Information on Biogenic CO2

Today, the EPA treats carbon emissions from fossil fuels exactly the same as carbon emissions from agricultural crops. A consensus of the scientific community agrees that makes no sense.

This similar treatment of two vastly different processes has created a regulatory roadblock at EPA which is thwarting the development of new bioeconomy products, where agricultural crops can replace fossil fuels as feedstocks for plastics, chemicals, and countless other products that hold important environmental promise. For example, plant-based plastics not only are better than petrochemical based plastics in terms of greenhouse gas emissions, but can be compostable or recyclable, offering benefits for water quality and soil health. Through a petition filed at EPA, we are calling on the agency to change how it treats carbon emissions from agricultural crops. This simple rule change will unleash the U.S. bioeconomy, fostering environmentally friendly innovation and driving rural job creation.


This quick video highlights why reform is long overdue and asks why the EPA is the only environmental agency in the world to treat carbon emissions from common agricultural crops the exact same as those from fossil fuels.


How are biogenic CO2 emissions different from those of fossil fuels?


  • What They’re Saying
    • A broad group of state and federal legislators, ag leaders and business leaders are voicing their support for the Biogenic CO2 Coalition petition for a U.S. Environmental Protection Agency (EPA) rule to clarify the regulatory treatment of carbon emissions from agricultural crops. We’ve gathered a collection of quotes from letters sent to EPA Administrator Andrew Wheeler in support of the petition. See what they’re saying.
  • Economic Analysis
    • This report shows how EPA reform on biogenic CO2 would result in the addition of 2,100 U.S. full-time jobs and $130 million in wages.
  • Full Petition Before EPA
    • Our petition provides a detailed explanation of the scientific and legal basis for EPA to change the status of carbon emissions from ag feedstocks.
  • Land Use Analysis
    • Primary finding: the study concludes that this policy change would not significantly affect current land use and should meet any reasonable de minimis criteria. Download the study.


  • U.S. Senators Urge EPA To Promulgate a Rulemaking on Biogenic CO2
    • Signatories: Joni Ernst (IA), Deb Fischer (NE), John Thune (SD), Chuck Grassley (IA), Mike Braun (IN), Todd Young (IN), Kevin Cramer (ND), Richard Burr (NC), Mike Rounds (ND), John Hoeven (ND), Jerry Moran (KS), Roy Blunt (MO), Pat Roberts (KS), and Josh Hawley (MO)
    • Letter urges EPA to “to take prompt action to promulgate a rulemaking that recognizes the de minimis character of biogenic carbon emissions from agricultural feedstocks used to make food, fuel, beverages, or bioproducts.”
  • House Lawmakers Urge EPA To Promulgate a Rulemaking
    • Signatories: Rodney Davis (IL) Collin C. Peterson (MN) Angie Craig (MN), Adrian Smith (NE), Susan Brooks (IN), Kelly Armstrong (ND), Adam Kinzinger (IL), Darin LaHood (IL), Mike Bost (IL), John Rose (TN), and Michael Turner (OH)
    • Letter calls on EPA to promulgate a rulemaking that recognizes the de minimis character of biogenic carbon emissions from agricultural feedstocks.
  • House Representatives Request Regulatory Clarity for Annual Farm Crops
    • Signatories: Rodney Davis (IL) Collin C. Peterson (MN) Dave Loebsack (IA) Roger Marshall, M.D. (KS)
    • Letter requests EPA “expeditiously provide regulatory clarity on the de minimus nature of biogenic carbon emissions generated from the processing of agricultural feedstocks.”
  • U.S. Senators Call on EPA to Provide Clarity on Biogenic Carbon Emissions
    • Signatories: Deb Fischer (NE), Tammy Duckworth (IL), Pat Roberts (KS), Gary C. Peters (MI), Kevin Cramer (ND), Tammy Baldwin (WI), Chuck Grassley (IA), Roy Blunt (MO), Jerry Moran (KS), Joni Ernst (IA), Todd Young (IN), Mike Braun (IN), Ben Sasse (NE), Richard Burr (NC), John Thune (ND), John Hoeven (ND), Michael Rounds (SD), Josh Hawley (MO)
    • Letter requests EPA “provide regulatory clarity on the de minimus nature of biogenic carbon emissions generated from the processing of agricultural feedstocks.”
  • Governors Call for Reform on EPA’s CO2 Emission Regulations
    • Signatories: Kim Reynolds (IA), Pete Ricketts (NE), Doug Burgum (ND), Eric Holcomb (IN), Matt Bevin (KY)
    • Letter requests EPA “prioritize regulatory reform clarifying that biogenic CO2 emissions… are not pollutants subject to regulation under the federal Clean Air Act.”
  • National Association of State Departments of Agriculture Calls for EPA Action on Biogenic Carbon Emissions in Agricultural Crops
    • Letter urges EPA to align policy “with the biogenic emissions standards applied by every other regulatory authority worldwide and acknowledge that biogenic carbon emissions from agricultural feedstocks are different than carbon from fossil fuels.”



  • Op-ed by John Bode, President & CEO, Corn Refiners Association in The Cedar Rapids Gazette
  • Coalition Members
    • Farm Bureau, Corn Refiners Association, Hemp Industries Association, National Corn Growers Association, National Cotton Council of America, National Cottonseed Products Association, National Farmers Union, National Grain and Feed Association, National Oilseed Processors Association, North American Millers’ Association
    • “As the bioeconomy grows, it will create new and sustainable markets for family farmers – something that is crucially important right now while the agricultural sector recovers from the pandemic, trade wars, and low crop prices,” said Rob Larew, President, National Farmers Union. “Unfortunately, misguided regulatory hurdles are hindering the success of this vital sector. We hope that EPA will remove these hurdles and open the door for additional financial opportunities and jobs in rural communities.”
    • “Many countries around the world include agricultural crops in their energy bioeconomy. It makes sense,” said Rock Trojan, President, Hemp Industries Association. “It’s time for the EPA to recognize the economic, environmental and energy value of agricultural crops. Now more than ever, American farmers need access to the bioeconomy to bring more revenue home to the farm.”