. POME is typically released 
into open-air holding ponds for remediation, thereby releasing carbon dioxide, methane, and 
hydrogen sulphide, all of which have a negative effect on the climate250. Palm oil mills that produce 
palm oil for EU biofuel are obligated to have a methane capture system in place.  

Biodiversity 

The tropical areas suitable for palm oil plantations are very rich in biodiversity. Land use change from 
tropical rainforests and other species-rich habitats to oil plantations may therefore result in high levels 
of biodiversity loss in Indonesia and Malaysia. Most impacts on biodiversity due to the EU biofuel 
demand will only be indirect displacement effects, as the Renewable Energy Directive sustainability 
criteria exclude many of the biodiversity risks related to direct land use change. Most certificates 
(RSPO and ISCC) do not only cover biodiversity impacts resulting from the planning and development 
phase, but also cover impacts from cultivation and processing activities. However, all the impacts 
described under soil-, water-, and air quality also have an effect on the soil-, aquatic- and terrestrial 
biodiversity. Currently biodiversity in Indonesia and Malaysia is still under a lot of pressure235. 

Management practices in existing plantations can contribute to biodiversity restoration. Historically 
elephants were found in large numbers throughout the forests of Malaysia. However, over the past 
100 years elephant numbers have been dropping fast due to habitat fragmentation by plantation 
development and human-elephant conflicts. Currently, the WWF, together with the Sabah government 

245 Tohiran et al., 2017. Targeted cattle grazing as an alternative to herbicides for controlling weeds in bird-friendly oil palm plantations. Agron. Sustain. Dev 
246 University of Göttingen, 2019. Palm oil: Less fertilizer and no herbicide but same yield? https://phys.org/news/2019-11-palm-oil-fertilizer-herbicide-
yield.html 
247 Zuraidah et al., 2017. Does soil compaction affect oil palm standing biomass? Journal of oil palm research 29 (3). 352-357. 
248 Dislich et al., 2017. A review of the ecosystem functions in oil palm plantations, using forests as a reference system. Biological Reviews 92, 1539–1569 
249 Abdullah et al., 2020.  The Southeast Asian haze: The quality of environmental disclosures and firm performance. Journal of Cleaner Production, 246. 
250 Febijanto, 2020. IOP Conference Series: Materials Science and Engineering. 742 

 
 
 
 
 
                                                      
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and agricultural companies, are partnering to enable a wildlife corridor through a Sabah government-
supported palm oil plantation to connect the Silabukan Protection Forest Reserve and the Tabin 
Wildlife Reserve251. The WWF will also support planting native vegetation to restore riverside habitat 
to attract elephants and species, such as orangutans and gibbons. The long-term aim of the WWF is 
to foster peaceful coexistence between wildlife and the plantation industry through solutions that 
benefit both. In the future, as long as further deforestation is limited, it should be possible for Malaysia 
to maintain a healthy elephant population on both the Peninsula and in Borneo252.  

A key requirement for oil palm plantations to be certified under the RSPO certification scheme, is that 
the plantations must protect areas of natural forest within their land. Fleiss et al. (2020) found that 
patches of protected forest play an important role in helping to conserve endangered species 
including hornbill birds and dipterocarp trees. Furthermore, the same study revealed that plantations, 
where a tenth of the land is protected as natural forest, store up to 20% more carbon than plantations 
with no protected forest253. It can be noted that a growing body of literature exists on the impact of 
management practices on biodiversity and the potential mitigation methods in existing palm oil 
plantations.  

Soy 

Soybean from Argentina is among the largest import streams of biodiesel feedstock for the EU, with 
9% of all biodiesel consumed in the EU based on Argentinian soybeans. Soy cultivation was 
introduced to Argentina around the 1970s, instigating a gradual but rapid switch from traditional cattle 
rearing to the farming of soy. The Argentine agricultural sector has always been export-focused and 
the increasing international demand for agricultural commodities has promoted a process of 
agricultural intensification254. Agricultural intensification has had multiple positive and negative effects 
on not only the economy and Argentina’s development, but also on the environment 255. 

