"The German Association of the Automotive Industry (VDA) expressly welcomes the fact that the German government, with its draft bill, extends the GHG quota beyond 2030, thus creating the long-overdue basis for investments in industry and infrastructure. However, the GHG quota pathway, in particular, remains too unambitious: with a mere 59% reduction in GHG emissions by 2040, climate neutrality by 2045 is unattainable. A realistic target curve is needed—with 35% by 2030, 60% by 2035, 90% by 2040, and 100% by 2045.

To achieve these goals, the right investment incentives for renewable fuels must now be in place. Therefore, it is welcome news that the sub-quota for RFNBO in road transport has been increased from 4% to 8% in 2040. This provides a significant boost for the ramp-up of power-based, non-biogenic fuels such as hydrogen and e-fuels, which are essential for climate neutrality in the transport sector. At the same time, the quota must be further increased for 2030 to ensure the right investment incentives are in place early on.

It is a positive development that the annual increase in the sub-quota for both advanced and waste-based biofuels is to continue beyond 2030. It is also welcome that the upper limit for conventional biofuels will not be lowered prematurely. In this context, it is positive that soybean oil will continue to be permitted as a feedstock, as it is approved by the EU as a sustainable base material for biofuel production. At the same time, the carryover of quotas, i.e., of excess of fulfilled quantities to the following year, should be clearly limited to avoid market distortions.

However, it's important to remember that the more electric cars are on the road, the less energy is needed overall for road transport. Therefore, a higher quota doesn't automatically mean that more actual quantities of renewable fuels will be produced. To truly achieve the climate targets by 2045, more ambitious targets and stronger incentives for investment in renewable fuels are needed."