Everyone agrees that decarbonising aviation is hard. Other than the illusion of CORSIA, sustainable aviation fuel (SAF) is our only hope.
Most of what qualifies as SAF today is produced from used cooking oil: the viscous, brownish stuff collected from McDonald’s deep fryers or a pisang goreng hawker’s wok. Herein lies one obvious problem with SAF: solutions that rely on voluntary consumer actions are rarely effective or scalable, as we have learned time and again from trying to recycle post-consumer plastics and textiles. The value of recycled materials is rarely worth the efforts to collect, sort, process, and transport the post-consumer waste.
But the situation with SAF is quite different. Flight shaming puts enormous pressure on the aviation industry to decarbonise its kerosene-guzzling planes, and SAF is the only viable solution today. Strong demand for SAF drives up the value of used cooking oil, to the point that used oil can be sold for more than virgin palm oil.
Herein lies an obvious fraud (arbitrage?) opportunity: buy cheap (partially subsidised) virgin cooking oil and sell it as used cooking oil to SAF producers.
Matteo Civillini, Azril Annuar, David Fogarty, Megan Rowling, and Sebastian Rodriguez report for Climate Home after conducting a joint investigation with the Strats Times:
As SAF producers scramble for limited raw materials to meet new blending quotas in Europe and growing demand elsewhere, barely used and virgin palm oil is being passed off as UCO to traders that supply fuel companies, experts and industry operators told us. Palm oil that is not considered waste is not permitted under European Union rules for SAF because of its links to deforestation.
[…]
A source at a leading Malaysian UCO supplier to companies including Repsol told The Straits Times that some UCO collectors and restaurants are committing fraud by providing oil that does not qualify as used, although it is difficult to prove.
In Malaysia, which is among the world’s leading suppliers of both UCO and virgin palm oil, government-subsidised cooking oil is cheaper than UCO – providing a clear incentive for fraud.
In a 2024 report, Brussels-based environmental group Transport & Environment (T&E) cited figures showing that Malaysia already exports aboutthree times as much UCO as it is estimated to collect domestically and import, raising concern about where that oil is coming from – and what it consists of.
The aviation industry’s desperate need for SAF creates a unique situation for palm oil, the widely available (and vilified) commodity, where the value of a used product is higher than the value of a new product. Without any other efforts, just cooking with palm oil adds value to it and transforms it into a different, more desirable, and valuable product. I’m surprised that such frauds are not more widespread.
This ridiculous incentive structure also exposes a more fundamental deception behind the promise of SAF. SAF producers prefer used cooking oil because, according to certification rules, they don’t need to account for the upstream GHG emissions and deforestation when they use “waste” materials as feedstock. The logic is that since cooking oil is intended for cooking, and used cooking oil is wasted anyway, all the upstream environmental and climate impacts are attributed to the kitchens, so SAF producers and airlines get a free ride.
But when the value of used cooking oil is higher than cooking oil, it’s hard to argue that cooking is the primary intended use of this product. When people commit fraud to pass off unused cooking oil as used for profit, used cooking oil becomes the product and can no longer claim environmental and climate immunity accorded to wastes. Fundamentally, palm oil is palm oil whether it’s used for cooking, making SAF, or cooking then SAF.
Sourcing from used cooking oil is an unenforceable, unscalable, and perversive fig leaf for the fundamental tensions in SAF supply. None of this will ever change the reality of aviation emissions and biofuel-driven deforestation. Let’s stop pretending otherwise.
UPDATE: The Straits Times published their version of the story. It’s mostly identical to the version published by Climate Home News that I linked to above, but Straits Times also added an interesting tidbit on the price gap between subsidised new cooking oil (RM2.5 per kg), and used cooking oil (RM3 – RM3.7 per kg at collection, and RM3.9 – RM 4.5 per kg for trading).