The Biobased and Renewable Products Advocacy Group (BRAG) helps members develop and bring to market their innovative biobased and renewable chemical products through insightful policy and regulatory advocacy. BRAG is managed by B&C® Consortia Management, L.L.C., an affiliate of Bergeson & Campbell, P.C.

By Lauren M. Graham, Ph.D.

On March 31, 2017, AkzoNobel, a member of BRAG, announced the launch of an online tool that uses e-certification to monitor the biobased content of products.  Companies that sign up to use the online platform will be able to exchange biobased material certificates for everything from base ingredients to finished products.  The online tool eliminates the need for separate, external biobased certifications at various points along the supply chain by allowing companies to transfer the certificates electronically.  According to AkzoNobel, tracking the exact amount of biobased raw materials used throughout the value chain will enable producers and consumers to purchase more sustainable products and move towards a more circular economy.  AkzoNobel partnered with Advanced Biochemical (Thailand) Co., Ltd. (ABT) and EY on the project, which is currently in the pilot phase, to encourage transparency and sustainable chemistry.


On March 24, 2017, Neste, a member of BRAG®, announced its approval of draft proposals by the Swedish government regarding mandated reductions in traffic fuel emissions and the continued tax exemption for high-blended biofuels.  By 2030, the government aims to reduce carbon emissions from transportation by 70 percent.  In addition to reducing carbon emissions, the ambitious targets and long-term perspective will help support innovation and investments in biofuels.  Neste, which has a strong focus on developing cost-efficient technologies to convert forest residues into biofuels, stated that the substantial amount of forest-based raw materials in the country will likely play a key role in achieving the proposed goals.

The 2017 Biobased and Renewable Chemicals Conference, which has been organized by the Delaware Sustainable Chemistry Alliance (DESCA) and supported by the American Chemical Society (ACS) Green Chemistry Institute, is a two-day event that will focus on the emerging landscape of technologies that are replacing fossil fuel-based raw materials and the major challenges and opportunities facing the industry.  The event features interactive panel discussions, keynote speakers, workshops, and networking opportunities with industry experts and thought leaders, including:
Mike Gudgeon, Technical Manager, PBF Energy;
Dr. Seetha Kammula-Coleman, President, STRIDE;
Dr. Stanley Merritt, Sustainability Leader, The Chemours Company;
■  Dr. Tim Mueller, North American Research Director, DuPont Science & Engineering Operations;
■   Dr. Erica Nemser, CEO, Compact Membrane Systems;
■  Lori Palmer, Chief Business Ventures Officer at Trellist Marketing & Technologies; and
■  Dr. Bryan Tracy, CEO & Co-Founder, White Dog Labs.

Lauren M. Graham, Ph.D., Manager of BRAG®, will be attending the conference and will be pleased to discuss questions attendees may have about the regulatory issues facing biobased and renewable chemicals.  Registration is available online.  We look forward to seeing you there.


On March 8, 2017, the Biotechnology Industry Organization (BIO), a member of the Biobased and Renewable Products Advocacy Group (BRAG®), announced that nominations for the fourth annual Rosalind Franklin Award for Leadership in Industrial Biotechnology were being accepted.  The award, which recognizes an outstanding woman in the industrial biotechnology sector who has made significant contributions to the advancement of the biobased economy and biotechnology innovation, will be presented during the plenary session at the 2017 BIO World Congress on Industrial Biotechnology in Montréal, Québec, Canada.  Past recipients of the award include Dr. Debbie Yaver, Director of Expression Technology, Genomics and Bioinformatics at Novozymes, Dr. Jennifer Holmgren, CEO of LanzaTech, and Anna Rath, President and CEO of NexSteppe.  Nominations will be accepted until March 24, 2017


On March 2, 2017, Kathleen M. Roberts, Executive Director of the Biobased and Renewable Products Advocacy Group (BRAG®), participated as a panelist alongside four other trade associations in the “Domestic Policy Forum” at the 2017 Advanced Bioeconomy Leadership Conference (ABLC2017).  Ms. Roberts discussed the challenges facing the bioeconomy, including the implementation of the amendments to the Toxic Substances Control Act (TSCA), issues with the TSCA nomenclature system, and the potential for increased scrutiny of renewable products under the current Administration, as well as the work being done by BRAG to address these challenges and to level the playing field for biobased chemicals.  If companies wish to ensure equitable regulations for biobased chemicals and products, they should consider joining BRAG to assist with future engagement with EPA.

On March 2, 2017, Richard E. Engler, Ph.D., Senior Chemist for Bergeson & Campbell, P.C. (B&C®), presented “New TSCA: How Renewable Chemicals Survive and Thrive” at ABLC2017.  Dr. Engler presented as part of the Renewable Chemicals Summit and provided an overview of amended TSCA with a focus on the fundamental changes that will impact the bioeconomy.  Amendments to TSCA Section 5 require EPA to make an affirmative determination on every new chemical review, which has resulted in significantly more regulations for new chemicals.  Additionally, under amended TSCA, Congress has the authority to preempt state action, and EPA has increased testing authorities, as well as the authority to determine chemical substances as equivalent and the authority to increase fees under Sections 4, 5, 6, and 14.  For a copy of this presentation, please contact Dr. Engler at .(JavaScript must be enabled to view this email address).



