The Dutch ministry of infrastructure and water management met on 29 September to discuss implementation of the EU's recast renewable energy directive (RED III).
RED III was adopted by the EU in October 2023 and sets out targets for renewable energy use in transport. EU member states must transpose the legislation into national law. Earlier this month, the government published an updated draft amendment of the Energy for Transport regulations for public consultation as part of the implementation.
The amendment builds on the ministry's earlier RED III proposal and focuses on stricter verification and documentation requirements for all types of renewable energy, including liquid biofuels, biogas, renewable fuels of non-biological origin (RFNBOs) and electricity.
It confirms the end of double-counting for the feedstock listed in Annex IX of RED III, as the Netherlands transitions from energy-based obligations to a greenhouse gas (GHG) savings mechanism.
Several motions were introduced and discussed during the meeting yesterday. Two similar motions were proposed to extend the investment horizon to 2035 and to 2040 and were generally supported. A motion to set a 2 petajoule sub-target for direct hydrogen use was held open pending possible revision. This is expected to be formalised by end of October. A motion was accepted to annually evaluate differences with neighbouring countries to ensure a level playing field, particularly with Belgium and Germany.
And a final motion on whether to allow mass balance for bio-LNG was withdrawn after the secretary of state committed to implementing it if the European Commission confirms that it is allowed.
The committee also discussed expanding the use of feedstocks from Annex IX-B of RED, such as used cooking oil, in maritime shipping. Updates on the European Commission's position regarding mass balance and Annex IX-B fuels are expected by December.
Votes on the bill, amendments and motions are scheduled for 2 October. Some Dutch market participants said an outcome is anticipated on 3 October.
The government is expected to provide updates on EU regulation developments and investment horizon studies later this year, with a view that the regulation will come in effect on 1 January 2026.
A study exploring the extension of RED III obligations beyond 2030 is expected to be completed by November, with decisions to follow in early 2026.
The secretary of state also confirmed that the Union Database will be mandatory for liquid biofuels from 2026. The EU has set up the Union Database (UDB) to track fuels as they move through the supply chain.
