The original deadline for the implementation of RED III was set at the EU level and passed on May 21 this year.
Under proposals seen by Fastmarkets, aviation will be excluded from the national mandate system. This followed earlier reports that it would be included – on account of the ReFuelEU SAF mandate covering the whole of the EU, and over-riding mandates at national level.
This will also extend to the Emissie Reductie Eenheden (ERE) ticket system in the Netherlands, the green house gas saving (GHG) replacement to the current HBE ticket system that is generated when a unit of biofuel is blended in the country.
“Our understanding is that aviation is out of ticket generation [under these proposals]… We would expect to see an increase in blending in other transport sectors in the Netherlands as a result,” Akman Ozel, renewable fuels market analyst at Netherlands-based STX Group, told Fastmarkets on Wednesday June 25 at the Biofuels International Conference and Expo in Brussels, Belgium.
The new GHG reduction biofuel compliance plan, which is due to launch in the new year, will be a significant move away from the current ticket-based system. The current system is more than a decade old and is measured on a euro-per-gigajoule (GJ) basis, with one renewable fuel unit (HBE) representing 1GJ of renewable energy delivered into the transport sector.
New GHG compliance ticket plan separated into three sectors
As a result of these recent changes, the new GHG compliance ticket plan will be separated into three sectors – road, inland maritime and maritime – and will take on marginally higher shares of the overall transport mandate in order to account for the loss of aviation from the national mandate. The highest increase was expected to be from the road sector, the proposal said.
Meanwhile, according to the government proposal, HBEs carried over into the new year will be converted into EREs on April 1, 2026.
“To calculate how much CO2 reduction each HBE represents, the register will use data from 2025, which will only be available from April 2026,” Job Barnhoorn, founder of Amsterdam-based consultancy Renewable Strategies told Fastmarkets. Then, the total amount of EREs will be distributed across the sectors based on how much energy was booked in 2025.
Blenders would also not be able to produce a saleable credit to offset the higher cost of sustainable aviation fuel relative to the cost of fossil jet fuel. But under the terms of ReFuelEU, a 2% share of jet fuel at airports must be from SAF.
Furthermore, the proposals published by the Dutch authorities on Wednesday sought an end to double-counting, mirroring draft proposals seen at the end of last week from German authorities.
A greater share of biofuels produced from so-called advanced feedstocks – those listed under list A of Annex 9 of the EU Renewable Energy Directive – will be required under the new system.
And the abolition of double-counting should mean that more of these fuels will be needed to meet the mandate targets.
Currently, double-counting provisions allow for half as much waste and advanced biofuel to be blended as crop, and these count twice toward the country’s mandate targets. And an additional sub-mandate on renewable fuel of non biological origin (RFNBO) will also be included.
According to the proposal, refineries can acquire a refinery reduction unit (RARE) by using green hydrogen in production, instead of grey or fossil fuel-based hydrogen, which can be used to fill the sub-mandate now required for RFNBOs across the three ERE categories.
Moreover, the new proposal increased the maximum share of bio-based components to 10% in diesel (B10), up from the current 7% cap. But Dutch fuel suppliers must continue to offer B7 diesel due to the incompatibility with B10 of a large number of cars.
Fastmarkets understands that, on July 2, the Dutch parliament will decide how quickly it will begin to debate the government’s proposal to implement RED III.
“With a caretaker cabinet in place, it falls to parliament to show leadership,” Barnhoorn said, adding that “a clear and ambitious decision” during the scheduled parliamentary meeting on July 2 was “essential to keep RED III implementation on track for 2026.”
He added that, after the impending summer recess, only five working weeks would remain before the pre-election break, with the country preparing to go to the polls on October 29.
“Any further delay,” Barnhoorn said, “would erode investment certainty and stall climate progress.”
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