EU – Double counting for cooking oil biodiesel approved in Germany

France and the Netherlands already double count biofuels made from used cooking oil, and Germany also does this, backdated to January 2011. This is all fuels, for aviation as well as for road transport.  It means products are counted twice towards the national quota of the amount of supposedly low carbon fuel being used by that country. They get this double countin because of their reduced greenhouse gas emissions. The German biofuels quota stipulates that the use of tallow-based products for biodiesel production be phased out completely from 2012. SkyNRG in Holland provides aviation biofuel based on  used cooking oil to several airlines.

Double counting for biodiesel approved in Germany

22 December 2011

The German Federal Finance Ministry says it will qualify biodiesel produced from used cooking oil for double counting, even if it includes animal fats.

The Netherlands and France already includes waste-based biodiesel within its double counting legislation and it is possible to double count in countries that have not yet implemented their schemes officially, such as in the UK.

Previously, Germany was unable to implement the double counting measures because of tracebility issues but it has since resolved this.

It is thought that Italy and Spain will soon follow suit, and with the double counting scheme applying to both used cooking oil and tallow, it should allow for these counties to use a wider range of feedstocks for biodiesel production. It is hoped that this will encourage price levels of raw materials to stabilise. 


Germany double counts waste-derived biofuels

08 Jun 2011 (Argus)

Germany has introduced the double-counting of certain types of biodiesel derived from waste products, as it looks to meet the EU 10% target share of renewables in transport fuels by 2020.

The measures, which were finalised on 6 June, have been enacted retrospectively from 1 January 2011, the Germany environmental ministry told Argus.

The German regulation aims to translate the EU Renewable Energy Directive into national law. The directive stipulates that waste-derived biodiesel products are counted twice towards the national quota because of their reduced greenhouse gas emissions.

The EU regulation allows for a wide interpretation of waste-derived products, ranging from used cooking oils (UCO) to animal fat or tallow feedstocks.

But Germany has only opted to include certain types of biomass, such as UCO, while tallow or animal-based produced remain exempt from double counting.

Several other European countries have already enforced legislation, including the double-counting of tallow products.

The German biofuels quota stipulates that the use of tallow-based products for biodiesel production be phased out completely from 2012.

Consumption of waste-derived biodiesel in Germany has fallen sharply over the past two years. Waste-derived products accounted for 5% of overall biodiesel consumption in 2009, falling to 1% last year. This is partially because of incentives offered in other European countries, promoting exports.

German biodiesel sales rose by 2.6% to 2.58mn t in 2010 from a year earlier.

The Dutch government says, on double counting of biofuel:

Double counting of advanced biofuels

Double counting of better biofuels
Economic operators who bring petrol or diesel on the Dutch market, can count certain biofuels double to fulfill their biofuel obligation. For example, a company that meets its entire target commitment for 2011 via these better biofuels, only needs to sell 2.125% biofuels, rather than the standard 4.25%.
The double counting of biofuels is described in paragraph 6 of theMinisterial Order Renewable Energy in Transport. With this order, the Ministerial Order Double counting better biofuels from 2009 is lapsed. The contents of this lapsed ministerial order are included in the new order of Renewable Energy in Transport.

Which biofuels should count double?
The paragraph applies to biofuels produced from waste, residues and lignocellulose materials. Only raw materials that can not be used for a higher value application other than for generating electricity or heat, composting or using the ligno-cellulosic part as animal fodder, are eligible for double counting. Should a particular raw material have an alternative application, then a market analysis must be used to prove that there is an excess of this material available, before it may become eligible for double counting.

Demonstrate that biofuels meet the requirements for double counting
In order to proce that the biofuels are eligible for double counting, companies must send annual reports to the Ministry of IenM as part of the reporting on the mandatory share of biofuels (see Article 3 of the Decree on Renewable Energy in Transport). The information provided by the fuel suppliers must be accompanied by a so-called verification statement. Inspection bodies should issue this verification statement.
Inspection bodies use the verification protocol double counting of better biofuels. This protocol includes basic rules, procedures and guidelines for the verification of double-counted biofuels. The verification process consists of two phases. The first, preparatory, phase is where the auditor gathers all the necessary information from the producer (and, where necessary, from suppliers) and visits the production site. On the basis of this information, the auditor conducts a risk-analysis and draws up a verification plan. The second phase consists of the actual audit and random checks, with reports of the tasks implemented and the conclusions drawn. If all criteria have been met, the inspection institute issues a verification statement at the end of phase two.

Requirements inspection bodies must meet to issue a verification statement
Inspection bodies that issue an verification statement, must be accredited in accordance to the information standard NEN-EN ISO/IEC 17020, type A. In addition, the institutions should be accredited to the additional tasks relating to the double counting of biofuels by the Dutch Accreditation Council or the Accreditation Council has finished a preliminary process to achieve accreditation, even if the complete procedure is not yet finalised.

Ability to demonstrate sustainability using the verification protocol
In addition to double counting, the protocol also provides an opportunity to demonstrate the sustainability of biofuels made from certain feedstocks. These include biofuels made from residues and wastes not originating from agriculture, aquaculture, fisheries and forestry origin.
The verification certificate issued by an inspection body then serves both as a declaration that certain biofuels may count as double as as a statement that the sustainability of biofuels is shown. For other feedstock, such as grown lignocellulosic biomass, a separate sustainability statement has still have to be sent in, along with a statement relating to double counting.

History of the verification protocol double counting better biofuels
In August 2009, then SenterNovem, commissioned DEKRA to draw a verification protocol. After developing an initial draft protocol, DEKRA and Control Union implemented three trial investigations at biofuel producers. After evaluation of these pilots, the final protocol was adopted. During 2010 and 2011 the protocol was updated twice. The latest updated version is known as version 3.0, dated May 2011.
NLAgency is currently responsible for managing the verification protocol.

Further information
More information on double counting and the verification protocol can be found in the following documents:

If you have any questions about the double counting of biofuels, please contact NLAgency: Bregje van Keulen (

Oct 6, 2011  The biofuel blend has been supplied by Netherlands-based SkyNRG, [seeSkyNRG comment below] which has already supplied fuel for the
Jun 23, 2011  The fuel is produced by Dynamic Fuels and supplied by SkyNRG, the SkyNRG is advised by an independent Sustainability Board, consisting

Thai Airways conducts biofuel test flight

December 21, 2011     Thai Airways has flown a 20 minute flight from Bangkok to Chiang Mai, for the media, airline representatives etc, using partly biofuels, provided by Dutch company SkyNRG. It used 50% ordinary jet fuel and 50% recycled cooking oil from the US. SkyNRG says “SkyNRG does not commit to one single feedstock or technology. The sustainability of alternative aviation fuels depends on many factors and has to be assessed on a case-by-case basis.” There will be the first passenger flight tomorrow.  Click here to view full story…


SkyNRG – Sky Energy | The Fuel Future » Finnair to start flying on…/finnair-to-start-flying-on-sustainable-jet-fuel-out-of-

13 Jul 2011 – Finnair and SkyNRG have also agreed to jointly work on a structural supply chain, as both parties firmly believe that the adoption of “green