Guidance document on Sulphur in Diesel Fuel Regulations: biodiesel questions


Biodiesel Questions

B.1 Biodiesel fuel is good for the environment. Why do the regulations impose requirements on it?

Though biodiesel is generally considered a clean fuel, some may have levels of sulphur greater than the regulated limit of 15 mg/kg. The source of the sulphur could be from production processes, inherent in the feedstock or from contamination during distribution.

Diesel fuel with sulphur less than 15 mg/kg is required for effective operation of advanced exhaust emission control technologies needed to comply with the new diesel vehicle and engine emission standards that are coming into effect, regardless of whether the fuel is produced from biomass or crude petroleum.

Therefore the regulations encompass biodiesel as well as conventionally produced diesel fuel.


B.2 Biodiesel has no sulphur or very low levels of sulphur. Why do the regulations include biodiesel?

Some biodiesel may have levels of sulphur greater than the regulated limit of 15 mg/kg. The source of the sulphur could be from production processes, inherent in the feedstock or from contamination during distribution.


B.3 The regulations define biodiesel fuel as " a fuel that is composed of or derived from plant or animal oils or plant or animal fats and is intended to be used in diesel engines." Where did this definition come from?

The definition of biodiesel was developed to capture any biodiesel fuel that may be used in a diesel engine. This results in a definition that is broader than either the CGSB or ASTM definitions for biodiesel. The broad definition is necessary as low sulphur fuel i s required to enable the efficient operation of advanced exhaust emission control technologies, regardless of the origin or other properties of the fuel.


B.4 What is captured under the definition of biodiesel?

The definition includes any fuel that is either composed of or derived from plant or animal oils or plant or animal fats that is intended to be used in a diesel engine. Though not all formulations are recommended for use in diesel engines, they include virgin vegetable oils, used vegetable oils, animal fats, seed oils, esters and ethers derived from vegetable oils or animal fats, or other chemicals that are derived from oils or fats from vegetables, seeds or animals. (The above list is not all encompassing.)


B.5 Do the regulations apply to biodiesel fuel that does not meet the CGSB or ASTM standards for biodiesel? Why?

Yes, fuel with sulphur less than 15 mg/kg is required to enable the efficient operation of advanced exhaust emission control technologies needed to comply with the new diesel vehicle and engine emission standards that are coming into effect. This is the case, regardless of whether the fuel meets or does not meet CGSB or ASTM standards.


B.6 I produce biodiesel fuel. What am I required to do under the regulations?

All aspects of these regulations apply to you. These include

  • meeting the limits (Section 3)
  • registering your production facility (Schedule 2), and
  • submitting regular reports on diesel volumes and sulphur levels (Schedule 1).


B.7 I produce a very small volume of biodiesel fuel for personal use. Am I still required to do everything set out under the Regulations?

Yes.


B.8 I import or produce biodiesel fuel for scientific research. Is this fuel exempt from the requirements of the regulations?

No, all requirements of the regulations apply.


B.9 I import biodiesel fuel. What am I required to do under the regulations?

All aspects of these regulations apply to you. These include

  • meeting the limits (Section 3)
  • providing registration information with respect to each province pf import (Schedule 2), and
  • submitting regular reports on diesel volumes and sulphur levels (Schedule 1).


B.10 Why do the regulations require producers and importers of biodiesel fuel to submit registration information (Schedule 2)?

The registration information provides basic information needed by Environment Canada to administer the regulations.


B.11 Why do the regulations require producers and importers of biodiesel fuel to submit regular reports (Schedule 1)?

Biodiesel fuel is a type of diesel fuel under the regulations. A certain minimum amount of information is required to be reported for monitoring purposes. As the 15 mg/kg limit comes into effect this information is required quarterly. In 2015, o nce there has been a few years experience with most of the diesel fuel pool at the 15 mg/kg limit, the reporting frequency changes to annual in 2015.


B.12 I produce or import biodiesel fuel, do the regulations require me to measure the sulphur in it?

The regulations do not specifically require you to measure the sulphur level for each batch of biodiesel. However, you must report sulphur information that includes maxima, minima and volume weighted averages in Schedule 1.


B.13 How do I measure sulphur in biodiesel?

The reference test method for measuring sulphur in diesel fuel, including biodiesel fuel, is ASTM D5453 from the American Society for Testing and Materials (ASTM):

ASTM International
100 Barr Harbor Drive
PO Box C700
West Conshohocken , Pennsylvania
USA
19428-2959


B.14 How much will sulphur analysis cost?

In 2005 the cost to have such an analysis done by a laboratory was $100 to $150 per sample.


B.15 Does the test method ASTM 5453-03a apply to biodiesel?

Yes.


B.16 Can I use a method other than ASTM D5453?

Please refer to Questions 5.40 to 5.52 for information on alternative test methods.


B.17 Are there any test methods for which equivalency has been demonstrated in accordance with the regulations that can be used for biodiesel?

Not at time of this publication. Refer to Q 5.49 for information on alternative test methods.


B.18 Can I have someone else measure the sulphur concentration in the biodiesel I produce or import?

Yes. However it is important to note that the producer or importer of diesel fuel is responsible for complying with the Regulations. Therefore, if it turns out that the method used was not one that is authorized under the regulations or which the Department validated, the importer or producer could find themselves in non-compliance if it turns out that the sulphur concentration exceeds the regulatory limits when tested using the method under Section 4 of the regulations.


B.19 Do the regulations apply to used cooking oil used in diesel vehicles?

Such cooking oil meets the definition of biodiesel and is diesel fuel under the regulations. Though using unprocessed used cooking oil in a diesel engine is generally not recommended by engine manufacturers, anyone producing or selling used cooking oil that is intended to be used in a diesel engine is subject to the regulations. If such fuel does not meet the regulatory sulphur limits, then its producer / seller / importer would be in violation of the Regulations.


B.20 I gather used cooking oil from local businesses and use it in my diesel vehicle. What am I required to do under the regulations?

The regulations do not address purchasers or users of fuels. If you do not import /produce /sell the fuel, you are not subject to the regulations.


B.21 I sell biodiesel fuel. What am I required to do under the regulations?

If you sell biodiesel, then the biodiesel you sell must meet the regulatory sulphur limits as set out in Section 3 of the Regulations.

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