Methodology

BioCO₂ Atlas is a screening and prioritisation tool for e-fuel (RFNBO) procurement teams — not an eligibility verdict database. It maps ~2,500 European industrial sites whose CO₂ stream is plausibly biogenic, estimated from open EU/UK ETS data via sector-ratio heuristics. Final eligibility always requires two checks this tool cannot perform: RED Art.29 certification of the underlying biomass, and operator confirmation that no double GHG credit was claimed.

1. Regulatory Basis

The governing regulation is Commission Delegated Regulation (EU) 2023/1185 — the Methodology Delegated Act for RFNBOs, supplementing Directive (EU) 2018/2001 (RED II, as amended by Directive (EU) 2023/2413, RED III). It defines which carbon sources may be used to produce renewable fuels of non-biological origin (e-methanol, e-kerosene/SAF, e-ammonia derivatives).

Two-gate eligibility test

• Gate 1 — Origin: the CO₂ must come from the production or combustion of biomass.
• Gate 2 — Sustainability: the underlying biomass must comply with RED Art.29 sustainability and GHG-saving criteria, evidenced in practice through voluntary schemes such as ISCC EU or REDcert.

No expiry date — the strategic advantage

Biogenic CO₂ has no expiry date under CDR 2023/1185. Fossil CO₂ captured from ETS installations is only an eligible feedstock until 2036 (CO₂ from electricity generation) or 2041 (other ETS activities). This is the primary reason e-fuel developers prefer biogenic sources for projects with 20–30 year horizons.

Double-credit rule

A site is ineligible if its CO₂ stream has already received GHG emission saving credits in a certified biomass-fuel pathway (e.g. the capture is credited in a bioethanol producer's ISCC GHG calculation). This cannot be determined from public data — it must be verified by direct contact with the site operator before any offtake commitment.

2. Data Sources

• Primary: EU ETS Union Registry installation data, published via the EEA Datahub (EUTL) — April 2026 vintage.
• UK: UK ETS installation registry (DESNZ) — equivalent structure, merged into the same dataset.

No paid data services or commercial datasets are used — the entire database is built from open public data. Geographic scope: EU-27, United Kingdom, Norway, Iceland (all in the EUTL/UK registries). Switzerland operates a linked but separate ETS whose registry is not included in the EUTL extract — Swiss sites are therefore absent (see Known Gaps).

3. Biogenic Classification Logic

Classification is a two-step decision per installation: first the ETS activity code (e.g. pulp production), then the NACE Rev.2 sector code for combustion installations whose activity code alone is not informative. Rules are applied in priority order; the first match wins. Installations with zero or null verified emissions (closed / inactive) are excluded.

Bio CO₂ estimation formula

Because the ETS emissions field contains fossil CO₂ only (biogenic is zero-rated), the biogenic CO₂ estimate is derived by inverting the biogenic fraction:

NACE data quality guard

Romania, Portugal and Cyprus have ~24 records where the NACE code falls in a biogenic category but the NACE description field clearly indicates a non-biogenic sector (e.g. NACE 17.11 mapped to "Production of electricity"). These sites are excluded. Activity-code-based rules (acts 9, 35, 36) are not affected by NACE data quality issues.

Sources for biogenic fraction ratios

• Pulp & paper — kraft (90%): large integrated kraft mills (activity codes 9 and 35) run almost entirely on black liquor and bark; published data from UPM, Mondi, Stora Enso, Södra Cell confirms 88–96% biogenic CO₂ share of total stack emissions. 90% is a conservative estimate for this sub-group.
• Pulp & paper — paper mills (65%): standalone paper/board production (activity 36) buys external market pulp and relies more on gas/steam for drying; sector average across mixed sites. Range 50–80% depending on fuel mix.
• Pulp & paper — combustion (72%): combustion installations at paper sites (NACE 17.x, activity 1/20) where plant type is less certain; conservative sector average (CEPI statistics, IEA Bioenergy Task 36).
• Fermentation (90–95%): fermentation off-gas is essentially pure biogenic CO₂; the residual fossil share covers on-site fossil-fired utilities.
• Sugar (60%): only the fermentation/processing step yields biogenic CO₂; beet processing heat is often gas-fired.
• Waste-to-energy (47%): EU average biogenic share of mixed municipal solid waste (CEWEP / national waste composition studies); actual values vary 35–60% by country.
• Food industry (45%): mixed fuel use; high uncertainty, hence L4.

