New rules are in place that have to be followed before farmers can access the biofuels market. Crops adviser Chloe Lockhart looks at the changes, how they affect you and what the NFU has done to help farmers.
With the upcoming introduction of RED II, there have been several changes to Red Tractor Standards for crops. These have been:
- The requirement for the location of grain stores to be recorded by the red tractor assessor with What3Words
- Prove that land used to grow grains destined for biofuels has not been converted from ‘highly biodiverse grassland’ since 2008
- The requirement for growers to keep a mass balance sheet outlining all grain in and all grain out
These have occurred for Red Tractor Crops producers to maintain access to the renewables and biofuels market under the Renewable Energy Directive (RED).These standards have been implemented now due to the changes to RED II at an EU level. These changes are effective from the 1 July. We have worked together with other stakeholders to get a more proportionate application of mass balance, and the NFU have worked closely with Red Tractor (RT) to ensure growers can remain RED compliant with the least possible disruption.
What is RED II?
The Renewable Energy Directive (RED) was revised in 2018 and is coming into force this year as RED II, including updated targets for EU member states and the EU as a whole. RED II is focused on sustainability of biofuels and renewable transport fuels.
Haven’t we left the EU?
Yes, but lots of our grain still goes for export as raw materials for biofuel production and we even export biofuels themselves. In addition, the UK has its own fuel targets under the Renewable Transport Fuels Obligation, which ensures a certain per cent of fuel supplied is from renewable sources and therefore includes a proportion of UK grain.
Why is RED II in RT?
Red Tractor has been certifying growers as RED compliant for 10 years, enabling growers to access markets for biofuels. As this legislation has been updated RT is essentially doing the same thing, but some of the details have changed. This ensures producers still have access to this market without any additional audits.
What has changed? What do I have to do for RED II?
Under RED II, there is no partial compliance option (as some growers will have been before) and therefore to be RED II compliant your whole farm must meet the criteria. If you were partially compliant then Red Tractor will have already been in touch and many of you have been re-assessed as being fully compliant. There are a couple of additional changes outlined below.
RED II now requires growers to keep a mass balance sheet outlining all grain in and all grain out. The NFU and RT have questioned the aim of this with the European Commission as the removal of partial compliance make this essentially redundant, but the commission has stood firm. Growers should have this data to hand, and it is just a case of demonstrating due diligence to RT.
Mass balance (or a more stringent system) is the only chain of custody system currently permitted under the RED. Read Renewable Transport Fuel Obligation Guidance Part Two Carbon and Sustainability. Please see the statement from RT below on the security of this data:
“It’s important to know that Red Tractor won’t collect mass balance calculation data. Your assessor will ask to see it to make sure the record of what was stored on site and what left the site matches. This is an EU requirement as part of its aim to prevent double counting or fraud”.
RED II also requires a precise location of stores in which your grain is stored, this may be through either a What3Words code or a longitude and latitude reading. In physical inspections, the assessor will gather this information themselves (you might not be aware of them taking them) but in a virtual inspection you are likely be required to provide it for them.
As with RED, RED II requires proof that land used to grow grains destined for biofuels has not been converted from ‘highly biodiverse grassland’ since 2008. The NFU, Red Tractor and AIC have been working with Defra to establish a reasonable and suitable definition for this.
Why have changes to Red Tractor not been included in the Version 5 consultation?
The changes which have been made on the mass balancing, grain store locations and land conversation have all been set by the EU, which will be effective from the 1st July 2021. Red Tractor have made the decision with stakeholders to embed these standards to ensure that Red Tractor continues to be recognised by RED II and producers have access to this market. The Red Tractor version 5 standards will not go live until November 2021, so this would have been too late to include the changes to RED II.
What has the NFU done to help farmers?
The NFU has had farmer representatives on the TACs throughout the consultation process on the V5 standards, this includes working to remove standards not relevant for the arable sector.
In terms of RED II, stakeholders have worked together to get a more proportionate application of mass balance and the NFU have worked closely with Red Tractor to ensure growers can remain RED compliant with the least possible disruption.
Why should I be RED II compliant?
To supply grain into biofuel supply chains, you must be RED II compliant. Not being so may restrict the end user or destination for your grain.
In 2020, of the 246 million litres eq. of verified renewable fuel produced from UK origin feedstock, the most common by feedstock and fuel type was bioethanol from wheat (57.2 million litres, 23% of renewable fuel from UK origin feedstock). Read the Renewable fuel statistics 2020: Fourth provisional report on GOV.UK.
There is potential for UK wheat to supply more of the renewable fuel requirements and with the rollout of E10 petrol expected in September of this year, ensuring RED II compliance is more important than ever to ensure growers can supply into the UK biofuel supply chain and secure the benefits of an increased domestic demand for feed wheat.