SUSTAINABLE COMMODITIES 3 B.V. FULL MARKET REFERENCE Source: https://www.sustainablecommodities.eu/ | Generated: 2026-09-08 Independent brokerage in waste-based feedstocks, renewable fuels and recycled polymer feedstocks. Lemmer, the Netherlands. Chamber of Commerce 99665042. ============================================================================== # Pyrolysis oil brokerage URL: https://www.sustainablecommodities.eu/markets/pyrolysis-oil We broker pyrolysis oil, from the Netherlands, across Europe and beyond: tyre-derived (TPO), plastic-derived (PPO) and biomass pyrolysis oil, into refiners, steam crackers, carbon black producers and industrial fuel users. On what actually decides a deal, it comes down to five numbers and one question. The numbers are chlorine, silicon, sulphur, water and metals. The question is whether your oil is legally a waste or a product, and it catches almost every newcomer. Send us the assay and the monthly tonnage and you will get a straight read, including when the answer is that you are not ready yet. ## The three pyrolysis oils are not one product Almost every stalled pyrolysis oil enquiry we see starts with the same mistake: seller and buyer both say "pyrolysis oil" and mean different liquids. They have different chemistry, different buyers and prices that are not remotely comparable. * Tyre pyrolysis oil (TPO), from end-of-life tyres. Strongly aromatic, sulphur typically 0.5 to 1.2 %, with a characteristic limonene fraction. Homes are carbon black production, industrial and marine fuel blending, or upgrading into a refinery cut. Not a drop-in cracker feed without treatment. * Waste plastic pyrolysis oil (PPO / WPPO), from mixed polyolefins, LDPE, HDPE, PP. Naphtha-like and paraffinic. The prize is a steam cracker taking it as circular feedstock under ISCC PLUS mass balance, which is where the value sits. Chlorine is the gate. * Biomass pyrolysis oil (bio-oil, FPBO), from wood and agricultural residues. A different animal entirely: 20 to 30 % water, heavily oxygenated, acidic (pH 2 to 3), not miscible with hydrocarbons and not a drop-in fuel. Specified under ASTM D7544 as grades G and D for industrial burners. ## What buyers actually screen on A specification sheet gets a cargo looked at. These parameters get it bought. Anything a buyer cannot design around is a hard no, not a discount, and it is better to find that out from the retained sample than from the discharge survey. Chlorine is the single biggest gate for cracker feed. PVC and chlorinated additives in the input plastic carry straight through into the oil, and untreated mixed-plastic pyrolysis oil routinely comes back in the hundreds or low thousands of ppm. Crackers generally work to single-digit ppm on total chlorine. Whether that gap is closed by dechlorination, by input sorting or by blending down is, commercially, the entire conversation. Silicon is the quiet deal-killer. It comes in from siloxanes and antifoam agents and permanently poisons downstream hydrotreating catalyst. Buyers with a hydrotreater will test for it even when it is not on the spec sheet, and a cargo that fails on silicon does not get a second look. Total chlorine: The gate for cracker and refinery feed. Organic and inorganic chlorine reported separately where possible. Silicon: Catalyst poison. Screened by any buyer with a hydrotreater. Sulphur: Low in polyolefin-derived oil; materially higher in tyre-derived oil. Nitrogen: Tracks polyamide, ABS and polyurethane in the input. Water content: Karl Fischer. Drives phase separation and freight cost. Metals (Fe, Na, Ca, Mg, Zn, Pb, K): Fouling and catalyst deactivation; zinc and lead point back to tyre or e-waste input. Distillation profile (IBP/FBP): Decides which refinery or cracker cut the oil competes with. Density and flash point: Blending, storage classification and freight. Diene value / MAV: Fouling and gum-forming tendency. TAN (total acid number): Corrosivity in storage and transfer. Filterable solids / ash: Char carry-over from the reactor. Bromine: Flame-retardant carry-over where WEEE plastics are in the mix. ## The certificate of analysis, parameter by parameter A certificate of analysis, usually written CoA, is the document a buyer reads before anything else. For pyrolysis oil it is longer than most people expect, and the parameters below are the ones an independent laboratory reports on a tyre pyrolysis oil sample. Each one carries its test method, and the method belongs in the contract next to the limit: two laboratories running different methods do not produce comparable numbers. Density at 15 degrees C: Method ASTM D4052; Why the buyer wants it Volume to weight conversion, and the first sanity check on grade. Kinematic viscosity at 20 and 50 degrees C: Method ASTM D445; Why the buyer wants it Pumpability and whether heated lines are needed. Reported at two temperatures because one figure says little. Total sulphur content: Method ASTM