Amid a surge in demand for renewable energy, EU regulators are working to develop a framework for its Renewable Energy Directive through the 2030s, and Brazilian farmers and ag stakeholders are weighing in to ensure the benefits of tropical agriculture are not ignored.
Introduced in 2009, the EU’s Renewable Energy Directive boosts renewable energy sourcing, which grew from 12.5% of EU’s total energy consumption in 2010 to 25.2% in 2024, according to the European Commission. The regulatory body is expecting to release a legislative proposal by the end of 2026 that will set energy policy for the 2030s, further boosting renewable energy consumption, including the use of ethanol and biodiesel.
Fueled by growth in its ag sector and regulatory policy, Brazil is the second largest biofuel producer with 1,143 petajoules in 2024, second to the U.S. with 1,917 petajoules, according to Statista data. Brazil domestically consumes a lot of biofuels and is expected to raise mandatory ethanol blending from 30% to 32% and biodiesel blending from 15 to 16%, according to Reuters reporting.
The EU solicited a public consultation and evidence period, with organizations like the Brazilian Sugarcane and Bioenergy Industry Association (UNICA) and energy producer Raízen sharing commentary.
Representing the largest agricultural state in Brazil, the Association of Soybean and Corn Producers of the State of Mato Grosso (Aprosoja-MT) submitted a technical contribution to the EU under the public consultation to reconcile “a disconnect between European regulation and the regulatory reality of the world’s leading producer country of tropical bioenergy,” according a document obtained by AgNavigator and sent to regulators on June 11.
The crux of the disconnect comes in part from EU’s current framework and issues related to indirect land-use change (ILUC) risk, which classified biofuel feedstocks in bulk based on 2015 models, Aprosoja-MT argued. The EU defines ILUC as when biofuels come from agricultural lands that are still seeing food and feed demand, implying that producers will convert more land to agricultural production, thus increasing CO2 emissions.
As part of six objectives outlined in the document, Aprosoja-MT is seeking EU regulators to recognize second-crop corn ethanol as outside the ILUC risk. Aprosoja-MT argued that current ILUC models do not factor into Brazil’s second corn crop, since the production is happening on the same land as soybean production and not converted land.
Brazil has two harvests a year, a soybean harvest from January to March and a following corn crop that is harvested from June to August, depending on the region.
Additionally, Aprosoja-MT wants to establish systemic regulatory equivalence; shift classification to the producer jurisdiction level; formalize channels for recognition between the Renewable Energy Directive, RenovaBio, and the Brazilian Emissions Trading System; and establish a timeline for the transition.
Brazil’s history of sustainability laws
Over the years, Brazil has developed numerous territorial governance and sustainability laws, including the Brazilian Emissions Trading System, the Forest Code, the National Biofuels Policy, and the Rural Environmental Registry; which were not all fully in place during the initial passage of the Renewable Energy Directive, Aprosoja-MT noted.
First passed in 1965 and then updated in 2012, Brazil’s Forest Code mandates producers set aside 20-80% of their land depending on the biome. However, the Brazilian Emissions Trading System and National Biofuels Policy were enacted later than the Forest Code in December 2024 and December 2017, respectively.
Over the years, the enforcement of the Forest Code has led to lower rate of deforestation. The annual deforestation rate hit a 11-year low in 2025 at 5,796 km2 or a 11.08% decline from the previous year, according to Brazil’s National Institute for Space Research.
