In 2023, the European Commission indicated that the previous NUTS2 values, developed and recognized under the Renewable Energy Directive (RED I), were no longer valid, though they allowed their use for crops from the 2023 harvest. The Commission has therefore requested Member States to submit new NUTS2 values for validation. These values will apply to crops from the 2024 harvest onwards.
Canada, Australia, and Argentina have already received validation for their new NUTS2 values; these values can be used. Other Member States, including France and Germany, have also submitted their updated values to the European Commission. However, the validation process led by the European Commission will take some time, according to the authorities. This process will follow several stages:
- The completion of the technical validation of the new NUTS2 values, triggering the possibility of communication of the new values by each Member State;
- Formal validation by the Member States in comitology;
- Official publication of the new NUTS2 values in a delegated act in the Official Journal of the EU.
This timeline means that economic operators cannot yet use the new NUTS2 values. We are therefore recommending the use of an intermediary procedure as outlined below.
Once the technically validated NUTS2 values are officially communicated to economic operators and voluntary schemes by the Member States, transformers and biofuel producers will be able to retroactively update the relevant documents (Sustainability Declaration – SD, Proof of Sustainability – POS) with the new NUTS2 value for the region, replacing the initially indicated default value.
Note: If multiple regions are indicated, the operator at the final interface must select the value of the region that is the least favorable in terms of greenhouse gas emissions.
In agreement with the stakeholders, 2BS recommends following the steps below when filling out the traceability documents (SD). This recommendation is intended to ensure continuity in the reporting of greenhouse gas emissions.
POS will have to comply with national provisions regulated by the Member States (the DGEC for France).
Recommendation for the completion of the SD :
Within the 2BS model, the following steps should be followed:
- Step 1: Check the “Yes” box for “Disaggregated default value.”
- Step 2: In the formula, indicate the name of the NUTS2 region(s) where the biomass was produced for the “eec” factor.
