The Dutch government has issued written answers to Senate parties' 4 November questions on national Renewable Energy Directive (RED) III implementation. The document confirms that the government aims to implement RED III and switch to emission reduction units (ERE) from 1 January, even if the legislative process faces further delays.
The committee chair may call an extra meeting next week, when members could decide on another round of questions, a debate, or a vote. If a vote is chosen, it would take place the same day, 16 December.
The written answers include confirmation that Annex IX-B biofuels will remain excluded from the marine sector to avoid breaching EU caps already exceeded in road transport. To ease competitive concerns, 2026 obligations for shipping and inland navigation will be temporarily reduced, lowering CO2 reduction targets before full requirements resume in 2027.
Maritime 2026 obligations are set at 2.9pc of CO2, down from 3.6pc, and 0.9pc flexible credit allowance, down from 1.1pc. Inland waterways 2026 obligations will be lowered to 2.5pc of CO2 from 3.8pc with 0.5pc flexible credit allowance, down from 0.8pc.
The "other" category was defined in the document, referring to the list on the NEa website, and provided examples for waste oils and residues such as potato peelings, fish oil ethyl ester and grease trap waste. It also states that these "other" category biofuels can be used in the maritime sector as an alternative option to Annex IX-B feedstocks.
The ministry published a detailed Annex IX-A feedstock list, clarifying which streams may contain animal components.
It rejected calls to lower the crop-based cap, arguing the current 1.2pc limit is already well below the EU maximum.
It was again confirmed that T1 transit deliveries of imported biofuels will not generate tickets under the ERE system, closing a loophole that stakeholders warned could distort competition.
The government addressed concerns about mass balanced bio-LNG, stating EU Regulation 2022/996 does not allow mass-balanced bio-LNG and that, to meet RED definitions, bio-LNG cannot be marketed through the combination of use of fossil LNG and a separately sold guarantee of origin. The House of Representatives previously backed the Van Groningen motion, urging the government to seek inclusion, but the reply indicates no change will occur until the European Commission revises the mass-balance framework, a process the Netherlands has requested and is pursuing. The government reiterated that bio-LNG must meet the definition of a bioliquid produced from certified sustainable biomethane, not via book-and-claim certificates, otherwise it cannot generate EREs.
The German cabinet today approved legislation to implement the RED III into national law, with parliamentary approval required as the next step.
