Similar-looking materials can receive very different regulatory treatment.
Animal fats provide one of the clearest examples of why feedstock classification matters in renewable-fuel compliance.
Category 1, Category 2 and Category 3 animal fats can appear physically similar, but they do not receive identical treatment under renewable-fuel frameworks.
Under Annex IX Part B, Category 1 and Category 2 animal fats are specifically included. Category 3 animal fats are not.
Why Category 3 is different
Category 3 material generally comes from lower-risk animal by-products and can have a number of alternative uses. That matters because material with other economically viable uses may not receive the same treatment as a genuine waste.
Under the UK RTFO, the distinction is different again. Category 1 tallow is treated as a double-counting waste, while Category 2 and Category 3 tallow are treated as products.
Annex IX classification and RTFO treatment are not always the same thing.
Where the risk appears
The problem arises when a material is described one way by a supplier and that description is simply repeated downstream. A trader may receive animal fat described as Category 1, copy that classification onto sustainability documentation, record the same material in the mass balance, and pass the description to downstream buyers.
If the original classification was wrong, the error can be carried through the entire chain.
What should be verified?
- where the material was generated;
- the process that produced it;
- who determined the animal-by-product category;
- what evidence supports that decision;
- whether the classification is consistent across contracts, certificates, invoices and sustainability records.
The key principle is simple: the category should be evidenced, not assumed.
Important terminology
Category 3 animal fat or tallow should not be confused with UCO that may fall within Category 3 Animal By-Products rules because it contains material of animal origin. These are separate regulatory issues and should be assessed accordingly.
Why this matters commercially
Where one category receives more favourable regulatory treatment than another, the incentive to misclassify increases. That does not mean every error is deliberate, but it does mean businesses dealing in animal fats need stronger due diligence than simply checking whether a certificate exists.
Geovitia supports feedstock classification review, supplier verification, mass-balance controls, audit preparation and ongoing compliance management.