In response to the increased global demand for oil for the production of biodiesel, natural lands are cleared to expand croplands. As natural lands store carbon in their soil and plants, the clearance of these lands translates to a net increase in greenhouse gas emissions, known as the ILUC effect. This ILUC effect can therefore be considered as an initial debt, which is amortised over time.

The debate about the ILUC science has considerably affected the biofuel sector in the EU, tarnishing the reputation of this promising industry and putting previous investments at risk.

There is no existing consensus on the ILUC science in the international scientific community

The various studies conducted thus far have demonstrated considerably different conclusions.
For example, the study conducted by the California Air Resources Board (CARB) in 2015 established that ILUC values for rapeseed biodiesel are four to five times lower than those established by the latest study commissioned by the European Commission (GLOBIOM).

The Low Carbon Fuel Standard of the CARB, which aims to reduce GHG emissions from transport, is based on an economic model approved by thorough independent academic counter-expertise. These findings come as the result of 7 years of research on the carbon efficiency over the whole life cycle of the different fuels.

This new study sets an ILUC value of 14.5gCO2eq/MJ for rapeseed biodiesel. These results are substantially different from those of the ILUC Directive (which gives an ILUC value of 55g for rapeseed) and the recent GLOBIOM study (which established an ILUC value of 65g).
At the EU level, however, the evaluation of ILUC is based on the IFPRI’s study (International Food Policy Research Institute, 2011), which has been subject of complaints to the European Ombudsman for its lack of transparency.

The GLOBIOM study, which was finalised in November 2015, is even more opaque. Within the study, neither the model, the data nor the hypothesis are available, nor have the results obtained been assessed by independent experts. In this regard, the European Commission has recently recognised, in an official letter, the need for peer reviewing GLOBIOM, and underlined that, as long as the model has not been made public, no review would meet the quality requirements established by academic standards.

ILUC has to be considered as an investment amortised over time

ILUC emissions are believed to occur when additional land is put on use to compensate for additional biofuels production. They are initial emissions, which can be defined as an “ILUC debt”, since, over time, biofuels that are replacing fossil fuels in the EU transport market allow for carbon savings that eventually compensate the initial ILUC emissions. For these reasons, we consider that ILUC factors should continue to be limited to a reporting exercise, and not subject to accounting obligations.
The number of years over which the ILUC effect is amortised is only a convention. When taking into account the real emissions savings of rapeseed biodiesel, the ILUC effect is amortised over 5.7 years (based on CARB calculations), and 14.5 years (based on the ILUC Directive).

Moreover, the Common Agricultural Policy required the use of fallow lands before 2008 due to food over-production, allowing the use of these lands for non-food products. Around 6.5 million tonnes of biodiesel produced in Europe come from the use of these fallow lands and, as such, do not have any ILUC effect. In addition, 3 million tonnes of biodiesel are produced from waste and residues (used cooking oils and animal fats). These also do not have an ILUC effect. The remaining 2.5 million tonnes of European biodiesel may have an ILUC effect.

As the production of biodiesel will remain stable in the future – notably because of the ILUC Directive – this effect will be amortised in 2030.

As a result, the use of biodiesel as a replacement to fossil fuels in transport will save 952 million tonnes of CO2 emissions by 2050 (when using the ILUC Directive figures), or 1013 million tonnes of CO2 emissions (when using the CARB calculations).

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