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Mar 2024

Advocacy to end crop and POME based biofuels

Published on February 26, 2024 on our platform

We gained access to a leaked draft of the National Biomass Strategy (NABIS), on which the Ministries of Environment (BMUV), Agriculture (BMEL) and Economy (BMVK) have worked for months. We detail the key proposals that would impact low-carbon fuels use in transport.


The version of the 83-page draft of the National Biomassestrategie (NABIS) dated February 6 contains a broad spectrum of proposals, including some transposing RED3. The key ones for the transport sector are the following:

  • Promote the use of advanced biofuels in aviation and maritime sectors

No specific details were provided. Implementation date mentioned: by 2030.

  • Strengthen the use of biofuels in agriculture and forestry sectors

The only concrete tool mentioned is “from a date yet to be determined, only new machines approved for operation with biofuels (or alternative drives) would be allowed to come onto the market”.By 2030.

  • Reform the THG quota by

1/ Decreasing the crop cap. BMUV wants to go to 0%.

2/Including ILUC factor for crop-based biofuels.

3/ Deleting the BlmSchG §37 h, which “automatically” increases the THG quota when the electric quota (9 PJ in 2023, 13 PJ in 2024, 25 PJ in 2025, etc) is overcame. According to the document, this option “increases the funding incentives for biomass, which is not compatible with the limited potential of it”.

            By August 2025.

  • Clarification of the definition of “hybrid fuels” at EU level

Fuels made from a combination of biomass and fuel products from renewable electricity should be countable towards biomass-based and renewable non-biogenic targets. Germany will lobby EU institutions to include those in EU regulations.

  • Ending the use of residual materials from palm oil production (POME)

“The Federal Government is lobbying the European Commission to adapt Annex IX A in RED II so that POME is removed from the list of biofuel raw materials that are particularly worthy of support to prevent incentives for increased, unsustainable palm oil processing.” This proposal is in clear contradiction with the RED2/3 statement that feedstocks can only be added to the Annex 9 list, not withdrawn.