For: Ad-hoc industry consortium
[July – September 2025]
Background
An ad-hoc industry consortium has asked studio Gear Up to assess the benefits of intermediate crops, to assess the bottlenecks to their development and deployment, and to provide recommendations for certification of these crops in the frame of the Renewable Energy Directive.
This report has been commissioned by Bayer Crop Science, Bunge, Camelina Company, Corteva Agriscience, and Nufarm in support of the ongoing work of the ad-hoc Annex IX industry coalition including the companies above and bp, Chevron, Moeve, Neste, Louis Dreyfus Company, Repsol, SkyNRG and other supporters. The group has provided input without endorsing this report. The contents solely reflect the views of studio Gear Up.
Intermediate crops are crops planted and harvested between main crops in a crop rotation scheme. Their development, on top of existing food and feed farm output, offer additional volumes of feedstocks for the bioeconomy without requiring additional land. In the EU, renewable fuel targets are stimulating the use of intermediate crops. Their inclusion within the Annex IX of the Renewable Energy Directive makes them an interesting feedstock to meet renewable fuel subtargets of the Renewable Energy Directive, ReFuelEU Aviation and FuelEU Maritime.
Read the full report here.
Benefits
The integration of intermediate crops in existing farming practices can have many benefits. Next to providing additional volumes of sustainable biomass feedstock to contribute to union objectives in energy, climate, agriculture and broader bioeconomy, intermediate crops can contribute to climate resilience of farmland, add to increasing organics matter and generate additional income and market for farmers in turn improving rural economy.
Bottlenecks
The technical potential to grow intermediate crops in the EU is large, and indispensable for meeting EU renewable fuel targets. Despite the many potential benefits of intermediate crops, their large-scale implementation and development face several challenges. Firstly, the roll out and scale up of the intermediate crop value chain takes time. Farmer contracting and an optimal integration of intermediate crops at a farm requires at least two to three cultivation seasons. In addition, farmers face unknown costs aspects due to requirements that may change and possible interference with other support schemes for instance from the Common Agricultural Policy. Certainty of the market is required to provide sufficient confidence for the large scale roll out of intermediate crop supply chain. In general, the lack of certification guidelines makes stakeholder hesitant, and time is of the essence.
Recommendations for practical certification guidance
We recommend to introduce a definition of intermediate crops that focuses on the role they have in providing additional feedstock volumes compared to the existing practice at a farm, and that relates to their position in the rotation scheme. Our more detailed recommendation can be found in Appendix A of the report.
To ensure a large and timely contribution of intermediate crops to renewable energy targets in transport and potential mandates for chemical markets, we recommend that the European Commission widens the optionality in the Annex IX definitions by either (1) allowing intermediate crops to count for Annex IX A subtargets in all transport sectors, or (2) lifting the cap on Annex IX B, so that intermediate crops become a next cost-attractive option besides waste vegetable oils.
We also recommend that the Commission swiftly finalises and publishes practical certification guidelines for intermediate crops in Regulation (EU) 2022/996:
- We recommend that the certification method is crop-agnostic because many crops may be made suitable as intermediate crops and no option should be ruled out.
- We recommend that compliance with requirements should be proven at the farm-level, because the options may differ from farm to farm – we therefore also recommend that the certification method is region-agnostic.
- The method should rely on farm-based strict documentation of the existing/previous practice and how intermediate crops are inserted.
- Intermediate crops can be inserted between main crops (outside of the primary cropping season) or use fallow land in break years.
- By documentation of existing farm practice, it can be proven that the intermediate crop does not displace main crops or (indirectly) expands arable land elsewhere.
- Use observation and documentation to prove that soil-organic matter is maintained without soil sampling.
We furthermore recommend aligning rulesets for intermediate crops with the Common Agricultural Policy (such as catch and cover crop subsidies) and the Carbon Sequestration and Carbon Farming regulation where possible, to limit competition between incentive frameworks and to align the administrative efforts for the farmers.
Finally, we find that the discussion on intermediate crops should be extended beyond their contribution to renewable fuels and climate targets. A more efficient land use benefits the production of food, feed, as well as (green chemical) materials and energy for the European bioeconomy and the European protein autonomy.