Argentina is one of the biggest biodiesel exporters and the number one supplier of soybean oil. Last 
year, Argentine’s global biodiesel exports amounted to around 1 million tonnes worth $775 million, 
with the European Union as one of the biggest importers. Almost all biodiesel produced in Argentina 
is made from soybean oil. In February 2019, the European Commission and Argentina agreed to a 
duty-free quota based on 10% of the EU average annual consumption and a minimum import price 256. 
The soy oil industry in Argentina is currently running at 50 percent capacity, however in 2019 the EU 
quota was not expected to be fully filled due to a large EU biodiesel supply and the use of low-priced 
palm oil255.  

Currently, Argentine biodiesel exports have come to a complete halt due to a decreasing demand in 
Europe caused by the coronavirus pandemic. Export biodiesel plants in the country are currently 
inactive, leading to a soybean oil surplus in Argentina this year 257. 

There are no specific environmental sustainability criteria for biofuels in Argentina. However, as the 
country is a major exporter of biodiesel, the criteria and regulations of other markets are closely 
monitored for export compliance. The EU’s Renewable Energy Directive requires minimum GHG 
emissions savings level of between 50-60%, therefore certificates granted by for example the Round 
Table on Responsible Soy Association voluntary scheme accompany Argentine exports255, 258. 

251 WWF, 2020. Wildlife corridors help elephants move between habitats in Malaysia. https://www.worldwildlife.org/magazine/issues/summer-
2020/articles/wildlife-corridors-help-elephants-move-between-habitats-in-malaysia 
252 EleAid, http://www.eleaid.com/country-profiles/elephants-malaysia/. Source; Sukumar, 2006. A Brief Review of the Status, Distribution and Biology of Wild 
Asian Elephants Elephas maximus- International Zoo Yearbook. 
253 Fleiss et al., 2020. Conservation set-asides improve carbon storage and support associated plant diversity in certified sustainable oil palm plantations. 
Biological Conservation, 2020; 248 
254 Tomei and Upham, 2009. Argentinean soy-based biodiesel: An Introduction to production and impacts. Energy Policy, 37-10; 3890-3898. 
255 USDA, 2019. Biofuels Report 2019.  
256 Commission Implementing Decision (EU) 2019/245 of 11 February 2019 accepting undertaking offers following the imposition of definitive countervailing 
duties on imports of biodiesel originating in Argentina. C/2019/877 
257 Reuters, 2020. Argentina biodiesel exports fully halted due to pandemic. https://www.reuters.com/article/us-argentina-biodiesel-exclusive/exclusive-
argentina-biodiesel-exports-fully-halted-due-to-pandemic-chamber-head-idUSKBN22H1Z3 
258 Round Table on Responsible Soy Association, RTRS Standard for Responsible Soy Production V3.1, June 2017.  

 
 
 
                                                      
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This section describes the environmental impacts on soil, water, air and biodiversity from the 
production of soy oil for EU biofuel demand.  

Water quality 

The biggest impact on water quality resulting from soybean cultivation in Argentina comes from 
pesticide- and fertilizer use. These agrochemicals are used to efficiently manage farms of increasing 
size and to reduce labour costs. When sprayed on crops, a fraction of the applied pesticides may 
reach surface- and groundwater through drift, run-off or drainage. These chemicals are a source of 
nutrient pollution in rivers and lakes. Recent studies revealed the presence of pesticide residues in 
fish, surface waters, groundwater, sediments, soils and rainwater of the Pampa region in Argentina259. 
Glyphosate has been marketed as “practically non-toxic”, however more research is now discovering 
the potentially toxic and carcinogenic effects on ecosystems and human health265.   

