Summary

Transport & Environment (T&E) commissioned Cerulogy to assess the environmental impacts and sustainable potential of intermediate crops and crops grown on severely degraded land (SDL) within Europe. While these feedstocks are promoted as promising new sustainable biofuel sources under the revision of the Renewable Energy Directive (RED), research indicates they have limited potential for sustainable European production. The expansion of the RED Annex IX feedstock list in 2024 included these crops specifically to incentivise sustainable aviation fuel (SAF) production, with claims that they deliver environmental benefits without competing with food production. However, significant uncertainty persists regarding their precise definitions, required sustainability safeguards, and the practicalities of implementation.

Intermediate crops and crops grown on severely degraded land: what are they?

Intermediate crops are broadly defined as those grown during the off-season between two main crops, intended to maintain soil health and avoid triggering additional land demand. SDL crops are meant to restore low-quality soils affected by severe erosion or salinisation. Oilseed crops, such as rapeseed, camelina, carinata, and castor oil, are currently being developed due to existing processing infrastructure and lower production costs. Several pilot projects and industry plans are underway, including the CARINA project exploring trials across EU countries. Major firms are also active: Repsol and Bunge are collaborating on camelina and safflower in Spain, Saipol is expanding camelina cultivation in France, and Nuseed and BP are developing carinata in the Americas. However, investigations into projects like Eni’s castor oil cultivation in Kenya and Congo have raised concerns over limited local benefits and threats to food security.

These crops deliver uncertain environmental benefits

The RED mandates that biofuels processed in recent facilities must achieve at least 65% greenhouse gas (GHG) emission savings compared to fossil fuels. Cerulogy finds that emissions from Annex IX crop biofuels vary widely depending on cultivation practices. Fertilisers are the primary driver, accounting for up to 60% of total biofuel emissions due to fossil-fuel-based production and the release of nitrous oxide during application. While soil-friendly farming can improve savings, strong biofuel incentives may drive increased fertiliser use on main crops to maximise yields, potentially eroding overall carbon benefits. Biofuels from intermediate crops show direct emission savings of 34–64%, while SDL crops offer 50–73%. However, in worst-case scenarios, including indirect land-use change (ILUC) risks where food production is displaced, emissions could approach or even exceed those of fossil fuels. Even a modest 5% reduction in main crop yields could add up to 10 g CO2e/MJ in emissions, lowering the effective savings threshold.

The limited role of intermediate and SDL crops in SAF demand

Cerulogy identifies approximately 7 million hectares (Mha) suitable for intermediate oilseeds and 3 Mha for SDL crops in the EU, representing roughly 10% of current arable land. The combined plausible production potential is estimated at 0.2 to 1.7 million tonnes per year. This could produce a maximum of 1 Mt of bio-SAF, covering 40% of the EU’s 2030 bio-SAF demand. However, this supply serves only as a short-term bridge; by 2050, these crops are estimated to cover a mere 4% of ReFuelEU’s projected demand of 26 Mt. There is also a significant risk of import dependency. Potential in the USA and South America is far higher, with up to 50 Mha identified for camelina and carinata in Argentina and Brazil alone. Large-scale production abroad could outcompete domestic producers and would be difficult to track and verify against European environmental safeguards.

Certification, monitoring and transparency will be key to ensure only sustainable feedstocks end up in European biofuels

To prevent fraud and ensure sustainability, the EU must establish robust standards in upcoming regulations. Past experiences with used cooking oil (UCO) and palm oil mill effluent (POME) have highlighted systemic weaknesses in audit processes. Improvements should include a dedicated fraud investigation unit at the EU level, market monitoring, and increased transparency of audits. T&E recommends moving away from private, industry-run voluntary schemes toward national and EU-level regulation to ensure that only genuine intermediate and SDL crops enter the supply chain.

T&E recommendations

T&E maintains that the promotion of these feedstocks must be secondary to strong, measurable safeguards. Recommendations include ensuring intermediate and SDL crops do not impact food production or increase fertiliser and pesticide use. Biofuels should be required to achieve at least 70% GHG savings, consistent with thresholds for renewable fuels of non-biological origin. Policy should prioritise local feedstocks to prevent import dependency and fraud. Finally, the use of these crops should be limited exclusively to hard-to-abate sectors like aviation, serving as a temporary bridge while long-term decarbonisation relies on scalable solutions like green hydrogen-based fuels.