Viewpoint: Dutch ticket move to help low-emission fuels

A change in the EU Renewable Energy Directive (RED III) is pushing the Netherlands, a key renewable fuel ticket market in Europe, to pivot from compliance based on energy share to greenhouse gas (GHG) savings, and should benefit fuels with higher emission savings.

The Netherlands will switch to GHG-based ERE tickets on 1 January 2026. The mandate will apply retroactively if the legislation is passed beyond that date.

The move more closely aligns Dutch compliance with Germany's THG quota and accelerates a broader shift to reward fuels with high greenhouse gas (GHG) savings, as well as RED Annex IX Part A feedstock status, positioning advanced Fame, hydrotreated vegetable oil (HVO) and biomethane as front-runners.

RED III's overall 2030 target gives EU member states the option to reduce their GHGs by 14.5pc, or to have a 29pc renewable energy share in their overall fuel mix. This is a significant step-up from RED II, which only required states to have 14pc renewable energy in their mix by 2030.

Most major states incentivise the uptake of RED targets through the use of renewable fuel ticket systems. Tickets are used by companies supplying liquid or gaseous fossil fuels in the country and are obligated to pay excise duty or energy tax on fuels. They can be traded to meet obligations and are primarily generated via the blending of renewable fuels into fossil fuels, with additional sources of tickets including electricity used to charge e-vehicles.

The Dutch change will benefit fuels with higher emissions savings and move away from a more simplistic approach where one HBE ticket is equal to 1 GJ of energy use, with multipliers available based on feedstock type. The current four HBE categories will expand to 16 types of ERE tickets, defined by transport sector — land, inland waterways and maritime — as well as feedstock.

An HBE-to-ERE ratio of 1:46, as per the Dutch Emissions Authority's (NEa) guidance, has already begun to guide transitional pricing. All 2025 HBEs must be submitted by 30 April, after which any non-redeemed HBEs will be converted into EREs, subject to a legal cap on the amount that can be carried from year to year.

Premiums for RED Annex IX Part A fuels should grow as demand for corresponding ERE-Gs does the same. But ERE-B values — comprising fuels from RED Annex IX Part B feedstocks — will be affected by a mismatch between RED III vs FuelEU Maritime rules.

Shipping mismatch

Under FuelEU, a separate legislation from RED III, Part B fuels remain eligible, whereas the domestic transposition of RED III means EREs count the same as using fossil fuel for only the maritime obligation. Shipping vessels are likely to either bunker elsewhere, or opt for Part A fuels that can meet both mandates.

Maritime suppliers can source up to 0.9pc of their mix from road and inland waterways, preserving a narrow role for Part B fuels via cross-sector ERE flows. But EREs from shipping cannot be used by land suppliers.

Aviation fuel blending will no longer generate Dutch tickets, removing a source of Part B tickets, as the bio-component of sustainable aviation fuel (SAF) has mostly been produced from used cooking oil.

Overall, liquidity in the Netherlands will fragment by sector — LREs for land, BREs for inland shipping and ZREs for maritime shipping — all taking a Dutch acronym.

Across the EU, GHG-based transport fuel mandates with tight feedstock caps should tighten supply of Part A fuels and renewable fuels from non-biological origin (RFNBOs), while remaining energy-based systems may lean on conventional and Part B biofuels. The Dutch-German axis, as the largest GHG-based ticket markets, may increasingly anchor to Part A fuel tickets. Advanced biofuel suppliers will be monitoring which market provides better ticket value for their fuel at a given time.

France also plans to replace its energy-based TIRUERT tickets with GHG-based IRICCs in 2027. Outside the RED III remit, the UK is consulting on whether to follow suit as it updates its RTFO scheme; consultation updates are expected in early 2026, and any resulting changes are expected in 2027.

By Madeleine Jenkins