Consultation outcome

Introducing E10 petrol: outcome and summary of responses

Updated 25 February 2021

Background

Introduction

The UK government has set ambitious targets to reduce greenhouse gas (GHG) emissions to net-zero by 2050. The transport sector accounts for the greatest share of UK GHG emissions: 27% in 2019.

Recognising the need to scale up efforts in the transport industry, the UK’s first Transport Decarbonisation Plan, announced in October 2019, brings together a bold and ambitious programme of coordinated action needed for transport to play its part in reaching net-zero transport emissions by 2050.

The plan will set out a credible and ambitious strategy for the UK to ensure transport:

• delivers its contribution to net-zero GHG emissions by 2050
• increases its contribution to carbon budgets

As part of delivering this plan, measures will be needed to reduce GHG emissions from the existing vehicle fleet in parallel with wider technological changes, such as the phasing out of new petrol and diesel vehicles.

Low-carbon fuels already play an important role in reducing carbon emissions from transport, with 27 million tCO₂e (metric tonnes of carbon dioxide equivalent) saved over the last 12 years.

Targets for renewable fuels under the Renewable Transport Fuel Obligation (RTFO) doubled between 2018 and 2020, and are set to rise further in the period to 2032. To harness the full potential of low-carbon fuels, however, rising targets for renewable fuels will need to be increasingly accompanied by additional measures such as removing market barriers for higher blends of biofuels.

A clear next step is the introduction of E10 petrol, a grade containing up to 10% bioethanol. This represents a quick way to increase biofuel blending without needing investments in large-scale infrastructure changes or new technologies. E10 is a proven fuel blend that works in almost all petrol vehicles.

UK fuel standards already permit E10 to be sold, but petrol with more than 5% bioethanol – a grade known as E5 – is not yet available at UK forecourts. Switching to E10 would reduce the CO₂ emissions from a petrol vehicle by around 2% (in addition to the 2% savings we already achieve from the current use of E5). This, combined with an increase to overall renewable fuel targets, could cut overall transport CO₂ emissions by a further 750,000 tonnes a year – the equivalent of taking around 350,000 cars off the road.

Introducing E10 could also help support UK farmers and particularly the ethanol industry based in the north east of England. E10 fuel’s valuable by-products – high-protein animal feed and stored CO₂ – would further reduce reliance on imported products, in line with the government’s Bioeconomy Strategy.

About the consultation

In March 2020, we published this consultation proposing to introduce E10 as the standard 95-octane petrol grade in the UK. The consultation also proposed keeping the current lower-ethanol content petrol available as the higher-octane ‘Super’ grade.

The consultation included detailed questions on specific points that would be required to be put in legislation to deliver a smooth E10 roll-out. This included updating the consumer message displayed when E10 petrol is sold on forecourts.

The consultation document also included a call for evidence seeking views on potential changes to other policy mechanisms such as the RTFO, which could support and facilitate the roll-out of E10 petrol, ensuring the GHG emissions benefits can be maximised. You can read a summary of responses to this call for evidence and the government response in the detailed summary of responses section.

Detailed proposals on future RTFO policy will be included in a forthcoming consultation on amendments to the RTFO.

Government decision on E10 petrol

In line with the feedback received to this consultation, we can confirm that we’ll introduce legislation as soon as possible to require fuel suppliers and retailers to introduce E10 petrol in the standard 95-octane petrol grade by 1 September 2021. We’ll also require the higher-octane ‘Super’ grade to remain E5 to provide protection for owners of older vehicles.

Subject to parliamentary approval, the introduction of E10 at forecourts will occur during summer 2021 supported by a comprehensive communications campaign.

The initial legislation will apply to Great Britain only. In line with our obligations under the Northern Ireland Protocol, we’ll also notify the European Commission of our intention to legislate for the introduction of E10 in Northern Ireland to ensure regulations are in place before the September 2021 change in petrol grade.

This will:

• ensure the change in the main petrol grade can be as smooth as possible
• secure additional capacity to blend biofuel and displace fossil fuels in road transport
• improve the domestic market for our valuable ethanol producers and the farming sector that supply them

We thank all those that submitted responses to the consultation. You can read an overview of the responses received and detailed summaries of responses to all questions posed during the consultation in later sections of this response.

Executive summary

About the consultation

In March 2020, the government published this consultation on proposals to introduce E10 petrol in the UK. The proposals contained 2 key elements:

1. Requiring standard 95-octane petrol to become E10 (petrol with up to 10% ethanol).
2. Requiring the higher-octane 97+ ‘Super’ grade to remain E5 petrol (up to 5% ethanol).

The consultation:

• set out how the proposals would be applied in legislation – that is, via amendments to existing regulations on fuel quality
• detailed who would be required to comply with the requirements, what exemptions and derogations would apply and set out a timetable
• consulted on amendments to fuel labelling regulations to help communicate the changes in fuel grade
• included a ‘call for evidence’ in relation to wider transport low-carbon fuels policy

You can read a more detailed summary of the consultation proposals in the Consultation proposals overview section.

Fuel terminology

This response and policy concern the 2 petrol grades that are widely available in the UK.

The following table explains how these grades relate to and are defined throughout this response:

Name of fuel at pump	Octane rating	Description
Premium	95	This is the standard petrol grade available at all filling stations. This is currently E5 (95 E5) and is proposed to become E10 (95 E10), which is suitable for almost all petrol-powered vehicles and equipment.
Super	97+	This is the higher-octane petrol grade available at many filling stations. This is proposed to remain E5. It’s suitable for all petrol-powered vehicles and equipment.

Who responded

In total, the government received 208 responses to the consultation and call for evidence. This included 65 responses from organisations and 143 responses submitted by private individuals.

All responses to the consultation have been recorded and analysed with common issues and themes identified. You can read an overview of the responses received and detailed summaries of responses to all questions posed during the consultation in later sections of this response.

The government thanks everyone who responded to the consultation and call for evidence. We value the evidence and opinions submitted; they were taken into consideration when developing the policy and have informed our decision on introducing E10 petrol in the UK.

The responses received have been further categorised as follows:

Type of respondent	Total responses received
Private individuals	143
Organisations (total)	65
Agricultural associations	4
Renewable fuel suppliers or associations	25
Fuel suppliers/distributors or associations	16
Local government	3
Motoring organisations	11
Non-governmental organisations	2
Other organisations	4
Total respondents	208

Government decision

Having analysed the responses, we remain convinced that the preferred approach outlined in the original consultation document remains the best approach to introducing E10 in the UK. Broadly, we plan to introduce E10 as the standard 95-octane petrol grade available UK-wide.

At the same time, E5 will remain available at all filling stations that supply at least 2 grades of petrol as the higher-octane ‘Super’ grade. This ensures both a wide roll-out of E10 as the standard petrol grade and UK-wide provision of lower-ethanol E5 fuel, which will still be required by some vehicles.

Based on additional information provided in the responses, we have also made the following technical amendments to the original proposal:

• exemptions for filling stations on the Scottish islands: the proposals in the consultation document have been extended to cover filling stations in very remote areas where access to the protection grade (E5) is most sparse. Any filling station within an area covered by the Rural Fuel Duty Relief Scheme, as defined in Schedule 1 to the Hydrocarbon Oil and Biofuels (Road Fuels in Defined Areas) (Reliefs) Regulations 2011, will not be required to sell E10 petrol. This includes the Scottish islands, as well as a small number of other remote parts of the UK. E10 petrol will still be permitted to be sold in these areas, but not required
• fuel terminals lacking blending facilities: responses to the consultation identified fuel terminals that currently lack the facilities to blend bioethanol into petrol. We have decided to permit these terminals to apply for a derogation of 2 years from the minimum ethanol blend requirement. This is the minimum timeframe estimated for any investments in blending facilities to be made. The exemption may be extended subject to a review that will take into consideration both the cost-effectiveness of any investments required and impacts of the exemption on the fuel market in affected regions
• introduction date: in line with the responses received, we agree that September 2021 would be the best date for an E10 introduction – this will best align with the change from summer to winter-grade fuels

Next steps and timings

We’ll lay the necessary legislation as soon as possible. Subject to parliamentary approval, E10 petrol will be required to be sold at filling stations from September 2021 and may be first available on forecourts during the summer.