D4294; Why the buyer wants it Catalyst and emissions constraint downstream. Total acid number: Method ASTM D664A; Why the buyer wants it Corrosivity, and an indicator of how the oil has aged. Water content: Method ASTM D95; Why the buyer wants it Settlement weight and phase separation risk in the tank. Nitrogen: Method ASTM D5762; Why the buyer wants it A hydrotreatment constraint that people forget until it blocks the cargo. Flash point: Method ASTM D93B; Why the buyer wants it Classification and transport. Below 40 degrees C the whole shipping conversation changes. Total sediment, existent: Method ASTM D4870; Why the buyer wants it Filter blocking on discharge. Micro method carbon residue: Method ASTM D4530; Why the buyer wants it Coking tendency in the receiving unit. Total chlorine content: Method ASTM D7536; Why the buyer wants it The headline chlorine figure, measured on the whole sample. Chloride, by combustion ion chromatography: Method ASTM D7359; Why the buyer wants it A different measurement, reported separately. See below. Total halides: Method ASTM D7359; Why the buyer wants it Fluoride, chloride and bromide together. Bromide points at flame retardants from WEEE plastics in the feed. Mercury: Method UOP 938; Why the buyer wants it Screened because a single high result closes most outlets. Total metals, plus sodium, calcium, aluminium and the heavy metals individually: Method ASTM D5185; Why the buyer wants it Reported as a total and element by element. A cargo can pass on every single element and fail on the total. The chlorine trap. A pyrolysis oil certificate carries at least two numbers that both get called chlorine, and they are not interchangeable. *Total chlorine content* to ASTM D7536 measures everything in the sample. *Chloride* by combustion ion chromatography to ASTM D7359 measures the ionic fraction, and it comes out lower. A seller who quotes the second figure when the buyer asked for the first is not necessarily being dishonest, but the cargo will be rejected on arrival all the same. So when a buyer sets a chlorine limit, settle which method it refers to before you agree the number. And expect the organic chloride to be asked for separately as well: that is the fraction a hydrotreater cares about, and it is the one that is hardest to remove. For what these parameters mean in general terms, our parameters explained page covers them one by one, and test methods and analysis explains why the method reference belongs in the contract rather than in the covering email. ## The numbers a steam cracker works to The section above lists parameters without limits, because the acceptance value belongs in your contract. The limits below are different: they are the published specifications that industrial steam crackers run to, collected in the peer reviewed literature. They are what the receiving plant is measuring against when it reads your CoA. Chlorine at 3 ppm is the one that decides most cargoes, and untreated oil from mixed plastic waste is commonly reported around 1460 ppm, which is a factor of roughly 500. Note the nitrogen row. The 100 ppm figure is the naphtha specification; a gas oil feed is allowed 2000 ppm. A buyer quoting one of those two numbers at you is telling you which cut they intend to blend your cargo into. Chlorine: Industrial limit 3 ppm; Method on the CoA ASTM D7536, ASTM D7359 Nitrogen: Industrial limit 100 ppm naphtha, 2000 ppm gas oils; Method on the CoA ASTM D5762 Sulphur: Industrial limit 500 ppm; Method on the CoA ASTM D4294 Oxygen: Industrial limit 100 ppm; Method on the CoA not on a standard CoA, ask for it Phosphorus: Industrial limit 0.5 ppm; Method on the CoA ASTM D5185 Iron: Industrial limit 0.001 ppm; Method on the CoA ASTM D5185 Sodium: Industrial limit 0.125 ppm; Method on the CoA ASTM D5185 Calcium: Industrial limit 0.5 ppm; Method on the CoA ASTM D5185 Silicon: Industrial limit 0.5 to 1 ppm; Method on the CoA ASTM D5185 Lead: Industrial limit 0.05 to 0.10 ppm; Method on the CoA ASTM D5185 Vanadium: Industrial limit 0.05 ppm; Method on the CoA ASTM D5185 Arsenic: Industrial limit 0.005 ppm; Method on the CoA ASTM D5185, specialist request Mercury: Industrial limit 0.005 ppm; Method on the CoA UOP 938 Copper: Industrial limit 50 ppm; Method on the CoA ASTM D5185 Nickel: Industrial limit 100 ppm; Method on the CoA ASTM D5185 ## Why the heavy fraction is the one nobody takes This is the same argument as the three fractions above, in numbers. Contamination is not spread evenly through the barrel: it concentrates in the heavy end. Calcium runs 17 ppm in the light fraction and 225 ppm in the heavy, against a cracker limit of 0.5 ppm, and lead goes from 0.04 ppm to 37 ppm against a limit near 0.05 ppm. That is why a distillation cut changes who your buyer is, and why a full range oil is a harder sell than the same volume split. The fractions are defined by carbon number and boiling point: light is up to C20 and boils below 250 