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 Lynn L. Bergeson

On April 24, 2018, UPM Biofuels announced that its crude tall oil (CTO) feedstock for BioVerno renewable fuels had received the first ever RSB (Roundtable of Sustainable Biomaterials) low ILUC (indirect land use change) risk certification. This certificate confirms that the amount of CTO used to make BioVerno is sustainable and not diverted from other uses, resulting in little to no ILUC risk. Rolf Hogan, Executive Director of RSB, said of the certification:

The RSB is proud to count UPM among the visionary biofuel producers that are not only RSB certified for their wood-based biofuels in Lappeenranta, Finland and Brassica carinata cultivation in Uruguay, but have now received the world's first RSB low ILUC risk certification. This shows that their biofuels have not only achieved the requirements of our rigorous standard for sustainability, they have also been verified under this module, meaning they have minimal or zero risk of indirect impacts - such as deforestation or increased food prices - elsewhere in the world. With reduced greenhouse gas emissions which meet the highest standards of sustainability and transparency, as well as demonstrating the lowest impacts on nature and food production, these are the biofuels of the future

Tags: UPM, Biofuel, ILUC, RSB


On March 11, 2016, a consortium made up of Ecofys, the International Institute for Applied Systems Analysis (IIASA), and E4tech announced that the final report on the Land Use Change (LUC) study is now available online. The study was commissioned and funded by the European Commission (EC) and was focused on using the GLOBIOM model to determine ILUC associated with the ten percent renewable energy use target for transportation mandated by the European Union's (EU) 2020 goals. The report, The land use change impact of biofuels consumed in the EU, determined LUC emissions results as well as total LUC caused by the EU 2020 biofuel mandate. Total LUC was determined to be 8.8 million hectares (Mha), with 8 Mha consisting of new cropland, and 0.8 Mha made up of short rotation plantations on existing cropland. LUC emissions were tested by scenario and divided by biomass and biofuel type. Conventional biodiesel feedstocks were found to have high LUC effects, with conventional ethanol feedstocks having lower LUC emissions, and advanced biofuels produced from short rotation crops or perennials having negative LUC emissions.

The credibility of the study has been questioned by several parties, including the EC itself. The European Biodiesel Board (EBB) stated that the study is based on "a model which has still not been disclosed nor validated by peers," resulting in reservations of the scientific reliability of the research. The California Air Resources Board had previously tested Indirect Land Use Change (ILUC) values for biodiesel in an open and peer-reviewed process, and found values four to five times lower than those found in the EU study. This disparity has lead to the EBB and the EC stating that a "scientific peer review of the [Ecofys] study would be desirable" and that "if the model structure cannot fully be disclosed, such a review cannot meet the quality standards set by academic rules." The project has been completed, but feedback and comments will be collected at .(JavaScript must be enabled to view this email address).


On June 1, 2015, the Roundtable on Sustainable Biomaterials (RSB) voted to pass the new Low iLUC Risk Biomass Criteria and Compliance Indicators standard. The standard was approved as an optional module for those undergoing RSB certification, and will be used to show that biomass is produced with low indirect land use change (iLUC), resulting in little impact on food production and biodiversity. It is important to demonstrate how iLUC in order to prove that a biobased alternative to a traditional product is better for the environment than the original product. iLUC takes into account the indirect carbon emissions released due to expansion of croplands for biomass production, in part due to clearance of forest areas.