Miracle crops?

The revision of the Renewable Energy Directive (RED) in 2023 raised EU targets for advanced and waste biofuels, and was followed by an expansion of its Annex IX feedstock list in 2024 to notably include intermediate crops and crops grown on severely degraded land (SDL). These feedstocks, specifically incentivised for sustainable aviation fuel (SAF) production in the current RED, are claimed to deliver environmental benefits while avoiding land use changes and competition with food production. Among them, oilseed crops are advertised as particularly promising Annex IX biofuel feedstocks, benefiting from established processing infrastructure and relatively low production costs.

Currently, intermediate crops are broadly defined to ensure their use in biofuels “does not trigger demand for additional land” and maintains soil health, while SDL crops are intended to restore low-quality soils for instance affected by severe erosion or salinisation. However, uncertainty persists regarding precise feedstock definitions, the specific sustainability safeguards and compliance thresholds required, and the practicalities of their implementation.

The RED requires biofuels processed in recent facilities to cut greenhouse gas emissions by at least 65% compared to fossil fuels, but Cerulogy finds that Annex IX crop biofuels emissions can vary widely depending on how the crops are grown. Fertilisers used in crop cultivation are the main driver, accounting for up to 60% of total biofuel emissions, due both to their fossil-fuel-based production and the release of potent greenhouse gases during application. While low-input and soil-friendly farming practices can improve emissions savings, strong incentives to produce biofuels may instead drive increased fertiliser use on the main crop to maximise yields, raising associated emissions and potentially eroding, or even cancelling, the overall greenhouse gas savings.

Although RED rules aim to prevent agricultural land expansion, growing these crops could still impact main crop yields and divert land from food and feed production, creating additional emissions. Some “degraded” lands may already support crops or natural ecosystems, so converting them to biofuels may cause both indirect and direct land-use changes with potential soil carbon loss. Cerulogy also finds that in worst-case scenarios, biofuel emissions could approach or exceed those of fossil fuels.

Production of intermediate and SDL crops will depend on site suitability, crop yields, growing cycles, and practical constraints. With yields generally lower than main crops and adoption limited by economic and logistical challenges, Cerulogy identifies around 7 Mha and 3 Mha of suitable areas in the EU for intermediate and SDL crops cultivation, respectively.

Such areas could produce a maximum 1 Mt of bio-SAF, potentially covering 40% of the EU’s 2030 bio-SAF demand. Combined with domestic waste oils, these feedstocks could theoretically meet the majority of the short term 2030 SAF targets, but rapidly scaling intermediate and SDL crops presents significant practical challenges. Furthermore, this supply remains a short-term bridge; by 2050, these crops are estimated to cover a mere 4% of ReFuelEU’s projected demand. Importantly, environmental integrity of all these biofuels would have to be strictly enforced to ensure they deliver the high GHG savings required to provide a credible sustainable alternative to fossil jet fuel.

While the EU RED now incentivises intermediate and SDL crops for advanced biofuels, their claimed benefits could be negated by significant risks of fraud, land-use change, and competition with food production. T&E maintains that the promotion of these feedstocks must be secondary to the implementation of strong, measurable safeguards and credible certification. To avoid repeating past biofuel failures, these measures must be rigorously enforced and their effectiveness proven in practice.