degrees C, medium is up to C30 and boils below 450 degrees C, heavy is above C30 with a final boiling point above 450 degrees C. Calcium: Light 17; Medium 149.5; Heavy 225; Cracker limit 0.5 Iron: Light below 0.2; Medium 7.3; Heavy 33; Cracker limit 0.001 Sodium: Light 0.8; Medium below detection; Heavy 2.8; Cracker limit 0.125 Lead: Light 0.04; Medium below detection; Heavy 37; Cracker limit 0.05 to 0.10 Zinc: Light 0.4; Medium 124; Heavy 128.1; Cracker limit not specified Silicon: Light below 100; Medium 4; Heavy below 50; Cracker limit 0.5 to 1 Copper: Light 1; Medium 15; Heavy 2; Cracker limit 50 Aluminium: Light below 0.2; Medium below detection; Heavy 17; Cracker limit not specified Titanium: Light below detection; Medium below detection; Heavy 456; Cracker limit not specified ## What tyre pyrolysis oil actually measures Tyre derived oil is a different product with different buyers, and the numbers show why. Crude TPO carries about 1.1 wt percent sulphur, roughly twenty times a road diesel limit, which is the single reason it goes to carbon black, industrial fuel or a hydrotreater rather than straight into a fuel pool. Hydrotreatment takes it to about 0.145 wt percent, and at the same time drops the flash point to 35 degrees C, which changes the storage and transport classification. Density and sulphur here are independently confirmed by the public product data of a European TPO producer, which reports 920 kg per cubic metre and 1 percent sulphur. Density at 15 degrees C: Crude TPO 921 kg/m3; After hydrotreatment 874 kg/m3; Method ASTM D4052 Kinematic viscosity at 20 degrees C: Crude TPO 5.82 mm2/s; After hydrotreatment 3.42 mm2/s; Method ASTM D445 Flash point, closed cup: Crude TPO 52 degrees C; After hydrotreatment 35 degrees C; Method ASTM D93 Sulphur content: Crude TPO 1.102 wt percent; After hydrotreatment 0.145 wt percent; Method ASTM D4294 Heat of combustion: Crude TPO 41.3 MJ/kg; After hydrotreatment 42.6 MJ/kg; Method - Initial boiling point: Crude TPO 63 degrees C; After hydrotreatment 74 degrees C; Method - Distils to 250 degrees C: Crude TPO 45 vol percent; After hydrotreatment 42 vol percent; Method - Distils to 350 degrees C: Crude TPO 84 vol percent; After hydrotreatment 88 vol percent; Method - Final boiling point: Crude TPO 353 degrees C; After hydrotreatment 356 degrees C; Method - Solidification temperature: Crude TPO minus 48 degrees C; After hydrotreatment minus 36 degrees C; Method - ## Waste or product: the question that strands cargoes Whether pyrolysis oil is legally a waste or a product decides the entire paperwork chain, and it is the most common reason a first cargo sits at the terminal. If the oil is still a waste, a cross-border shipment falls under the EU Waste Shipment Regulation (EU) 2024/1157: prior written notification and consent from the competent authority at both ends, a financial guarantee, and a movement document travelling with the cargo. If end-of-waste status has been established, it moves as a normal product. The catch is that this is decided nationally. The same oil can be a product in one member state and a waste in the next, and the receiving authority's view is the one that counts. Treat it as a commercial risk to be settled before fixing freight, not as a formality for the shipping department. Customs classification is equally unsettled. There is no dedicated CN code for pyrolysis oil. Depending on origin, aromatic content and intended use, parcels have moved under headings 2707, 2710, 2713 and 3824; a UK advance tariff ruling classified heavy plastic-derived pyrolysis oil under 2710 19 71. Agree the code with your customs agent and, where the value justifies it, obtain a binding tariff information before the vessel loads. ## Certification and the circular premium For plastic-derived oil, certification is not administration, it is the product. ISCC PLUS with mass balance chain of custody is what allows a polymer producer downstream to sell a certified circular grade. Without a credible, auditable chain of custody the same molecules trade as fuel, and the difference between those two prices is the whole business case for a pyrolysis plant. For biomass-derived oil heading into an energy outlet, ISCC EU or REDcert is the relevant route, with the sustainability characteristics and GHG saving carried on a proof of sustainability. We will ask for your certificate scope early. A plant certified for the wrong product group, or with the pyrolysis unit outside the certified boundary, is a problem worth finding in week one. ## What a pyrolysis oil buyer checks before they bid We work both directions: plant operators with production to place, and refiners, crackers, carbon black producers and fuel blenders looking for consistent feed. Because we are a broker and never take title, we have no reason to talk a marginal cargo into a buyer who cannot run it. * COA and retained sample first, price second. We ask for a full analysis and