The Renewable Energy Directive: An NGO’s Perspective

by Marta Lovisolo and Reinout Debergh

We all know we will need huge amounts of renewable energy to meet our climate goals. Part of the EU’s fit for 55 package is the revision of the Renewable Energy Directive. But is the revision enough and what are some ongoing issues? I asked Marta Lovisolo, Junior Policy Advisor at the Brussels-based NGO Bellona Europa.

Q1: I have heard a lot about additionality. What is it and why is it important?

In the context of green hydrogen production, deploying additional renewable energy production is key to supplying the electrolysers with the electricity they need. If additionality is not ensured, electrolysers will run on what is available on the grid. This means less renewable electricity available for power production resulting in increased natural gas consumption for electricity production.

Green hydrogen: hydrogen produced via electrolysis (splitting water into hydrogen and oxygen) powered by renewable energy (e.g. wind or solar) [1].

Electrolyser: the machine that splits water into hydrogen and oxygen by passing an electric current through the water [2].

Q2: Is the target of 40% renewable energy by 2030 ambitious enough?

What exactly is included in the 40% target is yet to be defined. Depending on whether or not the renewables for hydrogen production will be additional or included in this target will tell us whether or not this target is ambitious enough.

Q3: What are some of the good improvements in the proposal?

The revised proposal makes significant progress in terms of expanding the scope of the Directive, including mainstreaming renewable energy in heavy industry with additional targets. Moreover, the revised RED includes safeguards to prevent the double counting of emission reductions for carbon capture and utilization (CCU) products, thereby providing solid ground for fair allocation of any emission reductions that may occur.

CCU: capturing CO2 and then using it for applications such as combining it with hydrogen to make fuels [3].

Q4: What could be better?

The proposed revision misses the mark when it comes to renewable fuels of non-biological origin (RFNBO) production, biomass and accounting of GHG emissions for various fuels and electricity. Talking about fuels in particular, the impacts of the targets adopted within RED depend on the delegated act defining the methodology for the calculation of the GHG impact of fuels and the electricity used in their production process. If the delegated act won’t include additionality in the production of such fuels, the very high targets for RFNBOs adopted within RED will set us up for increased emissions in the power sector.

RFNBOs: liquid and gaseous fuels, the energy content of which is derived from renewable sources other than biomass [4].

Q5: The RED proposal does not set national targets, what will this mean in practice?

It’s hard to anticipate what this will mean in practice. On the one hand, in case the target won’t be met, it will be much more difficult to establish responsibilities and apply sanctions. On the other hand, this increased level of flexibility will allow countries to act faster wherever possible and assist less prepared Member States where needed.

Is the sustainability of biomass addressed sufficiently?

The RED is responsible for driving unsustainable demand for biomass as a feedstock for biofuels. The revision does not strengthen the sustainability criteria enough to consider it as progress. For instance, food crops continue to be labelled as renewable energy despite evidence to the contrary provided by the Joint Research Centre (JRC). Failure to address this substantial issue will further increase unsustainable demand for biomass, driving deforestation and worsening the climate and biodiversity crises.

Joint Research Centre: the Commission’s science and knowledge service. Scientists do research to provide independent scientific advice and support to EU policy [5].

Q6: How does it relate to other proposals of the Fit For 55 package?

The package was clearly built in a concerted way across files, whether this will remain the case throughout the legislative procedure is yet to be determined. Concerning the Renewable Energy Directive Revision, its alignment with other files can be mainly seen in the effort to deploy increasing quantities of RFNBOs in the transport and industrial sector, to kick off the hydrogen economy. The targets proposed within RED clearly mirror targets in the newly proposed ReFuel EU Aviation and FuelEU Maritime regulations, as well as the infrastructure deployment forecasted in the Alternative Fuel Infrastructure Regulation (AFIR).

Q7: Can the EU be self-reliant on 100% renewable energy?

There are studies that prove that this is possible, however many complementary measures will need to be put in practice for this to be the case. First and foremost, European grids must be strengthened so as to be able to transport electricity from areas where it is produced to areas where it is needed. Moreover, high level demand-side flexibility, enabled through smart grids, is necessary to align non-dispatchable generation with demand. Non-dispatchable generation refers to sources of electricity that cannot be turned on or off in order to meet societies fluctuating electricity needs. Wind and solar for example depend on the weather conditions and not on what consumers actually need.

Despite the possibility of running 100% on renewable generation. It’s most likely that some nuclear baseload will remain in the system for the upcoming decades, as well as some abated gas-fired production that can be ramped up quickly in case of shortage. With the improvement of batteries and hydrogen technologies natural gas will become more and more marginal and eventually disappear.

Demand-side flexibility: the share of electricity demand in the system that can be reduced, increased or shifted within a specific duration [6].

Smart grid: an electricity grid enabling a two-way flow of electricity and data with digital communications technology enabling it to detect, react and pro-act to changes in usage and multiple issues [7].


[1] Cho, R., Why We Need Green Hydrogen, 2021, Columbia Climate School,, accessed on 04/11/2021.
[2] What is an Electrolyser?, CoverTel Power,, accessed on 04/11/2021.
[3] CCU presentation_Bellona, 2019, Bellona Europa,, accessed on 04/11/2021.
[4] Directive of the European Parliament and of the Council amending Directive (EU) 2018/2001 of the European Parliament and of the Council, Regulation (EU) 2018/1999 of the European Parliament and of the Council and Directive 98/70/EC of the European Parliament and of the Council as regards the promotion of energy from renewable sources, and repealing Council Directive (EU) 2015/652, European Commission,, accessed on 04/11/2021.
[5] Joint Research Centre, European Commission,, accessed on 04/11/2021.
[6] Demand-side flexibility for power sector transformation, Irena,, accessed on 07/11/2021.
[7] Smart grids: electricity networks and the grid in evolution, I-Scoop,, accessed on 07/11/2021.
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