Furthermore, unsustainable water use and contamination can strain the Guarani Aquifer. The Guarani 
Aquifer System is one of the largest underground natural reservoirs of freshwater worldwide, which is 
shared by Argentina, Brazil, Paraguay, and Uruguay260. The use of water in soybean cultivation, 
especially in more arid areas, is still an underdeveloped field of research.  

Soil quality 

Soy is a relatively low-yielding oilseed crop, producing on average around 500 litres of oil per hectare, 
therefore requiring vast areas of land. The soybean cropping area has increased from nothing in the 
1970s to 18 million hectares in 2018. More than half of Argentina is currently under agricultural 
production261. Soybean plantations are mainly concentrated in the central provinces of Santa Fe, 
Buenos Aires, Entre Rios, and Córdoba. Most of the soy processing industry is located in the same 
central region, enabling easy access to the Paraná river254.  

Agricultural expansion has been the key driver of deforestation and habitat loss in Argentina. The 
Gran Chaco, the second largest forested area in Latin America after the Amazon, has declined by 
85% between 1969 and 1999 in Argentina254. Under the Renewable Energy Directive land use 
change and deforestation, to produce soybean oil for biofuel, is prevented by voluntary schemes. 
However, the expansion of soybean crops does contribute indirectly to land use change by pushing 
the agricultural frontier and forcing other crops and cattle ranching to less suitable land262. To protect 
native forests in Argentine, the Forest Law came into place in 2017. Since the enactment of the law, 
the amount of forest loss has slowed by half, from 300.000 hectares a year to 150.000. However, 2.6 
million hectares have still been deforested, of which 840,000 hectares were supposedly protected263. 
This extension of agriculture into forested areas will affect biodiversity, soil fertility, and leads to 
carbon losses from both soil and biomass. Research shows that soybean cultivation in areas with 
fragile soils carry a greater risk of soil erosion and deterioration, where cultivation in arid areas can 
cause desertification, and cultivation in low lying areas carry an increased risk of flooding254. 

In recent years, high rates of soil erosion have been reduced by the adoption of new technologies 
such as no-till cropping. No-till cropping is an agricultural technique for growing crops without 
disturbing the soil through tillage. Conventional tillage increases the amount of soil erosion, especially 
in sandy and dry soils on sloping terrain255. Other possible benefits from no-till farming include an 
increase in water infiltration in the soil, retention of organic matter, and nutrient cycling. These 

259 .D'Andrea et al., 2020. Sensitivity analysis of the Pesticide in Water Calculator model for applications in the Pampa region of Argentina. Science of The 
Total Environment, 698 
260 Sindico et al., 2018. The Guarani Aquifer System: From a Beacon of hope to a questionmark in the governance of transboundary aquifers. Journal of 
Hydrology: Regional Studies 20, 49-59 
261 FABLE, 2019. Pathways to Sustainable Land-Use and Food Systems. 2019 Report of the FABLE Consortium. International Institute for Applied Systems 
Analysis (IIASA) and Sustainable Development Solutions Network (SDSN). www.foodandlandusecoalition.org/fableconsortium 
262 Hoff et al., 2019. International Spillovers in SDG Implementation: The Case of Soy from Argentina. SEI Policy Brief. Stockholm Environment Institute. 
https://www.sei.org/publications/spillovers-sdg-implementation-soy-argentina 
263 Diálogo Chino, 2019. New images show soy-linked deforestation in Argentina. https://dialogochino.net/en/agriculture/24399-new-images-show-soy-linked-
deforestation-in-argentina/ 

 
 
 
                                                      
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methods may increase the biodiversity and SOC in and on the soil. However, lands that have been 
classified as highly erodible are still in use for soybean production, therefore the amount of soil 
erosion is still not fully sustainable. Also, soil compaction is a potential impact as most large soybean 
farms mechanized their cultivation processes264.  