a representative retained sample before we approach anyone. It is faster for everybody than three rounds of hopeful indications. * Trial parcel, then bulk. Most first deals run as IBCs or an isotank into the buyer's own lab, then a flexi or a parcel tanker once the numbers hold. * Independent survey at load and discharge. Sampling and sealing by a recognised inspection company, with retained samples held by both sides. * Agree the failure case in the contract. What happens if chlorine comes back above the limit, rejection, price adjustment, or reprocessing at whose cost, belongs in the contract, not in a dispute after discharge. * Consistency is the real product. Buyers commit to volume when batches look alike. A plant that can show a stable rolling analysis will be taken seriously well before one quoting a single flattering COA. ## Storage stability, and the reason a good cargo can fail on arrival Pyrolysis oil does not sit still. It oxidises, and the oxidation is not a slow cosmetic decline: it produces peroxides, which at higher concentrations are a genuine explosion hazard rather than a quality complaint. This is the part of the trade that surprises newcomers most, and it is why oxidative stability appears as a line in serious buyers' specifications. The practical consequence is uncomfortable. A parcel that tested in specification the week it was made can be out of specification a month later after a hot voyage, with nobody having done anything wrong. If you are selling on a load analysis and the buyer is testing on arrival, that gap is yours to manage. * Exclude oxygen. Nitrogen blanketing of tanks and nitrogen flushing of ISO containers before filling is the single most effective control. Research on refined oils shows inert gas flushing suppresses oxidation almost completely, even at elevated temperature. * Add an antioxidant at the production site, not on arrival. Once peroxides have formed you are managing a problem rather than preventing one. Antioxidants also lift the measured oxidative stability, which is often exactly the specification line that is failing. * Shorten the gap. Minimising the time between production and processing does more than most interventions. Material that moves promptly needs less chemistry. * Control the light ends and the condensation. Air ingress during condensation and handling promotes the formation of light oxygenates, so inerting the process rather than only the tank pays twice. * But check the contract first. Many supply agreements prohibit additives outright, with oxidation stability improvers as the one common exception. Get the approval in writing before you dose. See additives and blending. None of this is exotic. It is standard practice for unstable oils and it is well covered in the literature. What is striking is how many producers we meet who have never been told, ship without inerting, and then find themselves arguing about a discharge analysis they cannot explain. If your cargo has already landed in that argument, cargo claims sets out the route through it. ## Sources * Regulation (EU) 2024/1157 on shipments of waste, on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1157/oj * Regulation (EC) No 1907/2006 (REACH), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2006/1907/oj * ISCC PLUS, the scheme used for circular and bio based materials: https://www.iscc-system.org/certification/iscc-certification-schemes/iscc-plus/ * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj ## Frequently asked questions Q: Can pyrolysis oil move in an isotank? A: For trial parcels, yes: an isotank of roughly 20 to 25 tonnes is the normal first movement, with heating or insulation specified against the oil's viscosity and pour behaviour. Bulk volumes move by barge or parcel tanker instead, and the tank choice is part of what we arrange rather than something you chase yourself. Q: Can additives rescue an off-spec pyrolysis oil? A: Only some parameters. Stability and ageing respond to antioxidants, and some specification shortfalls can be managed by blending into a larger compatible stream. Chlorine cannot be dosed away, and neither can water or metals, which is why those parameters decide the cargo before chemistry enters the room. Where an oil genuinely cannot be corrected, we place it as an off-spec cargo instead: see off-spec and distressed cargoes. Q: How long can pyrolysis oil sit in a tank before it is a problem? A: It depends on which oil. Aromatic tyre-derived oil is comparatively forgiving; plastic-derived and biomass oils age in storage, with viscosity creep and, for bio-oil, phase separation over time. Test before storage and again before the buyer's survey, rotate stock first in first out, and treat an antioxidant as a way of slowing ageing rather than stopping it. A tank that has sat through a warm summer is a different cargo than the one that went in. Q: What is pyrolysis oil actually worth? A: There is no single