- UK biofuels are not made from animal fats that would be better used in petfood, cosmetics and candles etc
- DfT’s statistics show that only high-risk material was used in biofuels
- No palm oil will have been used to replace this material, as it is not permitted to use these grades of tallow for pet food or cosmetics in the first place
- Biofuel is the best environmental use of animal fats that pose a health risk
- UK road and aviation fuels policy has unique emphasis on the use of wastes and provides a model for sustainability
Explanations
The categorisation of animal fats
Animal fat when used as a biofuel is reported as “tallow”. Not all tallow is equal – some of it is derived from diseased livestock, or zoo animals – and the only viable disposal route for this material is burning it. This is known as Category 1 tallow. Turning it into a biofuel (where it ultimately gets burned in vehicle engines) is the best environmental outcome for it.
Tallow is categorised according to the Animal By-Products (ABP) Regulations. The ABP Regulations are in place to prevent the spread of diseases, and were introduced in response to outbreaks of disease such as BSE (“mad cow disease”) and Foot & Mouth. Category 1 & 2 Animal by-products are high-risk and it is illegal for them to used for things such as pet food or cosmetics. Category 3 material poses the least risk, and is technically suitable for human consumption, and has competing uses.
Due to the categorisation of tallow, this means that no palm oil will have been used to replace tallow in non-fuel uses, as it is not a legal option to use these grades of tallow for pet food in the first place. DfT’s statistics show that only high-risk material was used in biofuels. See the numbers below.
UK policy encouraging sustainable road and aviation fuels
Heavy goods vehicles are a ‘difficult-to-decarbonise’ sector. The DfT recognises the role that biodiesel, including that which is made from tallow, plays in these vehicles.
In 2025 a mandate increasing the amount of Sustainable Aviation Fuel (SAF) will be introduced. This requires an increasing amount of jet fuel to be made from renewable sources, and the cheapest way of doing this is to produce it from waste oils and fats. These are the same feedstocks used to make biodiesel.
The SAF Mandate will have a cap on the amount of SAF that can be made from these feedstocks, in order to limit the diversion of them from road decarbonisation to aviation. The cap will mean that other materials, such as black bin bag household waste, sewage sludge and industrial gases must be used to meet the mandate. The UK’s approach is unique in this respect.
Further Notes
The report which led to media coverage on animal fat requirements for transport fuel “Pigs do fly: the rise of animal fats in European transport” can be found here: https://www.transportenvironment.org/discover/pigs-do-fly-growing-use-of-animal-fats-in-cars-and-planes-increasingly-unsustainable/
The HEFA cap in the SAF Mandate is described on page 33 of Pathway to net zero aviation: developing the UK sustainable aviation fuel mandate (publishing.service.gov.uk)
In numbers – the of animal fat in UK transport fuels
The Department for Transport publishes statistics on which feedstocks have been used to make biofuels. They can be found here https://www.gov.uk/government/collections/renewable-fuel-statistics
It can be seen from these that in 2021 (the most recent complete year’s dataset, and 2022 (data so far), that only category 1 or 2 material has been supplied as biofuel in the UK – and overwhelmingly it has been category 1 material.
For 2021, just under 0.016 million litres of category 2 material was supplied, and just over 20 million litres of category 1 material were supplied.
For 2022, around 21 million litres of category 1 material have been reported. No category 3 material (the category that may be used for cosmetics etc.) was supplied at all. Due to the categorisation of tallow, this means that no palm oil will have been used to replace tallow in non-fuel uses, as it is not a legal option to use these grades of tallow for pet food in the first place.
