Biofuels on the Dutch
market
Update: data for 2013

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3.F24 – Biofuels on the Dutch market

Bibliographical data:

Biofuels on the Dutch market
Update: data for 2013

This report is prepared by:
Anouk van Grinsven, Bettina Kampman, Thijs Scholten
Delft, CE Delft, June 2015
Publication code: 15.3F24.43
Biofuels / Market / Feedstock / Production / Import / Export / Monitoring
VT: Dutch Market
Client:

ActionAid, Greenpeace Nederland
IUCN NL, Milieudefensie, Natuur & Milieu, Wereld Natuur Fonds

CE publications are available from www.cedelft.eu
Further information on this study can be obtained from the contact person, Bettina Kampman.
© copyright, CE Delft, Delft
CE Delft
Committed to the Environment
Through its independent research and consultancy work CE Delft is helping build a sustainable
world. In the fields of energy, transport and resources our expertise is leading-edge. With our
wealth of know-how on technologies, policies and economic issues we support government
agencies, NGOs and industries in pursuit of structural change. For 35 years now, the skills and
enthusiasm of CE Delft’s staff have been devoted to achieving this mission.

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3.F24 – Biofuels on the Dutch market

Contents

3

Summary

4

1

Introduction

7

1.1

Outline of this report

9

2

Biofuels brought on the market in 2013

10

2.1
2.2
2.3
2.4
2.5

Fuel suppliers included in the ranking
Type of feedstocks used and shift in feedstocks
Origin of the feedstocks
Ranking based on average GHG emission
Sensitivity analysis

10
10
14
16
20

3

Biofuel production in the Netherlands

21

3.1
3.2
3.3
3.4

Overall production, import and export
Feedstock used for the Dutch production of biofuels
Market scan of Dutch production facilities
The case of UCO

21
23
28
30

4

Conclusions and recommendations

34

4.1
4.2

Conclusions
Recommendations

34
36

References

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3.F24 – Biofuels on the Dutch market

Summary
Introduction
Under the Dutch biofuels obligation, fuel suppliers are required to include a
minimum share of biofuels in their overall sales of road transport fuels: 5.0% in
2013. They also have to submit an annual report detailing the biofuels they
sell on the Dutch market. The Dutch Emissions Authority (NEa) then publishes a
selection of the results. As there is a large variation in greenhouse gas (GHG)
emissions pf different biofuels, the actual GHG emission savings achieved by
the biofuels obligation then depend significantly on the biofuels mix that the
fuel suppliers choose to supply to meet the requirements of the obligation.
In earlier years, CE Delft analysed the NEa data for 2011 and 2012, and
presented a ranking of fuel suppliers based on the average greenhouse gas
(GHG) emissions of the biofuels that they had supplied to the Dutch market in
these years. To continue to monitor the developments, ActionAid,
Greenpeace, IUCN NL, Milieudefensie, Natuur & Milieu and Wereld Natuur
Fonds commissioned CE Delft to provide an update of the ranking based on the
NEa report of 2013 data.
In addition, these data were to be put in the broader context of the European
biofuels market, and the overall biofuels production in the Netherlands, based
on publically available information.
A (simplified) schematic of the fuel supply chain, provided in Figure 1,
illustrates the different points of analysis in this report: the ranking is based
on data reported at excise duty point level, whereas the additional analysis
looks at biofuels production, further upstream in this chain.
Figure 1

A schematic of the fuel supply chain

The new ranking of fuel suppliers
Figure 2 presents the update of the ranking of fuel suppliers and includes both
direct emissions and emissions related to indirect land use change (ILUC).

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3.F24 – Biofuels on the Dutch market

Figure 2

Ranking of fuel suppliers based on total GHG emissions of the seven biofuels mostly used in
2013
90

80

indirect emission
direct emissions

70

CO2 (g/MJ

60

50

40

30

20

10

0

*

Salland

Esso

Kuwait

Argos

Shell

BP

Gulf

Marees en Den Hartog
Kistemaker

TOTAL

The green dotted lines represent a 35 and 50% reduction of GHG emissions compared to the
fossil fuel reference (83.8 gCO2/MJ). The black lines indicate uncertainty in the data, due to
the reporting methodology of NEa (see text below).

This year the biofuels brought on the market by Salland have the lowest
average GHG emission factor, directly followed by Esso. The emission factor of
Salland (and Kuwait) is, however, uncertain due to the reporting methodology
of the NEa: only the top 7 feedstocks for biofuels are reported, the rest is
included in an ’other feedstock’ category 1. The position of Salland in this
graph is solely based on the feedstock that was specified (about 65% of their
sales), the black line indicates the uncertainty in the emission factor for their
total biofuels sales2. Esso moved from the highest average GHG intensity of the
ranking in 2011 to almost the lowest GHG intensity of the ranking today.
Kuwait, with the highest average GHG intensity in 2012, also seems to have
significantly improved as result of their shift from rapeseed and sugar beet to
less carbon intensive feedstocks, but their data are relatively uncertain.
Compared to last year, the average GHG intensity of the biofuels from
Den Hartog and TOTAL remain relatively high.

Overall improvement of GHG performance
Most fuel suppliers reduced the average GHG emission factor of their biofuels.
This is due to changes in feedstock used for the biofuels production: this has
been the first year with no biodiesel from food crops in the list of the seven
feedstocks mostly used, a shift that reduces both the direct and indirect
emissions. Some new waste and residues like wheat straw have appeared on
the top 7 list of feedstocks.

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June 2015

1

Note that the contributions bioCNG and renewable electricity are not included in these data,
only the biofuels blended into gasoline and diesel.

2

In the best case, the ‘other feedstock’ contains low-emission waste and residues and their
overall emission factor remains low, in the worst case, the ‘other feedstock’ is a vegetable oil
with high risk of ILUC emissions such as palm oil.

3.F24 – Biofuels on the Dutch market

Contrary to biodiesel, bioethanol production still relies heavily on agricultural
crops as feedstock. This can be explained by the status of the production
technology: converting used cooking oil and animal fat to biodiesel is a mature
technology, whereas the production capacity of bioethanol from waste and
residues is still very limited as the technology is still in the R&D phase.

Biofuel production in the Netherlands: mainly for export
Besides the fuel suppliers bringing biofuels on the Dutch market, the Dutch
biofuel sector also consists of biofuel producers. In 2013, about 1,375 kton of
biodiesel was produced in the Netherlands, and 414 kton of ethanol (compared
to a consumption of 220 kton and 194 kton, respectively). The producers are
not obliged to report on the mix of feedstocks they use for their production
process, so this market lacks transparency.
Although it is expected that the majority of biofuels produced in the
Netherlands meet the sustainability criteria of the RED3, these biofuels are
likely to have a poorer average GHG performance compared to the biofuels
brought on the Dutch market by the fuel suppliers: the biofuels mix in other
EU countries typically contains much higher shares of land-based feedstocks,
and most of the production capacity in the Netherlands is based on food crops.
However, this can not be quantified due to the limited data available.

Biofuels from waste and residues
The incentive of double counting in the biofuels obligation in the Netherlands
may create a number of risks related to fraud and price impacts on other
industries that use these feedstocks, as it drives up prices for both UCO and
UCO-based FAME. Nevertheless, UCO prices remain below prices for virgin oil,
and concrete cases of fraud have so far not been identified. Because the
Netherlands do not have sufficient waste and residues such as UCO to fulfil
demand, these feedstocks are also imported.

Key recommendations








3

6

June 2015

It is recommended to provide full disclosure of the feedstocks used and
country of origin for all biofuels supplied to the Dutch market by the fuel
suppliers, at company level. This will reduce the uncertainties in this
analysis and enable the assessment of the average GHG emission factors
(including ILUC) for all fuel suppliers.
To assess the actual GHG savings that the various fuel suppliers achieve
with the biofuels they blend, information on the volumes of biofuel
imported and consumed need to be provided, on company level.
The national legislation and definition of which biofuels are double
counted should be harmonised in the EU. This improves the effectiveness
of the policy, inter alia because it prevents trade and transport of waste
and residues between Member States.
It is recommended that this level of transparency and annual reporting is
rolled out throughout the EU, to maximise the positive effect of
transparency and enable European monitoring and reporting on this level.
It is furthermore recommended to also increase transparency of biofuel
production and trade, to get insight into whether the biofuels produced
and traded in the Netherlands meet sustainability criteria, and to enable
monitoring of the feedstocks used, the countries of origin and overall
GHG emission factors of the biofuels produced in the Netherlands.

