| Property |
NZS 7500 requirements |
Proposed requirements in Discussion Document |
Submissions |
Ministry comment |
Final Recommendation |
| Ester Content |
96.5% m/m
EN 14103 |
96.5% m/m
EN 14103 |
All submissions supported.
The ester content method has limitations, particularly when used on tallow or palm based biodiesel. The result is an underestimation of the ester content, which would make most samples fail the required minimum of 96.5ºC. |
Although the limitations of EN 14103 are recognised, there are no alternative appropriate test methods at this time. Modifications are possible, but the detail involved makes them unsuitable to include in the regulations. The regulations already provide the power for the Chief Executive to approve alternative test methods. |
96.5% mass min
EN 14103 |
| Density at 15ºC |
860 – 900 kg/m³ ASTM D1298 ASTM D4052 ISO 3675 |
860 – 900 kg/m³
ASTM D1298 |
All but one submission supported the limit.
Two submitters requested the use of ASTM D4052 as an alternative test method. |
ASTM D4052 is not suitable for B100 made from tallow |
860 – 900 kg/m³
ASTM D1298 |
| Viscosity at 40ºC |
2.0 – 6.0 mm²/s, but allows up to 7.5 mm²/s if required.
ASTM D445 ISO 3104 |
3.5 - 5.0 mm²/s to align with EN14214
ASTM D445 |
Four submitters disagree with the proposed specifications as they discriminate against some feedstocks, namely lauric oils such as coconut. Viscosity in B100 is related to the feedstock rather than the production process, and it is controlled in the blend specifications (the end use).
Several biodiesel manufacturers consider 5.0 maximum too stringent for waste cooking oil and tallow feedstocks.
All others agreed with the proposed requirement as this is consistent with the European Biodiesel Standard (EN14214). |
The European Diesel Standard (EN 590) requires a viscosity of 2.0 – 4.5 mm²/s. Thus, there should not be any issue with vehicles using good quality biodiesel that has a viscosity down to 2.0 mm²/s. An upper limit of 6.0 mm²/s will allow additional flexibility for biodiesel intended for blending. ASTM D6751 has a viscosity range of 1.9 – 6.0 mm²/s. |
2.0 – 5.0 mm²/s for final fuel
2.0 – 6.0 mm²/s for blending component
ASTM D445
|
| Flash Point |
100ºC min
ASTM D93 ASTM D3828 |
100ºC min
ASTM D93 |
All but one submission supported. |
|
100ºC min
ASTM D93 |
| Sulphur |
Max 50 mg/kg, reduced to 10 from Jan 2009.
ASTM D 5453 ISO 20846 ISO 20884 |
Max 50 mg/kg, reduced to 10 from Jan 2009.
IP 497 or ASTM D 5453 (to align with test methods in PPSR) |
Some submitters supported having a sulphur limit of 10 mg/kg at the outset. This would align with EN 14214 and the Australian Biodiesel Determination.
In the second round of consultation, no submitters objected to a limit of 10 mg/kg at the outset. |
This is not a controversial parameter as biodiesel naturally has a low level of sulphur. |
10 mg/kg max
IP 497 or ASTM D5453
|
Carbon residue (on 100% distillation residue) or
Carbon residue (on 10% distillation residue) |
0.050% m/m
ASTM D4530
0.30% m/m
ISO 10370 |
0.050% m/m
ASTM D4530
0.30% m/m
ISO 10370 |
All but one submission supported. |
|
0.05% mass max
ASTM D4530
0.30% mass max
ISO 10370 |
Cetane Number |
51.0 min |
51.0 min |
Several submitters are of the view that B100 as a blending component should have a less stringent cetane number requirement. Cetane in B100 is related to the feedstock rather than the production process, and it is controlled in the blend specifications (the end use).
