Planned High-ILUC Classification of Soybean Oil - Münzer Calls for a Differentiated Feedstock Assessment Instead of Blanket Categorization

• Blanket classification of soybean oil as “high ILUC risk” falls short of market realities
• Agricultural by-products and protein crop co-products are integral to sustainable circular systems
• Technology neutrality and investment certainty must not be undermined

The planned classification of soybeans and soybean oil as so-called “high ILUC risk” feedstocks at the European level is causing growing concern within the industry. The proposed reassessment under the EU Renewable Energy Directive (RED) aims to prevent indirect land-use change (ILUC) and strengthen the protection of forests, peatlands, and other carbon-rich areas.

Münzer Bioindustrie GmbH, a long-standing European producer of sustainable, waste- and residue-based biofuels and an active participant in the European renewable fuels value chain, takes a critical view of a blanket and undifferentiated classification of soybean oil as a high-ILUC feedstock.

Climate Policy Requires Differentiation

“Climate protection – yes. Blanket classification – no.” This summarizes Münzer’s clear position. A general categorization of soybean oil as high ILUC risk does not adequately reflect the realities of sustainable production and integrated value chains. In particular, the energetic use of agricultural co-products from protein crop cultivation, grassland management, and livestock farming is a core element of functioning circular economy systems.

From Münzer’s perspective, the EU should explicitly recognize and anchor the energetic use of agricultural co-products as a strategic component of both its energy and agricultural policy.

“Renewable energy derived from agricultural co-products must have clear priority within Europe’s energy and climate framework. Utilizing these streams replaces fossil energy and reduces emissions. As such, it must be fully recognized toward climate targets,” emphasizes Ewald-Marco Münzer, CEO of Münzer Bioindustrie GmbH. At the same time, regulatory barriers for the use of organic residues should not be further tightened.

Feedstock Base and Technology Neutrality Are Critical for the 2040 Climate Target

In light of the EU Member States’ commitment to reduce greenhouse gas emissions by up to 90 percent by 2040 compared to 1990 levels, a broad, fact-based, and technology-neutral approach is essential. Only differentiated evaluation criteria and reliable regulatory frameworks for sustainable feedstock pathways will enable the level of investment and innovation required to achieve these targets.

“We clearly support ambitious climate objectives, particularly with regard to the EU’s 2040 climate target. However, regulatory instruments must be designed objectively, based on sound data, and with appropriate differentiation. A blanket classification of soybean oil as high ILUC risk sends the wrong signal in the context of achieving these goals,” concludes Ewald-Marco Münzer.