Most biofuels export is to other EU countries where the RED requirements have also been
implemented. However, exact data are lacking.

3.F24 – Biofuels on the Dutch market

1 Introduction
In 2012 the Dutch NGO Natuur & Milieu, together with three European
environmental NGOs, commissioned the study ‘Biofuels on the Dutch market –
Ranking oil companies in the Netherlands’ (CE Delft, 2013). In this study
CE Delft analysed the biofuel data per supplier as published by the Dutch
Emissions Authority (NEa), resulting in a ranking of fuel suppliers based on the
average greenhouse gas (GHG) emissions of their biofuel blends in 2011
(NEa, 2012). In February 2014, CE Delft updated this ranking based on the data
over 2012 (CE Delft, 2014).
Mid December 2014, the NEa published the data over 2013 (NEa, 2014a).
Therefore, ActionAid, Greenpeace, IUCN NL, Milieudefensie, Natuur & Milieu
and Wereld Natuur Fonds requested an update of the ranking in order to assess
the developments in the biofuel mix and the related GHG impacts until 2013.
In addition, the NGOs requested an overview of the industry as a whole, i.e. of
biofuel production in the Netherlands. The biofuel industry in the Netherlands
not only supplies the fuel suppliers blending biofuels in the diesel and petrol
mix in the Netherlands, but also exports significant volumes.
The main aim of this report is therefore twofold:
 to provide an update of the previous ‘Biofuels on the Dutch market’
reports;
 to provide insight in the large difference between the type of biofuel
feedstocks consumed in the Netherlands and other European countries and
to put the role of the Dutch biofuel industry and its exporting role in
perspective.
As the biofuels market is very much policy driven, Box 1 contains a summary of
the main policy context, both on EU level and on the national policy level in
the Netherlands.

Box 1 – Summary of main policy context
RED and FQD
Since 2009, two European Directives, the Renewable Energy Directive (RED) and the Fuel
Quality Directive (FQD), affect renewable energy use in the transport sector. The RED sets a
10% target for the share of renewable energy in the transport sector for the year 2020.
The FQD obliges fuel suppliers to reduce the average GHG intensity of the fuels sold on the
market with 6% by 2020 compared to the baseline 2020 (EC, 2009a; EC, 2009b). The two
targets will be mostly fulfilled with the use of biofuels due to a lack of alternatives to ‘green’
the transport sector. These directives contain sustainability criteria for the biofuels, and there
has been quite some debate on implementation of indirect land use change, both are briefly
explained in the following.
Sustainability criteria and minimum GHG emission reductions
A number of environmental sustainability criteria are laid down for biofuels, both in the RED
and FQD. Neither Directive includes binding social criteria. There are sustainability criteria
related to the protection of areas with high carbon stocks and biodiversity, and the following
minimum GHG emission reduction criteria are defined:

2010: 35% reduction

from 2017 onwards: 50% reduction

from 2018 onwards: 60% reduction (only for new installations)

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3.F24 – Biofuels on the Dutch market

Indirect land use change (ILUC) and indirect emissions
The GHG emission reduction requirements of both Directives only cover the direct emissions,
not the indirect emissions as result of indirect land use change (ILUC). The consumption of
land based biofuels (biofuels from food and energy crops, such as sugar beet, rapeseed, corn
and maize), may cause indirect land use change effects: cultivating these commodities
requires land, so that an increasing demand of these biofuels will lead to expansion of the
global agricultural area. In case of direct land use change, this effect can be directly
attributed to specific biofuel batches, for example in case a palm oil plantation is started on
land that used to be forest or grass land the year before. However, these effects can also be
indirect, when the biofuel feedstock is produced on existing fields or from plantations that
have been in place for many years. The land conversion will then be somewhere else, perhaps
even in a different region, country or continent. Because of the high GHG emissions associated
with this indirect land use change different policy options were being studied and debated in
the past years, including a cap on land based biofuels and ILUC-factors to add as malus factor
to the direct emission factor.
On April 28, 2015, the European Parliament and the Council reached a final decision on this
issue, deciding, inter alia, to set a cap on biofuels from crops grown on agricultural land of 7%
(energy consumption in transport), with the option for Member States to set a lower cap, to
require fuel suppliers and the European Commission to report ILUC-related emissions, and to
require Member States to decide on national targets for advanced biofuels. This new
regulation would thus allow to carry out a motion that was adopted in the Dutch Parliament in
December 2014, to limit the share of biofuels from crops to 5% (Kamerstuk 32813, nr. 97).
4
Member States must enact this legislation by 2017 .
Land based biofuels versus biofuels from waste and residues
An alternative to the use of land based biofuels are biofuels produced from waste and
residues, like used cooking oil (UCO) and animal fat. Biofuels from waste and residues do not
cause indirect emissions and on average result in relatively high emission savings. However,
incentives for waste and residues might result in shifts of feedstock use which will also cause
ILUC and indirect emissions: for example, while UCO is increasingly being used for biofuels,
the use of UCO for soap, etc. might be replaced by less sustainable palm oil. The resulting
effect may then be similar to the indirect effect of using land based feedstock. Therefore, for
optimal use of waste and residues, these potential impacts as well as the principles of
cascading use should also be taken into account and monitored.
Double counting
To provide an incentive for the use of biofuels from waste and residues (rather than from food
crops) the RED includes a double counting provision for these biofuels, enabling these biofuels
to count double towards the 10% renewable energy for transport target. Besides providing an
incentive for biofuels from waste and residues, double counting also results in less absolute
volumes of biofuels and thus in less replacement of fossil fuels.
Biofuels obligation in the Netherlands: blending quota
The RED and FQD have been implemented by the introduction of a blending obligation for fuel
suppliers: they need to bring a certain share of biofuels on the Dutch market. In the table
below the annual targets and the increase of these targets over time are depicted.

Total

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

4%

4.25%

4.5%

5.0%

5.5%

6,25%

7%

7,75%

8,5%

9,25%

10%

obligation

Except from subtargets for the share in the petrol and diesel mix (in 2013 3.5% for both diesel
and petrol), fuel suppliers are free to choose the type of biofuel and the feedstocks used as
long as the sustainability criteria of the RED and FQD are met. Due to this free choice there

4

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http://www.europarl.europa.eu/news/en/news-room/content/20150424IPR45730/
html/Parliament-supports-shift-towards-advanced-biofuels

3.F24 – Biofuels on the Dutch market

can be significant differences between fuels suppliers in the type of biofuels they use, and the
average GHG performance of their biofuels.
As explained above, the ILUC proposal has only very recently been decided on, and will be
implemented in the Dutch policy in the coming years.

1.1

Outline of this report
The first part of this report, Chapter 2, contains the update of the ranking.
It starts with an overview of the fuel suppliers included in the ranking and an
overview of the feedstocks used by these fuel suppliers, and their origin.
Based on these overviews the update of the ranking is presented in Section
2.4. To assess the potential impacts of uncertainties in the data, this first part
ends with a sensitivity analysis in Section 2.5.
The second part of this report, Chapter 3, focuses on the biofuel production
developments in the Netherlands. Overall production, import and export is
described in Section 3.1. Section 3.2 zooms in on the feedstock used for
biofuel production, which can then be compared with the feedstock used for
the biofuels consumed in the Netherlands. In Section 3.3, an overview of Dutch
biofuel production facilities is presented. Section 3.4 then describes the case
of used cooking oil (UCO), which is an important feedstock from waste and
residues on the Dutch market, in more detail.
The report ends with a chapter on conclusions and recommendations.

