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1 - In the context of agri-hub activities in Kenya, could you explain whether and how rapeseeds – including any supplies from South Africa – are used for vegetable oil production and how this integrates with the project developed with local farmers?
Rapeseeds, included those imported from South Africa, were processed to produce vegetable oil and animal feed for the local livestock market. In agriculture, is well known that crops follow a rotation plan, to enhance farmland productivity, resulting in a seasonal variation in farmland availability. The use of diversified feedstock sources is a standard agricultural practice to manage seasonality, maintaining production objective while optimizing performances. According to this, Eni Kenya is undertaking a process of operational efficiency, focusing in Kenya on geographic areas most suitable for a diversified sustainable production. This activity is functional to the goal of developing a local agricultural value chain.
2 - According to the Italian government’s SAF roadmap, “SAF produced by Eni is derived from waste feedstock, such as waste cooking oils, animal fats, and other biomass. This feedstock is transformed into biofuel at the Gela biorefinery, with additional feedstock from Kenya.” — are South African rapeseeds considered as one of the types of feedstocks listed here?
According to the Renewable Energy Directive (REDIII) SAF can be produced with feedstock listed in Annex IX part A, that include waste and residues, crops cultivated on severely degraded land and intermediate crops and only this types of feedstock are used in Gela to produce SAF.
3 - What certifications or data support the indication that rapeseeds imported into Kenya from South Africa come from severely degraded land, in line with the definitions of the EU RED regulation?
Regulatory Framework of the certification of crop cultivated on severely degraded land is under definition by the EU Commission. Eni by using the expression “severely degraded land” refers to land classified as degraded in accordance with the EU RED Directive. Eni has received the origination points for rapeseeds cultivation in South Africa and has been verified that the Soil Organic Content of such farms is in line with the definition of Severely Degraded Land prepared in the Guidehouse’ report for the EU Commission “Support for the implementation of the provisions on ILUC set out in the Renewable Energy Directive – Lot 2 Mitigating ILUC: Pilots and review”. Gela biorefinery (Enilive) produces SAF only from what is allowed by REDIII.
4 - The ESIA (Environmental Social and Impact Assessment) for the Makueni Agri-hub indicates that rapeseeds will represent a marginal share of the supply. How the 2025 import-export data on biofeedstocks from Kenya to Italy should be interpreted within this context?
Rapeseeds represent approximately 40% of total exported volumes by Eni Kenya in 2025.
Please note that the exported volumes do not represent the total production volume, because the volume is influenced by logistics, industrial planning and storage availability.
Further, the ESIA for the Makueni Agri Hub was submitted in 2021 before the commencement of the agricultural activities. It is a standard and virtuous practice to optimize the supply mix of raw materials during the execution phase.
5 - The project documentation about Makueni Agri-hub indicates a low risk of ILUC. How is this aspect assessed to avoid that land used by farmers for castor cultivation does not displace the land for cultivation of food crops?
All Eni Kenya vegetable oil production is certified according to RED EU standards, such as ISCC EU, which, among other, assess land-use change, including both direct and indirect impacts. Castor has been introduced through intercropping systems and crop rotation on the same agricultural plots, not replacing previous food crop production within the farmland as additional contribution.
Local aggregators of Eni Kenya value chain that have been granted with ISCC Low ILUC and Food Security Standard certifications, shows that castor cultivation is designed to avoid both direct and indirect land-use change and does not negatively affect food production or farmers food security. These certifications have been awarded as first of a kind for biofuel supply chains in Africa.
6 - What type of bags are used to transport seeds to Eni’s agri-hubs in Kenya?
Seeds moved from bulk storage facilities to Eni’s agri-hubs are transported using jumbo bags purchased on local markets. They are used to facilitate the movement of seeds from bulk storage locations to the company’s agricultural hubs.
7 - Has Eni imported rapeseed into Kenya by sea for its agri-feedstock activities?
Yes. Some rapeseed shipments have been transported by sea to Kenya for Eni’s activities. The use of imported rapeseed represents a partial and complementary input within Eni’s broader Agri Feedstock strategy in Kenya, which focuses on developing a diversified supply of feedstocks.
8 - Within the scope of the ISCC audit conducted by RINA Services for the latest ISCC EU certification regarding the Gela warehouse and the HVO and HEFA plants, certain aspects related to feedstock traceability were highlighted. Which elements were reported and what measures were taken to strengthen the traceability system?
The “high” risk level indicated by RINA does not represent a finding or non-conformity but reflects the ISCC methodology (Doc 204 Risk Management), which determines the audit depth and the size of the sample to be verified. For the Gela biorefinery, this level could be linked to the complexity of the system (multiple feedstocks and products), recent changes in the certified scope (Biojet production, new HEFA scope in certificate, new product categories in the mass balance) and stricter ISCC requirements for certain inherently high-risk supply chains (e.g., UCO, Food Waste). In the audit report, RINA confirmed that the site’s documentation is accurately managed, up to date, complete, and easily accessible. High risk level required the auditors to review a larger sample, including three full months of documentation, without identifying any issues related to traceability. Importantly, in a dynamic operational context, a higher audit intensity represents an additional safeguard for integrity and compliance, ensuring that the system continues to meet ISCC requirements even as conditions evolve.