On January 17, 2017, Neste, a member of BRAG, announced a research and development cooperation with Bioenergy La Tuque to study the potential of using forest residues as a raw material in biofuel production in La Tuque, Canada.  The cooperation will expand Neste’s raw material selection, which currently consists of ten raw materials for renewable product production, and will increase the use of waste and residues.  The project will assess the biomass availability at a competitive cost, identify technology bottlenecks in process lines, and validate the acceptable level of risk.


The Algae Biomass Summit is the largest algae conference in the world.  This is where leading producers of algae products go to network with industry suppliers and technology providers, where project developers converse with utility executives, and where researchers and technology developers rub elbows with venture capitalists.  Biobased and Renewable Products Advocacy Group (BRAG®) affiliate Bergeson & Campbell, P.C. (B&C®) is a proud sponsor.  B&C Senior Chemist Richard E. Engler will chair “Legal, IP, and Regulatory Challenges and Opportunities” on Tuesday, October 25, 2016.


On July 12, 2016, Neste, a BRAG member, published "4 Reasons Why The World Needs Biofuels," highlighting the positive results of seeking alternative, low-carbon sources of renewable energy. The article mentions that "biofuels offer a solution to reduce carbon emissions of traffic when other solutions, such as switching to electric vehicles, is not an option due to high vehicle costs or lack of vehicle charging network." Biofuels also help to combat climate change, respond to higher energy consumption, safeguard energy security, and best utilize scarce resources.


Scientists, executives, investors, and media representatives gathered in San Diego, California on Monday evening for a fascinating and wide-ranging panel discussion on current issues facing bioeconomy leaders and innovators. The reception, hosted by the Biobased and Renewable Products Advocacy Group (BRAG®), Bergeson & Campbell, P.C. (B&C®), and Industrial Biotechnology, included panelists Christophe Schilling, Ph.D., Founder and CEO of Genomatica; Blake A. Simmons, Ph.D., Chief Science and Technology Officer and Vice-President of the Deconstruction Division of the Joint BioEnergy Institute; and Anna Rath, President and CEO of NexSteppe and recipient of the 2016 BIO Rosalind Franklin Award honoring outstanding women in the field of industrial biotechnology. The panel took advantage of the relaxed atmosphere of Southern California and sat at a table amongst the invited guests to field questions from moderator Richard E. Engler, Ph.D., Senior Chemist with B&C, and from many of the attendees.

Asked to name the most important factor in the success of their respective companies and labs, each panelist mentioned the quality of the people on their scientific and management teams as being more critical than any other factor. In response to the question "[d]o you discover a product and then find or create a market for it, or do you notice a market opportunity and then develop a product to meet it?," all three responded that they start with a market focus and seek ways to satisfy that market need. When asked about whether regulatory or policy hurdles have impacted them at all, Ms. Rath mentioned those concerns as a factor in NexSteppe's approach to product lines and bases of operation. By creating different sorghum varieties using traditional breeding and hybridization techniques, NexSteppe can optimize its products for biofuels, biobased chemicals, bioenergy, and biogas so that its operations are not overly impacted by any one policy or regulatory change, such as the Renewable Fuel Standard (RFS) in the U.S. Dr. Schilling identified regulatory issues as one of the reasons Genomatica initially focused on applying its bioengineering processes to create sustainable versions of existing industrial chemicals, that is, chemicals already in commerce that would not face regulatory scrutiny as a new substance.

After lamenting the lack of scientists in politics, a guest somewhat jokingly asked if anyone on the panel would consider running for office. While fervently denying any chance of that (eliciting an audience member to wonder if this was only a "Paul Ryan-esque disclaimer?"), the panelists went on to point toward the many outstanding scientists working at federal agencies, in the White House Office of Science and Technology Policy (OSTP), the National Science Foundation (NSF), and in other advisory roles. Dr. Simmons particularly lauded the scientists in the 17 U.S. Department of Energy (DOE) National Laboratories, who not only create scientific breakthroughs for the benefit of U.S. business and citizens, but also advise political leaders on science issues, mentioning that after the reception, he needed to work on notes for a briefing he will give Energy Secretary Ernest Moniz later in the week. At the conclusion of the scheduled panel portion of the evening, many guests stayed to continue in conversation with the panelists, attendees, and sponsors.


In less than two months, renewable fuel and biobased chemical companies that have successfully moved from research and development to commercialization will be required to respond to the U.S. Environmental Protection Agency's (EPA) Chemical Data Reporting (CDR) rule under the Toxic Substances Control Act (TSCA). This may come as a surprise to some biobased chemicals companies that are under the misperception that they are not regulated under TSCA. This is simply wrong. Unless otherwise regulated as a pesticide, food, food additive, drug, cosmetic, or nuclear material, biobased chemicals used for a commercial purpose, including fuels regulated under the Renewable Fuel Standard program, are subject to the rules and requirements under TSCA. Companies that do not comply are subject to enforcement actions and significant fines of up to $37,500 per violation, per day.

The reporting window for the 2016 CDR is June 1, 2016, to September 30, 2016. CDR reporting includes detailed information on volumes of chemicals produced, imported, used on site, and exported. It also requires information on amounts and functions for downstream uses in industrial, commercial and consumer applications. CDR reporting is further complicated with numerous potential exemptions that must be carefully analyzed for applicability. Bergeson & Campbell, P.C. (B&C®) is hosting an informational webinar on CDR reporting on May 3, 2016, from 1:00 p.m. - 2:00 p.m. (EDT). All impacted stakeholders are invited to participate, but companies new to the TSCA arena and CDR reporting are urged to attend.

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