6. Biodiesel and Ethanol Labelling
6.1 Introduction
The current labelling requirements in the PPSR are that petrol and diesel being sold by retail sale must have a dispensing pump or container that is clearly marked. Clearly marked in this context means having a label that is able to be easily seen by the person dispensing the fuel.
This section provides a discussion of the considerations for labelling biodiesel and ethanol, and for blends, at point of sale, and proposed wording for labels. The purpose of the labelling requirements is to protect the consumer from unknowingly filling their vehicle with fuel that may be unsuitable for their vehicle. As for petroleum petrol and diesel, it is proposed that labels for the alternative fuels discussed below must be in place on the dispensing pump or container where they can be easily seen and read. Note that Cabinet has agreed that blends containing one percent or less biofuels by volume must not be promoted or advertised as "containing biofuels" or "biofuel blend".26
6.2 Retail Biodiesel and Ethanol Blends
6.2.1 Biodiesel blends up to B5
Cabinet has agreed that biodiesel blends up to B5 do not require labelling.27
6.2.2 Ethanol blends up to E10
Currently the PPSR require that if petrol is blended with ethanol, the seller of the petrol must ensure that the dispensing pump or container displays the words "contains ethanol".
The labelling of petrol/ethanol blends was further discussed in the Biofuels Sales Obligation Discussion Paper (September 2006). Cabinet has since agreed that ethanol/petrol blends must be labelled as containing ethanol, if the blend comprises more than one per cent ethanol.28
It is suggested that the term "bioethanol" is used on the label to match consumer information and emphasise the renewable nature of the blending component. While it is unlikely that non-renewable ethanol will enter the market, if the ethanol added is not from a renewable source it is proposed that the ethanol be termed "non-renewable ethanol" on the label. If the proportion of non-renewable ethanol in the ethanol blending component is greater than 20% by volume, the ethanol shall also be termed "non-renewable ethanol". The other alternative is to simply retain the use of the word "ethanol" in the label, but this would not enable consumers to distinguish between renewable and non-renewable ethanol.
Dispenser labels should differentiate between different levels of ethanol in the blend to allow consumers to identify ethanol levels that are stated as compatible with their vehicle type. In recognising that vehicle compatibility varies with different ethanol levels and also to allow for variation in blend levels in the distribution process, particularly at service stations, a 3% blend could be labelled as "up to 10% ethanol" should the supplier wish. However, a higher ethanol blend could not be labelled as a lower blend, for example a 7% blend could not be labelled as a 5% blend.
It is proposed that retail pumps dispensing petrol/ethanol blends containing more than 1% ethanol by volume up to maximum 10% ethanol are labelled as:
"Contains up to X% bioethanol. May not be suitable for all vehicles/engines. Check with the manufacturer"
or
"Contains up to X% non-renewable ethanol. May not be suitable for all vehicles/engines. Check with the manufacturer"
where X may be any number between 1 and 10.
6.3 Non-Retail Biodiesel and Ethanol
As already discussed non-retail biodiesel and ethanol, and their associated blends, are those for which there is a written contract for supply. Where there is a written contract, biofuel or oil companies are able to negotiate and supply commercial customers with neat or high level blends of biodiesel or ethanol. Under the new regulations, fuels that will not be able to be supplied for retail sale but may be sold via a written contract include B20, E85, and E100.
It is expected that fuel companies will ensure that any dispenser offering non-retail biodiesel or ethanol, or associated blends, is not accessible to retail customers and that their commercial customers are able to differentiate between various fuels. As noted previously, some non-retail fuels and blends of fuels do not yet have approval from the Environmental Risk Management Authority under the Hazardous Substances and New Organisms Act.
It is proposed that there be no regulated labelling requirements or standardised wording for non-retail biodiesel and ethanol, or for their associated blends. This is consistent with the current approach for non-retail petrol and diesel. Labelling is not considered necessary given that customers must have a written contract or supply agreement. Comments are sought on this approach.
w) For labelling requirements of biodiesel and ethanol blends at the point of sale, please provide comment on whether you agree with the proposals. If not, please provide an explanation and alternative requirement (if appropriate).
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