IATP Europe submitted the following comments on January 26, 2026, to the European Commission regarding the revision of Annex V and VI of the Renewable Energy Directive (short: RED, Directive (EU) 2018/2001) regarding proposed changes related to the calculation of the climate benefits of manure-based biogas and biomethane.
The Institute for Agriculture and Trade Policy (IATP) Europe appreciates the opportunity to provide feedback on the European Commission’s proposal of the review of Annex V and Annex VI of the Renewable Energy Directive (Directive (EU) 2018/2001) as laid out in Article 31(5) of the Directive. The following comments are relevant to the default values related to manure-based biogas and biomethane, as reflected in the amendments to Annex IV.
We are concerned that the RED methodologies for manure-based biogas and biomethane appear to be overestimating the technologies’ real world climate benefit and risk creating incentives to further entrench, rather than address, climate pollution from industrial livestock production. We urge you to take the following aspects into account.
Overall, the treatment of manure as a zero-greenhouse gas (GHG) emissions waste in the current RED accounting framework disregards the broad scope of emissions that the production of manure relies on in the first place. The omission of these GHG emissions results in exceptionally high default values for GHG savings attributed to manure-based biogas and biomethane.
Not only does the account framework disregard methane emissions from ruminant enteric fermentation and carbon dioxide emissions from land use and land use change, but also nitrous oxide and carbon dioxide emissions from feed production and transport. A narrow perspective on the boundaries of the LCA overstates the climate benefits of manure-based biogas and biomethane. Rather than setting an incentive to address the livestock sector’s climate challenge at large, such omissions risk creating perverse economic incentives for increasing/maintaining the scale and intensity of industrial livestock production, as has occurred in the United States, when biogas incentives were introduced.
In addition, other assumptions add to the risk of overstating actual climate benefits, including the assumed potential of mitigating methane leakage: The best-practice assumptions for leak detection and repair results in up to double the GHG emission savings compared to standard assumptions. It appears overly optimistic to assume that the theoretical maximum potential of methane leakage mitigation is realistically deployable. Even in countries with advanced regulatory frameworks, leakage remains difficult to detect, and monitoring and enforcement is often insufficient. The German Commission on Plant Safety documented persistent and widespread non-compliance in the German biogas sector since at least 2007, with more than two thirds of inspected plants exhibiting significant deficiencies.
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