In line with our obligations under the Northern Ireland Protocol, we’ll also notify the European Commission of our intention to legislate for the introduction of E10 in Northern Ireland to ensure regulations can be introduced there before the September 2021 change in petrol grade.

The government will also work with industry to ensure members of the public are aware of the change in fuel grade and what it means for them.

To this end, new ‘E10 petrol explained’ guidance has been published covering:

• what E10 petrol is
• its compatibility with different vehicles and equipment
• its benefits
• its availability
• fuel pump labelling

An E10 vehicle compatibility tool has also been developed to ensure motorists can check their vehicle compatibility now in preparation for the introduction of E10 later this year.

Consultation proposals

Background to the proposals

Rationale for introducing E10

The transport sector is currently the largest contributor to GHG emissions in the UK, accounting for around 27% of emissions. While increasing the number of electric vehicles on our roads will help to reduce this over time, there are actions we can take now to reduce the impact of the millions of vehicles already on our roads.

The government’s RTFO has been running since 2008 and requires fuel suppliers in the UK to supply a certain share of renewable fuels. To date, this has mainly been achieved by either blending bioethanol into petrol or biodiesel into diesel. In 2019 alone, the renewable fuels supplied under the RTFO reduced CO₂ emissions by over 5 million tonnes – the equivalent of taking 2.5 million cars off the road.

Two petrol grades are widely available in the UK: a 95-octane standard grade available from all filling stations, and a higher-octane super grade available at many filling stations. Currently, both these petrol blends contain no more than 5% ethanol, known as E5; however, fuel quality regulations in the UK have permitted petrol to be blended with up to 10% ethanol since 2011. Since then, E10 has become widely available in several countries within and outside Europe, but has not been introduced at any filling stations in the UK.

Most modern petrol vehicles (meaning those produced since 2000) have been approved by their manufacturers for use with E10 and, since 2011, all new cars must be able to use it. E10 has also been the reference fuel for vehicle performance and emissions tests since 2016.

Increasing the ethanol content of petrol could therefore help reduce CO₂ emissions from petrol vehicles, helping to meet UK climate change targets without requiring adaptations to most vehicles. Consequently, we’re planning to introduce E10 as the new standard petrol grade in 2021 across the UK.

However, some older vehicles will continue to need E5 fuel. Classic and cherished vehicles, as well as some from the early 2000s, were not approved for use with E10 so it will be important that supplies of E5 petrol are maintained in the ‘Super’ grade.

Benefits of E10

Introducing E10 could have a range of benefits, especially in reducing carbon emissions and building a UK bioeconomy.

GHG emission savings

Using bioethanol in place of fossil petrol can reduce CO₂ emissions by around 65% for an equivalent volume of fossil petrol. As a result, increasing the proportion of bioethanol in petrol from 5 to 10% could reduce CO₂ emissions of a standard car by around 2%^{[footnote 1]}.

While this is a relatively small difference for any given vehicle, if combined with an increase in RTFO targets, it could reduce CO₂ emissions from road transport by a further 750,000 tonnes a year – this would be the equivalent of taking around 350,000 additional cars off the road.

UK bioeconomy

Under the RTFO, UK-grown feed wheat has historically been the most widely used feedstock to produce bioethanol. However, the UK bioethanol sector is currently operating below capacity, partly due to domestic demand being limited given the prevalence of E5 petrol and wider (European and global) ethanol supply exceeding demand. Introducing E10 introduction could consequently provide a boost to UK industry and agriculture, particularly to the large bioethanol producers in the north east of England.

Bioethanol production also results in valuable by-products, such as high-protein animal feed and stored CO₂, for the nuclear and food and drink industries. By supporting UK ethanol producers, we can reduce imports of these products and support local economies. The introduction of E10 would therefore align with the aims of the government’s 2018 Bioeconomy Strategy.

Barriers to E10

At present, the main barrier to E10 is the initial commercial hurdle of introducing a new type of petrol to the UK market and uncertainty how consumers might react to the change in blend. While E10 is suitable for use in the majority of petrol-powered engines, there are some cars, motorbikes and other petrol equipment that are not approved for use with more than 5% ethanol. As a result, when introducing E10, care needs to be taken to ensure consumers are aware of the changes and have the necessary information to ensure they pick the right fuel for their vehicle or equipment.

This uncertainty and communications challenge has acted as a barrier to any single fuel retailer unilaterally introducing E10.

Given the risk consumers could reject the changes, individual retailers have been reluctant to introduce E10, especially as competitors could continue to market E5 as their primary grade. A single supplier switching to E10 would be concerned about falling sales if consumers could purchase E5 from competitors as the more familiar fuel with no potential concerns around compatibility attached.

Industry representatives have also pointed out that any joint effort by suppliers or a group of suppliers to introduce E10 would be challenging without government intervention.

Previous call for evidence

Before this consultation, a call for evidence on E10 petrol, consumer protection and fuel pump labelling was issued in 2018 on whether, and how best, to introduce E10 in the UK. This looked at different options for getting E10 petrol onto forecourts, including adding it as an additional grade to the current 2 petrol grade system.

Respondents to the call for evidence, including fuel suppliers, were clear that they did not believe introducing E10 as an additional grade was suitable for the UK market. They highlighted that the UK fuel market is heavily optimised around supplying no more than 2 grades of petrol and adding a third grade would be costly and take significant time to implement.

Responses to the call for evidence from motorists and motoring groups, as well as other niche petrol users such as light aviation, highlighted the need for E5 to remain available for those that need it. Many respondents were keen to ensure that the lower-ethanol E5 grade was preserved in the higher-octane ‘Super’ petrol. High-octane fuel is suitable for all vehicles, and often preferred by owners of classic and cherished vehicles that may also need lower-ethanol blends.

Government responses to this consultation on E10 and consumer protection and fuel pump labelling were published in 2020, and were used to develop the policy proposals upon which we consulted.

Overview of our proposals and approach

With the overall objective to facilitate further carbon savings, the proposals within the consultation consisted of 2 key elements:

1. Introduce E10 supply in the standard 95-octane grade petrol.
2. Maintain E5 supply in the higher-octane ‘Super’ grade petrol.

The consultation proposed that any changes would apply UK-wide from a specific date onwards (with certain exemptions for some remote areas and specialist/low-volume fuel retailers).

The change would mean all filling stations in the UK would sell E10 petrol as their main grade, while all filling stations stocking a second high-octane petrol grade would need to ensure this remained E5.

We proposed setting these requirements by making amendments to the Motor Fuel (Composition and Content) (MFCC) Regulations 1999 Regulations. These regulations control the minimum standards for motor fuels supplied across the UK.

The preferred approach was to amend the MFCC Regulations such that petrol with an octane rating of 95 or 96 (standard petrol) must have an ethanol content of at least 5.5%. As the ethanol content of the fuel would fall between 5 and 10%, it would need to be labelled as E10. Suppliers would, however, maintain flexibility over the specific blend level to allow the efficient and cost-effective delivery of overall renewable fuel targets.

The MFCC Regulations would also be amended to ensure petrol with an octane of 97 or higher (the ‘Super’ grade) must contain no more than 5% ethanol (E5), as is currently supplied. This would ensure those that need access to a lower-ethanol fuel – such as historic vehicle, petrol-powered machinery and some light aircraft owners – would have UK-wide access to E5 fuel.

The consultation also included detailed proposals on who would be obligated to adhere to the new regulations and exemptions for certain remote areas, namely the Scottish islands. Derogations were also proposed for situations where there are short-term issues with ethanol supplies to blending sites.

