* Fails to acknowledge the growing international concerns about the impact of agrofuels on the environment and food security and presses on with a mandatory target.
* Does not sufficiently address the knock-on effect of rising food prices.
* Will not prevent agrofuel production from pushing other farming activities (e.g. cattle ranching or other crops) into rainforests or other important eco-systems. The Commission proposes to just monitor the situation.
* Provides no criteria to protect people in developing countries from the negative impacts of agrofuel production. Land disputes, forced evictions, human rights abuses and poor working conditions occur frequently in many countries producing crops for Europe.
* Introduces only limited "sustainability criteria" aimed at preventing deforestation and damage to wetlands but ignores other important ecosytems such as threatened biodiversity-rich savannahs (for example, the Brazilian Cerrado). The criteria are only applicable to crops used as fuels in transport but not for the same fuels used to produce electricity.
* Prevents EU member states from introducing stronger criteria at a national level.
The European Commission is expected to define the greenhouse gas savings that an agrofuel would have to meet - compared to fossil-based fuels - in order to be supported by the EU. However the leaked draft is still missing this figure, indicating continued internal disagreement within the Commission.