Over 20 clean energy organisations have written a letter to the European Commission (EC) and Member States to warn against a loophole that would allow biofuel production to be relabelled as e-fuels on the basis that green hydrogen is used in its processes.
According to the letter, authoring companies wish to “express [their] concern regarding the ongoing pressure to allow electrolytic hydrogen used as an intermediate processing input in biofuel production to be counted towards the dedicated e-SAF supply obligation under Regulation (EU) 2023/2405 (ReFuelEU Aviation). While this accounting trick is currently primarily being pushed to bypass the ReFuelEU e-SAF targets, its approval would establish a dangerous regulatory precedent across the entire EU transport framework. If this interpretation prevails, electrolytic hydrogen used in processes like HEFA/HVO hydrotreatment would generate a synthetic fuel share in resulting biofuel outputs. This would allow existing biofuel refiners to claim they are delivering e-fuels, without building new synthetic fuel plants.”
The letter calls for the loophole to be resolved in the upcoming RFNBO Delegated Acts revision. Authoring companies include T&E, Climate Catalyst, Elyse Energy, DeutscheUmwelthilfe, FjordPtX, France Hydrogène, FRANCE KEREAUZEN engie, Hynamics, Hy2gen, Iðunn H2, NABU, NGF, NorSAF, Green Transition Denmark, RIC eFuels, SASHA Coalition, StornFisher, Verso Energy and Zero.