Several biodiesel manufacturers do not support relaxing cetane number as this will allow for imports of soybean based biodiesel to meet the specifications. |
|
B100 as a final fuel: 51 min
B100 as a blending component: 47 min |
| ASTM D6890 ISO 5165 ASTM D613 |
ASTM D613 |
A number of submissions requested that the regulations also allow the use of the ASTM D6890 (Ignition Quality Tester - IQT) for testing cetane in biodiesel and biodiesel blends. ASTM D613 measures the cetane number using a cetane engine, which is expensive and archaic technology. |
The ASTM D6890 is a modern, practical and precise test method, which correlates well with ASTM D613. |
Cetane Number: ASTM D613 or ASTM D6890. |
| Sulphated Ash Content |
0.02% m/m
ASTM D874 ISO 3987 |
0.02% m/m
ASTM D874 |
All submissions supported. |
|
0.020% mass max
ASTM D874 |
| Water Content |
500 mg/kg max
ASTM D6304 ISO 12937 |
500 mg/kg max
ASTM D6304 |
One submitter noted that in the UK some oil companies have had issues with blending that have been ascribed to the water content of on-spec fuel. They suggest that if the industry imposes a water content limit of 200 mg/kg that this be considered for the regulations.
In the second round of consultation it was noted by several submitters that the test method ASTM D6304 has very poor precision. IP 438 uses the same equipment but has much better precision. |
New Zealand would review the water content parameter if the maximum allowable content was tightened in other jurisdictions. |
500 mg/kg max
IP 438 |
| Total Contamination |
24.0 mg/kg max
EN 12662 |
24.0 mg/kg max
EN 12662 |
All but one submission supported the limit.
IP440 is equivalent to EN 12662. In general submitters prefer IP tests over EN tests. |
|
24 mg/kg max
IP 440 |
| Copper Strip Corrosion (3 h at 50ºC) |
Class 1
ISO 2160 |
Class 1
rASTM D 130 (to align with PPSR) |
All submissions supported. |
|
Class 1
ASTM D130 |
| Oxidation Stability, 110ºC |
6.0 hours min
EN 14112 |
Options discussed |
Submissions are divergent on the appropriate requirements for oxidation stability.
The Japanese Automobile Manufacturers Association (JAMA) strongly advocate 10 hours for B5 blends. The Motor Industry Association (MIA) endorse JAMA's stance. NZRC and the Oil Companies generally support 10 hours. This support is to acknowledge JAMA's concerns.
Biodiesel manufacturers namely support 6 hours. |
Vehicles represented by JAMA make up approximately 75-80% of the diesel fleet, or approximately 15% of the entire vehicle fleet.
The nature of the retail market requires more rigorous fuel quality regulations than when fuel is being sold via a written contract or supply agreement.
A requirement of 10 hours minimum should have minimal cost implications. Rapeseed biodiesel may require up to 1100 mg/kg antioxidant, but this should cost less than $0.014 per litre (or $0.0007 per litre for B5 blends). Tallow based biodiesel should only require approximately 200-250 mg/kg antioxidant, which should cost less than $0.003 per litre. |
6.0 hours min, 10.0 hours min for blending component for retail biodiesel blends.
EN 14112 |
| Acid Value |
0.5 mg KOH/g max
ASTM D664 EN 14104 |
0.5 mg KOH/g max
ASTM D664 |
All but one submission supported. |
|
0.50 mg KOH/g max
ASTM D664 |
| Iodine Value |
120 max
EN 14111 |
140 max
EN 14111 |
Most submitters agreed to a 140 max iodine value. The exceptions to this were JAMA who supported a 130 limit, and those submitters who support alignment with EN14214 (120 max). A stepped increase was also suggested by one biodiesel company (e.g. increase to 130 before going to 140). Two biodiesel manufacturers supported no specified iodine value, on the basis that it is not necessary to control fuel stability. As with cetane number, two biodiesel manufacturers do not support a relaxation of the iodine value as this will allow imported soybean based biodiesel to meet the specifications. |
Iodine value is a coarse measure of oxidation stability. As a more stringent oxidation stability requirements is proposed (i.e. 10 hours minimum IP), the iodine value loses significance. |
140 max
EN 14111 |
| Linolenic acid methyl ester |
12.0% m/m
EN 14103 |
12.0% m/m
EN 14103 |
All but one submission supported. |