The expansion of agriculture and the use of no-till agriculture go hand-in-hand with the cropping of 
genetically modified (GM) soy, and an increased use of agrochemicals254. The GM soy used in 
Argentina is glyphosate-tolerant, and therefore only weeds will be affected by the herbicide255. 
However, weeds are becoming more resistant to glyphosate. Controlling these resistant weeds will 
require changes in management and increased use of additional herbicides 265. The widespread 
application of agrochemicals can lead to changes in soil properties. However, there is little information 
available about the ecosystem impacts of agrochemicals in Argentina.  

Air quality 

Soy used to be a high-risk crop for air quality due to the prevalence of burning of crop residues as a 
means of field preparation or as waste management, and possible pesticide drift-off. However, 
voluntary schemes under the RED mitigate these risks. The RTST standard for responsible soy 
prohibits the burning of crop residues, waste, or other burning as part of vegetation clearance on any 
part of the property. Burning is only allowed as a sanitary measure, for the generation of energy, the 
drying of crops, or when only small-calibre residual vegetation from land clearing remains258. The 
effect and magnitude of these burning practices on air quality is unknown.   

Biodiversity 

The expansion of soybean cultivation in Argentina can be a potential risk in terms of indirectly driving 
deforestation of important biodiversity hotspots. Vulnerable species in these biomes are at high risk of 
extinction, including almost 100 vertebrates on the Red List of the IUCN264, 262. In addition to the 
biodiversity risks associated with land use change, farm management can also play a role. The 
interconnections between biodiversity and other environmental aspects have been reviewed in the 
previous sections on water, soil, and air. 

Intensive farming does on the one hand prevent the indirect drive of deforestation, by producing a 
higher yield per unit area of land. However, intensive farming is a driving force behind biodiversity loss 
on a farm and field-level. Intensification can have an effect onthe whole food chain. Decreasing 
numbers and diversity of flora and insects can affect the abundance of small mammals and farmland 
birds, and lower numbers of insects which may reduce yield and quality in crops 266. Drivers of 
biodiversity loss are large monocultures of crops, reduced crop rotation, limited seed exchange 
between farms, drainage of soils, and increased use of pesticides. Agricultural production relies on 
good ecosystem functioning and biodiversity. Important processes are pollination by insects, 
biological pest control, maintenance of soil quality by soil organisms, and nutrient cycling by 
microorganisms. Also weeds play an important role in these processes, supporting a range of 
organisms. GM soy cropping systems have a very efficient removal of weeds, reducing the diversity of 
weeds and seeds significantly. However, it is important to develop farming systems that produce high 
yield with low environmental impact, drawing on techniques from both organic and conventional 
systems267. To prevent potential trade-off effects, such as biodiversity loss due to higher land 
demand. Organic farming has a large positive effect on biodiversity. In the last year, a steep increase 
in organic agriculture has been observed in Argentina. At the end of 2018, 3.6 million hectares of 

264 Wordwilfe.org, Sustainable Agriculture – Soy. WWF. 
265 Bøhn and Millstone, 2019. The Introduction of Thousands of Tonnes of Glyphosate in the food Chain—An Evaluation of Glyphosate Tolerant Soybeans. 
Foods 2019, 8(12), 669 
266 Schütte et al., 2017. Herbicide resistance and biodiversity: agronomic and environmental aspects of genetically modified herbicide-resistant plants. 
Environ Sci Eur 29, 5. 
267 Tuomisto et al., 2012. Does organic farming reduce environmental impacts? A meta-analysis of European research. Journal of Environmental 
Management 112. 

 
 
 
                                                      
Technical assistance in realisation of the 5th report on progress 
of renewable energy in the EU 

farmland were organically managed in Argentina 268. Some soy farms already produce organic oil, 
however it is not clear what percentage of soy oil for EU biofuels is produced on organically managed 
Argentinian farms. It should be noted that organic farms do showcase lower yields and greater yield 
variabilities compared to conventional farms269. It is unclear if this is also the case for organically 
produced soy in Argentina.  