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3.F24 – Biofuels on the Dutch market

2 Biofuels brought on the market
in 2013

2.1

Fuel suppliers included in the ranking
As described in Box 1, fuel suppliers are obliged to blend a certain share of
biofuels with the fuels that they bring on the Dutch market. In order to prove
compliance with the legislation, each fuel supplier has to annually submit a
report to the Dutch government. The ranking in this study is based on the
overview of the information submitted by the fuel suppliers, as published by
the Dutch Emissions Authority (NEa, 2014a).
Due to changing market activities, the group of fuel suppliers which physically
blended biofuels for the Dutch market in 2013 slightly differs from the group
of 2012:
 North Sea Group Netherlands B.V. changed its name to Argos Supply
Trading B.V.
 Smeets & Geelen B.V. are now included in the ranking as Lukoil
Netherlands B.V.
 Catom Distribution B.V. has not been active in blending biofuels for the
Dutch market in 2013 and therefore is no longer included.
 Marees en Kistemaker B.V. is new on the list as result of its activities on
the blending market in 2013.
 Allesco and Lukoil both reported 100% of their biofuels in the category
‘other feedstocks’, which means their biofuel mixes do not include any of
the seven feedstocks mostly used. For this reason, both companies could
not be included in this year’s ranking.
The relevant fuels suppliers of 2013 are thus:
 Salland;
 Esso;
 Kuwait;
 Argos;
 Shell;
 BP;
 Gulf;
 Marees en Kistemaker;
 Den Hartog;
 TOTAL.

2.2

Type of feedstocks used and shift in feedstocks
The average GHG emission factor of the biofuels that each fuel supplier brings
on the market largely depends on the type of feedstocks used for the
production of biofuels and their relative shares in the mix. Like last year, the
estimate of this average GHG emission factor and the resulting ranking could
only be based on the seven biofuel feedstocks used mostly, due to the
limitations of the reporting methodology of the NEa. These seven feedstocks
are: animal fat, UCO, corn, sugarcane, wheat, sugar beet and wheat straw.
This year rapeseed and tallow are no longer part of the seven feedstocks
mostly used. This implies that 2013 has been the first year without biodiesel
from food crops in the top seven of the feedstocks mostly used.

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3.F24 – Biofuels on the Dutch market

The disappearance of tallow is the consequence of changes in the categories
used by NEa: ‘other animal fat’ and ‘tallow’ are merged into ‘animal fat’.
The use of sugarcane and wheat straw has increased to such an extent that
these feedstocks are now part of the top 7. An overview of the development of
the feedstock categories used since this type of reporting was started is
provided in Table 1.
Note that the NEa report only includes shares of different types of feedstock in
the overall biofuels sales of a fuel supplier, absolute volumes are lacking.
Therefore, only emission factors can be provided, not the actual emission
savings that each fuel supplier achieved due to the biofuels blended.
Table 1

Seven feedstocks mostly used in 2011-2013
2011

2012

2013

Animal fat

x

x

x

Glycerine

x

Rapeseed

x

x

Corn

x

x

Tallow

x

x

Wheat

x

x

x

UCO

x

x

x

x

x

Sugar beet
Wheat straw

x

Sugar cane
Other feedstocks

x

x
Palm oil, soy,
sugarcane, sugar beet

Other animal fat,
glycerine, palm oil,
sugar cane, wheat
straw

Glycerine, municipal
waste, waste from
starch production,
palm oil, rapeseed,
fatty acids, soy and
triticale

In Figure 3, the feedstock use per fuel supplier is depicted. It clearly shows
the large variation in feedstock use: while some fuel suppliers have fulfilled
their obligation with biofuels from waste and residues, other fuel suppliers
have solely used food crops. This is to a large extent related to the type of
biofuel: production of biodiesel from waste and residues such as used cooking
oil is technologically mature, whereas ethanol production from waste and
residues is still in the R&D phase, and production capacities are still very
limited5.
The figure shows the actual shares of the blended biofuels volumes, without
taking into account double counting.

5

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June 2015

Note that biodiesel can be blended with diesel, ethanol with petrol.

3.F24 – Biofuels on the Dutch market

Figure 3

Overview of feedstocks used per fuel supplier based on NEa, 2014a

100%

90%

80%

70%
other feedstocks

60%

UCO
animal fat

50%

wheat straw
sugar beet
sugar cane

40%

corn
wheat

30%

20%

10%

0%
Salland

Esso

Kuwait

Argos

Shell

BP

Gulf

Marees en
Kistemaker

Den Hartog

TOTAL

To put these data into context, the absolute volumes of the various biofuelsfeedstock combinations consumed in the Netherlands in 2013 are given in
Figure 4 (in TJ, source: NEa, 2014b). This graph clearly shows the large market
share of FAME from waste and residues (FAME double counting), followed by
ethanol from food crops (ethanol single counting) and FAME from food crops.
Biogas, not included in the ranking as the company data in (NEA, 2014a) are
limited to diesel and gasoline biofuels only, represent about 3% of total
biofuels consumption.

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3.F24 – Biofuels on the Dutch market

Figure 4

Overview of feedstocks used per type of biofuel in TJ, based on (NEa, 2014b)

14000

12000

unknown
UCO

10000

triticale

wheat straw
animal fat
8000

sugarcane

sugarbeet
TJ

municipal waste
soy
6000

oil palm
corn
rapeseed

fatty acids
4000

glycerine
animal fat (other)

waste from starch production
2000

0

biogas
double

ETBE single

ethanol
single

ethanol
double

FAME single

FAME
double

HVO single HVO double

MTBE
double

methanol
double

As indicated before the GHG performance of the biofuels brought on the
market are mainly determined by the feedstock used. Table 2 lists the seven
feedstock types including their direct and indirect GHG emission factors as
used in the calculations of the ranking. The indirect GHG emission factors are
based on the ILUC-factors as proposed in the ILUC-proposal of the European
Commission of October 2012.
Table 2

GHG emission factors for the direct and indirect emissions per feedstock
Group

Feedstocks

Direct GHG
emissions
(gCO2eq./MJ)

Indirect GHG
emissions
(gCO2eq./MJ)

Bioethanol from cereals
and other starch rich
crops (food crops)

Corn

38.5

12

Wheat

41.1

Bioethanol from sugars
(food crops)

Sugar beet

34.1

Sugar cane

25.4

Biodiesel from waste
and residues

Animal fat

10.7

UCO

10.7

Wheat straw

11.4

Source: EC, 2012a (ILUC proposal).

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3.F24 – Biofuels on the Dutch market

13
0

2.3

Origin of the feedstocks
Overall, waste and residues (UCO, animal fats) are the main feedstock for the
biofuels sold in the Netherlands in 2013 (about 51%). Less than one fifth of
these feedstocks are produced in the Netherlands: 18.7% of UCO, 19.7% of the
tallow and none of the other animal fats. The remaining share of tallow and
the total share of other animal fats are imported mainly from countries in
Western-Europe (Germany and the United Kingdom). Other feedstocks strongly
rely on imports from outside the EU: sugar cane is imported from South
America, a substantial share of the corn from North America, the origin of the
imported UCO is highly international dispersed.
The origin of the feedstocks per fuel supplier are shown in Figure 5.
Salland stands out in these figures, as it is the only fuel supplier with
50% of its feedstock originating from the Netherlands.

Figure 5

Origin of feedstocks per fuel supplier
100%
90%
80%

70%
Other countries
60%
50%
40%

South Korea
United States
Brazil
United Kingdom
Ukraine

30%

Germany
France

20%
10%

Belgium
the Netherlands

0%

Source: NEa, 2014a.

The origin of the feedstocks for the last three years is shown in Figure 6. In the
period 2011-2013 the use of feedstocks from the Netherlands was stable at
about 20%. The import from Western Europe and Eastern Europe together
increased from about 35 to 50%, while the (relative) import from North
America decreased from about 45% in 2011 to not more than 5% in 2013.
This decrease can partly be attributed to the substantially lower import of
corn and animal fat from the USA during this period, caused by price and
import tariff fluctuations.

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June 2015

3.F24 – Biofuels on the Dutch market

If we take a closer look at the origin of waste and residues, the import from
animal fat from Germany increased in 2013. This can be explained by the fact
that Germany itself does not allow animal fat to be double counted.
Exporting it to countries where double counting is allowed then becomes an
attractive option (ePure, 2013). While UCO mainly came from the Netherlands
in 2011 (67% of all UCO), the origin of UCO became more dispersed in 2013,
where only 19% still came from the Netherlands. Note that these shares are
relative: in absolute terms the growth in demand for UCO has probably been
fulfilled with import from abroad, while the absolute volumes in the
Netherlands probably kept stable. In Figure 6 the origin per feedstock type in
2013 is depicted6.
Figure 6

Origin of the seven feedstocks mostly used in the period 2011-2013

100%
90%

unknwon

80%

other

70%

Africa
Australia

60%

Asia (other)

50%

Southeast Asia

40%

South America

30%

North America
Eastern Europe

20%

Western Europe

10%

Netherlands

0%

2011

2012

2013

Source: NEa, 2014a.