Finally, the consultation included proposals on amending the consumer message that must accompany the sale of E10 petrol as defined in the Biofuel (Labelling) Regulations 2004. This message is to inform customers at the forecourt that E10 petrol may not be suitable for all petrol vehicles. Ensuring the wording of this message is appropriate is an important part of the wider communications campaign that would support any E10 roll-out.

Overview of consultation responses and government decision

Overview of respondents

We received 208 responses in total to the consultation, broken down as follows:

Type of respondent	Total responses received
Private individuals	143
Organisations (total)	65
Agricultural associations	4
Renewable fuel suppliers or associations	25
Fuel suppliers/distributors or associations	16
Local government	3
Motoring organisations	11
Non-governmental organisations	2
Other organisations	4
Total respondents	208

The responses can also be broken down into:

• those who submitted responses directly to the questions put forward in the consultation, normally via the proforma response form (138)
• those who submitted written statements on the general proposal to introduce E10 in the UK (70)

Many of the written statements did not address the specific questions in the consultation form but instead contained general points and observations on the subject of E10 introduction in the UK.

We have included these in the following general overview of consultation responses, while responses to the specific questions are summarised in more depth in the detailed summary of responses section of this response.

Overview of consultation responses

Around two-thirds of organisations responding were broadly supportive of E10 introduction, with others raising some specific concerns but not opposing the introduction in principle. Around a third of private individuals either explicitly supported the introduction of E10 or did not object in principle.

A small number of organisations argued against E10; however, among private individuals, more than two-thirds raised concerns about the introduction of E10, with the main concern being vehicle compatibility issues, particularly among owners of classic and older vehicles.

Respondents in favour of the proposals highlighted the use of E10 around the world as a tested means to decarbonise transport, noting that many countries already use E10 or even higher-ethanol blends to reduce fossil fuel use and CO₂ emissions. They argued that increasing ethanol blending would allow fuel suppliers flexibility to meet renewable fuel blending targets (set under the RTFO). Respondents also stressed that measures to decarbonise petrol would be important as the fuel would still be required for many years to come.

The responses also suggested that any vehicle compatibility issues could be managed via the protection grade – that is, keeping E5 available – and highlighted that the majority of vehicles on our roads were approved for use with E10 petrol. Examples were provided of the introduction of E10 in a number of European countries over recent years, with no issues having been reported following the change in grade.

Some respondents also pointed out the benefits of supporting UK ethanol producers and the wider agricultural sector, particularly their role in delivering the UK’s ongoing decarbonisation agenda.

Respondents not in favour of the introduction of E10 raised a number of concerns, mainly around vehicle compatibility. Their responses stressed the importance of keeping E5 available for use in vehicles not approved for use with E10 petrol. Many of these responses were from owners of classic and cherished vehicles who highlighted the damage ethanol-blended fuel can do to certain rubbers and alloys used in older vehicles. A number also raised the issue that not all incompatible vehicles are classic cars and that some incompatible older vehicles from the early 2000s are still in regular use.

Some respondents were concerned that the proposals to maintain E5 in the ‘Super’ grade might not be able to guarantee equal access to E5 around the country (with rural areas potentially at a disadvantage) and could mean increased costs. A particular concern was that the proposals would not guarantee E5 being kept available indefinitely.

Other concerns raised by respondents related to the sustainability and carbon savings of ethanol, and biofuels in general. Specifically, respondents saw a risk that increased ethanol production might divert food and feed crops to biofuel production, which could increase food costs and result in land-use change and deforestation (with some also linking it to concerns around increasing demand for palm oil for biofuel production and impact on rainforests).

The efficiency of importing ethanol from the global market was another concern raised. Others worried that any decrease in miles per gallon (MPG), due to ethanol containing less energy than fossil petrol, effectively negated any carbon savings.

Overview of the government’s response and outcomes

The government is grateful for all the responses and suggestions provided by respondents to the consultation. These have been used to inform our next steps.

It’s clear from the responses that industry representatives generally welcome the coordinated introduction of E10 in the standard 95-octane grade and that this could help reduce emissions from road transport in the longer term. It’s also clear that many owners of older vehicles are concerned that low-ethanol E5 petrol may not be widely available after E10 is introduced.

We’re therefore committing to 2 main actions in this government response:

1. To introduce E10 petrol UK-wide in the standard 95-octane grade.
2. To ensure the higher-octane ‘Super’ grade remains E5 at all forecourts that stock 2 petrol grades.

Both measures will be reviewed within 5 years to ensure they remain appropriate as is required by good legislative practice.

In relation to the E5 protection grade, such a review will examine if there’s a viable and widely available alternative to ensure suitable low-ethanol fuel remains available for older vehicles and other petrol-powered machinery that require it. We would like to reassure owners of such vehicles or equipment that, without such an alternative becoming available, it’s highly likely the E5 protection grade would continue to apply.

The carbon savings from an E10 introduction as presented in this consultation and accompanying impact assessment (PDF, 955KB) take into account the lifecycle emissions associated with ethanol from:

• the production of the feedstock
• fuel processing
• transport to the combustion
• other impacts such as reduced MPG of the fuel

The fuel would also be subject to the sustainability criteria and minimum GHG savings threshold under the RTFO.

It’s also important to highlight that ethanol is not produced from palm oil or other oilseeds that are associated with a higher risk of causing indirect land-use change.

Detailed summary of responses and government decisions

This section summarises the responses to the individual questions in the consultation and call for evidence, and provides the government’s response to issues raised.

Consultation on introducing E10 petrol

Consultees were asked the following questions about introducing E10 petrol:

Q1: Do you agree that the best way to introduce E10 petrol is as a direct replacement for the current 95 E5 premium grade? If not, please provide further information.

Response	Total responses received
Yes	64
No	56
Other	1
Total	121

Feedback received

The government received 121 responses to this question with over half agreeing that the proposed method for introducing E10 was the best available one.

Those that supported this method of introducing E10 petrol included fuel suppliers, renewable fuel producers and organisations from the agricultural sector. They highlighted a number of benefits of this approach, including:

• The simplicity of the approach: A straight swap to the main petrol grade would minimise any confusion caused to consumers. This approach would also limit the costs to suppliers and retailers (and, in turn, consumers) of introducing the new fuel.
• Alternative options to introducing E10 being less viable: Respondents highlighted that the UK’s two-petrol grade system cannot easily be altered to provide additional grades. As a result, they considered changing an existing petrol grade to E10 the only viable route. Switching to E10 in the ‘Super’ grade (rather than the ‘Premium’ grade), however, would mean only a minimal increase in ethanol blending due to the ‘Super’ grade taking a small part of the market share of petrol. Classic car owners also pointed out that the higher-octane ‘Super’ grade is often the preferred fuel for those with older cherished vehicles that cannot use E10.
• E10 being one of the few remaining easily deliverable options for meeting higher renewable fuel targets: In particular, fuel suppliers, renewable fuel suppliers and the agricultural sector pointed out that E10 would be widely used in Europe and around the world, and the fuel could be rolled out without further infrastructure or vehicle changes.
• Domestic benefits: Renewable fuel producers and the agricultural sector also pointed to the domestic benefits increased ethanol demand could drive – for example, for UK farmers.

The majority of respondents that did not agree with the proposal to introduce E10 in the ‘Premium’ grade were private individuals; they generally opposed any E10 introduction at all, with a number arguing for the complete removal of ethanol from petrol supply.

Private individuals also suggested adding 95-octane E10 (95 E10) to forecourts alongside the current 95-octane E5 (95 E5) as a choice for consumers instead of as a complete replacement, with clear guidelines on who should continue to use 95 E5.

The main arguments related to:

• Vehicle compatibility: Nearly half of the private individuals who responded were concerned that ethanol can damage engine and fuel-related components in older vehicles. Most argued that low or ethanol-free petrol should be widely available at forecourts.
• Fuel economy or increased cost: Concerns were also raised by a quarter of private individuals in relation to reduced fuel economy resulting from increased ethanol content, and that this could mitigate emissions benefits. The cost impact of increased fuel consumption was also highlighted.
• Sustainability concerns: Respondents also indicated wider concerns on the environmental benefit of ethanol as a road fuel and biofuels in general. Around a third of private individuals raised concerns in relation to food and feed crops being diverted to produce bioethanol and potential negative impacts, such as land-use change including deforestation (linking this also to discussions on palm oil).

