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ICF | Clean Fuel LCA&Carbon Intensity | GHG Accounting | Low-Carbon Feedstock | Regulatory Compliance | Emission Scope 3

🍁 (7) Canada Clean Fuel Regulations (CFR) Update — Land Use and Biodiversity Criteria with respect to Used Cooking Oil feedstock (UCO) This afternoon, Environment and Climate Change Canada (ECCC) posted an emphasis on UCO feedstock (specifically subsection 46(1)). The main items are: 🔊 Fuel producers must demonstrate that the UCO feedstock they are sourcing is of Type 2, thereby proving with a reasonable level of assurance that it is a waste product from an upstream processing operation. 🔔 (WL: According to CFR LUB criteria, Type 1 is non-biomass feedstock, Type 2 is residue and waste-based material, and Type 3 is agricultural or forest biomass materials. This emphasizes that the UCO must be a waste bio-source.) 🔊 Fuel producers must ensure that collection points retain records of contracts, delivery records, invoices, etc., detailing where the UCO was sourced from. 🔔(WL: Producers should maintain the UCO purchase records. This requirement is similar to the USEPA RFS 80.1454 and California LCFS 95488.8.) 🔊 It is not required for the low-CI producer to determine the specific composition of the originating material that the UCO mix is derived from (e.g., palm, corn, canola, etc.). 🔔(WL: This is nothing new; regulators do not concern themselves with the specific components of the UCO.) What lies behind these pieces showcases the stringent chain of custody of UCO feedstock and the concerns about UCO fraud from a regulatory perspective. UCO is a highly favorable low-carbon feedstock for producing low-carbon intensity fuels such as biodiesel and hydrotreated esters & fatty acids (HEFA), including renewable diesel, sustainable aviation fuel (SAF), and renewable naphtha. However, due to its numerous origin sources and an extensive supply chain, compliance becomes very complicated. In a nutshell, producers using UCO to produce low-carbon fuel must provide sufficient evidence and documentation to ensure regulators and verifiers can be assured of its authenticity. #LCFS #CFR #RFS #usdcookingoil #biofuels #alternativefuels #SAF #regualtorycompliance #California #Canada #lowcarbon #feedstocks #LCA #Sustainability #Sustainable #Biofuels #UCO

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