Perspectives of non-EU countries on EU rules on sourcing renewable electricity for RFNBO production

The requirements set out in the Delegated Acts (DA) “apply regardless of whether the liquid and gaseous transport fuel of non-biological origin is produced inside or outside the territory of the [European] Union” (Article 6, DA on Article 27). But can these ambitious requirements be met by projects outside of the EU and what are potential obstacles?

The PtX Hub joined forces with Hinicio and Dii Desert Energy to analyse whether the requirements can actually be met in the regulatory system of countries outside of the EU. Therefore, we conducted interviews with project developers and other industry partners and aggregated the feedback received from a questionnaire designed to capture obstacles and open questions concerning the DA on Article 27.

It became clear that there are still unclear aspects in the exact application and interpretation of the criteria in the non-EU context (e.g., definitions of bidding zones or investment aid), but at the same time no criterion was interpreted as a “show-stopper” that would be impossible to fulfil. Below feedback and open questions are summarised and structured by the specific Articles in the DA.

Please be aware that the summary of feedback in the attached document does not necessarily reflect a position of the PtX Hub and of the commissioning institutions or the implementing agency. It rather aims at providing aggregated comments and questions from multiple perspectives from non-EU countries. No feedback directly from the PtX Hub, Hinicio and Dii is included.