answer and anyone giving you one without seeing your analysis is guessing. Price is built off a reference, usually naphtha or crude, adjusted for quality, with a premium where the material is certified. The spread between crude uncertified oil going to a burner and distilled certified oil going to a cracker is wide. Send the assay and the monthly tonnage and we will tell you which end of that range you are realistically in, including when the honest answer is the lower end. Q: Is pyrolysis oil a waste or a product? A: It depends on the material, the jurisdiction and the paperwork, and it is the single question that catches most newcomers. Waste status changes who may ship it, what documentation travels with it, and in some cases whether a buyer may accept it at all. It is not settled by what you call it in an offer. Settle it before you agree a cargo rather than after, because discovering it at a border is expensive. See REACH for pyrolysis oil. Q: Why did my pyrolysis oil pass at load and fail on arrival? A: Most often because it oxidised on the way. Pyrolysis oil forms peroxides in storage, and oxidative stability degrades with time, temperature and exposure to air. A parcel that was in specification the week it was made can be outside it a month later without anyone having done anything wrong. The controls are nitrogen blanketing of the tank or ISO container, an antioxidant added at the production site rather than on arrival, and shortening the time between production and processing. Retained sealed samples from load are what settle the argument if it has already happened. Q: Is pyrolysis oil dangerous in storage? A: It deserves respect. Oxidation produces peroxides, and peroxides at higher concentrations are an explosion hazard, not an off specification result. That is why buyers ask for nitrogen flushed containers and why antioxidant addition at the supplier's site is commonly recommended. Handling and classification information has to come from the producer's safety data sheet: see documents and safety data sheets. Q: Should I add an antioxidant to my pyrolysis oil? A: Usually yes, and at the production site rather than after the fact, because once peroxides have formed you are managing a problem instead of preventing one. But check your contract before you dose: many supply agreements prohibit additives, with oxidation stability improvers as the one permitted exception, and some require prior written approval. An additive that fixes a number and voids a contract has fixed nothing. Q: Does tyre pyrolysis oil count as a biofuel under RED III? A: Partly, and that is the point. A tyre is part natural rubber and part synthetic, so the oil carries both biogenic and fossil carbon. Under RED III the biogenic fraction is treated as an advanced biofuel aligned with Annex IX Part A, while the fossil fraction can contribute through the recycled carbon fuel route. Published estimates put the biogenic share of TPO in the region of 40 to 50 %. Q: How do you prove the biogenic content of TPO? A: Radiocarbon analysis, carbon-14 testing. Fossil carbon has no measurable C14 left, so the ratio tells you the biogenic share. Since RED III accounts for the two fractions separately, a credible and repeatable biogenic percentage from a recognised laboratory is now part of the product rather than a nice extra. If you have not had it measured, do that before your next buyer conversation. Q: What GHG saving does TPO have to achieve? A: It depends which door the fraction goes through: broadly 70 % for the recycled carbon fuel route and 65 % for advanced biofuels from newer installations. Confirm the threshold that applies to your specific installation and delivery years rather than working from a general figure. Q: What is the difference between tyre pyrolysis oil and plastic pyrolysis oil? A: They are different products with different buyers. Tyre pyrolysis oil (TPO) is aromatic with sulphur typically around 0.5 to 1.2 %, and goes to carbon black production, industrial and marine fuel blending or refinery upgrading. Waste plastic pyrolysis oil (PPO/WPPO) from polyolefins is naphtha-like and paraffinic, and its highest-value home is a steam cracker under ISCC PLUS mass balance. Quoting one against the other is the fastest way to lose credibility with a buyer. Q: What chlorine level do steam crackers accept in pyrolysis oil? A: Crackers generally work to single-digit ppm on total chlorine, and some run tighter still. Untreated mixed-plastic pyrolysis oil frequently tests in the hundreds or low thousands of ppm because of PVC and chlorinated additives in the feed. Closing that gap, by input sorting, dechlorination, or blending into a larger stream, is the central commercial question in almost every plastic pyrolysis oil deal. Always confirm the individual buyer's limit; there is no single industry figure. Q: Is pyrolysis oil classified as waste in the EU? A: It depends on the member state and on