UCO and Annex IX Feedstocks: Where Waste Classification Goes Wrong – Insight 1

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Why the origin and use of a waste oil matter as much as the certificate that accompanies it.

Used cooking oil, animal fats and food-processing wastes are increasingly important renewable-fuel feedstocks. But their regulatory treatment depends on something deceptively simple: how the material is classified.

That classification can affect sustainability evidence, renewable-fuel treatment and commercial value. Under Annex IX of the Renewable Energy Directive, Part B specifically includes used cooking oil and Category 1 and 2 animal fats. Category 3 animal fats are not included in Part B.

UCO is not simply “waste oil”

Used Cooking Oil has a specific meaning. It is generally oil or fat that has actually been used to cook food and is no longer suitable for that original purpose.

An oil does not automatically become UCO simply because it came from the food sector, is no longer wanted, can be converted into biofuel, or looks similar to restaurant UCO. Oil arising from an industrial food-production process may need to be classified differently.

The right question is not “Did this come from a food business?” but “What process generated it, what was it originally used for, and what evidence supports the classification?”

Why classification risk matters

Where one feedstock category receives more favourable regulatory or commercial treatment than another, there is an incentive for misclassification. That does not mean every error is deliberate.

  • inherited supplier descriptions;
  • mixed waste streams;
  • weak Point-of-Origin records;
  • inconsistent documentation;
  • incorrect mass-balance treatment.

Once an incorrect classification enters the supply chain, it can be repeated across sustainability declarations, invoices, certificates and downstream transactions.

A changing regulatory environment

Classification is becoming even more important as new EU import controls develop. Commission Regulation (EU) 2025/2181 introduces harmonised requirements from 19 November 2027 for certain UCO imported into the EU from third countries where the material falls under Category 3 Animal By-Products rules.

This adds another reason for operators to understand exactly what material they are handling and what regulatory framework applies.

The practical test

For auditors and operators, certification should not be the end of the question.

A defensible position requires origin + classification + volume + documentation + mass balance to tell the same story.

Geovitia can advise, implement and manage the systems needed to keep that evidence aligned.