Government response

It’s clear from the responses that there’s wide agreement among all parts of the fuel sector that replacing the current 95 E5 standard grade with 95 E10 is the best method to introduce E10 in the UK.

The benefit of this approach is that it allows for a rapid change with high uptake of the new fuel because the majority of petrol vehicles using the 95 grade can continue to use this grade following the switch to E10. The change in grade also requires minimal change in infrastructure in the fuel supply chain, meaning it can be implemented quickly and cost-effectively.

We recognise that many owners of older vehicles not approved to use E10 are concerned about the damage that prolonged use of E10 could do to their vehicle’s engine and fuel components; however, we’re committed to keeping an E5 grade available throughout the UK for those that will need it. (This is covered in more detail in our response to question 6.

We have considered the impact on fuel economy and decreasing MPG, which is due to the lower energy density of ethanol compared with fossil petrol, when developing our proposals. Analysis based on average calorific values of the 2 products suggests fuel economy could reduce by between 1 and 2%; however, the impact will vary based on driving style and refinements in fuel blending by suppliers. Importantly, E10 has been the reference fuel for vehicle MPG figures since 2012.

We would like to reassure those that raised concerns in relation to overall sustainability and carbon savings that moving to E10 can help deliver genuine GHG savings. The RTFO itself includes strict sustainability criteria, including minimum carbon savings requirements, that all biofuel must meet to qualify for the support offered by the scheme. We regularly publish statistics on the performance and sustainability of biofuels used in the UK as part of our RTFO reporting process.

It’s important to note that E10 petrol contains bioethanol, which is typically made from sugar and cereal crops as well as some waste products. These feedstocks generally carry a lower risk of causing indirect land-use change compared with oil crops (such as palm oil, soy or rapeseed), which are used in the production of crop biodiesel.

Due to the design of the RTFO, we actually see very little crop-based biodiesel supplied in the UK, with most of our targets met through bioethanol or waste-derived biodiesel with higher carbon savings. The combination of introducing E10 petrol and the RTFO’s sustainability criteria as well as the inbuilt ‘crop-cap’, which limits the overall volume of crop-based biofuel supplied in the UK, should help prevent any significant increases in the volumes of crop-based biodiesel being supplied to the UK in the future.

Ensuring that the renewable fuels that we support are sustainable and deliver genuine GHG savings is a cornerstone of our low carbon fuels policy.

We’ll continue to monitor how the overall scheme operates and plan to consult shortly on further amendments to the RTFO to ensure it:

• continues to deliver high levels of carbon savings
• supports the most effective routes to road fuel decarbonisation
• complements the decarbonisation policies of other transport modes such as aviation and shipping

Q2. Do you agree that introducing a minimum ethanol content of 5.5% in the 95 grade is the best way to ensure E10 is introduced across the UK? If not, what alternative would you propose?

Response	Total responses received
Yes	48
No	68
Other	2
Total	118

Feedback received

We received a total of 118 responses to this question.

Over half of the respondents did not agree with the introduction of a minimum ethanol content. More than two-thirds of those were private individuals who did not agree with the overall proposals in general, with the remaining third consisting of fuel suppliers, renewable fuel suppliers, agricultural associations and motoring associations.

Those that disagreed with the proposal fell into broadly 3 groups:

1. Those that were generally opposed to E10. These were mainly private individuals and made up the majority of those who did not agree with this question.
2. Those that agreed with the general approach but not with the minimum 5.5% ethanol threshold (accounting for about 10% of those who disagreed). This group was mainly comprised of fuel suppliers that favoured a ‘labelling only’ requirement, meaning all premium grade petrol would need to be labelled as E10 but the market would ultimately dictate the ethanol content blended to meet overall RTFO targets at any point. They argued that, under either proposal, most suppliers would likely blend towards the 10% maximum ethanol content for E10 as a cost-effective means of meeting targets. They highlighted that an advantage of the ‘labelling only’ requirement would be the increased flexibility, which would also enable the use of alternative renewable fuels, such as bio-methanol, to be blended into petrol should market conditions allow.
3. Another small group of respondents, made up of renewable fuel suppliers, fuel suppliers and private individuals, felt that the 5.5% limit was too low and should be set higher – perhaps 7.5% to ensure the positive effects from increasing ethanol levels.

Some of the fuel suppliers who disagreed with the proposal also suggested to amend the definition of E10 to:

a minimum 5.5% ethanol content or a greater than 2.7% oxygen content” (while remaining equal to or below 10% ethanol and 3.7% oxygen as the upper limits)

In practice, this would mean petrol containing more than 2.7% oxygen could also be classed as E10 regardless of the actual ethanol content. They outlined the benefits to such an approach would be that this would also allow for petrol blends containing renewable fuels other than ethanol, resulting in increased flexibility for suppliers to meet their RTFO obligation and potentially stimulating second-generation biofuel production, which may increase carbon savings.

Those who were supportive were a mix of fuel suppliers, renewable fuel suppliers, agricultural organisations, motoring organisations and private individuals. They argued that setting the minimum at 5.5% still gave fuel suppliers flexibility to deal with supply and demand issues while ensuring that the new fuel could be labelled as E10.

They also noted that fuel suppliers were likely to blend up to 10% ethanol – as demonstrated, for example, in other countries such as the Netherlands, where fuel suppliers immediately blended to 9.8% ethanol despite the minimum renewable content having been set at a lower level.

Government response

Based on the responses received, we have decided to proceed with requiring a 5.5% minimum in the 95-octane standard petrol grade. While we appreciate suppliers want maximum flexibility in meeting their obligations, it’s also important that the new fuel we introduce does contain more than the current 5% ethanol content to ensure there’s a clear environmental benefit and continued consumer trust.

The 5.5% minimum provides fuel suppliers with the maximum flexibility while still ensuring the petrol supplied is consistent with the labelling and consumer information supporting the roll-out.

Under the ‘labelling only’ proposal – where fuel would be labelled E10, but could still contain little or no ethanol – fuel consumers could rightly be confused and concerned about the true quality of the new fuel supplied. By requiring the fuel to have more than 5% ethanol, the government ensures that the new fuel will provide environmental benefits, and clear guidance around vehicle compatibility and carbon savings can be provided to consumers.

We have not included reference to the oxygen content of fuel in the new requirements as these could be equally met by fossil-based oxygenates. This would potentially allow a 100% fossil petrol with more than 2.7% oxygen content to comply with the requirements. As a result, allowing the new regulations to be met in this manner would undermine the very principle behind the regulations: to increase the use of renewable fuels in petrol.

To account for technology development and alternative solutions potentially coming to the market, however, we’ll keep the 5.5% minimum ethanol content under review to ensure it meets policy objectives. In line with government best practice, we’ll conduct a formal review within 5 years following the adoption of the legislation.

Q3. Do you agree that the minimum ethanol content requirements should apply to filling stations that sell more than 1 million litres of fuel a year and that this would only allow certain specialist retailers to continue to sell 95 E5? If not, please provide further information and alternative suggestions.

Response	Total responses received
Yes	44
No	62
Other	1
Total	107

Feedback received

We received a total of 107 replies to this question and the majority of respondents disagreed with the proposal.

There was a clear split, however, between responses by organisations and those providing detailed comments to the question who, in their majority, supported the proposals, and private individuals who were opposed to the general approach, which constituted the vast majority of those in opposition to the proposal.

Respondents who agreed with the proposal included fuel suppliers, trade associations, motoring organisations and private individuals. They noted that 85% of filling stations met these criteria and those sites supplied significantly more than 85% of petrol in the UK. This would therefore ensure a wide consumer take-up.

