In April 2023, the government proposed to increase the use of biofuels, including to reach Denmark's climate target for 2025. Green Transition Denmark recommends that the 2025 target be met with other means, as the mixing of biofuels has an uncertain and, at worst, counterproductive effect on global greenhouse gas emissions. If biofuels are maintained as a means of action, it is crucial that the most climate-damaging fuels are sorted out.

Specifically, the Green Transition Denmark recommends

• Together with FDM and Drivkraft Danmark RGO recommends that the "calculation rules" for biofuels be updated so that all emissions count, including emissions from changes in land use (ILUC, Indirect Land Use Change). This will result in a technology-neutral market phase-out of the most climate-damaging biofuels.

• If this is not possible, RGO recommends that biodiesel based on crops (including rape) be phased out directly by law, as these have the greatest climate impact.

• In addition, RGO recommends that waste-based biofuels with limited raw materials (such as used frying oil and waste from animal production) be limited to levels corresponding to residual products collected in Denmark.

The vast majority of biofuels have a high climate impact

Biofuels made from crops that could have been used for food or animal feed are called 1st generation (1G) biofuels. In 2020, 87% of biofuels used in Denmark were 1st generation. They have a high climate impact because the raw materials used for biofuels cannot be used as food and feed at the same time, and therefore there is a need for new fields to grow food. When we in Denmark choose to grow rapeseed for biodiesel, there is ultimately a great risk that rainforests will be cleared to make way for new fields in South America or Southeast Asia. This is because it is especially in the tropics that new cultivation areas are included.

The result is that many of the biofuels grown on fields in Denmark and Europe have a very high indirect climate impact (the dark blue and orange columns in Figure 1). It is called "indirect land use change" or ILUC (indirect land use change). Often, the total climate impact from biodiesel in particular is even greater than for fossil diesel (the red line in Figure 1).

Implement the Danish Parliament's decision: Updating the biofuels' climate account

The Danish Parliament has already decided once that the most climate-damaging biofuels must be phased out, and that the "climate calculation rules" for biofuels must be updated, so that all emissions count, including ILUC emissions. Therefore, RGO, FDM and Drivkraft Danmark recommend that the parliamentary decision be followed up from 2020, as it will result in a market-based and technology-neutral phasing out of the most climate-damaging biofuels.

Should, contrary to the conclusions of a report commissioned by the Danish Energy Agency, it turns out not to be possible due to EU legislation in the area, the Green Transition Denmark recommends that a direct phase-out of crop-based biodiesel be introduced, as these biofuels have the greatest climate effect (see figure 1). This will be both in line with the agreement on the green transformation of road transport, which states that "it is crucial that first generation biofuels with high global emissions are phased out on an ongoing basis", as well as Article 26 of the Renewable Energy Directive.
There are also other solution models - Biogas Danmark has, for example, advocated for the distribution of 2G biofuels according to the German model.

Waste-based (2nd generation) biofuels are not unproblematic either.

Biofuels produced from waste are (unfortunately) not without indirect and problematic climate effects either. Eg. there is extensive fraud going on today where virgin palm oil (by far the greatest climate impact, see figure 1) is sold as used frying oil. In addition, biofuels from animal fat can lead to problematic substitution effects in the cosmetics and soap industry, where a lack of animal fat as a resource often leads to the use of palm oil. When that happens, the net effect of animal fat as a biofuel can be 1,7 times higher than that of conventional diesel.

Therefore, RGO recommends limiting the use of problematic 2nd generation biofuels, so that Denmark's consumption of used frying oil and residual products from animal production (dead animals and animal fat, etc.) is limited to levels corresponding to residual products collected in Denmark. In addition, a mapping of the various waste-based biofuel raw materials and their life cycle climate and environmental impact should be prepared, and on the basis of this, an assessment should be made as to whether further measures are necessary.

Facts about Denmark's consumption of biofuels

In 2020, more than 380.000 m³ of biofuels were used, of which 87% were based on crop and feed raw materials. Rapeseed oil accounted for almost 50%. In a conservative estimate, the hidden climate footprint (ILUC emissions) from biofuels in 2021 was 350.000 tonnes of CO₂, of which 300.000 tonnes of CO₂ from canola alone.

In 2020, the consumption of biofuel seized 100.000 hectares of agricultural land, of which rapeseed accounted for 76.000 hectares. This corresponds to respectively just under 4% and 3% of Denmark's agricultural area, and for comparison, 100.000 hectares corresponds to 140.000 football pitches or 2 x Falster. On the area you could:

• produce food to feed 2,5 million people
• or carry out a full green transformation of the entire Danish transport sector (road transport, shipping and aviation) via solar cells, batteries and Power-to-X.

Find all sources in the PDF below.