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Future Made in Australia
(Guarantee of Origin) Rules 2025
Joint Submission
April 2025
Joint response to Department of Climate Change, Energy, the Environment and Water
Future Made in Australia (Guarantee of Origin) Rules 2025
Ampol, IFM, and GrainCorp welcome the federal government's efforts in developing a Guarantee of Origin (GO) Scheme
for products such as renewable electricity and hydrogen, including the establishment of a framework for GO certificates.
Through the development of new and renewable fuels, governments have the opportunity to transform the energy
landscape, which is essential for achieving emissions reduction goals and progressing toward net zero. In the 2024-
2025 budget, the government announced funding to extend the GO Scheme to low carbon fuels as a viable short- to
medium-term alternative to fossil fuels in hard to abate sectors.
However, this has not been prioritised, creating a continuing uncertainty in the development of Australia's low carbon
fuels market.
We believe that Australia’s potential to build a large domestic renewable fuel production industry is best achieved
through a combination of Commonwealth and State government policy development and incentivisation measures. This
will enable emission reduction of hard to abate sectors, increased fuel security, grow domestic economic opportunity,
and an internationally competitive market. Ensuring policies are complementary, will develop industries that attract
investors, provides certainty for the flow of feedstocks, and keeps the production and use of fuels as competitive as
possible.
Introduction of investment incentive programs and appropriate policy development will ensure that Australia is able to
catalyse investment in primary processing, such as oilseed crush, and Hydrotreated Esters and Fatty Acids (HEFA)
production capabilities to position itself as the centre of the industry in the eastern states.
Following the announcement in 2024 of a three-way Memorandum of Understanding (MoU), Ampol, GrainCorp, and
IFM Investors have partnered on the Brisbane Renewable Fuels (BRF) Project. This initiative is exploring the
establishment of a world-scale low-carbon liquid fuels (LCLF) manufacturing plant at Ampol’s Lytton Refinery in
Queensland, capable of producing at least 450 million litres of renewable diesel1 (RD) and sustainable aviation fuel
(SAF).
The proposed plant will leverage commercially proven HEFA technology, utilising feedstocks such as tallow, used
cooking oil (UCO), and canola oilseed. The project, currently in the pre-FEED stage, will need a supportive policy
environment to be economically viable.
The MOU combines the capabilities of three iconic Australian brands to explore large scale investment opportunities to
catalyse the development of this opportunity.
A GO Scheme verifies the emissions intensity of renewable products by either assessing individual products upon
application from businesses or establishing default emissions factors for product categories. Independent verification
ensures consumer confidence in the carbon emission reduction benefits of these products and enables producers to
monetise these benefits through tradeable GO certificates.
This is particularly important for providing certainty to investors and industry stakeholders, as it establishes clear,
transparent, and credible standards for low-carbon fuels and renewable fuels. A well-defined GO Scheme helps drive
market development, supports long-term investment decisions, and ensures alignment with both domestic and
international sustainability requirements.
1
‘Renewable fuels’ is an industry term used for liquid hydrocarbons made from non-petroleum based renewable feedstocks such as purpose grown biomass, or from waste material such as tallow or used cooking oil. Sustainable aviation fuel (SAF) and renewable diesel (RD) are industry terms used for particular types of renewable fuels.
Ampol/GrainCorp/IFM Investors ● Joint response to Future Made in Australia (Guarantee of Origin) Rules 2025 1
As Australia’s leading fuel supplier with over 120 years of operations experience, Ampol manages Australia’s largest
fuel and convenience network as well as refining, importing, and marketing fuels and lubricants. With our extensive
experience, we have grown to become the largest transport fuels company listed on the Australian Securities
Exchange (ASX).
In Australia, our robust supply chain is underpinned by our market – leading infrastructure, including 14 terminals, six
major pipelines, 53 wet depots, approximately 1,800 retail sites and one refinery located in Lytton, Queensland.
In May 2021, Ampol released its Future Energy and Decarbonisation Strategies, which outlines our plans to transition
our business to succeed in a low carbon economy through decarbonisation of our Australian operations (Scope 1 and
2) and offering low carbon energy solutions to our customers to assist them with their own transition.
GrainCorp is an integrated agribusiness and food ingredients company, recognised as the largest grain storage and
handling business on the east coast of Australia and a leading processor and crusher of edible oils and oilseeds in
Australia and New Zealand.
GrainCorp is also a leading supplier of renewable fuel feedstocks in Australia and New Zealand, including vegetable
oils, used cooking oil (UCO), and tallow.
With over a century of expertise, GrainCorp operates a robust global supply chain underpinned by high-quality
infrastructure assets that store, process, and transport grains and edible oils efficiently.
GrainCorp connects farmers with markets worldwide through the company’s extensive network of strategically located
grain storage facilities, modern processing plants, and advanced transportation systems that ensure the seamless
movement of products from paddock to port.