6

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June 2015

Note that in these graphs, the category ‘other’ is a category used by NEa for 26 countries
with an overall contribution of <1%. These countries are: Argentina, Bulgaria, China,
Costa Rica, Denmark, Egypt, Greece, Hong Kong, India, Iran, Lithuania, Luxembourg,
Morocco, Portugal, Saudi-Arabia, Serbia, Slovenia, Slovakia, Taiwan, Trinidad & Tobago,
Czech Republic, Tunisia, Turkey, United Arab Emirates, Sweden and South Africa.

3.F24 – Biofuels on the Dutch market

Figure 7

Origin of feedstocks used for biofuels brought on the Dutch market in 2013

100%
90%
80%
70%
60%

other

50%

Australia

Asia (other)
40%

Southeast Asia
South America

30%

North America
20%

Eastern Europe
Western Europe

10%

Netherlands
0%

Source: NEa, 2014a.

2.4

Ranking based on average GHG emission
Combining the data on the relative shares of feedstocks per fuel supplier with
the direct and indirect emission factors as listed in Table 2, the average
biofuel emission factor of each fuel supplier can be calculated. The results of
these calculations were then used to rank the fuel suppliers.
Figure 8 presents the new ranking of fuel suppliers, based on the biofuels they
supplied to the Dutch transport fuel market in 2013 as reported in (NEa,
2014a).

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3.F24 – Biofuels on the Dutch market

Figure 8

Ranking of fuel suppliers based on total GHG emissions of the seven biofuels mostly used in
2013
90

80

indirect emission
direct emissions

70

CO2 (g/MJ

60

50

40

30

20

10

0

*

Salland

Esso

Kuwait

Argos

Shell

BP

Gulf

Marees en Den Hartog
Kistemaker

TOTAL

The dotted green lines represent a 35 and 50% reduction of GHG emissions compared to the
fossil fuel reference (83.8 gCO2/MJ). From 2010 onwards, a minimum of 35% savings is
required, from 2017 onwards, this increases to 50% (RED requirements).

The ranking of 2013 differs from the ranking of 2012 in terms of fuel suppliers
included, the order of the ranking and the height of the average emissions
factors.

Order of the ranking
This year, like in 2011, the biofuels brought on the market by Salland
have the lowest average GHG emission factor, directly followed by Esso.
Both companies have hardly any indirect emissions. Note that Salland has a
relatively high share of ‘other feedstocks’ (35.4%), which could not be taken
into account in this ranking as the CO2 emissions of this category are
unknown7. Depending on the GHG performance of these ‘other feedstocks’ the
ranking could have led to a different outcome. Esso does not have any
feedstocks in the category ‘other feedstocks’: their biofuels were only made
from UCO (96.1%) and sugarcane (3.9%). Due to changes in feedstock use in the
past few years, Esso moved from the highest average GHG intensity of the
ranking (in 2011) to having almost the lowest GHG intensity of the ranking
today.
Kuwait, having the highest average GHG intensity of the ranking in 2012, also
significantly improved as result of their shift from rapeseed and sugar beet to
less carbon intensive feedstocks.
Compared to last year, Den Hartog and TOTAL remain to have the highest
average GHG intensities of the ranking. The positions of Shell and Argos
somewhat worsened in the ranking, mainly as result of better performance of
other companies.

7

17

June 2015

Note that Salland is a relatively small fuel supplier, and this share of their feedstock is likely
to be very small compared to the overall biofuels sales in the Netherlands.

3.F24 – Biofuels on the Dutch market

All companies managed to realise an average 50% reduction in direct emissions
compared to the fossil fuel reference as a result of feedstock shifts. When also
taking into account indirect emissions, only the three fuel suppliers with the
highest average GHG intensity (Marees en Kistemaker, Den Hartog and TOTAL)
exceed the 50% reduction limit: their emission reduction is then reduced to
around 45%. They use feedstock that have a high risk of causing indirect land
use change GHG emissions.

Uncertainty as result of the category ‘other feedstocks’
As in previous versions of this ranking, a sensitivity analysis was performed to
estimate what the impact could be if the share of other feedstocks would
consist of the best or worst performing biofuel. The results are indicated in
Figure 8, where the range between the worst and best case is visualised by
black error bars. The ends of these represent the best and worst case and the
length of the error bars is determined by the share of ‘other feedstocks’.
See Section 2.5 for more detail on methodology used for the sensitivity
analysis.
As can be seen in Figure 8 the positions of Salland and Kuwait are highly
uncertain, because of their shares of ‘other feedstocks’. In case these shares
will be palm oil, they both will end as the fuel suppliers with the highest
average GHG intensity of the ranking, as biodiesel from palm oil has a
relatively high average emission factor. With respect to the other suppliers,
the impact of the worst case only makes them shift one position. It could be
questioned, however, to what extent the worst case would be realistic,
because most of the feedstocks in the category ‘other feedstocks’ consist of
waste and residues. If the share of ‘other feedstocks’ from all fuel suppliers is
assumed to be waste or residues, with emission factors close to that of animal
fat and UCO, the ranking remains the same.

Box 2 - The impact of double counting biofuels on the overall fuel mix and GHG emissions
It is important to realise that the data used for the ranking in this report only looks at the
biofuels component in the fuel mix. In that respect, it should also be noted that a higher share
of biofuels from waste and residues will actually reduce the biofuels content in the fuels,
compared to meeting the blending obligation with single counting biofuels.
Due to this double counting, the impact of using higher shares of biofuels from waste and
residues on overall GHG emissions is not straightforward: one the one hand it will result in the
use of biofuels with relatively high GHG emission savings and low risk of indirect land use
change, but on the other hand, it also reduces the absolute volume of biofuels sold and thus
increases the share of fossil fuels in total transport fuels sales.
This effect can be illustrated with the following (hypothetical) example, where the GHG
savings of using double counting biofuels are compared with singe counting biofuels.
Assuming that:

fossil fuels have an average GHG emission factor of 85 g CO2 per MJ (or ktoe) of fuel;

the double counting biofuels have an average emission factor of 11 g CO2/MJ, achieving
88% GHG savings compared to fossil fuels;

the single counting biofuels are on average 60 g CO2/MJ, and thus achieve about 33%
savings (incl. ILUC emissions).
If the 10% is then met with the single counting biofuels, the average GHG intensity of the
transport fuels would be 82.5 g CO2/MJ, a 2.9% saving of overall emissions.
If it is met with double counting biofuels, 5% of these biofuels would be sufficient to meet the
transport target. The average GHG intensity of the transport fuel would then be 81.3 CO2/MJ,
a 4.4% saving.
The net effect depends strongly on the actual emission factors of the various fuels.

18

June 2015

3.F24 – Biofuels on the Dutch market

Relation to the type of feedstock
The fuel suppliers with the highest average GHG intensity in the ranking did
not blend any biofuels from waste and residues, only bioethanol from food
crops, while the suppliers with the lowest average GHG intensity to a large
extent rely on biodiesel produced from UCO and animal fat. As explained
above, this is mainly due to technology: ethanol production from waste and
residues is still in R&D phase and production capacity is limited (and costs are
high), whereas biodiesel production from waste oils and fats is mature and
operational on a large scale. As the biofuels obligation for 2013 included
subtargets of 3.5% for both petrol and diesel, a certain minimum level of
ethanol supply in the Dutch fuel mix was required.
Again note that the share of ‘other feedstocks’ creates an uncertainty in this
ranking. Especially the position of Salland and Kuwait is uncertain due to their
high share of ‘other feedstocks’.

