There is one exception, used cooking oil (UCO), which falls under Part B of this list. The feedstocks in the figure are listed in RED II’s Annex IX, Part A, and are used to meet RED II’s advanced fuel sub-target of 3.5%. The left-hand axis shows the total quantity of fuel production in million metric tons of oil-equivalents (mtoe), and use of these volumes in the transport sector would mean large GHG savings for Germany. If the circumstances of the penalty were amended and advanced alternative fuels, which are more expensive, were instead incentivized, the figure below projects the volumes that could be used by the transport sector in Germany to 2030 (based on Figure 4 in this paper). However, suppliers are allowed to use much cheaper first generation fuels like corn ethanol to avoid this penalty. Currently, Germany penalizes fuel suppliers €470 per metric ton of CO 2e GHG savings not achieved under a GHG quota. To understand, let’s examine how Germany supports alternative fuels. If they press again and succeed, it would jeopardize the greenhouse gas (GHG) savings that could be achieved from RED II. Meanwhile, industry seeking to increase opportunities for financial support for certain advanced biofuels has pressed before for the government to lift a ban on certain feedstocks. A recent ICCT study found that Germany will likely meet its obligation for the transport sector under the recast of the Renewable Energy Directive (RED II) with renewable electricity alone.
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