Respondents highlighted that many of the small filling stations falling below the threshold for being required to stock 95 E10 would still likely stock that fuel. This would be because the supply chain available to them would be unlikely to offer a 95 E5 option due to the required additional infrastructure and inherent costs.

Some respondents noted, however, that it could allow certain remote rural communities and specialist retailers to continue to provide 95 E5 petrol with between 0% and 5% ethanol.

The majority of respondents that disagreed were private individuals who were generally against the introduction of E10 (as outlined in question 1) and as such did not provide further details.

Some respondents, however, raised concerns that requiring rural filling stations with only a single petrol grade available to switch to E10 could mean longer journeys to access supply of E5 petrol from a filling station stocking the ‘Super’ grade. Respondents argued that these extra or extended journeys could undermine emissions benefits derived from the switch to E10.

Government response

We can confirm that the minimum ethanol requirement would apply to filling stations that sell more than 1 million litres of fuel (both petrol and diesel) a year, unless a specific exemption applies (see question 4).

This will ensure the roll-out of E10 is widespread and consistent, allowing a simple and clear message to be delivered to motorists in terms of what fuel grade they can expect to find at filling stations.

We expect the regulations would mean that all large and medium-sized filling stations and the majority of small filling stations will switch to E10 in the standard ‘Premium’ grade. The regulations will, however, allow small and specialist filling stations to sell ‘Premium’ grade E5 if it’s available via local supply chains.

While we appreciate some motorists may need to drive further to find suitable fuel if their local filling station is only able to supply E10, it’s unlikely most motorists will not pass close to larger filling stations regularly as part of their general driving.

Question 4 also sets out additional mitigation proposals for those living in the most remote parts of the UK.

Q4. Do you agree that there should be an exemption for filling stations supplied from fuel terminals that are in turn supplied by ship? Is this definition suitable? Should other terminals be included or should a different or no exemption be applied?

Response	Total responses received
Yes	46
No	24
Other	0
Total	70

Feedback received

The government received 70 responses to this question; the majority agreed with the proposal.

Those that agreed with the proposal included fuel suppliers, renewable fuel suppliers, motoring organisations and private individuals. They pointed out the need for remote areas, such as the highlands and islands in Scotland, that currently supply ethanol-free fuel to continue to do so due to the infrastructure and geographical challenges these areas pose.

Fuel suppliers with direct involvement in the supply of fuel into certain areas of Scotland, however, cautioned that a wider exemption may be needed. They explained that currently all petrol supplied into the Aberdeen and Inverness fuel terminals would be ethanol free. The fuel is currently supplied to the terminals via ship from the east coast of England, and distributed across northern and central Scotland and onward via further ship distribution to the Scottish islands.

The suppliers stressed that it would currently not be possible to transport a blended petrol product via the existing ship supply lines, while also cautioning against the feasibility, timelines and costs of installing ethanol-blending facilities at the terminals.

They highlighted that alternative supply lines, such as road-tankering blended fuel, would present additional challenges and costs. They cautioned that this approach would lead to increased vehicle emissions and traffic, and could make the current ship-based supply route, which also handles diesel and other fuels, uneconomic. The onward supply to the Scottish islands could also be affected as these sites would still require a relatively small volume of ethanol-free petrol. Similar challenges with onward supply to the islands would also apply should blending facilities be installed at the terminals.

While these issues may be resolvable in the medium term, it was made clear it would not be feasible in the short term.

These respondents were therefore keen for any minimum ethanol requirement to be waived for supply chains operating out of Aberdeen and Inverness.

Responses also suggested alternative mechanisms to identifying regions in which filling stations might be exempted from the requirement to supply E10 – most notably the areas defined by the Rural Fuel Duty Relief Scheme. It was argued that filling stations in these areas were those most removed from larger towns that would also offer ‘Super’ grade fuel. Allowing these single grade sites to continue selling E5 95 would ensure they supply all petrol vehicles needing fuel in their area.

Many of those that disagreed with the proposal were private individuals who were unclear on its purpose or how it related to the wider proposals on E10 petrol. Concerns were, however, also raised by some of those that were supportive of an E10 introduction, arguing that offering significant exemptions could undermine the policy and limit the benefits it seeks to provide.

Government response

Based on the detailed responses to this question, we have decided to further refine our approach to both how to:

• classify the most remote filling stations
• provide a mechanism for those fuel terminals that are currently unable to supply petrol blended with ethanol

Firstly, we propose that any fuel terminal that is unable to blend ethanol into petrol will be able to apply for an exemption to the 5.5% minimum blend level. This will allow those fuel terminals to continue to supply ethanol-free petrol to filling stations. The exemption will also automatically permit filling stations receiving that fuel from an exempted terminal to sell that fuel and still be deemed to have met the requirements of the MFCC Regulations.

Fuel terminal exemptions will apply initially for 2 years. This is the minimum timeframe estimated for any investments in blending facilities to be completed; however, we recognise that a longer period may be required before ethanol blending can be achieved at the relevant terminals. Accordingly, the exemption may be extended via a further application. Any extension will be subject to consultation with stakeholders to ensure such exemptions remain proportionate.

The petrol volume affected is expected to be relatively small, accounting for less than 1% of total UK petrol supply. The fuel volumes supplied in this area still fall under the wider RTFO targets and, therefore, fuel suppliers will need to find alternative renewable fuel supply options to meet overall emissions reductions targets. As a result, overall CO₂ emissions reductions should not be adversely affected.

Secondly, we also propose that filling stations that are eligible for the Rural Fuel Duty Relief Scheme – as specified in Schedule 1 of the Hydrocarbon Oil and Biofuels (Road Fuels in Defined Areas) (Reliefs) Regulations 2011 – will not be required to meet the 5.5% ethanol requirement. This would cover the Scottish islands, as originally proposed, but also certain mainland areas particularly removed from larger towns that are likely to only stock a single petrol grade. It also includes some small parts of England and the Scilly Isles.

Filling stations in these areas would, therefore, be permitted to continue to sell E5 95, provided it’s available from local supply chains.

Both exemptions will be kept under review and will be required to be part of a formal review of the wider policy within 5 years.

Q5. Do you agree that introducing E10 in 2021, and providing industry and motorists with at least 6 months’ notice and a 2 months’ implementation period is sufficient to prepare for the change in fuel grades? If not, what alternative timelines would you suggest and why?

Response	Total responses received
Yes	46
No	72
Other	0
Total	118

Feedback received

The government received 118 responses to this question; the majority of respondents did not agree with the proposal.

This included mainly respondents that wanted longer to prepare for the change (for example, private individuals, including owners of classic vehicles, and motoring associations), but also some that wanted a quicker introduction (for example, some renewable fuel suppliers).

Those arguing for a longer implementation period (mainly private individuals with many owners of classic vehicles) made reference to the 600,000 vehicles that would not be able to use E10 and the time required to modify these vehicles to make them E10 ready. In addition, in line with challenges highlighted in question 4, some fuel suppliers also argued for a longer timeframe to be able to address challenges around the Aberdeen and Inverness fuel terminals.

Those that wanted a quicker transition did not give firm timeframes, but highlighted that the fuel should be introduced as quickly as possible.

Those that supported the proposal and agreed that the given timelines were appropriate were mainly made up of fuel suppliers, retailers, ethanol suppliers and other organisations. Many of them argued for the shortest possible notice and implementation period, with some highlighting that it was essential to introduce E10 in 2021 to realise environmental benefits and give a clear message in support of the UK bioethanol industry. Some also highlighted that similar timelines had been widely agreed as appropriate as part of previous industry working groups on E10.

Fuel suppliers were generally in consensus that the introduction of E10 should coincide with the switch between summer and winter fuel grades that occurs in April and September. There was a general preference for September as increasing ethanol blending would be more easily achieved during this change in fuel specifications.

Government response

Based on the responses to this question, we’re content that a notice period of at least 6 months is suitable for members of the fuel sector to prepare and implement the change in fuel grade. We also recognise that the change from summer to winter fuel specification in September is the most suitable point in the year to require fuel suppliers to increase the ethanol content of one of their petrol grades.