IFM Investors (IFM) is an asset manager driven to make a positive difference. IFM’s purpose is to invest, protect and
grow the long-term retirement savings of working people.
Established more than 25 years ago by a group of Australian pension funds, IFM has A$230 billion under management
as at 31 December 2024. IFM prioritises the interests of 698 like-minded investors worldwide who aim to build a real
and lasting impact by focusing on assets that combine excellent long-term risk/reward characteristics with broad
economic, environmental, and social benefits to the community.
As a responsible long-term investor IFM actively engages with the companies in which we invest on issues we care
about, with the aim of improving their net performance while minimising investment risk. Operating globally, IFM
manages investments across infrastructure, debt, listed equities, and private equity assets and is a key investor in
Australian and International airports.
Ampol/GrainCorp/IFM Investors ● Joint response to Future Made in Australia (Guarantee of Origin) Rules 2025 2
Timing
We welcome the recent announcements from the Federal Government regarding the Hydrogen and Renewable Electricity
(REGO) certification mechanism and the approximately $10 billion allocated to programs such as the Hydrogen HeadStart
Program and the Hydrogen Production Tax Incentive. These aligns with the Government's announcement that the GO scheme will commence with renewable electricity and hydrogen. However, it is crucial that the commitment to expanding the scheme to include low-carbon liquid fuels (LCLF) is prioritised, concrete and implemented within a defined timeframe to provide certainty for investment and industry planning in LCFL.
It is essential that the GO Scheme includes product expansion and recognises LCLF as a short-to-medium-term alternative with significant carbon emission reduction benefits. Ensuring these fuels are tangibly integrated into the scheme is pivotal, as they offer to deliver near term actual emissions reductions, supporting the transition to lower-carbon energy solutions while maintaining energy security and market stability.
In particular the GO Scheme needs to include LCLF in a timely way in order to support possible decisions to progress the
Brisbane Renewable Fuels project into FEED (2025) and through to FID (2027). There must be clarity on the inclusion of
LCLF in the GO Scheme and particularly, clarity on the treatment of seed oil feedstocks along with supply and demand side.
Measures such as refundable tax credits and a mandate are essential for enabling project partners to make the necessary investments.
Complexity and diversity of LCLF supply chains
We acknowledge that the methodology as presented has contemplated potential hydrogen supply chains, including a straightforward view of production, transportation and consumption. In considering the certification of LCLF, it is critical that the structure of the methodology is fit-for-purpose for the LCLF supply chain which can be significantly varied between feedstocks, refining technologies and distribution modes. For example, there will be a large number of primary feedstock producers with varying sizes and sophistication of operations, intermediate processing and treating facilities, and transportation and blending operations that differ from large scale hydrogen supply. This fundamental difference between
LCLF and potential hydrogen supply chains and end use is a material consideration for the expansion of the GO Scheme to
LCLF, and we anticipate there will be significant consultation in the near future to work through such issues.
Leverage existing emissions reporting
Given the potential of the GO scheme to capture the large number of feedstock providers and existing operators in the fuels supply chain, it is important to acknowledge existing emissions reporting frameworks currently in use to reduce administrative burden on supply chain operators. This is particularly true for on-farm emissions measurements, which are already being used for food and feed markets. Acknowledgement of these systems and others across the supply chain will reduce administrative burden on small and large operators alike, and will also ensure greatest access to GO Scheme certification, helping to support the efficient development of the domestic LCLF industry.
Use of default emissions factors
In the theme of administrative burden on supply chain proponents, default Australian specific emissions factors for major feedstock/technology LCLF pathways should be included in the GO Scheme, again recognising the large number of potential feedstock providers, supply chain operators and the diversity of supply chains. Limiting certification to operators who provide actual emissions reporting may in turn limit the speed and size of LCLF market development in Australia. Default emissions factors for major LCLF pathways are in common use in other certification schemes such as the EU Renewable Energy Directive and CORSIA.
Book-and-claim considerations
We acknowledged the GO scheme considers only a ‘mass balance’ chain of custody approach, however there are significant benefits to the domestic LCLF manufacturing industry if a domestic book-and-claim method is adopted under the GO scheme.
Given the vast distances across Australia and challenges with facilitation of LCLF in regional areas, leveraging proximity to feedstock or existing distribution infrastructure, coupled with a book-and-claim scheme, is a way to provide more competitive
LCLF to end users. We acknowledge there are critical boundary and integrity considerations to be made in the integration of a LCLF certfication scheme and book and claim scheme, but we urge that consideration is made in future GO Scheme consultations to support a domestic LCLF manufacturing industry aligned with policy mechanisms.
Ampol/GrainCorp/IFM Investors ● Joint response to Future Made in Australia (Guarantee of Origin) Rules 2025 3