Difference in average GHG intensity compared to earlier years
As can be seen in Figure 9, almost all companies that have been part of all
three rankings of the past years seem to have decreased the GHG intensity of
their biofuels between 2012 and 2013. In other words: all companies, except
Argos, have improved the GHG performance of their biofuels over the last
year. Argos already had relatively low GHG intensity in 2011, their
performance improved further in 2012 and then remained the same in 2013.
Figure 9

Developments in the average GHG emission factors of the fuel suppliers included in all three
years (including direct and indirect emissions) (in gCO2/MJ)
90
80

70
60
50

2011
2012

40

2013

30
20
10
0
Salland

*

Esso

Kuwait

Argos

Shell

BP

Gulf

Den Hartog

TOTAL

The green dotted lines represent the minimum GHG requirements of the RED, the blue line the
fossil fuel GHG emission factor – direct emissions only. In order to count towards the target
biofuels should at least reduce 35% GHG emissions. From 1 January 2017 biofuels this minimum
reduction will be 50% (based on NEa, 2014a).

Between 2011 and 2013 some fuel suppliers have reached higher reductions
(Esso) compared to other fuel suppliers (TOTAL, Den Hartog, Gulf, etc.)

19

June 2015

3.F24 – Biofuels on the Dutch market

In general the fuel suppliers with the lowest average GHG intensity have
managed to realise higher reductions compared to 2011.

2.5

Sensitivity analysis
2013 is the first year without a feedstock category ‘unknown’, which implies
all data gaps were resolved (in 2011, 4.6% of feedstocks were ‘unknown).
The category ‘other feedstocks’ includes the feedstocks that have only been
used in small amounts. This years these feedstocks include waste from starch
production, glycerine, industrial acids, rapeseed, oilpalm, soy, municipal
waste and triticale. Although the shares of these feedstocks are known, the
reporting requirements as laid down in Dutch legislation prescribes that the
feedstocks not belonging to one of the seven feedstocks mostly used are
reported as ‘other feedstocks’.
In 2013 the category ‘other feedstocks’ contained 7.2% of all feedstocks,
which is higher compared to 2012 (5.4%) and 2011 (2.0%). A reason for this
could be diversification resulting in more types of different feedstocks and
therefore less coverage by the seven feedstocks mostly used.
There are five fuel suppliers with a share of ‘other feedstocks’. Their shares
are presented in Table 3. Fuel suppliers not listed here do not have a share of
‘other feedstocks’.

Table 3

Share of ‘other feedstocks’ per fuel supplier
Share of ‘other feedstocks’
Kuwait

42.8%

Salland

35.4%

BP

6.5%

Argos

3.0%

Shell

1.5%

Looking at the feedstocks in the category ‘other feedstocks’ we use the
following values for the best and worst case for the sensitivity analysis:
Table 4

Emission factors assumed for best case and worst case calculations
Feedstock assumed

20

June 2015

Worst case

Palm oil biodiesel

Best case

Waste vegetable oil/
animal fat biodiesel

3.F24 – Biofuels on the Dutch market

Direct GHG emission
factor used
(gCO2/MJ)

Indirect GHG emission
factor used
(gCO2eq./MJ)

57

55

10.7

0

3 Biofuel production in the
Netherlands

Where the previous chapter assessed biofuels sales on the Dutch fuels market,
this chapter looks at the broader picture of biofuels production in the
Netherlands.
This chapter starts with a description of overall biofuels production, import
and export, in Section 3.1. Section 3.2 will zoom in on the feedstock used for
biofuel production, and compares this with the feedstock used for the biofuels
brought on the market, as shown in the previous section. In Section 3.3, an
overview of Dutch biofuel production facilities is presented and finally,
Section 3.4 includes a case description of used cooking oil (UCO), as important
feedstock from waste and residues on the Dutch market.

Data availability
When assessing the biofuels production sector, it has to be noted that much
less data are publically available, compared to what is available on biofuels
supply to consumers. There are several reasons why the data on biofuel
production is limited. First of all, there is no obligation for biofuels producers
to report on the origin and type of feedstock they use to the authorities, as is
the case for the fuel supplier when supplying in the Netherlands. Biofuel
producers do not publish detailed information on feedstock use voluntarily,
these data are typically confidential. Secondly, trade statistics on the various
types of feedstock for biofuels do not distinguish between end use.
For example, import data on palm oil do not provide information on which part
goes to the food sector, and which is used as feedstock for biofuels production
plants. Nevertheless, the Dutch Central Bureau of Statistics (CBS) gathers data
and reports on the overall production capacity, production volume and import
volume in the Netherlands, and some additional relevant data on this sector
can be found in public literature.

3.1

Overall production, import and export
According to Ecofys (2011) the Netherlands is the country with the largest
biofuel distribution sector in Europe. Several reasons can be identified to
explain the significant role of the Netherlands in biofuel trade:
 the hub function of the ports of Rotterdam and Amsterdam and the
(transport) connection with biofuel plants along the Rhine river;
 the large fossil fuel refining capacities in these port areas;
 the long-established oilseed handling and crushing sector (e.g. ADM,
Bunge, Cargill) which have installed biodiesel facilities next to their
vegetable oil mills.
Section 2.3 showed that only about 20% of the feedstock for the Dutch biofuels
originates from the Netherlands. Likewise, it can be said that only a small part
of the biofuels produced in the Netherlands is actually used in the
Netherlands. As depicted in Table 5 the production volume of bioethanol is
around twice as high as actual consumption. For biodiesel the production
volume is seven times higher compared to the consumption of biodiesel in the
Netherlands. This clearly confirms the role of the Netherlands as significant
market player in biodiesel trade.

21

June 2015

3.F24 – Biofuels on the Dutch market

In Table 5 the differences between production volume and production capacity
reflect the current overcapacity in the European biofuels market.
For bioethanol the overcapacity is limited, but only around 70% of the
biodiesel production capacity was in use in 2013. There are several reasons for
this overcapacity: first of all, most production capacity has been installed at
the time the market expectations were estimated to be far more positive than
the market demand turned out in practice. This lower demand for biofuels has
been the result of increasing concerns on the sustainability of biofuels,
especially on biofuels from land based biofuels (leading to the recent decision
on ILUC, as briefly explained in the introduction of this report) and, to some
extent, of the economic crisis. According to (Ecofys, 2013), which assessed the
sustainability of biofuels for the European Commission, the capacity in use as
share of total installed capacity has dropped from 64% in 2007 to only 42% in
2010. Since then, this has not improved: in 2013, only 43% of the EU’s
biodiesel production capacity and 44% of bioethanol capacity was actually used
(Eurostat data). A final decision on the ILUC proposal was been reached in the
European Parliament on 28 April 20158 Nevertheless, the development of
biofuels production and demand remains uncertain: it will depend on how the
EU Member States will implement the ILUC decision in national policies, and
on the post-2020 biofuels ambitions and policies of both the EU and its
Member States.
Table 5 also shows that the Dutch export and production volume of biodiesel
grew by a small amount between 2012 and 2013, while the consumption and
the production capacity in the Netherlands decreased. For bioethanol this
comparison cannot be made because the figures of 2012 were not available.
Table 5

Import, export and production of biofuels in the Netherlands (in kton)
Units: kton

Bioethanol, etc.

Biodiesel

2012

2013

2012

2013

Production capacity

Confidential

503

2,051

2,014

Production volume

Confidential

414

1,177

1,375

Net import pure biofuels

Confidential

-215

-849

-989

Net import blended biofuels
Net export pure biofuels

54

-9

-35

-54

Confidential

215

849

989

Net export blended biofuels

-54

9

35

54

Consumption pure biofuels

Nihil

Nihil

Unknown

Unknown

Consumption blended
biofuels

193

194

238

220

Source:

CBS (2014) Table ‘Biobrandstoffen voor het wegverkeer; aanbod, verbruik en
bijmenging’.

Note that the shares of bioethanol and biodiesel produced in the Netherlands
are generally in line with the European consumption data: in the Netherlands,
biodiesel production volumes were 3.3 times as high as bioethanol production,
where biodiesel consumption is the EU is 3.8 times as high as bioethanol
consumption.

8

22

June 2015

See http://www.europarl.europa.eu/news/en/news-room/content/20150424IPR45730/
html/Parliament-supports-shift-towards-advanced-biofuels, the final text of the decision will
be published on this website.

