MVO the association for the Dutch oils and fats industry supports the main elements of the SER sustainability framework for biomass. The Dutch oils and fats industry supports and works actively on international corporate social responsibility, achieving the Sustainable Development Goals (SDGs) of the United Nations and is in favour of a broader due diligence framework as currently being developed in an EU context.
MVO supports the SER's choice to join the European framework of the Renewable Energy Directive (RED). European harmonization is of great importance when it comes to international trade in raw materials. After all, the Netherlands is a small country and our industry largely produces for the rest of Europe.
The reference to the use of ILUC (Indirect Land Use Change) by the European Commission seems premature. There is no scientific consensus on ILUC and Indonesia has objected to the use of ILUC at the World Trade Organization (WTO). Applying the ILUC principle actually means a ban on the use of the relevant raw material. Further sustainability efforts are then no longer relevant and all dialogue stops. The report that served as the basis for designating palm oil as a high ILUC risk raw material was drawn up by the European Commission itself and not independently. A revised report should be on the table in a year.
MVO is pleased that the SER appreciates the successes of international multi-stakeholder initiatives such as the Roundtable on Sustainable Palm Oil (RPSO) and the Round Table on Responsible Soy (RTRS) sustainability certification. These initiatives encompass both environmental and socio-economic aspects.
Although the sector can agree with the SER advice on many points, the Dutch oils and fats industry does not recognize itself in the SER's picture of the place of biomass in society. The SER seems to see biomass mainly as a source of food and to subordinate all other applications to it. This is a somewhat narrow view of the world in which farmers grow crops on the basis of which the agro-industry produces products and semi-finished products. Only a small part of the crops are suitable and available in sufficient quantities to meet the nutritional needs of humans. A broader view shows that in biomass production the production of food, feed, materials and energy go hand in hand. The distinction made by the SER between high-quality and low-grade application is also arbitrary. Energy is no less important than food. Energy is needed to produce, process, transport, condition and ultimately prepare food. Moreover, people cannot do without energy for heating and cooling and without building materials and chemicals. An integrated vision shows that food production is not possible without using the entire plant by applying biomass for useful applications like materials, chemicals, fertilizers and energy.
SER chair Mariëtte Hamer concludes in her preface that certain forms of biomass such as biodiesel will be used as a transition fuel for the time being for specific purposes that do not yet have an alternative: “Sometimes the use of biobased raw materials is an interim solution because technical alternatives are not yet affordable and available, as for heavy road transport, maritime shipping and aviation. But the direction is clear: sustainable biobased raw materials in the form of high-quality applications in materials and certain sectors, such as chemistry, are a permanent part of the sustainable final picture. ”
Click here for the SER Advice Sustainability Framework Biomass.
Click here for the SER press release.
Click here for the official presentation (video).