Five EU member states push back on UCO role in SAF plans

Concerns are raised over the use of waste-based feedstocks

The representatives of five European Union member states have voiced their concerns over the use of waste-based feedstocks in ambitious plans to scale up the adoption of sustainable aviation fuel (SAF) to an influential committee that gathers individual countries’ positions ahead of policy negotiations.

The Committee of the Permanent Representatives of the Governments of the Member States (Coreper) meets every week and helps shape the range of views held by the governments of European Union member states into a unified, baseline position.

Fastmarkets Agriculture understands that, at the meeting held on April 19, the representatives of five of those governments called for the use of waste-based used cooking oil (UCO) in SAF plans to be placed under review, with all five thought to be looking to cap the use.

While UCO shoulders the brunt of the concerns, the cap covers all aspects of Part B of Annex IX of the EU’s Renewable Energy Directive, covering used cooking oil, animal fats, and free fatty acids (FFAs).

A source close to the discussion, who preferred to remain anonymous, explained that the main concern is that UCO is already a major feedstock in the production of waste-based and advanced biodiesels – and competition from SAF would drain the biodiesel sector of its primary feedstock.

That, in turn, would paradoxically force emissions higher – as greater savings can be made by using UCO in advanced biodiesels for truck, train, and shipping use, than would be achieved by using it in aviation.

“Based on the limited availability of UCO, [the fear is…] all will be diverted to aviation,” the source said, and proposals to limit the use of UCO in aviation had been raised before but had never made it through to the final proposals.

“UCO plays a big part, and finally it was openly discussed in the Coreper meeting,” the source said, estimating that the diversion of waste oils from road and maritime to aviation would lead to 1 million tonnes of additional GHG emissions into the atmosphere by 2025.

“Five member states openly supported a limitation on the use of waste lipids from the existing Annex IX/Part B (namely UCO, animal fats) in the ReFuelEU aviation on the basis of existing better uses in other transport modes,” a second source told us via an emailed response.

While it was unclear which five nations have raised their concerns on UCO in EU plans, the first source also said that other nations could also raise objections to the plans as a key debate on the EU’s ambitious ReFuelEU proposals looms next week.

“I think there are very good grounds for thinking that, if there is more time, there will be more support from more member states,” the source said.


The bloc’s governing body has pioneered biofuel policies across member states since the start of the century, driving the adoption of biofuels through initiatives such as the Renewable Energy Directive (RED) and the Fuel Quality Directive (FQD).

Its most recent proposals, known as ‘Fit for 55’, seek to cut net emissions across all areas of the bloc’s activity by 55% by 2030 and include a separate series of proposals for aviation under the banner ReFuelEU.

As a last outlier of unadulterated oil-based fuel demand, the aviation sector is increasingly the focus of decarbonization initiatives, but technological limitations mean most options currently being pursued globally focus on sustainable liquid fuels.

The ReFuelEU policy calls for 63% of aviation fuel used for intra-EU flights or on EU-originating international flights to be of sustainable origin by 2050.

Currently, by the EU’s own figures, use amounts to less than 0.05% of total EU aviation fuel use.

If realized, the increment would represent a massive increase in SAF demand and production, which is currently estimated at around 150,000 tonnes per year across the entire bloc and comes at a time when the US is also looking to significantly increase its use of SAF to meet aggressive climate goals.

The strain that could put on wider vegetable oil supply – as well as waste-based feedstocks, the use of which are typically highly incentivized – has already prompted questions over whether the assumed supply is there to meet this huge expansion.

Recently the UK published its consultation documents on SAF adoption and capped its proposals at 2040, citing fears that “uncertainties in technology development and feedstock supply become too great after 2040 to set specific targets.”

The UK proposal recommends common pathways to reach a 10% mandate by 2030, rising to 32% by 2040 in the most ambitious scenario – in line with the EU’s ReFuelEU target at the same point in time.

But the proposal also considers a lower 17% mandate by 2040 in the event of feedstock supply falling short.

Objections to the policy

Europe already operates with a patchwork of biodiesel blend mandates, with most EU countries operating a blending requirement of up to 7% of the final diesel blend, but the often-poor qualities of conventional biodiesels have limited adoption.

However, the rise of biodiesel production – such as waste-derived biodiesel and hydrotreated vegetable oils (HVO) – has changed the debate and opened a pathway towards higher blends and even drop-in fuels, with the resultant fuels often outperforming oil-based equivalents.

That has opened the door to aviation use, as the ability of fuels to be ‘dropped in’ to a highly regulated and heavily monitored supply chain – and to be utterly indistinguishable from its mineral oil equivalent – is a key requirement for airlines and airports.

However, much of the used cooking oil supply being drawn into the region is already being used to produce biodiesels for road, rail, and marine transportation – a sector where the use of biofuels delivers greater greenhouse gas emission savings.

Critics also argue that over-reliance on UCO could also limit innovation and policy support for other potential approaches – although possibilities in aviation are limited as electrification is not viable for commercial aircraft, and hydrogen is both controversial and only in its earliest stages.

The next milestone is the upcoming trialogue meeting to be held in Brussels on April 25 on the ReFuelEU proposals.

The three-way meeting between the European Commission, the European Parliament, and the European Union is expected to discuss the proposals, but the objections raised by the five member states do not guarantee it will be discussed next week.

“Now, it’s really up to the Swedish presidency to take this into consideration during the next ReFuelEU trialogue discussion on April 25,” the second source said.

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