Ladies and Gentlemen ,

the ongoing defence of biofuels is refreshing and the commitment to its development encourages our members to include the bio component in our transport fuel business. Concerning the relevant proposal for a RES directive there are some important issues that fall under the headings of sustainability, competitiveness and security of supply.

Sustainability

Pronouncements to choose winners by creating a subdivision for e.g. hydrogen are - from our point of view - a dangerous route. We also fear that the default values set for biofuels does not take sufficient account of by-products (such as fermented substrates of plant and animal origin). It is also important that new oil discovery techniques, e.g. from oil sands, must lead to a higher level against which the default values are measured. A review mechanism is necessary.

Likewise, it is a pity that in the effort to achieve greater sustainability the idea of demanding a higher bio content in diesel than regulated by EN 590 has been neglected. Aims to restrict biofuels strictly to Eurostat and IPCC definitions pose a threat to the development of new biofuels in this otherwise rapidly growing industry.

Competitiveness

The functioning of the internal market is a key prerequisite for Europe's competitiveness. So we miss all the more some protection of the internal market in biofuels and transport fuels against national rules regulating the details of the RES directive. It is our strongly held conviction that the key elements of the control mechanisms should not be left to the member states under the principle of subsidiarity.

For the functioning of the internal market, certification of sustainability in one member country must become accepted on an EU-wide level. After all protectionism goes directly against market liberalisation!

Security of supply

Security of supply is boosted by internal biofuel production and a greater diversity of sources. And it would greatly enhance our supply options if the EU quickly agreed with countries such as Brazil, Indonesia and Malaysia on specific default values for production in these areas. As European independent oil traders we continue to support the aims of the RES directive, but we also urge all parties involved that our concerns receive some attention.

The most important issue for us is that whatever results from the ongoing deliberations will be clear, consistent and easy to execute, given the realities of the liquid fuel market. We would like to stress that we clearly see the RES directive falling under Article 95 of the EC treaty. We see the need for harmonisation in the field of bioenergy, especially for sustainability criteria, because non-harmonised criteria prevent trade and competition in the internal market.

Thank you very much for your attention!