whether end-of-waste status has been established for that specific material and process. If it is still a waste, a cross-border shipment needs prior written notification and consent under the EU Waste Shipment Regulation (EU) 2024/1157, plus a financial guarantee. Because the receiving authority's view governs, settle this before fixing freight. Q: Which CN code applies to pyrolysis oil? A: There is no dedicated code. Depending on origin, aromatic content and intended use, cargoes have moved under CN headings 2707, 2710, 2713 and 3824, and a UK advance tariff ruling placed heavy plastic-derived pyrolysis oil under 2710 19 71. Agree the classification with your customs agent in advance and consider a binding tariff information, because a reclassification after arrival can move duty, excise and energy taxation all at once. Q: Do I need ISCC PLUS to sell plastic pyrolysis oil? A: Not to sell it as a fuel. You do need it if the buyer intends to make a certified circular polymer claim downstream, which is where the premium comes from. ISCC PLUS with mass balance chain of custody is the usual route in Europe. Check that the pyrolysis unit itself sits inside the certified boundary and that the certificate covers the right product group. Q: Is there a standard specification for waste plastic pyrolysis oil? A: There is no universal trading spec. ASTM D8577 is a standard guide for characterising waste plastic process oil and is a sensible basis for a COA. Biomass-derived pyrolysis liquid for industrial burners is specified under ASTM D7544 (grades G and D). In practice each buyer applies its own acceptance limits, so the useful question is not "does it meet the standard" but "can this specific plant run it". Q: Can pyrolysis oil be used to make sustainable aviation fuel? A: Biomass-derived routes to SAF are established and certified under ASTM D7566. Plastic-derived pyrolysis oil into aviation fuel is a live area of standards work rather than a settled, widely certified pathway, and eligibility under EU renewable fuel rules is a separate question from technical suitability. Treat any offer that presents it as routine with caution, and ask which approved pathway is being claimed. Q: What parcel sizes do you broker? A: From an isotank trial of roughly 20 to 25 tonnes through to full parcel tanker cargoes. First business between new counterparties is almost always a trial parcel into the buyer's own laboratory, with bulk following once two or three batches look alike. ============================================================================== # Waste plastics brokerage URL: https://www.sustainablecommodities.eu/markets/waste-plastics We broker waste plastics into recyclers, chemical recyclers and pyrolysis plants across Europe and on export. On what decides it: a clean, repeatable bale with a moisture figure and actual photographs places quickly, and an unsorted mixed load at any price is now genuinely hard to move. On the rules, the export picture changed materially in 2026 and it changed hardest for the lower grades. Tell us what you have arising monthly and we will tell you where it realistically goes. ## The 2026 shipment rules, in plain terms This is the biggest change to EU plastic waste movement in a generation, and the dates matter more than the detail: * From 21 May 2026: exports of non-hazardous plastic waste to OECD countries require the full prior written notification and consent procedure. The old green-list Annex VII route no longer covers them. * From 21 November 2026: exports of non-hazardous plastic waste from the EU to non-OECD countries are prohibited. * From 21 May 2029: non-OECD countries may apply to the European Commission to be re-listed, if they can demonstrate environmentally sound management. Nothing moves to them before that. * Intra-EU movements continue, but under the tightened regime of Regulation (EU) 2024/1157, with digital submission of documentation phasing in. ## Which grades move, and which ones are about to have nowhere to go The market for plastic waste is really several markets, and the 2026 export rules split them further apart. Where your material sits on this table decides more than the tonnage does. Clean single-polymer, post-consumer: Where it goes Mechanical recycling into new packaging; What happens next Demand rises hard. PPWR obliges 30 % recycled content in contact-sensitive PET and single-use bottles from 2030, and only post-consumer counts Clean single-polymer, post-industrial: Where it goes Mechanical recycling into non-food applications; What happens next Good material, but it does not count towards the PPWR thresholds. Priced accordingly Washed mixed polyolefin: Where it goes Compounding, or chemical recycling; What happens next The swing grade. Follows the spread between mechanical and pyrolysis Mixed rigids, printed film, hard-to-sort: Where it goes Chemical recycling, or energy recovery; What happens next This is the grade the