3.F24 – Biofuels on the Dutch market

3.2

Feedstock used for the Dutch production of biofuels
Differences between Member States
Biofuels that are exported to and used in other EU Member States also have to
comply with the sustainability criteria defined in the Renewable Energy
Directive. However, as the previous chapter showed that there is a large
variation in the GHG performance of RED compliant biofuels. Member States
have implemented the RED differently, mainly resulting in different (or no)
incentives for double counting biofuels, leading to different preferred
feedstocks being used in the various Member States.
The different incentives and policies are also the reason that in 2012, only four
Member States, namely the Netherlands, Italy, Germany and the UK, are
responsible for 70% of the biofuels from waste and residues consumed in the
EU, as shown in Figure 10 (based on final energy consumption, i.e. without
double counting). Taking into account that the fuel market in the Netherlands
is relatively small9, this implies that the other Member States rely to a much
larger extent on the consumption of single counting, land based biofuels.
The overall use of biofuels from waste and residues was still limited to 1.4% of
all EU compliant biofuels in 2010. In that specific year biodiesel was mainly
been produced from rapeseed (56%), soybean (13%) and palm oil (9%), while
wheat (30%), maize (23%) and sugar beet (30%) were the main feedstocks for
the production of ethanol (Ecofys, 2013). Since only very few EU countries,
including the Netherlands had double counting implemented in 2010,
the waste and residues were partly sourced from (neighbouring) countries
without double counting.
Since 2010, an increasing number of Member States has implemented the
doubling counting incentive in their policies, and the consumption of double
counting biofuels increased significantly, as shown in Figure 10. In 2012, these
1,900 ktoe double counting biofuels comprised almost 15% of overall EU
biofuels consumption. The 9 countries in the blue box represent the Member
States with substantial markets in 2012.
These data suggest that the biofuels produced in the Netherlands for export
will be based much more on land-based feedstock than those produced from
the Dutch market. However, as these data do not distinguish between origin of
the biofuel or feedstock, it is not known to what extent these biofuel volumes
were produced in the Netherlands.

9

23

June 2015

The Dutch biofuels consumption only accounts for about 2.5% of the EU biofuels consumption,
whilst Germany and Italy, for example, have a share of 20 and 10% respectively (Eurostat
data).

3.F24 – Biofuels on the Dutch market

Figure 10

Double counting biofuels in EU Member States

Source: Pelkmans et al.,2014.

Biofuels exported to outside the EU will be subject to the national legislation
of those specific countries, but this was not further analysed within the scope
of this project. Similar to the EU, the incentives provided in these countries
determine the type of feedstocks used in these areas.

Overall import of feedstocks
The relatively high share of biofuels from food and energy crops in Dutch
biofuel production in the Netherlands is confirmed by the data in Figure 11 and
Figure 12 (source: NL Agency, 2014), which provide a qualitative overview of
the import and export of biofuels and their feedstocks, as published by the
NL Agency for both biodiesel and bioethanol in 2013.

Biodiesel
Although the quantities can not directly be related to the different flows, the
figures show that biodiesel was mainly produced from palm oil, and most of
this biodiesel was exported. This is in line with the results of the ranking
where palm oil does not belong to the seven feedstocks mostly used (in 2013).
While the use of single counting biofuels by fuel suppliers operating in the
Dutch market has decreased in the last few years, according to (Netherlands
Enterprise Agency, 2014) the import of palm oil increased sharply from 2011 to
2012 as result of the growth of the palm-based biofuel production. This palm
oil mainly originated from Indonesia and Malaysia. The palm oil processed for
energy purposes in 2012 was about 10 times higher compared to the processed
palm oil in 2011 (NL Agency, 2014).
As Figure 11 shows, industry that uses vegetable oils strongly depend on import
of feedstocks: the raw material production in the Netherlands itself only
consists of some small flows of waste and residues (0.29 MT).
These data confirm what was seen in the previous paragraph: biodiesel
production in the Netherlands does not only heavily rely on import, but also
far more biofuels (a total of 1.58 MT) are exported than consumed in the
Netherlands itself (0.26 MT), which only equals 14% of all biofuels produced.

24

June 2015

3.F24 – Biofuels on the Dutch market

This dominating export is only valid for biodiesel: other applications of
imported vegetable oils are more for consumption within the Netherlands.

Bioethanol
According to Figure 12, the production of bioethanol does not rely on import
and export to the extent biodiesel production does: bioethanol production is
also based on national raw material production of wheat and maize. The green
maize production in the Netherlands (3.78 MT) is even slightly higher than the
amount of imported corn (3.43 MT). Because soybean is mainly a source of
proteins rather than an oil crop, this flow, mainly supplied by Brazil and the
US, is mainly used for animal feeds in the Netherlands, rather than for biofuel
production.
Around 0.48 MT of bioethanol is exported to other countries compared to
0.18 MT designated to biofuel consumption in the Netherlands itself and
implies around 27% is consumed nationally.

25

June 2015

3.F24 – Biofuels on the Dutch market

Figure 11

Mass balance for oils and fats flows in the Netherlands in 2012 (dry content)

Source: NL Agency, 2014

26

2-6-2015
DRAFT

4.F24.1 Biofuels on the Dutch market – update: data for 2013

Figure 12

Mass balance for carbohydrates flows in the Netherlands in 2012 (dry content)

Source: NL Agency, 2014

27

2-6-2015
DRAFT

4.F24.1 Biofuels on the Dutch market – update: data for 2013

3.3

Market scan of Dutch production facilities
Approach
This section provides the results of a market quick-scan of the Dutch biofuel
production companies. Two earlier reports on biofuel producers in 2011
(Peters, 2013) and 2008 (Bersch, 2008) were taken as a starting point and
updated to the current situation where possible. New companies were added
based on their registration in the GAVE databases from NL Agency (2014) and
the databases of the main certification systems of biofuel producers (ISCC and
NTA8080).
Since the aforementioned reports, a lot has changed in the Dutch biofuel
market. Some companies went bankrupt or projects were not realized
(e.g. Vesta Biofuels, Noord Ned. Oliemolen, BioDSL and Biofueling), some
made a restart with a new owner (Dutch Biodiesel, Rosendaal Energy/Goes on
Green), some are or were some time on hold due to a difficult economic
market (Dutch Biodiesel Pernis, Maatschap Bosma, CleanerG, Vesta Biofuels),
others could not be traced back or identified as Dutch producers anymore
(e.g. Dekro, Harvest, J&S Bio Energy, OPEK, Pentagreen, Wheb Biofuels).
Most of these companies produced biofuels from food crops. Some companies
have switched between food crops and waste and residues as feedstock, for
example Sun Oil.
The next two paragraphs give an overview of the companies that could be
traced and are still in the Dutch market. Production capacities are tabulated,
but the actual production volumes are not known. Except for Neste Oil, none
of the companies were transparent on their website about the origin of their
feedstocks.
Since most of the feedstocks are imported and also a lot of biofuel is exported,
many companies are located at harbors.

Diesel replacers
From a few companies it is known that they cooperate with local feedstock
producers that use at least some local feeedstock: Coöperatie Carnola,
Biodiesel Amsterdam, Biodiesel Kampen and Ecoson. The palm oil of
OIO/Loders Crocklaan and Wilmar/KOG is likely to come from Asia (Indonesia
and Malaysia), since these are the countries of origin for palm, as reported by
the NEa (NEa, 2014a), although this can not be stated with certainty.
Table 6
Company & location

Biodiesel production overview
Type biodiesel

Capacity
(kton)

Feedstock

Certification

Since

Land based feedstocks (food crops)
ADM, Rotterdam

FAME

3,000 *

Rapeseed, canola, soybean
(oilseeds)

ISCC EU, DE, Plus

≤ 2009

Biopetrol Industries,
Rotterdam

?

400

Rapeseed, canola, soybean,
palm, sunflower, free fatty
acids

ISCC EU, Plus

2008

CleanerG, Zwijndrecht

FAME *

200

Rapeseed, soybean, palm

Unknown

> 2011

Coöperatie Carnola,
Limburg

PPO

2,5 **

Rapeseed

Unknown

2006

Ecopark, Harlingen

PPO

32 (only

Rapeseed

Unknown

2007

small % for

28

2-6-2015
DRAFT

4.F24.1 Biofuels on the Dutch market – update: data for 2013

Company & location

Type biodiesel

OIO/Loders Crocklaan

Palm oil

Wilmar/KOG

Palm oil *

Capacity
(kton)

Feedstock

Certification

Since

10,000 *

Palm

ISCC EU

≤ 2009

500 *

Palm

ISCC EU

110

UCO (Benelux), Animal fat
cat.1

ISCC EU, DE

2010

fuels) ***

Waste and residues based feedstock
Biodiesel Amsterdam,
Amsterdam

FAME (UCE)

Biodiesel Kampen, Kampen

UCE

UCO (local), Animal fat cat.1

ISCC EU, DE

N/A

Eco Fuels, Eemshaven

UCOME

50

UCO

ISCC DE

2007

Ecoson (VION), Son

FAME *

5

Animal fat cat. 1,2,3

ISCC EU; NTA8080

≤ 2011

SunOil, Emmen

FAME *

70

UCO(, animal fats)

ISCC EU, DE

≤ 2011

SES International, Moerdijk

?