9 - How do export volumes relate to the overall production of vegetable oils within Eni’s agri-feedstock projects?
Export volumes are not representative of total production levels. Over recent years, Eni’s agri-feedstock portfolio has evolved through active global management, with a strong emphasis on geographical diversification and diversification of the production mix.
This strategy strengthens the business model by reducing industrial risk and increasing resilience. As a result, total production has grown from 2.5 kt in 2022, the project’s start-up year, to 130 kt in 2024, with 2025 production exceeding the company’s targets.
10 - What is the role of aggregators in defining guidelines for castor cultivation, particularly regarding intercropping and crop rotation, and how is the farmers’ freedom of choice guaranteed in specific regions of Kenya?
According to the agreements in place, aggregators undertake to provide farmers guidance on cultivation techniques, for every specific region, stimulating intercropping and crop rotations, without farmers’ obligations.
11 - How is the relationship between farmers and aggregators managed in castor cultivation, particularly to ensure food security, price stability, and technical support during the season, and which certifications attest to the practices adopted?
Eni Kenya has contracts with aggregators who are responsible for and hold the direct relationship with farmers, including technical support and payments.
The contractual terms between aggregators and farmers are set by them at the beginning of the season; according to our internal control system, there is no evidence that prices have changed during the season or any other amendments to the original agreements.
Castor cultivation is designed to avoid negative impact on food production and guarantee food security for farmers. To this end, some aggregators working with several farmers have been granted with ISCC Low ILUC and Food Security Standard certifications. These certifications have been awarded as first of a kind for biofuel supply chains in Africa.
12 - How is the collection of castor seeds by aggregators and Eni Kenya managed, and what measures are in place if contracts are not respected?
The few cases in which Eni Kenya learnt that the aggregator, notwithstanding the contractual obligation to do so, did not follow up properly the collection of seeds, the contract between Eni Kenya and the aggregator was terminated.
13 - What services and support are provided to farmers within the framework of the Kenya project, and how does the contractual model with aggregators protect voluntary participation and the management of agricultural risks?
The contract between Eni Kenya and the aggregator defines the services the aggregator undertakes to provide farmers. According to our information, those services foreseen in the contract have been provided.
Among the services that may be included in the contract: land preparation, agricultural inputs (fertilizers and agro-chemicals), planting seeds, agronomic support, traceability.
The business model does not create debt or financial obligations for the farmers. The financial exposure and most of the agricultural risk are borne entirely by Eni Kenya.
The program is built on a principle of voluntary participation, according to contractual terms and conditions agreed between aggregators and farmers. Farmers are free to join or exit the initiative at every cycle without any penalties.
14 - Which certifications have Kenyan aggregators obtained under the Agri Feedstock programme, specifically for the voluntary “Low ILUC” certification and the “Food Security Standard”?
The voluntary certification “low ILUC” granted to our Kenyan aggregators is a public news. https://www.iscc-system.org/news/certified-low-iluc-biofuel-a-solution-for-degraded-land/.
15 - Could you please provide a full list of aggregators used by Eni in Kenya, and specify whether each is still being used or was only used in the past?
For commercial and contractual reasons, such info is confidential.
16 - Regarding the Bonje Agri-hub is Eni compliant with all terms of the $135 million loan contracted with the IFC?
Eni Kenya is complaint with the IFC loan agreement.
17 - How many farmers is Eni working with on this project, and how many of them have already been paid for the crops grown on their land as part of it?
Cumulatively more than 130 thousand farmers have been involved. According to the information we have, all farmers who have participated to the project have been paid based on the quantity delivered and according to the contract they have with the aggregators.
18 - What results have been achieved so far in the Agri Feedstock programme in terms of vegetable oil production, and what is the progress towards the 700,000-tonne target set for 2026?
Since the beginning of the program in 2022, the Agri Feedstock production recorded a CAGR (compounded average growth rate) in excess of 100%.
The Agri Feedstock production in 2024 was over 130.000 ton, while 2025 production has been in line with our plan, developing the contribution of vertical integration coherently with Eni industrial value chains.
19 - How does Eni describe the contribution of biofuel production linked to Kenyan agri-hubs in terms of social prospects for local farmers and sustainability?
Eni’s collaboration with the International Finance Corporation (IFC) on the project, testifies the alignment with international and rigorous environmental, social, and economic sustainability standards, audited across the entire supply chain. Since the beginning of the program in 2022, the Agri Feedstock program have recorded a continuous growth with a CAGR (compounded average growth rate) in excess of 100%. Farmers have been provided with mechanization services and agricultural inputs without any financial exposure and have been given secure access to market at transparent conditions. Farmers’ activity has been supported by agronomic assistance, certification services and continuous improvement programs to develop agriculture programs resilient to arid and semi-arid conditions. The more than 130.000 farmers cumulatively involved to date prove the value generated by the Agri Feedstock program in Kenya.
20 - Are there any ongoing legal proceedings involving Eni Kenya and, if so, what is the company's position regarding any disputes relating to relations with farmers?
There is no legal proceeding against Eni Kenya. As already said Eni Kenya does not have any direct contract with farmers.
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