By 2035, the French aviation sector will need to integrate around 1.2 million tons of Sustainable Aviation Fuel (SAF), while the European demand is expected to reach approximately 7 million tons. To meet this challenge, securing more than 9 million tons of feedstock at the European level will be necessary.
However, regulations impose a major constraint: SAF must be produced exclusively from non-conventional feedstocks that do not compete with the food sector. The restricted list of eligible feedstocks includes bio-waste, residues, and cover crops, explicitly excluding conventional agricultural raw materials to prevent competition with food production.
Compared to its needs across all sectors (air, road, maritime, and industrial), Europe has a limited supply of bio-waste due to both its land area and population. For example, the supply of used cooking oil is around 1 million tons per year, while animal fats and other fat wastes amount to approximately 3 million tons. The remaining supply of residual oils is negligible compared to the total demand across all sectors, which exceeds 10 million tons per year.
The challenge of unconventional raw materials and intermediate crops
Where Can Such a Volume of Non-Conventional Feedstock Be Found? These resources are already extensively demanded in road and maritime transport biofuel production, as well as in industrial sectors such as chemistry and electricity generation. The challenge is immense, and time is short. The industry has just ten years to structure an adapted collection system. Cover crops are often cited as a potential solution, especially since Annex IX was updated by the European Commission in March 2024. However, the real potential of intermediate crops in France and Europe remains unproven. Yield, land availability, and economic viability are all challenges that could turn this solution into an illusion rather than a real alternative.
Classified as « advanced » feedstocks in Annex IX, Part A, intermediate crops are gaining increasing interest for bio-jet fuel production. But will they be able to provide a significant volume by 2030, or will they remain a marginal resource?
More importantly, will this emerging sector be able to develop at a European scale, or will it once again rely on imports, as is already the case for used cooking oil and waste residues?
Types of Cover Crops Considered for SAF
Among these crops, camelina and linoleic fast growing sunflower are found in Europe. Their fast growth cycle (60 to 90 days) makes them potential options for SAF production. While in South America, carinata & camelina appears to be the most promising candidate. The US also has a pathway for carinata and camelina as high GHG crops to be allowed in their sustainability frameworks.
Challenges to Overcome in Structuring an Intermediate Crop Sector
However, while promising on paper, these crops face several constraints, particularly land availability during the 75 to 90 days between the harvest of a main crop and the planting of the next one and making sure farmers are growing crops in a properly manner. Their cultivation is therefore a real challenge due to the tight planting schedules imposed on farmers and could be source of stress for a short period. The cultivation of sunflower and camelina as cover crops must be carried out in Europe quickly after the harvest of barley, for example. This requires an early harvest, ideally between June 15 and June 25. This requirement excludes many agricultural regions where cereal harvesting takes place later, in July. In these areas, planting intermediate crops becomes difficult or even impossible, as it reduces land availability for the required 90-day period before preparing the next main crop.
Focus in France – where to grow?
We conducted interviews with French farmers and realized that the regions favorable to these crops are those with a climate that allows for an early summer cereal harvest, such as Aquitaine, Occitanie, Auvergne-RhĂ´ne-Alpes, Italy, Spain, Slovenia, and Croatia. In contrast, major agricultural regions in northern France, the Paris area, Germany, Poland, and Central Europe face significant challenges due to a later harvest schedule. In these areas, planting camelina and sunflower as cover crops becomes very difficult, as the harvest would only take place in October, making these crops economically unviable and riskier due to weather uncertainties at that time of year.
Yields and Challenges of Intermediate Crops
Intermediate crop yields range between 0.5 and 1.8 tons per hectare. Camelina and sunflower are low-maintenance crops that do not require significant operational costs for farmers. However, their main challenge is low productivity:
Camelina: 500 kg to 1 ton/ha
Sunflower: 500 kg to 1.8 tons/ha
Linoleic sunflower, with its fast growth cycle, is particularly well-suited for cover cropping. It is a well-known crop among farmers and seed producers, with an established logistics and industrial chain, covering storage, transportation, crushing, and biofuel conversion. However, to ensure the economic viability of this crop and secure yields—especially since it is sown in dry periods—irrigation is recommended to support germination, early growth, and final yield. It is generally advised to schedule 1 to 2 irrigation cycles. This irrigation requirement is a major barrier to its development, further compounded by strict site selection criteria based on the harvest timing of the main crop. Additionally, only irrigable lands and farmers with irrigation rights can be considered. These constraints represent a significant challenge to the large-scale deployment of sunflower as an intermediate crop in Europe.
The Scale of the Agricultural Challenge
To better grasp the magnitude of the challenge, covering just 50% of the feedstock needs for SAF in France – approximately 700,000 tons of oil – by 2035 would require: 1.5 million hectares of cover sunflower, or 4 million hectares of camelina.
For comparison, the total barley cultivation area in France today is 1.24 million hectares. This stark contrast highlights the gap between ambitions and the actual agricultural potential available.
A real risk of import dependency exists, given the potential feedstock availability in Europe
With these numerous constraints, intermediate crops appear more as an economic opportunity for industry players rather than a viable large-scale solution to support the SAF sector. Far from being a local, secure, and abundant feedstock, their development is likely to hit agronomic and climatic limitations.
As with other feedstocks, large-scale production will likely depend once again on imports, particularly from South America, where conditions are more favorable for these crops. Once again, Europe imposes strict restrictions on feedstocks for bio-jet fuel and biofuels, while inadvertently creating an incentive for imports. Rather than acknowledging that its true local biofuel resources remain rapeseed and sunflower, it continues to expand the list of « advanced » feedstocks without considering real-world constraints.
Challenges in Defining Cover Crops
How can the European definition of a cover crop, which is supposed to be grown between two main crops, be applied to South America, where a Brazilian farmer can already harvest two to three main crops per year? This regulatory distortion could once again favor foreign producers, who will adapt their model to capture this new regulatory-added value—a phenomenon already observed with certain oils exported to the biofuel sector.
A Regulatory Framework Disconnected from Market Realities
Instead of learning from RED II, Europe continues to design a framework disconnected from market realities. With each addition to the advanced feedstock list, exporters find creative ways to benefit from these policies, at the expense of true energy sovereignty.
At a time when European and global policies are shifting towards more protectionism and energy security, the question of revising Annex IX, Part A, may arise.
Will we eventually see first-generation crops like rapeseed return to the debate on SAF feedstocks? Nothing is certain, but the need to ensure a local, controlled supply could ultimately change the game.
Intermediate crops like camelina and linoleic sunflower could partially meet SAF industry needs. However, numerous challenges and risks must be addressed by regulators before they can become a viable large-scale solution:
Agronomic and calendar constraints:
Limited cultivation windows exclude many agricultural regions.
Low productivity:
Yields are too low for competitive production.
Climate change sensitivity:
Weather fluctuations impact crop viability.
Irrigation requirements:
Water demand to secure yields restricts viable cultivation areas.
Dependence on imports:
Insufficient European production increases reliance on imports.
Fraud risks:
Potential regulatory loopholes, as seen with other advanced biofuel feedstocks.