268 IFOAM, 12 February 2020. Over 71.5 Million Hectares Of Farmland Are Organic! https://www.ifoam.bio/global-organic-area-continues-grow 
269 Smith et al., 2019. Organic Farming Provides Reliable Environmental Benefits but Increases Variability in Crop Yields: A Global Meta-Analysis. Frontiers 
in Sustainable Food Systems 3:82. 

 
 
 
 
                                                      
Technical assistance in realisation of the 5th report on progress 
of renewable energy in the EU 

Appendix D. Underlying numbers for graphs in Chapter 3 

The following table contains the detailed data for the aggregates of 'other Member States' in ktoe in 
2018. 

Country 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czechia 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
United Kingdom 
EU-28 

Figure 10: 
Primary production of solid 
biomass 

Figure 16: 
Primary production of 
biogas 

Figure 18: 
Gross electricity production from 
MSW  
(renewable fraction) 

4,601  
1,231  
1,524  
1,496  
23  
3,070  
1,774  
1,648  
8,852  
10,225  
11,702  
782  
2,132  
247  
7,066  
2,447  
1,249  
92  
0  
1,338  
6,147  
2,662  
3,443  
908  
549  
5,441  
9,231  
4,473  
94,353  

234  
228  
54  
74  
13  
604  
489  
14  
186  
877  
7,631  
113  
92  
50  
1,892  
87  
37  
22  
2  
326  
288  
82  
21  
149  
24  
265  
176  
2,809  
16,839  

29  
83  
0  
0  
0  
9  
74  
4  
57  
189  
530  
0  
14  
28  
204  
0  
4  
4  
0  
187  
7  
28  
0  
1  
0  
65  
142  
313  
1,973  

 
 
 
 
 
Technical assistance in realisation of the 5th report on progress 
of renewable energy in the EU 

Appendix E. Underlying numbers for graphs in Chapter 4 

The following table contains the detailed data for the aggregates for 'other Member States' and 
biodiesel and bioethanol combined in ktoe in 2018. 

Country 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czechia 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
United Kingdom 
EU-28 

Figure 19: 
Biodiesel 
consumption 

Figure 20: 
Bioethanol 
consumption 

Total 
consumption 
of biofuels 

Figure 21: 
Biodiesel 
production 

Figure 22: 
Bioethanol 
production 

Total 
consumption 
of biofuels 

441  
370  
135  
27  
9  
247  
173  
12  
281  
2,827  
2,062  
167  
142  
121  
1,220  
31  
70  
113  
10  
378  
740  
267  
207  
132  
67  
1,567  
1,477  
900  
14,194  

58  
113  
29  
0  
0  
61  
44  
5  
89  
585  
753  
0  
52  
25  
33  
8  
8  
10  
0  
177  
173  
6  
90  
18  
7  
155  
120  
387  
3,006  

499  
483  
164  
27  
9  
309  
217  
17  
370  
3,412  
2,815  
167  
195  
146  
1,252  
40  
78  
123  
10  
556  
912  
273  
297  
150  
74  
1,722  
1,597  
1,287  
17,200  

206  
227  
114  
0  
0  
172  
0  
0  
281  
2,435  
2,960  
151  
144  
27  
664  
83  
136  
0  
0  
1,625  
784  
321  
165  
105  
0  
1,561  
259  
423  
12,845  

127  
197  
11  
0  
0  
48  
0  
0  
0  
672  
400  
0  
302  
0  
14  
5  
11  
0  
0  
0  
120  
0  
23  
62  
0  
266  
105  
263  
2,628  

333  
424  
125  
0  
0  
220  
0  
0  
281  
3,107  
3,360  
151  
447  
27  
678  
88  
147  
0  
0  
1,625  
904  
321  
188  
166  
0  
1,828  
364  
685  
15,472  

 
 
 
 
 
Technical assistance in realisation of the 5th report on progress 
of renewable energy in the EU 

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