We therefore plan to lay the necessary legislation as soon as possible for an E10 introduction in September 2021. The legislation will require that, where fuel is subject to the new 5.5% minimum ethanol requirement, it must be distributed from fuel terminals as such from 1 September 2021 to coincide with the change from summer to winter fuel grade.

There will then be a 2-month period before the fuel sold at filling stations will be required to meet the 5.5% minimum requirement to allow time for fuel deliveries to forecourts around the UK.

A number of respondents were concerned that they would not be able to adapt their vehicles to the new fuel before it’s introduced. We recognise that such changes could be costly and complex, and so are committed to keeping an E5 option available at filling stations across the UK. This means motorists should not need to consider adapting their vehicle because suitable fuel will remain available after E10 is introduced in the 95-octane grade. This is discussed in more detail in questions 6 and 7.

Q6. Do you agree that the protection grade should apply to the 97+ octane ‘Super’ petrol grade at filling stations that supply at least one million litres of fuel in the last calendar year and supply at least 2 grades of petrol? If not, please explain why and provide any alternative suggestions.

Response	Total responses received
Yes	60
No	40
Other	1
Total	101

Feedback received

The majority of respondents agreed that all filling stations supplying more than one million litres of fuel and 2 grades of petrol should provide the protection grade in 97+ octane. This included fuel suppliers, biofuel producers and some private individuals.

Some classic car owners supported the proposal on the basis that the ‘Super’ grade is already the fuel of choice for many owners of older cherished vehicles and keeping this as a low-ethanol petrol was the most appropriate option. Some private individuals qualified their support, arguing that E5 ‘Super’ grade needed to be widely available at filling stations across the UK.

Most of those that disagreed with the proposal were private individuals who gave a range of reasons for not supporting the protection grade in this form. Some argued that E5 petrol should be available at all filling stations; a number noted that the proposals could leave rural areas with lower levels of protection grade availability as many small filling stations only sell one petrol grade.

Some noted that requiring motorists to drive further for suitable fuel would reduce the emissions benefits of the policy as a whole. Concerns were also raised that keeping E5 available in the more expensive ‘Super’ grade would most impact poorer motorists with incompatible vehicles.

One respondent also argued that there was no need for the protection grade to be defined in legislation as the market should determine whether the ‘Super’ grade remained E5 or switched to E10.

Government response

We’re committed to ensuring that E5 will remain available to those consumers that still require it. Accordingly, we’ll put into place legislation to guarantee that the higher-octane 97+ ‘Super’ petrol grade will remain E5 across the UK.

Responses to the consultation confirmed many classic and cherished car owners already use the ‘Super’ grade, and the limited mileage these vehicles generally do means that switching to the more expensive grade should have a minor impact on the costs of running an older vehicle.

Filling stations that stock 2 grades of petrol and supply at least one million litres of fuel in total will need to ensure one is a higher-octane E5 option. While not all filling stations meet these criteria, almost all towns across the UK will have a filling station that supplies the ‘Super’ grade. The main exception to this is in certain parts of the Highlands, north and west coast of Scotland, which will be covered by the exemption discussed in question 4.

We recognise that there are a small number of non-classic vehicles from the early 2000s that will also need to switch to the more expensive ‘Super’ grade. It’s estimated that, by the end of 2021 when E10 is introduced, this will represent less than 1% of all cars on the road. Most of these vehicles are also likely to come to the end of their life in the near future and vehicles that are compatible with E10 are available for every budget, including on the second-hand market.

Previous analysis has not found any link between ownership of these older vehicles and lower incomes, so the policy will not disproportionately impact poorer motorists. While we recognise that these owners could be adversely affected as a result of the higher fuel costs associated with using the ‘Super’ grade, given the small and declining numbers, the significant benefits E10 can provide outweigh these considerations. It has not been possible to identify proportional mitigation for owners of these vehicles that would not significantly increase the cost and complexity of rolling out the new fuel.

Q7. Do you agree that the protection grade should apply for the maximum period of 5 years after the introduction of E10 before being reviewed for any further extension? If not, please explain why and provide any alternative suggestions.

Response	Total responses received
Yes	51
No	54
Other	0
Total	105

Feedback received

The government received 105 responses to this question with a near even split on those who agreed and disagreed; slightly more respondents disagreed on the length of the protection grade.

Those that agreed included private individuals, fuel retailers, renewable fuel suppliers and other organisations. Many of these respondents stressed that the protection grade most likely would need to be extended following the 5-year review because a large number of classic vehicles would still be in use beyond this period.

At the same time, some fuel suppliers cautioned that having the ability to review the policy earlier could be valuable should fuels that provide greater emissions savings be developed. They argued that, after 2 or 3 years, it should be left to the market to decide on ethanol content offered in the ‘Super’ grade.

The majority of those that did not agree with the time-period for the protection grade were private individuals who wanted to see the protection grade available indefinitely for those with classic vehicles or vehicles that cannot use E10.

Some interpreted the question to mean that the protection grade would expire after 5 years and wanted to ensure suitable fuel for their vehicle would continue to be available for the classic car sector for many years to come.

Government response

As highlighted in question 6, we’re committed to supporting the continued availability of suitable petrol for older vehicles that are not approved to use E10. We also recognise that classic car sector is an important part of UK heritage and source of great enjoyment to many people.

We’ll therefore ensure that ‘protection-grade’ regulations requiring the widespread availability of E5 petrol will be in place for a minimum of 5 years. Regulations such as this must be reviewed periodically to ensure they’re still appropriate, and we therefore included a review clause after 5 years.

It’s important to stress, however, that the protection grade requirements would only be removed after 5 years if a suitable, widely available alternative solution becomes available for vehicles that are not compatible with E10. This question will be central to future decisions on whether to maintain the legal requirement for forecourts to stock a low-ethanol grade.

In terms of the flexibility called for by some in the fuel sector, we do not expect to see a novel fuel developed in the next 5 years that outweighs the benefits of ensuring a consistent supply of E5 for those that need it; however, should new evidence emerge, this could be addressed as part of any future review.

Q8. Do you agree that short-term derogations are required to ensure fuel supply resilience can be maintained? If you do not agree, please set out the reasons why.

Response	Total responses received
Yes	58
No	21
Other	1
Total	80

Feedback received

We received 80 responses to this question with the majority in support of short-term derogations, including fuel suppliers, biofuel suppliers, motoring organisations and private individuals.

Fuel suppliers who agreed argued that it was necessary to allow for unforeseen supply constraints – particularly because fuel with less than 5.5% ethanol would still be compliant with fuel quality standards and, as such, suitable for sale to the general public. Short-term derogations would prevent issues arising in fuel supply chains due to unforeseen circumstances, such as short-term issues with supply chains.

A number of organisations also highlighted that the derogations should be closely monitored to ensure they were being applied for and used appropriately. Those that disagreed included renewable fuel suppliers that felt there was no need for any derogation from the 5.5% minimum ethanol requirement as fuel suppliers have been blending consistently just below the current 5% threshold.

They argued that a derogation would not be required because there’s only a small percentage increase required to meet the 5.5% standard; however, most qualified that they could support a derogation process, provided the scenarios had narrow definitions and were well monitored to prevent any loopholes.

Government response

We have combined our response to questions 8, 9 and 10 – see question 10.

Q9. What are likely scenarios in which a derogation may be required?

Feedback received

We received 61 responses from fuel suppliers, renewable fuel suppliers, motoring organisations, other organisations and private individuals, which offered the following scenarios for when derogations may be required:

• short-term disruption to ethanol supply – for example, due to production facility disruption or local delivery of off-spec ethanol to a fuel terminal
• in the event of a national emergency – for example, coronavirus (COVID-19) where ethanol supplies are reduced or diverted to other uses such as sanitiser
• loss of short-term blending capability at fuel terminals due to technical issues on site
• 10-year inspection cycle for ethanol storage tanks could cause issues in certain years
• an increase in the price of ethanol could make blending uneconomic compared with alternative biofuels

Government response

We have combined our response to questions 8, 9 and 10 – see question 10.

