Transparency Register-ID: 174042620514-51 May 16, 2019
Bioenergy Association of Finland’s response to the
Consultation on the Prolongation of the State aid Regulations and
Guidelines reformed under the State aid modernisation (SAM) package
and expiring by the end of 2020
The Bioenergy Association of Finland represents the interests of the bioenergy sector
domestically and abroad. We cover the whole technology, production and usage chains of solid,
gaseous ja liquid biofuels.
We welcome the opportunity to comment on the Commission’s proposal to prolong the State aid
rules reformed under the State aid modernisation (’SAM’) package until December 2022. We also
look forward to participating in their evaluation in order to contribute to their optimal
design/implementation post 2022.
We support an extended validity of the above-mentioned regulations. However, with regard to the
Energy and Environmental Aid Guidelines (EEAG), we would like to highlight the need for the
European Commission to ensure consistency of the Guidelines by also extending the time limit
for operating aid to “food-based biofuels” mentioned in paragraph 113 and 121 of the EEAG from
the end of 2020 to the end of 2022.
Today these biofuels contribute significantly to reduced CO2 emissions compared to their fossil
alternatives, and during the coming years both food-based and second-generation biofuels are
needed to decarbonise the transportation sector. This was also the outcome of the negotiations of
the recast Renewable Energy Directive (2018/2001) which came into force on 24 December
2018. The EU legislator decided not to phase out biofuels made from “food and feed crops” (term
used by the Directive 2018/2001). Instead, these fuels are – as long as they fulfil the sustainability
criteria – eligible for support schemes in the Member States at levels attained by 2020.
A prohibition of operating aid to any food-based biofuels would seriously hinder both the EU and
Member States to meet decarbonisation targets in the area of transport, including the 14% target
for renewables in transport by 2030 under the revised Renewable Energy Directive.
Member states should have their own discretion and flexibility to operate within the thresholds set
by REDII directive. Members states should independently resolve what kind of market
development they wish to see to reach the targets, which in the end determine the levels and
quality of biofuels used in 2030.
We therefore ask the Commission to amend the Communication on the extension of the
validity of the State aid rules to provide for a corresponding extension of the 2020 limit for
operating aid to food-based biofuels under the Energy and Environment Guidelines until
The Bioenergy Association of Finland
Tel. +358-40-1630 465