Sustainable biofuels are an important tool for the decarbonisation of transport. This is especially true in aviation, maritime, and heavy-duty sectors with limited short-term alternatives. Their use by conventional transport fleets requires few changes to the existing infrastructure and engines, and thus their integration can be smooth and relatively rapid. Provision of feedstock should comply with sustainability principles for (i) producing additional biomass without distorting food and feed markets and (ii) addressing challenges for ecosystem services, including biodiversity, and soil quality. This paper performs a meta-analysis of current research for low indirect land use change (ILUC) risk biomass crops for sustainable biofuels that benefited either from improved agricultural practices or from cultivation in unused, abandoned, or severely degraded land. Two categories of biomass crops are considered here: oil and lignocellulosic. The findings confirm that there are significant opportunities to cultivate these crops in European agro-ecological zones with sustainable agronomic practices both in farming land and in land with natural constraints (unused, abandoned, and degraded land). These could produce additional low environmental impact feedstocks for biofuels and deliver economic benefits to farmers.

Producers of biofuels for the EU market may use ‘low ILUC-risk’ certification as evidence that they have not deprived other economic sectors of feedstock material, and hence that indirect land use change (ILUC) emissions have been avoided. At present, the uptake of low ILUC-risk certification is limited to a handful of niche projects, as there is little commercial incentive for obtaining certification. This may be considered a missed opportunity, because low ILUC-risk farming methods offer a range of sustainability co-benefits beyond the mitigation of ILUC emissions. This paper examines the policy foundations of low ILUC-risk and develops policy recommendations that would aim to confer advantages to low ILUC-risk biofuels. Some weaknesses in the low ILUC-risk system’s environmental safeguards are also highlighted.

The “low indirect land use change risk” (“low ILUC-risk”) concept was developed to assess whether crop-based biofuels would compete with other land uses and cause the expansion of agricultural land. At the core of low ILUC-risk is an “additionality principle”, which requires that biofuel feedstock receive special treatment only if it is produced over and above the business-as-usual baseline. This paper examines and tests the European Commission’s methodology for calculating the baseline for yield improvement projects, by applying it to publicly available Eurostat data at national and NUTS2 scales. We assess from a statistical perspective how variation in regional yield trends would lead to differences in the long-term outcomes of low ILUC-risk certification; we conclude that, as currently designed, the methodology would over-state the amount of additional production in some cases and could hence incentivise the diversion of crops from other uses into the biofuel sector. We introduce the terms “tailwind additionality”, “headwind additionality”, and “additionality ratchet” to characterise the phenomena which contribute to this outcome. Our results lead us to recommendations which may enhance both the attractiveness and the robustness of the low ILUC-risk system.