Q10. Are the duration, process and reporting elements of the derogations appropriate, and if not, what changes would you like to see and why?

Response	Total responses received
Yes	29
No	28
Other	0
Total	57

Feedback received

There was a near even split between the 57 responses received in relation to whether the derogations were appropriate, with a very slight majority in favour of the proposals.

Those that agreed with the duration, process and reporting elements of the derogations included fuel suppliers, motoring organisations, other organisations and private individuals.

They supported the relatively short durations and the requirement to provide an explanation of events and remedial measures. They felt that the proposed limit of 3 applications a year would prevent systematic abuse of the system; however, they equally stressed that if trends emerged, further investigation and possible amendment of the regulations should be required.

Those that did not agree with the proposals consisted of fuel suppliers, motoring organisations and private individuals. They asked for the following changes:

• some fuel suppliers raised a concern that the limit on derogation application would be determined by fuel supplier company: they suggested this could unfairly disadvantage those with larger or more distributed supply operations, and suggested allocating derogations by distribution location would be more appropriate
• some fuel suppliers also suggested that 14 days would be a more appropriate timeframe for a derogation (rather than the proposed 10 working days): ultimately, the actual situation on the ground would determine how quickly compliant fuel supply could be restored. It was suggested that a system of derogation extension could be implemented to alleviate this. Some stated that more than 3 derogations a year may be required
• other respondents raised a concern about fuel suppliers being granted ‘de-facto approval’ and argued that fuel suppliers should have to apply for approval before any non-compliant fuel is supplied

Government response

This response covers questions 8, 9 and 10.

In line with the proposals set out in the consultation, we’ll include provisions within the regulations to allow for short-term derogation to mitigate against short-term fuel supply issues where fuel suppliers are unable to blend fuel with the minimum 5.5% ethanol content.

Based on the responses, we have reviewed our approach and agree that it would be more appropriate to permit claims to be made based on sites rather than overall company. This means a single blending facility may not claim more than 3 blending derogations in a 12-month period. This ensures larger companies with multiple sites where ethanol blending is carried out will not be at a disadvantage compared with companies with fewer blending sites.

The 10-day derogation must be claimed within 2 working days of the issue arising and will last for 10 working days from the day the issue arose. The derogation will be granted automatically; however, details will need to be provided by the claimant to ensure the derogation process can be monitored.

At the time of notifying the DfT of the issue and formalising the 10-day derogation, a request for a longer exemption may be made if the issue is not expected to be resolved within 10 working working days. Such requests will be considered on a case-by-case basis.

We’ll publish details of the derogations claimed on an annual basis.

The derogation mechanism is designed to be simple as possible to ensure fuel supplies can be maintained without a complex application system. The short duration and limit on applications should ensure the system is not abused. We expect the derogations to be claimed only in limited circumstances where ethanol blending is not possible. If we have concerns the system is being used for other reasons, we’ll look to review the derogation mechanism.

Q11. Is the classification of a fuel supplier appropriate for the application of derogations and if not, what would you suggest?

Response	Total responses received
Yes	40
No	13
Other	1
Total	54

Feedback received

The majority of the 54 respondents agreed with the classification of a fuel supplier for the application of derogations.

These included fuel suppliers, renewable fuel suppliers, motoring organisations, other organisations and private individuals.

One respondent highlighted, however, that fuel retailers may also need direct derogations to temporarily retail fuel that did not meet the new ethanol requirements.

Those that disagreed with the proposal were generally disagreeing with previous elements of the E10 policy rather than the specific definition of a fuel supplier; however, one respondent did suggest that the definition should mirror that used in the RTFO guidance to ensure consistency.

Government response

We recognise the broad agreement on the proposed definition of a fuel supplier for the purposes of claiming derogations. To ensure that those involved in the distribution and blending of petrol are able to use the derogation, we’ll use existing definitions in the legislation, with amendments where necessary.

We’ll also ensure the derogation applies downstream of the blending point – including at the point of sale – to ensure fuel retailers can still offer fuel for sale when the ethanol content is below 5.5%.

Q12. Do you agree with the proposed wording for the E10 labelling? If not, why not and what alternative would you suggest?

Response	Total responses received
Yes	49
No	37
Other	1
Total	87

Feedback received

The majority of the respondents agreed with the suggested wording of the message:

Suitable for most petrol vehicles: check before use

Those supporting the proposal argued that the proposed text provided the right combination of brevity, reassurance and required information to drivers.

Many respondents suggested that it was vital that information on checking vehicle compatibility was also clearly visible at filling stations. While the required legal message would provide a warning to consumers around vehicle compatibility, it would be important that additional focused information was easily available to support the consumer decision, particularly around the time of the change in the fuel grade.

These points were also covered in the responses to question 13 on the wider communications requirement to support the roll-out of E10.

Respondents not in favour generally called for a more conservative approach with more precise guidance on the dates upon which many or all compatible vehicles were manufactured. Suggested dates ranged from 2000 to 2011.

Some suggested that the wording should direct motorists to check with the vehicle manufacturer while others proposed the wording should include the potential dangers for vehicles that are incompatible with E10.

Government response

We’ll proceed with amending the wording of the E10 consumer message to ‘Suitable for most petrol vehicles: check before use’.

This proposal received broad support, and while we recognise the differing views and welcome the alternative options put forward, we believe the current proposal strikes the right balance in terms of reassurance and essential information.

Including a reference to 2011 – the date when all new cars had to be compatible with E10 – could suggest to consumers that millions of older cars that are actually approved for E10 should not use the new fuel grade. This could lead to many more motorists than required purchasing more expensive petrol. Equally, while most cars produced since 2000 are compatible with E10, using the year 2000 as a marker could provide false reassurance to those that do not.

As a result, cautioning motorists to check before use and supporting this with an effective communications campaign will provide the best balance in supporting the smooth roll-out of the new grade. This is discussed further in question 13.

Q13. Do you have further comments or suggestions for communicating the E10 compatibility message?

Feedback received

The government received 73 responses to this question from a range of respondents including fuel suppliers, renewable fuel suppliers, motoring organisations, other organisations and private individuals.

About two-thirds of respondents agreed that, should E10 be introduced, there would need to be a comprehensive communications campaign. Respondents stressed that the message would need to be simple, clear and impactful.

Suggestions included:

• creating a website or QR code where users could check their vehicle compatibility and learn more about the introduction of E10
• running TV campaign
• running a radio campaign
• providing information at petrol station forecourts
• providing information on car compatibility via the DVLA or Driver and Vehicle Standards Agency (DVSA) when renewing tax or as part of the MOT reminder

Respondents were clear that the communications campaign should be government led. The development of the communications plan should happen in cooperation with fuel suppliers, vehicle manufacturers, motoring organisations and environmental groups. Respondents also referred to the previous approach taken for the introduction of new fuel labels and suggested a similar approach for the E10 campaign.

A number of suggestions were also made for what should appear on any government website. This included:

• a vehicle compatibility checker
• a link to the European Automobile Manufacturers Association (ACEA) list of unwarranted vehicles
• well-reasoned justification for the introduction of E10
• clear warning of the dangers to unwarranted vehicles

Respondents also noted the importance of consumers having the ability to check vehicle compatibility at the pump as this could be the first time a consumer might come into contact with the new fuels.

Government response

We acknowledge that, when E10 petrol is introduced, it will be important for motorists to have access to clear information on the compatibility of their vehicle. We’re therefore committed to working with industry to ensure this information is made widely and easily available.

As noted in the consultation, the government recognises the need for a comprehensive communications campaign to ensure the successful introduction of E10, and that those with vehicles not approved for E10 are able to choose and use the correct fuel.

We have launched an online vehicle compatibility tool, which is available to the public and will be developed further based on feedback. This will support a wider government and industry communications campaign that will launch closer to the introduction of the new fuel.

