Fundación Renovables, ECODES, Ecologistas en Acción and Transport & Environment consider the carbon-intensity reduction target for transport to be ambitious, but it must be accompanied by environmental safeguards and a clear commitment to genuinely sustainable solutions.
The organisations support measures that ensure a real reduction in emissions without putting biodiversity or food security at risk.
Madrid, 29 January 2026.- Spain is at a crucial moment in defining the roadmap for decarbonising transport, with the transposition of the Renewable Energy Directive (RED III) into national law currently under public consultation. The Directive establishes ambitious targets to reduce carbon intensity, which in Spain have been reinforced through a proposal for even more demanding goals than those set at EU level.
RED III sets a reduction of at least 14.5% in greenhouse gas intensity in transport by 2030. In its transposition into national law through the draft Royal Decree to promote the decarbonisation of transport and renewable fuels, a more ambitious target is established: a 17.6% reduction in GHG emissions from road transport by 2030. This represents a key opportunity to accelerate climate action in one of the highest-emitting sectors nationally, something highly valued by ECODES, Ecologistas en Acción, Fundación Renovables and Transport & Environment.
However, the organisations warn that “the current design of the regulation poses significant environmental and climate risks by introducing specific sub-targets to promote certain biofuels and biogas from raw materials whose large-scale expansion could worsen the climate crisis, biodiversity loss and food insecurity instead of helping to solve them”.
Eliminating soy is necessary but insufficient
According to ECODES, Ecologistas en Acción, Fundación Renovables and Transport & Environment, it is relevant that the European Commission has recently published the annex (still under public consultation) declaring soy a high-risk feedstock for indirect land-use change (ILUC). It is also relevant that its use as a fuel must be phased out by 2030, as civil society organisations and the European Parliament itself have been requesting for years.
“This decision confirms warnings about its climate and environmental impact and reinforces the need, in the process of transposing the directive, to accelerate its effective and immediate removal from the calculation of renewable energy targets in transport”, the organisations stated.
Among the main risks identified is dependence on unsustainable biofuels, including feedstocks linked to deforestation—such as soy—as well as others of questionable sustainability, such as palm residues or imported waste from Asia, without being able to rule out fraud in supply chains.
This is compounded by the absence of a clear pathway to progressively eliminate biofuels from food and feed crops, despite their indirect negative impact on food security, expansion of the agricultural frontier and global emissions. All this stems from increased pressure on ecosystems and competition for agricultural resources by encouraging the production of biofuels from food crops, palm residues or used cooking oil imported from Asia.
According to the most recent data (2024), the raw materials most used in biofuels sold and consumed in Spain are imported, exceeding 80% of the total: for example, more than 70% of the residues used for HVO came from Asia; 38% from Malaysia; 31% from Indonesia; and 5% from China. As for biodiesel, 58% also came from organic waste of Asian origin and 5% from Brazil, probably from food crops such as soy.
Moving from false solutions to structural measures
These risks, the organisations explain, are aggravated by the possible promotion of greenwashing practices by industry, by treating as “renewable” solutions that do not guarantee real and sustainable emission reductions. Ultimately, this approach may delay the implementation of structural and genuinely effective solutions to reduce greenhouse gases, such as cutting energy demand in transport and direct electrification, especially in road and rail transport.
With regard to synthetic fuels or renewable fuels of non-biological origin (RFNBOs), the organisations believe it would be preferable to encourage their use in sectors where direct electrification is not always viable, such as maritime transport, rather than allowing compliance to be channelled mainly through the intermediate route of oil refineries, where it delivers only marginal reductions in fossil fuel production.
Real, fair decarbonisation aligned with science
ECODES, Ecologistas en Acción, Fundación Renovables and Transport & Environment stress that the transposition of the Renewable Energy Directive must be a tool for transforming the transport system, not for perpetuating models dependent on fuels with high environmental impacts.
“To guarantee real and fair decarbonisation, it is essential to prioritise efficiency, reducing energy demand and direct electrification in road and rail transport, strictly reserving the role of biofuels for the aviation and maritime sectors and ensuring solid, verifiable sustainability criteria aligned with scientific evidence. The climate emergency demands coherent policies capable of ensuring real emissions reductions without putting biodiversity or food security at risk”, they concluded.
