The Dutch government's updated draft legislation to transpose the EU's revised Renewable Energy Directive (RED III) notably proposes abolishing double-counting renewable energy contributions from Annex IX feedstocks.
The draft introduces a greenhouse gas (GHG) emission reduction mandate for land, inland shipping and maritime shipping, but excludes aviation — which was included in a previous draft. The RED III mandate will take effect in 2026.
Obligated parties have to fulfil the mandate by surrendering a sufficient amount of so-called emission reduction units (EREs) in each sector. The mandate's flexible credit allowance allows EREs generated in the land sector to be used to partly meet emission reduction obligations in inland and maritime shipping (see table), but EREs from inland and maritime shipping cannot be used by land sector suppliers to fulfil their compliance requirements.
Fuel suppliers with overall consumption of more than 500,000 l/yr will need to incorporate a 14.4pc share of renewable fuels in their annual deliveries in 2026. This increases linearly, to reach 27.1pc in 2030.
The amount of crop-based biofuels in the land sector will be limited to 1.4pc of the overall energy content of total consumption until 2030, and will not be accepted towards targets in maritime and inland shipping and aviation.
The amount of Annex IX Part B biofuels — such as used cooking oil (UCO) and animal fats categories 1 and 2 — that can be counted towards the mandate will be limited to 4.29pc in the land sector and 11.07pc in inland shipping. Obligated parties will be unable to claim EREs from Annex IX Part B fuels used in maritime shipping.
The draft also introduces a minimum share of emission reductions that have to be achieved by Annex IX Part A and renewable fuels of non-biological origin (RFNBO), for all sectors.
RED III mandates that 5.5pc of all fuels supplied must be advanced biofuels, including at least 1pc RFNBOs by 2030. The Netherlands' draft decouples these targets, to reduce investment uncertainty (see table).
Refineries that use renewable hydrogen in their production process can claim refinery reduction units — or RAREs — which can be used by a supplier to meet an RFNBO sub-target in various sectors.
Correction factor delay
The ministry will delay its plans to apply a "correction factor" of 0.4 to its "refinery route" stimulus for hydrogen demand, in order to ensure the measure does not undermine direct use of hydrogen in transport.
The correction factor means the value of emissions reductions credits generated through the use of renewable hydrogen for transport fuel production would be limited to a certain percentage of those generated through direct use of renewable hydrogen or derivatives in transport.
The government leaves the option open to impose a correction factor from 2030.
Although the EU Fuel Quality Directive increases the maximum share of bio-based components to 10pc in diesel, the Dutch government said fuel suppliers must continue to offer B7 — diesel with up to 7pc biodiesel — as a protection grade, because of the large number of cars incompatible with B10.
Companies will be able to carry forward any excess EREs to the next compliance year. Companies with an annual obligation can carry forward up to 10pc of the total amount of EREs needed to fulfil their obligation in a year, with registering companies allowed to carry forward 4pc. Dutch renewable fuel tickets (HBEs) carried into 2026 will be converted into EREs on 1 April 2026, the government said.
| Overview of future Dutch obligations | pc CO2 | ||||
| 2026 | 2027 | 2028 | 2029 | 2030 | |
| Land (Road) | |||||
| Sector-Specific Obligation | 14.4 | 16.4 | 22.8 | 24.8 | 27.1 |
| Flexible Credit Allowance | 0.0 | 0.0 | 0.0 | 0.0 | 0.0 |
| Total Obligation | 14.4 | 16.4 | 22.8 | 24.8 | 27.1 |
| Annex 9A Sub-Obligation | 3.1 | 4.5 | 5.9 | 7.3 | 8.8 |
| RFNBO Sub-Obligation | 0.05 | 0.06 | 0.36 | 0.77 | 1.07 |
| Conventional Biofuel Limit | 1.2 | 1.2 | 1.2 | 1.2 | 1.2 |
| Annex 9B Limit | 4.3 | 4.3 | 4.3 | 4.3 | 4.3 |
| Maritime | |||||
| Sector-Specific Obligation | 2.5 | 3.3 | 4.1 | 4.9 | 5.7 |
| Flexible Credit Allowance | 1.1 | 1.5 | 1.8 | 2.2 | 2.5 |
| Total Obligation | 3.6 | 4.8 | 5.9 | 7.1 | 8.2 |
| Annex 9A Sub-Obligation | - | - | - | - | - |
| RFNBO Sub-Obligation | 0.00 | 0.02 | 0.08 | 0.16 | 0.32 |
| Conventional Biofuel Limit | 0.0 | 0.0 | 0.0 | 0.0 | 0.0 |
| Annex 9B Limit | 0.0 | 0.0 | 0.0 | 0.0 | 0.0 |
| Inland Waterways | |||||
| Sector-Specific Obligation | 3.0 | 4.1 | 6.1 | 8.2 | 11.6 |
| Flexible Credit Allowance | 0.8 | 1.0 | 1.5 | 2.0 | 2.9 |
| Total Obligation | 3.8 | 5.1 | 7.6 | 10.2 | 14.5 |
| Annex 9A Sub-Obligation | - | - | - | - | - |
| RFNBO Sub-Obligation | 0.02 | 0.04 | 0.09 | 0.17 | 0.34 |
| Conventional Biofuel Limit | 0.0 | 0.0 | 0.0 | 0.0 | 0.0 |
| Annex 9B Limit | 11.1 | 11.1 | 11.1 | 11.1 | 11.1 |
| The Ministry of Infrastructure and Water Management | |||||
| *RFNBO: Renewable fuel of non-biological origin | |||||