We’re focused on delivering a campaign that encourages motorists to check their vehicle compatibility before E10 introduction, but will also work with industry to provide clear and obvious guidance at the forecourt.

Call for evidence on wider policy impacts

The consultation document also included a call for evidence on the impact of introducing E10 on other related policy. The government received 63 responses to this call for evidence.

The information provided to these questions has been used to inform our next steps, including, for example, with respect to future targets for renewable fuel supply under the RTFO.

More information on our policy proposals will be provided as part of a forthcoming consultation on wider changes to the RTFO.

The following questions were asked as part of the call for evidence:

Q14. Would an increase in RTFO targets, alongside or subsequent to an introduction of E10, deliver additional GHG savings from the scheme?

Response	Total responses received
Yes	36
No	17
Total	53

Feedback received

The government received 53 responses to this question. More than two-thirds of respondents agreed that increasing the RTFO target in line with the introduction of E10 would see an increase in GHG savings.

Those included fuel suppliers, renewable fuel suppliers, agricultural organisations, local government and private individuals.

They argued that the introduction of E10 would provide industry with flexibility as to how they reached their targets under the RTFO. Increased flexibility would in turn reduce the risk of suppliers buying-out^{[footnote 2]} of their obligations to supply renewable fuel under the RTFO.

Increased buy-out of suppliers would in practice mean that projected GHG savings of the RTFO would not be realised. Respondents noted that Renewable Transport Fuel Certificates (RTFCs) had recently been trading very close to the buy-out price included in the legislation.

Some respondents stressed that the introduction of E10 should not be delayed to align with any increase in the RTFO targets.

Those that did not agree included private individuals who considered the impact of E10 to be insignificant in terms of GHG savings, and argued that the benefits would be offset by owners of older vehicles having to purchase new vehicles and the carbon emissions associated with building those vehicles.

Other respondents highlighted how difficult it would be to provide a definite answer, as any assessment would necessarily be based on a range of assumptions (for example, on the availability of waste-derived biofuels, future prices, demand for petrol and diesel, international competition for fuels and feedstock, carbon intensity of fuels supplied and so on).

They noted that, should not enough sustainable biofuels be available, this could lead to an increase in costs, resulting in fuel suppliers buying-out of their obligation rather than supplying fuels with a negative impact on carbon savings. As such, increasing RTFO targets would not necessarily result in higher GHG savings.

Government response

We have combined our response to questions 14, 15 and 16 – see question 16.

Q15. Would you be supportive of such a change? You may wish to consider the level of any increase and the timing of it within your answers. Please provide any evidence you may have to support your response.

Response	Total responses received
Yes	31
No	22
Total	53

Feedback received

We received a total of 57 responses with 35 respondents being supportive of an increase to RTFO targets.

The majority of respondents were receptive to a change in RTFO targets to accommodate E10. This included renewable fuel suppliers, fuel suppliers, agricultural organisations, local government and private individuals.

In terms of the level and timing of the increase, respondents made the following suggestions:

• a 1.5% increase over 3 years
• a steady increase to 15% by 2032 (rather than the current 12.4%)
• some renewable fuel suppliers suggested an increase of the existing targets (10.1% in 2021^{[footnote 3]}) to up to 11%, concurrent with E10 introduction in 2021. One supplier argued for a 10.75% target to prevent the displacement of waste biodiesel through crop-based ethanol, with the target rising by 0.5% each year to maintain current biodiesel levels.

Government response

We have combined our response to questions 14, 15 and 16 – see question 16.

Q16. Do you expect any other risks or potential impacts of such a change other than the ones listed in this call for evidence?

Response	Total responses received
Yes	30
No	23
Total	53

Feedback received

We received a total of 53 responses to this question.

Respondents were split between those that considered there were additional risks and those that did not identify additional risks to those already identified in the call for evidence (for example, the potential displacement of waste biodiesel through less sustainable biofuels or the risk of companies buying-out of their obligation).

Those that highlighted additional risks included mainly classic car owners who raised concerns regarding the use of E10 petrol in their vehicle.

Others included some fuel suppliers, renewable fuels suppliers, motoring associations and agricultural associations. They were worried that the crop cap under the RTFO, which limits the contribution crop-derived biofuels can make to RTFO targets, could deter further investments into bioethanol. These concerns included advanced bioethanol produced from wastes, which could be an issue with increasing RTFO targets.

Government response

This response covers questions 14, 15 and 16.

To be confident that additional GHG savings will be realised, there’s a need to balance ambition for increased RTFO targets against the amount of sustainable feedstock available.

The government is therefore considering increases to the main RTFO target. Any changes would need to be consulted on and legislated for, and the consultation would be accompanied by a cost-benefit analysis setting out the expected costs and GHG savings.

Q17. Please provide any evidence you have on the potential impacts of continuing the GHG saving obligation beyond 2020. We’re interested in evidence relating to costs and GHG savings as well as wider impacts on the industry. If the targets were to continue, do you have any views on:

a) which measures should be rewarded with GHG credits? For example, should Upstream Emissions Reduction Credits (UERs) continue to be included?

b) the level of the obligation, i.e. should it remain at 6%?

c) any other changes to the system you would like to propose

Feedback received

A total of 36 responses were received across all parts of this question.

The majority of respondents – including fuel suppliers, renewable fuel suppliers and local government – wanted to see the GHG scheme maintained, arguing that it had been instrumental in delivering significant GHG savings and driving renewable fuels blending.

Some renewable fuel suppliers noted the work done by the European Environment Agency, which stated that scrapping the scheme could lead to instability in the area, and set back investment and continued decarbonisation of the sector.

Most respondents argued that it should be renewed in its current form until a full consultation could take place to review the continued inclusion of UERs and the level of obligation.

Government response

The government welcomes the stakeholder input and notes the stakeholder interest in the continuation of the GHG saving obligation remains.

During 2020, initial work was undertaken to understand whether it was feasible to continue the GHG saving obligation in 2021. As previously communicated to stakeholders, it was determined that this work could not be completed in the time available.

There’s emerging evidence that having a GHG saving obligation in parallel to the RTFO may have delivered additional GHG savings; however, this picture will not be complete until data on the fuel supply in 2020 is available.

While the incentives available through the RTFO are not directly linked to the GHG savings of the renewable fuels supplied, the RTFO incorporates measures to encourage the fuels with the best GHG savings, including double counting for fuels made from wastes and residues, the cap on crop-based biofuels, and the minimum thresholds for GHG saving performance.

Next steps

We’ll lay legislation implementing these proposals as soon as possible. Subject to parliamentary approval, E10 will become the standard 95-grade petrol from 1 September 2021.

We expect filling stations to be begin switching to the new grade during the summer, with precise timings to be confirmed.

In line with our obligations under the Northern Ireland Protocol, we’ll also notify the European Commission of our intention to legislate for the introduction of E10 in Northern Ireland to ensure regulations can be introduced there before the September 2021 change in petrol grade. Once the notification process is complete, similar legislation will be introduced in Northern Ireland to ensure consistency. We’ll work with relevant stakeholders to ensure this does not alter the timetable for E10 introduction in Northern Ireland.

Guidance on E10 petrol, including a compatibility checker, has now been published.

We’ll be working with the fuel sector to develop a comprehensive communications campaign ahead of the roll-out of E10 in the summer of 2021.

1. The 2% figure includes allowances for indirect land-use change (ILUC) and accounts for the energy difference between fossil petrol and ethanol. ILUC is calculated based on the indirect effect of increased crop land-use leading to additional CO₂ emissions. ↩

2. Suppliers can meet their annual obligations to supply renewable fuel under the RTFO by either redeeming RTFCs (issued for the supply of sustainable renewable fuel) or by buying out of some or all of their obligation. ↩

3. This figure includes the sub-target for development fuels. Development fuels are advanced fuels, which are strategically important because they’re suitable for sectors that are more difficult to decarbonise through electrification, including aviation and road freight. ↩