FEDIAF reaction to the European Parliament Plenary vote on ReFuel Aviation proposal

On 7 July, the European Parliament voted to adopt its legislative position on the ReFuel EU Aviation legislation – a historic chance to drive decarbonization of the air transport sector using truly sustainable feedstock.

FEDIAF regrets the decision of the European Parliament to extend the definition of sustainable aviation feedstock to category 3 animal by-product – the only by-product which can be legally used in pet food and our essential raw material.

Qualifying category 3 animal by-product as sustainable aviation fuel feedstock will serve as a regulatory incentive to divert it away from pet food use. We are already seeing this situation when it comes to road transport targets: according to the EU waste hierarchy (which is referenced in the Renewable Energy Directive) and the cascading principle, resources should be used as long as possible in line with applicable product legislation, with energy recovery being a residual option. However, the lack of safeguards against using category 3 animal by-products in fuels, is leaving our sector without crucial raw materials.

The proposed 2034 deadline does little to alleviate our key concern – availability of category 3 by- products in the near term, since by-products cannot be produced on demand, making them a very scarce resource. Our industry will be forced to look for less adequate alternatives both in terms of nutrition, safety, and environmental footprint. Our sustainable business model is based on valorizing animal by-products sourced locally, whereas the lack of local supplies might lead to higher demand for materials from other parts of the world, which could lead to a whole new set of sustainability challenges.

Ironically, this would likely be the same material that ReFuel EU Aviation and the Renewable Energy Directive (RED) aim to discourage.

There is still a chance – the revision of the Renewable Energy Directive needs to result in appropriate legal safeguards to ensure category 3 animal fats are not considered sustainable energy feedstock. This can be either done through an explicit exclusion of by-products approved for use in EU legislation and by supporting the new accounting GHG methodology proposed by the European Commission in Annex V.

Given the ReFuel EU Aviation reliance on RED II definitions, we believe this would be the most appropriate way to create a credible & sustainable renewable energy model across all transport modes.

We implore the Council and the European Parliament to reconsider their position on the definition of sustainable aviation fuels and exclude category 3 animal by-products.

We equally invite the European Parliament to clarify in RED III that by-products which are used as pet food cannot be considered sustainable.

Jointly we can ensure that decarbonization of transport does not occur at the expense of pets and pet owners.

To download the PDF of the statement, please click here.