export ban hits. From 21 November 2026 the non-OECD route closes and it has to find a European or OECD home PVC-contaminated or chlorine-rich: Where it goes Very limited; What happens next Chlorine corrodes furnace tubes and downstream metallurgy. Pyrolysis will not take it either without pretreatment Read the fourth row twice, because it is the whole opportunity. Material that is expensive to sort loses its export route on a known date while demand for the clean fractions is legislated upward. The spread between good and poor material widens, and chemical recycling is the only outlet that genuinely tolerates the difficult end. What a pyrolysis buyer screens on is not the bale grade but what it carries into the oil: chlorine and silicon above all, then nitrogen and metals. A bale that looks poor to a mechanical recycler can be perfectly acceptable to a pyrolysis operator, and the reverse is also true. See plastic pyrolysis oil. ## What this actually does to the market Two things, and they pull in opposite directions. First, volume that used to clear to non-OECD destinations has to find a European or OECD home, which puts sustained pressure on the lower grades, mixed rigids, heavily printed film, anything above roughly 5 % contamination. Second, notification adds weeks of lead time and a financial guarantee to shipments that used to move on an Annex VII document, which rewards anyone holding a standing notification and punishes spot exporters. The practical consequence for a producer of arisings is that the value of consistency and documentation has gone up relative to the value of tonnage. A clean, repeatable 98/2 film bale with a moisture figure and photographs places quickly. An unsorted mixed load, at any price, is now genuinely hard to move. ## Grades we work with For material heading into chemical recycling, the relevant question is not the bale grade but the chlorine and silicon it will carry into the oil. See pyrolysis oil for what the downstream buyer screens on. * LDPE film: 98/2 and 95/5 natural, clear, coloured and printed; post-industrial and post-consumer; baled or in regrind. * LLDPE and stretch film: post-industrial, typically clean and single-source, the easiest grade to place. * HDPE: blow-moulded rigids, natural and mixed colour, crates and drums; baled, regrind or washed flake. * PP: bumpers, crates, big bags, raffia and injection-moulding arisings; baled, regrind or pellets. * Mixed rigids and residual polyolefin fractions: usually routed to pyrolysis or energy recovery rather than mechanical recycling. * Recycled pellets and compounds: where a producer wants to place surplus or off-grade production. ## What a buyer needs before quoting Plastic waste trades badly on description alone. Everything below is normal, not demanding, and having it ready shortens a negotiation from three weeks to three days. Polymer and grade: LDPE 98/2, HDPE natural rigid, PP regrind, and so on. Origin: Post-industrial or post-consumer; single source or collected mix. Form: Baled, loose, regrind, washed flake or pellet. Bale weight and dimensions: Decides loading and freight cost per tonne. Moisture: Percentage, and whether the material has been stored outside. Contamination: Percentage and type, paper, label, other polymers, dirt. Colour breakdown: Natural, clear, light, mixed or printed. Photographs: Of the actual bales, not a stock image. Non-negotiable in practice. Volume and frequency: Tonnes per month and whether it is a one-off or an ongoing arising. EWC / Basel code: For example B3011 for the relevant plastic entries; drives the shipment route. Loading point and Incoterms: EXW, FCA, DAP; whether the site can load a 40 ft HC. Sample availability: A 5 to 10 kg representative sample for anything ongoing. ## How we work it We act for waste management companies and manufacturers placing regular arisings, and for recyclers, compounders and pyrolysis operators who need steady, predictable input rather than opportunistic lots. Because we are paid a commission on business that performs, we will tell a seller when a grade is not worth offering in its current form, and quite often the fix is upstream. Separating a printed film fraction at source, or getting a moisture figure onto the offer, moves more value than another round of price haggling. ## Sources * Document checklist: exactly which papers a European buyer asks for, per product: /markets/document-library * Regulation (EU) 2024/1157 on shipments of waste, on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1157/oj * Regulation (EU) 2025/40 on packaging and packaging waste (PPWR): https://eur-lex.europa.eu/eli/reg/2025/40/oj * Directive 2008/98/EC, the Waste Framework Directive: https://eur-lex.europa.eu/eli/dir/2008/98/oj ## Frequently asked questions Q: What happens to plastic waste exports after 2026? A: Under Regulation (EU) 2024/1157, exports of non-hazardous plastic waste to non-OECD countries are banned from 21 