What is ILUC?

ILUC stands for Indirect Land Use Change, which can occur when pasture or agricultural land previously destined for food and feed markets is diverted to biofuel production. In this case, food and feed demand still needs to be satisfied, which may lead to the extension of agriculture land into areas with high carbon stock such as forests, wetlands and peatlands. 

This implies land use change (by changing such areas into agricultural land) and may cause the release of greenhouse gas emissions (CO2 stored in trees and soil) that negates emission savings from the use of biofuels instead of fossil fuels (Source: European Commission).

EU Policy

With the Recast of the Renewable Energy Directive (RED II), the EC introduced two main measures to tackle ILUC.


Firstly, the Directive sets a cap to the total contribution towards the national renewable energy targets of biofuels, bioliquids and biomass fuels produced from food or feed crops, since these fuels present a risk of causing ILUC. The cap is set at as 1% higher than the 2020 national share of these fuels in the final energy consumption for road and rail transport in each Member State, with a maximum limit of 7%


Secondly, the Directive sets national limits between 2021 and 2023 and a gradual phase out after 2023, for high ILUC-risk biofuels, bioliquids and biomass fuels produced from food or feed crops with a significant expansion into land with high carbon stock , with a target to decrease to zero by 2030 at the latest. The limits affect the amount of these fuels that can be taken into account when calculating the overall national share of renewables in transport.
However, the Directive introduces an exemption from these limits for biofuels, bioliquids and biomass fuels that are certified to present a low ILUC-risk.

Low ILUC risk biofuels, bioliquids and biomass fuels

Low ILUC risk biofuels are then considered as a renewable energy source capable to help the decarbonization of Europe, the precise definition given by the directive describes them as “fuels produced in a way that mitigates ILUC emissions, either because they are the result of productivity increases or because they come from crops grown on abandoned or severely degraded land”.
The Delegated Act published in 2019 supplementing the RED II, set out both the criteria for determining high ILUC-risk feedstock for biofuels and the criteria for certifying low indirect land-use change (ILUC)–risk biofuels, bioliquids and biomass fuels.
According to this, the certification of “low ILUC risk” can be granted if fuels meet the following cumulative criteria:
This evidence shall include information on the additionality measures taken to produce the feedstock, the areas on which these measures have been applied, and the 3-year average yield obtained from the land included in those areas.

Sources and further information