The draft Royal Decree transposing the RED III Directive on biofuels could jeopardise climate targets
The promotion of ecofuels (RFNBOs) should be limited to sectors where electrification is technically and economically impossible
Madrid, 23 September 2025. The draft Royal Decree transposing the RED III Directive on biofuels contains shortcomings that could jeopardise Spain’s climate targets and slow the electrification of transport. Fundación Renovables and ECODES have conveyed this to the Ministry for the Ecological Transition and the Demographic Challenge (MITERD) through the submissions presented during the public consultation process.
As the organisations argue, the transposition of this directive only prioritises the development of biofuels for transport, forgetting direct electrification, which should be the priority solution not only for environmental and economic reasons but also for reasons of efficiency. Indeed, with 1 MJ of renewable electricity, an electric vehicle (EV) performs 3.2 times more transport work and avoids 5.4 times more greenhouse-gas emissions than the equivalent of 1 MJ of crop-based ethanol. This fact must be taken into account when drafting a regulation that currently favours solutions less efficient than direct electrification.
Fundación Renovables and ECODES also highlight the need to expand the targets presented in the draft Royal Decree so that Spain has a pathway beyond 2030. Specifically, this means a reference framework up to 2035 with targets differentiated by energy vector and aligned with the European Union’s climate-neutrality pathway for 2050. As they state, setting a long-term horizon will reduce uncertainty and help mobilise investment in the right direction.
To ensure compliance, it is essential to apply monitoring and follow-up measures. MITERD is therefore asked to publish quarterly monitoring tables showing how transport decarbonisation is progressing as a result of the changes introduced by this Royal Decree.
In the same direction, certain feedstocks used to produce biofuels must be excluded because of their high environmental impact. Just as palm was banned because of its impact on deforestation, the organisations defend the elimination of soy, a food crop mostly produced outside the European Union. To this end, the regulation must define a pathway for the progressive elimination of all food and feed crops used for biofuels, reaching 1.5% in 2030 and 0% in 2035. As Sarah Galeran, ECODES specialist in this field, points out: “Using food crops to produce biofuels is a risk to global food security and also increases pressure on ecosystems, driving deforestation and biodiversity loss”.
To avoid this, it is also important to include flexibility mechanisms that allow MITERD to establish additional limits, by country of origin or by feedstock, based on sustainability risks, after consulting the European Commission.
“If we really want to guarantee sustainable, safe and independent mobility, we must make the electrification of all transport the central axis of our strategy. However, the transposition of the RED III directive leaves this in the background and focuses on far less sustainable solutions, such as biofuels, which provide neither the efficiency nor the energy autonomy that Spain needs in its mobility”, said Juan Fernando Martín, Head of Mobility at Fundación Renovables.
