The position paper is a response of the ART Fuels Forum to the draft delegated act on high low ILUC risk. The Forum understands that at this stage the low-iLUC risk certification serves to get an exemption to the limits posed on high-iLUC risk biofuels (phasing out by 2030). So, for now it is only relevant for palm oil, which is currently the only crop qualified as high iLUC risk. In that sense, it is assumed not to be relevant for crops cultivated in the EU. However, there is the possibility that some Member States decide to apply the low ILUC risk criteria for all biofuels feedstocks (not only high ilUC risk ones) and that in that case, a series of points need to be kept in mind regarding to European feedstocks. The specific ART Fuels Forum comments are provided in the position paper.