NA

UCO, vegetable oils, fats

Unknown

> 2007

Electrawinds Greenfuel,
Sluiskil

FAME *

250

Multifeedstock; vegetable
oils, UCO, animal fat

Unknown

≤ 2011

Neste Oil, Rotterdam

HVO

800

Multifeedstock; vegetable
oils, UCO, rape, canola,
animal (fat) waste residues,
palm oil, stearine

ISCC EU, DE, Plus

>2011

Multifeedstock

(*)

Ecofys (2013); “Oilseed crushers operate both for food and biofuel markets. Crushers often
have biodiesel capacity integrated with their crushing facilities. In the EU on average 38%
of vegetable oil resulting from the crushing ends up in biodiesel, while non-oil components
resulting from crushing end up as animal feed”.
Bersch (2008).
NL Agency (2015)

(**)
(***)

Petrol replacers
The Dutch bioethanol production is dominated by two large international
companies, Abengoa and LyondellBasell. Only a relatively small number of
facilities use waste and residues based feedstock for bioethanol production.
This is in line with the general state of the art of current technologies, which
offer more options for the conversion of waste and residues into diesel
replacers and less options for ethanol replacers.
Table 7
Company & location

Bioethanol production overview
Type
bioethanol

Capacity
(kton)

Feedstock

Certification

Since

Land based feedstocks (food crops)
Abengoa, Rotterdam

bioethanol

480

corn, wheat

ISCC EU, DE; RBSA

≤ 2011

LyondellBasell, Rotterdam

Bio-ETBE

600 **

unknown

ISCC EU

2008

32

Palm oil, starch slurry

ISCC EU

≤ 2011

Unknown

?

unknown

unknown

Waste and residues based feedstock
Cargill, Bergen op Zoom/Sas
van Gent
SABIC, Geleen

?
ETBE/MTBE
(*)

(**)

29

2-6-2015
DRAFT

Ecofys (2013); “Oilseed crushers operate both for food and biofuel markets. Crushers often
have biodiesel capacity integrated with their crushing facilities. In the EU on average 38% of
vegetable oil resulting from the crushing ends up in biodiesel, while non-oil components
resulting from crushing end up as animal feed”.
Bersch (2008).

4.F24.1 Biofuels on the Dutch market – update: data for 2013

Other biofuels
A few companies produce other biofuels: bio-LNG, biomethanol and biobased
jet fuel. Biomethanol can be used to replace petrol, like bioethanol. These are
all produced from waste and residues.
Table 8
Company & location

Other biofuels
Type biofuel

Capacity
(kton)

Feedstock

Certification

Since

Waste and residues based feedstock
Bioethanol Rotterdam,
Rotterdam

Bio-LNG

Unknown

Biomass waste

Unknown

Unknown

BioMCN, Farmsum

Biomethanol

200

Crude glycerine

ISCC EU

≤ 2011

3.4

The case of UCO
In Section 3.2, it was concluded that the Netherlands is likely to be the EU
country with the highest share of biofuels from waste, and a significant share
of these are produced from used cooking oil (UCO). Various studies have been
published on the potential of waste and residues such as UCO, and on the
market impacts of the differences in incentives provided across the EU.
For these reasons, this chapter ends with a short case description of the
market impacts of UCO.

Availability of UCO in the Netherlands
Figure 11 already showed the flows of waste and residues, which were
relatively limited compared to other types of oils and fats. According to a
position paper of the KNAW (2015) the Netherlands have almost reached the
potential of the consumption of UCO from the Netherlands. This statement
was explained by the following calculation:
 In 2012, 1.1% of the energy for transport consisted of biofuels from waste
and residues. This accounted for 3.9 days of driving per year, of which
2.6 days were produced from animals fats and tallow and 1.3 day of UCO.
 1.3 day driving on UCO in the Netherlands equals 41,000 tons of UCO.
 The potential of UCO to collect from the hotel and catering industry is
estimated to be 44,000 tons of UCO and 10,000 from individuals.
This equals 54,000 tons in total on an annual basis (KNAW, 2015).
This is in line with Pelkmans et al. (2014), who also mentions a potential of
60,000 tons annually.
Because it is unknown to what extent the full potential of the UCO collection
can be achieved, and 100% may be unlikely, it can be concluded that the
Netherlands already have quite a good UCO collection system in place, and
approaches the maximum that may be achievable. Especially when considering
that UCO has other potential applications as well, and when applying the
cascading principle some of these other applications may be preferred to using
it in the transport sector. Any further growth of UCO on the Dutch biofuel
market will therefore come from imported UCO of other waste and residues.

Import and export of UCO
In the Netherlands the trade data in UCO and animal fats show a net import
volume, see Figure 13. The feedstocks are imported mainly from Germany and
other Western European countries, but also from countries such as Canada and
the US. In the period 2010-2012 imports increased, while the export volumes
remained more or less have been stable, indicating a growing consumption of

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UCO on the national fuel market, which is in line with the shift in feedstock
use by the fuel suppliers included in the ranking. The Netherlands are seen to
export UCO and animal fats mainly to Germany and other European countries.
Figure 13

Trade balance of (used) oils and fat mixtures and other animal fats for the Netherlands

Source: Pelkmans et al. (2014).

UCO price developments
The high market demand for UCO in the Netherlands, mainly caused by policy
incentives (the double counting in the biofuels obligation), in combination with
the lack of sufficient UCO at the national level, results in several risks.
The various literature sources (Pelkmans, 2014)(Arup URS Consortium, 2014)
(Ecofys, 2013) mention price increases, possible fraud and the fact that the
current biofuels from waste and residues do not provide any incentive for
investments in more advanced biofuels. The economic added value of double
counting biofuels is difficult to predict and forecast and does not result in
sufficient investment security to invest in more advanced biofuels (Arup URS
Consortium, 2014). According to the same source a higher share of UCO in the
fuel mix is only possible by imports from Asia, which is, like Indonesia, at the
same time also a big supplier of virgin palm oil. UCO cannot chemically be
distinguished from virgin oil, so that monitoring and verification has to depend
on adequate processes for tracking and certification.
Note that UCO prices strongly depend on certification, quality and volume.
Certified UCO has a higher market value (Pelkmans et al., 2014). According to
this same source, the prices of UCO ranged from € 300-€ 500 per tonne in
February 2014 and has been quite stable in the period before. Pelkmans et al.
also refer to prices reported by Greenea (a broker in Europe specialised in
waste-based feedstock and biodiesel). Greenea reported much higher prices
ranging from € 500 to nearly € 800 per tonne. However, Pelkmans et al. (2014)
state that as result of the declining prices of UCOME (processed UCO) the
prices of UCO are still lower compared to the virgin oil prices presented in
Figure 14.

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Figure 14

Evolution of vegetable oil prices, delivered in the Netherlands (based on FAOSTAT, 2014)

Although the above mentioned figures do not indicate the attractiveness of
fraud, Arup URS Consortium (2014) states that based on data for the UK
market, labelling new Indonesian palm oil as UCO increases the price by 5-20%.
The authors also state that the value of double counting fuel is in principle
two times the price premium of conventional biofuel over conventional fuels.
This statement is illustrated by the following price indications taken from
Platts (2013):
Table 9

Premium prices to fossil diesel (Platts, 2013) in (Arup URS Consortium, 2014)
Dollar/GJ

Premium to fossil diesel
(Dollar/GJ)

Fossil diesel

21

-

Vegetable oil FAME

29

8

UCO FAME

37

16

According to the authors this example shows that the UCO FAME has reached
its maximum price premium over FAME produced from vegetable oil due to
double price premium of $ 16/GJ compared to the $ 8/GJ. This is based on the
assumption that blenders only need half the volume to comply with blending
obligations in case of double counting biofuels. However, because the
transport demand itself does not reduce by 50% the fossil diesel should also be
taken into account in case of biofuels from waste and residues. This is
illustrated in Figure 5.

