B100 marine biodiesel has been trading at very low prices at German ports this year, primarily — market participants said — because mismatched regulations have created an arbitrage between different regulatory regimes.
B100, which is 100pc Advanced fatty acid methyl ester (Fame), has been selling at the German port of Hamburg for around €700-800/cbm in the first half of 2026, equivalent to about $914-1,044/t. This compares with the same fuel sold dob Netherlands, which averaged $1,210.10/t during 22 January-22 May.
The lower price is achieved by two mechanisms, participants said. The first is a reduction in the total cost of the fuel, created by the value of German renewable fuel tickets generated via the German GHG quota system. Maritime supplies are not currently eligible for quota generation in Germany, since international shipping was excluded from the scope of the EU renewable energy directive (RED) III transposition into German law. But, separately, such fuels can nevertheless qualify for renewable ticket status if they are taxed as road transport fuels, under article §52 of Germany's energy tax law (EnergieStG). Some of the marine product sold at low prices meets EN14214 specifications, widely considered to be the "gold standard" for biodiesel products heading into road fuels.
According to the German General Customs directorate, it is currently permissible for biofuels physically used in maritime transport to be counted towards the German GHG quota system, provided they meet the tax requirement. This interpretation has not been altered by the latest amendment to the quota system rules, which entered into force on 5 June. As a result, some market participants have been able to generate quotas from supplying advanced Fame into the marine sector, allowing buyers to benefit from an effective price discount reflecting the value of the quotas.
The second mechanism enabling lower prices is the possibility of reclaiming the energy tax paid after the fuel has been used in international shipping. Under German tax law, energy products that have been demonstrably taxed can qualify for tax relief if they are subsequently used for exempt purposes, such as commercial maritime transport. This applies to biodiesel, meaning that buyers may initially pay the full taxed price and later apply for a refund once the fuel's maritime use is proven. This creates a structural inconsistency — taxation is required to generate renewable fuel tickets, while tax relief remains available after maritime use.
The process can take many months, however, and can only be initiated after the fuel volume is completely used, which means those taking this path require credit lines and imposes some constraints on use of the loophole. Further, participants told Argus that obtaining the reduced price is only viable by bunkering B100 and other, more commonly used, blends such as B30 would not qualify. Many vessels do not burn B100 because of concerns about engine compatibility and the possible impact on warranties provided by engine manufacturers. Shipowners told Argus that often a prior approval from the engine manufacturer may be required to burn B100 while retaining warranty and insurance protection in case of any future issues. Some added that the US-Iran war has contributed to "liquidity pressures" for many companies, resulting in hesitation to take on the fuel while awaiting a tax rebate that will arrive many months after the fuel purchase.
The German Federal Council (Bundesrat) has acknowledged the issue and indicated its intention to close what it describes as a loophole arising from the interaction of tax and quota rules. The concern is that fuels used in maritime transport are effectively being used to meet road transport decarbonisation targets, undermining the integrity of the system. While no concrete cases of abuse have been formally identified by customs authorities, the current framework allows for such outcomes.
Some market participants have warned that any tightening of the rules could potentially be applied in a way that affects existing transactions, although there is no official confirmation of retroactive measures. Some suppliers that had previously offered discounted B100 have reportedly withdrawn such offers since March, reflecting growing regulatory uncertainty.
