Sounds like a complex move but reality is that the expansion of Annex IX part B was necessary as it was so limited to essentially two items Used Cooking Oil and class 1&2 animal fats. Most of the additions will have minor impact except for Brow Grease that was already being used in some EU countries as an advanced feedstock. This will open the arbitrage from US to EU on Brown Grease and solidify the existing BGME
flows from China to EU. An addition to part B of intermediate crops or catch crops adds ambiguity and could mean that some rotation crops such as Soy could become eligible as long as there is only one harvest - some crops in Brazil could be eligible. The additions in part A are non-events except for another ambiguous category of "non-food crops grown on severely degraded land not suitable for food or feed crops". My feeling is that the expansion of the part A and B is tied to the expectation that double counting mechanism are being curtailed in some countries (Netherlands) and this in addition to a decreasing % cap through 2030.
Comments