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Figure 15

Price structure for single and double counting biofuels from a fuel supplier perspective

As depicted in this figure, the compliance cost associated with 1 GJ of
biodiesel (FAME, in this case) are equal for both single counting FAME and UCO
based FAME in case the price premium of the double counting FAME is twice as
high as the price premium for FAME. If the prices of UCO-based FAME would be
higher than the $ 37/GJ it would cost a fuel supplier more to fulfil its blending
obligation. Solely from an economic perspective, the fuel supplier will then
prefer the single-courting FAME over the double-counting FAME. In practice,
fuel suppliers might be willing to pay a higher price for UCO-based FAME if
other considerations than economic consideration are taken into account, as
discussed in the previous chapter, for example if a fuel supplier would rather
not sell single counting FAME due to the sustainability concerns and ILUC
impacts associated with the feedstock.
Using the cost example in the figure above, UCO-based FAME could deliver up
to 27% ($ 37 compared to $ 29) more profit compared to FAME produced from
virgin oils, which indicates it may be attractive to simply convert virgin oil into
UCO before selling it on the market. To what extent it is indeed an attractive
option depends on the actual cost of the various fuels and oils, but also on the
cost associated with the conversion of the oils to FAME and the administrative
burdens of certification processes.
(Pelkmans et al., 2014) addressed the potential issue that these price
differentials might lead to fraud, but could not find conclusive evidence for
this. The study does conclude, however, that some inconsistencies can be
identified in the markets in previous years, and a uniform mechanism at
EU-level is needed for tracing and verification, to reduce unclarities.

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4 Conclusions and

recommendations

4.1

Conclusions
The new ranking of fuel suppliers
Based on the data for 2013, the following conclusions can be drawn for
biofuels consumed in the Netherlands:
 Overall improvements in GHG performance: Compared to 2011 and 2012,
the large majority of the fuel suppliers reduced their average GHG
emission factor and thus improved the GHG performance of their biofuels.
The only exception is Argos, who already had a relatively good
performance in 2011 and 2012, and now also in 2013.
 The ranking: The biofuels that Salland and Esso sold to the Dutch market
had the lowest average GHG emissions, achieving average GHG savings of
about 85%. Marees en Kistemaker, Den Hartog and TOTAL had the highest
average emissions, about 50% of that of the fossil fuels they replace.
Part of this is due to the different types of biofuels they blend and the
associated production technology and capacity: the low emissions are
typically achieved by using used cooking oil and animal fat for biodiesel
production, whereas production capacity of bioethanol (a petrol
replacement) from waste and residues is still very limited.
 Changes compared to last year: Some companies shifted in the ranking,
not because the average GHG intensity of their biofuels worsened, but
because other companies managed to improve the GHG intensity of their
biofuels even more. Due to changes in feedstock use in the last years, Esso
moved from the highest average GHG intensity of the ranking (in 2011) to
almost the lowest average GHG intensity of the ranking today.
 Uncertainties: The GHG performance of the biofuels brought on the
market by some of the fuel suppliers is still uncertain due to a lack of
transparency concerning the category ‘other feedstocks’. Compared to the
previous years, the category ‘unknown’ has dropped to 0%. Also, volumes
of the claimed biofuels are not reported on individual company-level,
making it impossible to rank the biofuel suppliers on a more absolute
scale.
 A declining role for biodiesel from food crops: this has been the first year
with no biodiesel from food crops in the list of the seven feedstocks mostly
used. It is clear the fuel suppliers are shifting away from virgin oils as
feedstock for biofuels, as far as the Dutch market is concerned.
 Origin of the feedstocks: compared to previous years the share of
feedstocks from within the EU is still increasing.
 Role of biofuels from waste and residues: the role of biofuels from waste
and residues is still increasing. Some new double counting feedstocks like
wheat straw have appeared on the list of the seven feedstocks mostly
used.
The overall results of the ranking are shown in Figure 16.

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Figure 16

Ranking of fuel suppliers based on total GHG emissions of the seven biofuels mostly used in
2013
90

80

70

60

50
CO2
in g/MJ

indirect emission
direct emissions

40

30

20

10

0
Salland

*

Esso

Kuwait

Argos

Shell

BP

Gulf

Marees en Den Hartog
Kistemaker

TOTAL

The dotted green lines represent a 35 and 50% reduction of GHG emissions compared to the
fossil fuel reference (83.8 gCO2/MJ, blue line). From 2010 onwards, a minimum of 35% savings
is required, from 2017 onwards, this increases to 50% (RED requirements).

Biofuel production in the Netherlands
Besides the fuel suppliers bringing biofuels on the Dutch market, the Dutch
biofuel sector also consist of biofuel producers. These are not obliged to
report on the mix of feedstocks they use used for their production process, so
this market is much less transparent.
In 2013, about 1,375 kton of biodiesel was produced in the Netherlands, and
414 ktoe of ethanol (compared to a consumption of 220 kton and 194 kton,
respectively). Overall, the Netherlands is a large importer and exporter of
biofuels. Many production facilities were planned and realized before the
sustainability concerns related to ILUC started to dominate biofuel policy, and
these still use a large share of land based feedstocks. Because of a delay of a
policy decision on ILUC and due to current lack of a long term policy
framework for biofuels after 2020 only a few biofuel production facilities have
been realised in the period after 2011. These few new facilities mainly focused
on the conversion of waste and residues, while the food-crop oriented
facilities, are still operational, albeit not on full capacity.

The role of land-based biofuels in the Dutch biofuel trade
Although the role of land based biofuels to meet the blending obligation is still
declining, Dutch biofuel producers still contribute to the consumption of land
based biofuels: they have a significant role in biofuel trade, and produce for
other European countries that still have much higher shares of biofuels from
land-based feedstocks in their mix. For example, the volumes of palm oil in
biofuel import and export have increased in the period up to 2012, despite a
declining demand for the Dutch market.

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The biofuels produced in the Netherlands are likely to have a poorer average
GHG performance compared to the biofuels brought on the market by the fuel
suppliers, because of their higher share of land-based feedstock and the
associated ILUC emissions. However, this performance can not be quantified.

Biofuels from waste and residues
The incentive of double counting in the biofuels obligation in the Netherlands
creates a number of risks related to fraud and price impacts on other
applications. Because the Netherlands do not have sufficient waste and
residues such as UCO to fulfil demand, these feedstocks are also imported.
Whether this indeed leads to fraud or other undesired impacts is, however,
unknown.

4.2

Recommendations
A number or recommendations can be provided that can further increase
transparency of the origin and environmental impacts of the biofuels that are
consumed in the Netherlands, for each fuel supplier.
 There is still a data gap due to the methodology of the NEa reports, where
only the data on the top 7 feedstocks (animal fat, UCO, corn, sugarcane,
wheat, sugar beet and wheat straw) are provided. This results in relatively
large uncertainties for some of the fuel suppliers, as they use ‘other types
of feedstock’ that are not in this top 7. It is therefore recommended to
provide full disclosure of the range of feedstocks used, also to enable the
assessment of the average GHG savings that these suppliers achieve.
 It is currently only possible to estimate average GHG emission factors of
the biofuels of the various fuel suppliers. To assess the actual GHG savings
that they achieve with the biofuels they blend, information on the volumes
of biofuel (feedstocks) imported and consumed need to be provided, on
company level.
 The national legislation and definition of which biofuels are double
counted should be harmonised in the EU. Different policies encourage
trade and transport of waste and residues between Member States, as they
are double counted in one country but not in another (see, for example,
the UCO trade from Germany to the Netherlands).
 Transparency helps to incentivise fuel suppliers to supply biofuels that
exceeds the minimum criteria set in the RED. Whilst this effect can not be
quantified, it is recommended to roll out this transparency and annual
reporting throughout the EU, to maximise the effect and enable European
monitoring and reporting on this level.
 It is furthermore recommended to also increase transparency of biofuel
production and trade, to get insight into whether the biofuels produced
and traded in the Netherlands meet sustainability criteria, and to enable
monitoring of the feedstocks used, the countries of origin and overall
GHG emission factors of the biofuels produced in the Netherlands.

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