|
12.0% mass max
EN 14103 |
| Polyunsaturated Alkyl Esters |
Should be limited to 1% m/m
Suitable test method to be developed |
Not Specified, wait for test method to be developed. |
Submitters generally supportive of not specifying. One submitter proposes that the regulations specifically exclude certain high polyunsaturated fats and oils. Another recommended that a placeholder be included to provide guidance of future requirements. |
Including this parameter will give a signal to industry that biodiesel should not include fish oil as a feedstock. This is considered important given some recent interest in domestic production using fish oil. |
1% mass max
Suitable test method to be developed |
| Methanol content |
0.20% m/m mono alcohols content
EN 14110 |
0.20% m/m
EN 14110 |
All submissions supported. |
|
0.20% mass max
EN 14110 |
| Monoglycerides |
0.80% m/m
ASTM D6584 EN14105 |
0.80% m/m
ASTM D6584 |
All but one submission supported. |
|
0.80% mass max
ASTM D6584 |
Diglycerides
Triglycerides |
Not Specified. |
Not Specified. |
Submissions are evenly split between whether diglycerides and triglycerides should be specified or not. The reasoning for those who support inclusion of limits is for alignment with EN 14214, and the impacts that excess di and triglycerides have on vehicles (namely injector deposits). The arguments against inclusion are that glycerides are adequately controlled by the inclusion of total glycerol and monoglyceride specs. |
Inclusion of diglyceride and triglyceride specifications are not going to impact on compliance costs as they are obtained in the same test that produces results for monoglycerides, total glycerol and free glycerol (all of which are specified). In addition, there should be no impact on feedstocks as glycerides are related to the production process. Including di and triglycerides will align the NZ spec further with EN14214. |
0.20% mass max Diglycerides
0.20% mass max Triglycerides
ASTM D6584 |
| Free glycerol |
0.02% m/m
ASTM D6584 EN 14105 EN 14106<</TD>
| 0.02% m/m
ASTM D6584 |
All submissions supported. |
|
0.02% mass max
ASTM D6584 |
| Total glycerol |
0.24% m/m
ASTM D6584 EN 14105 |
0.24% m/m
ASTM D6584 |
All but one submission supported. |
Change to 0.25% because now proposing to individually specify diglycerides and triglycerides. |
0.25% mass max
ASTM D6584 |
| Group l metals (Na+K) |
5.0 mg/kg max
EN 14108 or EN 14109 |
5.0 mg/kg max
EN 14108 or EN 14109 |
All submissions supported. |
|
5.0 mg/kg max
EN 14108 or EN 14109 |
| Group ll metals (Ca+Mg) |
5.0 mg/kg max
EN 14538 |
5.0 mg/kg max
EN 14538 |
All submissions supported. |
|
5.0 mg/kg max
EN 14538 |
| Phosphorus content |
10 mg/kg max
ASTM D4951 EN 14107 |
10 mg/kg max
ASTM D4951 |
All but one submission supported. |
|
10.0 mg/kg max
ASTM D4951 |
| Cold Flow Performance |
Need to be measured and recorded |
Not Specified |
All but one submission agreed with no specified requirements.
One submitter proposed that cold flow performance be specified for B100 for retail sale. |
It is not proposed that B100 be available for retail sale at this time. |
Not specified |
| Different grades of B100 and B100 for retail sale. |
Not covered |
Not discussed |
One submitter would like to see three grades of biodiesel – a 'premium' (EN 14214, retail and non-retail sale), ‘regular' (less stringent specs, non-retail), and 'low specification', non-retail, aimed at less spec-sensitive applications'. |
In Europe, there is a standard for biodiesel for heating purposes, but this does not differ significantly from the automotive standard (i.e. EN14214). All biodiesel should be able to meet the specifications proposed for non-retail B100 if the production process has been undertaken properly. When public confidence and awareness in biodiesel has improved, there may be value in providing limited waivers to the B100 specifications for use in less sensitive applications. |
Not covered |
| Filter Blocking Tendency (FBT) |
Not specified |
Not specified |
Two submitters requested that B100 be required to pass an FBT test. |
No other jurisdiction specifies a filterability test for B100. Filterability is controlled in the retail diesel (& B5) specifications |
Not specified |