In comments submitted today in response to a request for information from the California Air Resources Board, the Renewable Fuels Association urged the state agency to do more to ensure the integrity of imported used cooking oil (UCO) and tallow for biomass-based diesel production under the state’s Low Carbon Fuel Standard.
According to CARB data on fuel consumption in California, usage of biomass-based diesel (BBD) produced from UCO doubled from 2019 to 2023, while usage of BBD produced from tallow tripled, RFA noted, and some in the marketplace believe these feedstocks may be of questionable origin and content.
“Many biofuel market participants and other observers have expressed concerns about the legitimacy of imported ‘waste’ feedstocks and have questioned whether some volumes of UCO in particular may contain palm oil and/or other incorrectly labeled fats, oils, and greases,” wrote RFA Chief Economist Scott Richman. “These concerns have been heightened in recent months as Indonesia and Malaysia, which jointly account for nearly 85% of world palm oil production, have emerged alongside China as leading origins of UCO imported into the U.S.”
This flood of foreign feedstock has suppressed demand and prices for domestically produced feedstocks like distillers corn oil, which is produced by the ethanol industry. Moreover, the impact extends beyond the LCFS program. Significant volumes of imported waste-based BBD, along with BBD produced domestically from imported UCO and tallow (and consumed in California) are also being used to satisfy conventional renewable fuel volume obligations under the federal Renewable Fuel Standard, undermining demand for ethanol and, especially, its use in higher blends like E15 and E85.
CARB should require that BBD producers conduct chemical analysis on batches of imported UCO and tallow and provide associated documentation to substantiate that feedstocks are properly characterized and that the resulting BBD truly qualifies for the carbon intensity score it receives under the LCFS, Richman said.
