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US shows feedstock resilience while Germany low Biodiesel blend could lead to end of Double counting

Writer's picture: Henri BardonHenri Bardon



The U.S. biofuel market showed signs of resilience this week as RINs recovered to 79 cents per gallon, with BOGO climbing nearly 4%, primarily due to weakness in the broader energy sector. This modest recovery in RIN prices comes as EMTS data for January reveals a troubling production decline of at least 20% compared to previous periods, signaling that policy uncertainty is already having tangible impacts on the market. Against this backdrop, the recently released EIA December 2024 data highlights a significant transformation in feedstock utilization patterns throughout 2024. Comprehensive analysis of the complete feedstock mix shows vegetable oils increased from 72.8% to 74.0% of total feedstock usage between H1 and H2, while animal fats and waste oils correspondingly decreased from 27.1% to 26.0%. Within this broader shift, individual feedstocks showed varying trajectories. Looking at the EIA data for December 2024, soybean oil was the dominant feedstock at 1,097 million pounds (representing approximately 34% of the total mix), with 697 million pounds used in biodiesel plants and 400 million pounds in renewable diesel plants. Tallow followed as the second-largest feedstock at 707 million pounds (about 22%), while corn oil was the third-largest at 524 million pounds (around 10%). Yellow grease was the only feedstock to register a volumetric decline (-11.2%) in H2 compared to H1, highlighting the shifting preferences within the industry. Looking at the breakdown between production methods, biodiesel plants reduced their soybean oil usage by 10.7% (from 20.0% to 15.4% of their mix) while increasing corn oil by 23.9%, suggesting a strategic realignment of resources in response to evolving market conditions. Renewable diesel producers, conversely, increased both soybean oil (50.7%) and canola oil (38.5%) usage in H2, while reducing corn oil by 4.3%. The December data shows several specialty feedstocks declined in absolute volumes year-over-year, with canola oil (-8.3%), corn oil (-3.9%), and tallow (-5%) all showing reductions despite overall growth for the full year. These declines in specialty fats feedstocks appear strategically timed, likely representing industry preparation for the implementation of the 45Z clean fuel production credit and winter production. Producers appear to be positioning themselves to optimize their feedstock slate once the credit's parameters are finalized, demonstrating forward-looking operational planning despite the broader uncertainty. These complex shifts in feedstock utilization highlight the industry's remarkable adaptability in response to changing market economics and regulatory challenges.


The Southeast Asian palm oil sector has experienced substantial volatility following the Palm Oil Conference in Kuala Lumpur, with POGO dropping from +328 to +280 over the past week as palm oil prices tumbled by $50/MT to $930/MT for May delivery. This dramatic price decline has triggered domestic concerns across Malaysia, where elevated local prices have created considerable market tension. The situation appears equally challenging in Indonesia, which continues to grapple with the fallout from the Pertamina scandal while facing similar market pressures. These regional disruptions in the world's largest palm oil-producing nations signal potential supply chain complications that could reverberate throughout global biofuel markets in the coming months, particularly for traders heavily invested in palm oil-derived biofuels.


Meanwhile, European markets present a contradictory picture, with RME (Rapeseed Methyl Ester) and UCOME (Used Cooking Oil Methyl Ester) trading actively in spot window markets despite troubling developments in Germany. Recent data from the Federal Office of Economics and Export Control reveals that November 2023 marked a historic low for biodiesel blending rates at just 3.9%—the lowest level since the introduction of blending obligations in 2009. Total consumption of biodiesel and HVO (Hydrotreated Vegetable Oil) is projected to fall below 2 million tonnes for the first time in the January-November period, with annual consumption expected to decline to approximately 2.20 million tonnes in 2023, down from 2.62 million tonnes in the previous year, despite an increase in the GHG quota reduction obligation from 8.0% to 9.35%.


The Union zur Förderung von Oel- und Proteinpflanzen (UFOP) attributes this counterintuitive trend to the double counting of biodiesel or HVO from specific waste categories towards quota obligations and existing GHG quota surpluses. With Germany's biodiesel blending rates hitting a historic low of just 3.9% in November 2024—the lowest since the introduction of blending obligations in 2009—the risk to double counting policies in Europe has never been greater. The alarming decline in actual physical blending despite increased GHG quota obligations presents compelling evidence that the current policy framework is failing to achieve its intended environmental outcomes. UFOP is advocating for the abolition of double counting methods during the upcoming amendment to the Federal Immission Control Act, scheduled for spring 2025, which will transpose the updated Renewable Energy Directive (RED III) into German law. Additionally, UFOP has expressed concern regarding potential changes in U.S. customs and subsidization policies for biofuels, which could significantly increase supply pressure in the EU, particularly for used edible oils and fats, as new U.S. tariffs (25% on non-energy imports from Canada and Mexico, 10% on Canadian energy imports, and an additional 10% on Chinese goods) disrupt established trade patterns.


For traders navigating these complex market dynamics, several strategic considerations emerge. The divergence between U.S. feedstock adaptability and European regulatory challenges presents both arbitrage opportunities and potential pitfalls. The comprehensive feedstock data reveals that while vegetable oils slightly increased their dominance (to 74% of the mix), animal fats and waste oils continue to play a crucial role at 26% of total feedstock, with white grease maintaining its position as the second-largest individual feedstock at 23.2%. The sharp decline in yellow grease usage (-11.2%) despite overall market growth suggests specific economic or technical factors affecting this feedstock that savvy traders should monitor. The shift from H1 to H2 2024 demonstrates the industry's ability to quickly adjust feedstock strategies, with biodiesel plants increasing corn oil usage by 23.9% while renewable diesel facilities dramatically increased soybean oil by 50.7%. These operational changes, coupled with the decline in specialty feedstocks in December (likely tied to 45Z credit preparations), indicate a sophisticated market that rewards close attention to policy signals. Simultaneously, the palm oil price collapse in Southeast Asia may create favorable entry points for traders able to manage the associated political and logistical risks. Most critically, the European regulatory landscape—particularly Germany's implementation of RED III—warrants close monitoring, as changes to double counting provisions could rapidly alter market economics for waste-derived biofuels. As these interwoven factors continue to evolve, successful trading strategies will likely depend on maintaining flexibility across geographic markets while closely tracking both regulatory developments and feedstock production patterns.





 
 
 

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