Rapeseed farmers in Germany calling out double-counting

The use of UCO and advanced Biofeedstocks like POME (palm oil effluent) has been consistently displacing crop based biodiesel/HVO and causing excess GHG savings tickets in Northwest Europe and particularly in Germany.. Despite the soft cap on waste based biofuels of 1.7% under RED II, it is still double counting and highly favored within the 7% mandate. What this means in practice is that a refiner only needs to blend 3.5% double counting (DC) Biodiesel to meet the mandate but in fact, most pumps and distributors in Europe move a B7 diesel blend causing a surplus of tickets. Note that there is also a cap of 7% on crop based biofuels under RED II based on 2020 consumption levels that also encourages use of waste oils in addition to DC. As agricultural products are coming back to 2021 price levels we see this discussion intensifying on both side of the Atlantic as oilseeds farmers don't seem to have been aware of the GHG savings goals that go beyond farming practices ability to follow. The other consequence for Europe has been the lower demand for road diesel leading to increasing exports particularly from Germany who exported 1.7 Million MT of Biodiesel in the first half of 2024 with nearly half going to the Netherlands. Exports to the US accounted for 242Kt. Despite the exports to US, there is no free trade in Biodiesel as EU has countervailing duties on US made Biodiesel and Renewable diesel because of the large amount of subsidies that are in place under the RFS. US equally assessed countervailing duties on Argentina SME while Europe applies an MIP (Minimum Import Price) model on Argentina imports. The increasing use of GHG savings or Carbon intensity calculations introduced a new method of valuing biofuels that will increasingly impact trade. Surely the days of double counting in Europe are now numbered and could have significant impact on the cost of waste oils further diverting it to the US. Gasoil chart still looks ugly as we are now back where the Ukraine rally began but Heat crack was not what it is today at nearly $21/brl on screen.