A coalition of German bioenergy associations has broadly welcomed a draft law on the further development of the Greenhouse Gas Reduction Quota (GHG Quota), while calling for targeted improvements in several key areas ahead of the bill's first reading in the German Bundestag on 25 February.
The associations praised elements of the draft, including a raised ambition level for the GHG quota, an extension of the quota until 2040, strengthened fraud prevention measures, and an increased sub-quota for advanced biofuels. However, they identified a number of provisions they argue would undermine the regulation's climate policy effectiveness.
Chief among their concerns is the proposed quota level of 16 per cent for 2027, which the associations say would be insufficient to reduce existing surplus volumes or prevent another crash in the quota price. They are calling for the 17.5 per cent quota currently planned for 2028 to be brought forward by a year to avoid market distortions and a decline in physical demand for renewable fuels.
The associations are also critical of the decision to retain the capping limit for cultivated biomass-based biofuels at 4.4 per cent. With energy demand in transport expected to fall as electric vehicles become more prevalent, they argue that maintaining this cap would result in an effective reduction in biofuel volumes and their contribution to climate protection. They are instead calling for the upper limit to be raised to 5.8 per cent — the maximum permitted under EU law — to maintain the sector's climate protection contribution.
On advanced biofuels, the associations welcomed the planned abolition of double counting, but urged that mandatory official on-site inspections be introduced immediately rather than phased in from 2027. They also called for an official registration procedure for producers of advanced biofuels to be established.
Another key demand concerns biogenic hydrogen, which the associations argue should be treated on equal terms with electrolysis-based green hydrogen when used in mineral oil refineries. "Biogenic hydrogen is available at short notice, cost-efficient and can noticeably accelerate the hydrogen ramp-up," the associations stated, adding that its inclusion in GHG quota calculations for refinery use is both appropriate and required under European law.
The groups also raised objections to the planned expansion of the raw material pool for co-HVO to Annex IX Part B materials, which they said would lead only to a shift in raw materials and a reduction in efficiency. They additionally criticised a proposed EU delegated act that would exclude soybean oil-based biofuels, and called on the German government to advocate for the withdrawal of that draft.
The associations further backed changes to fuel standards for biodiesel and bioethanol under the 10th Federal Immission Control Ordinance (BImSchV), including establishing E10 as the standard petrol grade.
Sustainable biofuels saved approximately 11.5 million tonnes of CO₂ in 2024, according to the associations, which describe the sector as the main pillar of climate protection in road transport.
The joint position paper has been published in full and in summary form by the German Bioenergy Association, the German Bioethanol Industry Association, the German Farmers' Association, the German Raiffeisen Association, the Biogas Association, the Bioenergy Office, the SME Association of Waste-based Fuels, OVID – the Association of the Oilseed Processing Industry in Germany, the Union for the Promotion of Oil and Protein Plants, and the Association of the German Biofuel Industry.
German bioenergy associations urge improvements to GHG quota legislation
