Union database to cover relevant data from the point of production or collection of the raw material used for the fuel production
FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe has taken notice of the Commission’s Delegated Regulation on extending the scope of the data to be included in the Union Database (UDB) as it can potentially be an important tool for increased transparency under the Renewable Energy Directive (RED). Nonetheless, we believe that the current proposal will apply excessive regulatory burdens on biowaste traders, biofuel producers and users which can impede its effectiveness. Comprehensive waste regulation already exists to document the origin of the waste with sufficient traceability as well as a system of proof for sustainability criteria. Hence FEAD considers the new proposal onerous.
Additional certifications at national level already exist in the different Member States and our concern is that the new rules would create duplicative reporting obligations for economic operators, requiring compliance with both national systems and UDB, with strong penalties for any delays or missing information. Moreover, the national certification systems already experience implementation issues currently. For example, when standard-data or solid material values for the calculation of bio-fuel-emissions from specific organic waste streams are allocated wrongly and then combined with missing correct waste-codes. As long as these implementation issues persist, no additional EU requirements should be applied.
In particular, the additional data requirements included in the proposal are unnecessarily burdensome and only provide limited traceability and transparency of the biofuel production in the EU. For example, article 3 of the proposal requires the registration of economic operators in the UDB voluntary and national schemes, while articles 4 and 5 of the proposal require the economic operators to register the data of the initial stock and all the transactions. This means that the economic operators would be obliged to report the same information to both schemes, the national or voluntary one and the UDB. A solution to this duplication of administrative work would be either requiring the national or voluntary schemes to report the transaction data to the Union Database directly or creating an obligatory link between the national or voluntary scheme’s databases and the Union Database.
Moreover, we believe that the strict data deadlines mentioned in article 5, paragraphs 1 and 3, namely three working days to enter transaction data in the UDB and three working days for the buyer to accept or reject the transaction are unrealizable. The value chain for the production of biofuels is highly complex and includes a lot of economic operators, especially if required at every waste collection stage, therefore, these deadlines should be extended to 30 days in order to accommodate the complexity of the value chain.
In line with the aforementioned, article 6 proposes a disproportionate penalization when it comes to missing data or a delayed updating of relevant certification, in the form of a suspension of the active status of the economic operator concerned within the Union Database. This is excessive and should urgently be amended to include more business-friendly options.
FEAD urges a more streamlined approach, advocating for data integration between national schemes and the UDB to ensure the Regulation is effective without overloading with unnecessary administrative burdens the involved economic operators. Especially for economic operators that utilise waste, the current information requirements are more than sufficient.
FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 19 national waste management federations and 3,000 waste management companies. Private waste management companies operate in 60% of municipal waste markets in Europe and in 75% of industrial and commercial waste. This means more than 320,000 local jobs, fueling €5 billion of investments into the economy every year.