4. RFNBO Priority Tier

Strategic guidance

For procurement teams: Tier 1 sites offer the lowest capture cost per tonne but small unit volumes (typically 10–100 kt/yr). Tier 2 pulp mills offer the largest single-site volumes in Europe (often >200 kt/yr biogenic) and strong Art.29 traceability via certified wood supply chains — they are the natural anchor sources for world-scale e-fuel plants. Tier 3 should only be pursued where a metering and certification pathway is contractually committed.

5. Uncertainty Framework

Why no L1 data by default

The EEA's summary installation dataset publishes only total verified CO₂eq. The biomass (zero-rated) emissions field exists at installation level but is only contained in the raw EUTL compliance ZIP, a separate bulk download. The tool therefore starts at L3/L4 and is designed to be upgraded.

Upgrading L3 → L1 with the P1 pipeline

1. Download the raw EUTL data ZIP from the EEA Datahub (EUTL bulk export, "compliance" table).
2. Save it as eutl_raw.zip next to p1_enrich.py.
3. Run python3 p1_enrich.py — it matches installations by permit ID, replaces sector-ratio estimates with verified biomass tonnages, sets uncertainty to L1, backs up the previous database, and prints an upgrade report.
4. Rebuild the Docker image to serve the updated sites.geojson.

6. Known Gaps

• Cement kilns with alternative fuels not included. Cement installations (ETS activity codes 6, 29, 30) can have biogenic CO₂ when they use alternative fuels (AFR) such as paper, wood waste or agricultural residues. EU average AFR substitution rate is ~48% of thermal energy; of this, ~25% is typically biogenic — giving a biogenic fraction of ~5–7% of total cement CO₂ (process calcination CO₂ is always fossil). This is insufficient to classify at volume without per-installation AFR data, which is not in the ETS registry. Integration roadmap: cross-reference with E-PRTR waste input declarations or Eurostat IEF reports to estimate per-plant AFR rates.
• Biogas / biomethane upgrading plants are absent. They sit below ETS thresholds, so they don't appear in this registry-based database — yet they are among the purest Tier 1 sources. Integration is planned (see roadmap: CRE registry for France, DBFZ for Germany, Vertogas for NL, E-PRTR for WWTP biogas).
• Switzerland missing: the Swiss ETS is linked to the EU ETS but keeps a separate registry not included in the EUTL extract.
• WtE biogenic fraction varies by country (35–60% depending on waste composition and recycling rates); the 47% EU average can misestimate individual plants.
• ETS emissions are CO₂eq, not pure CO₂ — figures include other GHGs and cannot distinguish capture-relevant CO₂ concentration in the stack.
• Double-credit risk: whether a site's CO₂ already received GHG saving credits in a biomass-fuel pathway is not public information — operator verification is mandatory before relying on any site listed here.
• Data vintage heterogeneity: emissions years range 2020–2025 depending on the installation's most recent verified report.

7. How to Use This Tool

1. Define your logistics radius. Zoom the map to the region reachable from your planned e-fuel plant (pipeline, truck or rail distance).
2. Filter to bankable quality. Set RFNBO Tier to "Tier 1 + 2" and RED status to High + Probable to remove sites with weak eligibility prospects.
3. Set your minimum volume. Use the Min Biogenic CO₂ slider to hide sites too small to matter for your plant's carbon demand (a 100 kt/yr e-methanol plant needs ~150 kt/yr CO₂).
4. Shortlist and inspect. Click candidate sites; review operator, estimated volume, biogenic share, uncertainty level and method.
5. Verify the two gates. Contact operators to confirm (a) Art.29 certification of their biomass inputs and (b) that no GHG saving credit has been claimed on the CO₂ stream (double-credit rule).
6. Prioritise outreach. Rank your shortlist by volume × tier × distance, and secure LOIs with the top sites before FEED.

8. Contact & Disclaimer

All biogenic CO₂ figures in this tool are indicative estimates derived from public data using the documented methodology. They are not suitable as the sole basis for investment decisions, offtake contracts, or regulatory compliance claims. Always verify with site operators and certification bodies.

• EU ETS data: EEA Datahub (EUTL)
• UK ETS data: UK DESNZ