November 2026. From 21 May 2026 exports to OECD countries move to the notification procedure, meaning prior written consent rather than green-list simplicity. Non-OECD countries may request a derogation from 21 May 2029 by demonstrating environmentally sound management. Q: What does the export ban do to prices? A: It widens the gap between good and poor material, on a known date. Volume that used to clear to non-OECD destinations has to find a European or OECD home, which presses hardest on mixed rigids, heavily printed film and anything expensive to sort. At the same time PPWR raises demand for clean recyclate. Supply and demand are being legislated in opposite directions for different grades. Q: Is chemical recycling a way around the sorting problem? A: Partly, and that is exactly why it matters after 2026. Pyrolysis tolerates contamination that mechanical recycling cannot, so material with nowhere else to go acquires a route. What pyrolysis does not tolerate is chlorine and silicon, so PVC content and certain additives still decide whether a bale is usable. See plastic pyrolysis oil. Q: What information does a buyer need before quoting on a bale? A: Polymer and grade, origin (post-industrial or post-consumer, single source or collected), form (baled, loose, regrind, washed flake), tonnage per month, and a photograph. For anything heading to chemical recycling, add chlorine and silicon. Plastic waste trades badly on description alone, and having this ready turns a three-week negotiation into a three-day one. Q: When does the EU plastic waste export ban start? A: Exports of non-hazardous plastic waste from the EU to non-OECD countries are prohibited from 21 November 2026 under Regulation (EU) 2024/1157. Since 21 May 2026, exports to OECD countries have required the full prior written notification and consent procedure rather than the green-list route. Non-OECD countries may apply for re-listing from 21 May 2029. Q: Can I still export plastic waste from the EU to Turkey? A: Turkey is an OECD member, so it is not caught by the non-OECD prohibition. However, since 21 May 2026 such shipments fall under the prior written notification and consent procedure, which means competent-authority consent at both ends, a financial guarantee and a materially longer lead time than an Annex VII movement. Turkey also applies its own national import restrictions on plastic waste, so confirm the current position at the receiving end before committing. Q: What is the difference between 98/2 and 95/5 LDPE film? A: It is the cleanliness ratio: 98/2 means around 98 % target polymer to 2 % contamination, 95/5 around 95 % to 5 %. The gap sounds small and is not, 98/2 clears readily to mechanical recyclers, while 95/5 and below competes for a narrower set of buyers and, since the 2026 export changes, a much narrower set of destinations. Moisture is assessed separately and can matter as much as the contamination figure. Q: Do you handle mixed or contaminated plastic waste? A: Yes, but honestly. Mixed rigids and heavily contaminated fractions generally route to pyrolysis feed or energy recovery rather than mechanical recycling, and price accordingly. What we will not do is take an unsorted load to market as something it is not, that wastes the seller's time and costs us the buyer. Q: What is Basel code B3011? A: B3011 covers the plastic waste entries on the Basel Convention green list, introduced by the 2019 plastic waste amendments that replaced the former single B3010 entry. It is used for sorted, single-polymer and readily recyclable plastic waste meeting the entry conditions. The code determines which shipment procedure applies, so getting it right on the paperwork is not cosmetic. Q: Do you buy the material yourselves? A: No. We are a broker: we introduce the seller to the buyer, agree the terms between them and take a commission on concluded business. We never take title to the cargo, so we have no position to protect and no reason to press a load onto a buyer who cannot run it. Q: What volumes do you work with? A: From a single 40 ft container of a clean, well-described grade up to ongoing programmes of several hundred tonnes a month. Recurring arisings are where a broker earns their keep, because the value is in a stable home rather than a one-off clearance. ============================================================================== # Waste PET and rPET brokerage URL: https://www.sustainablecommodities.eu/markets/waste-pet We broker waste PET and rPET, from bales and flake through to food grade pellet. On what decides the grade: colour, contamination and the intrinsic viscosity, and the food contact route is a different conversation entirely with its own approvals. On volume, a clean single stream places far more easily than a larger mixed one, which is not what most sellers expect to hear. ## Why PET is a specification market In most recycled polymers a buyer will take a view on a borderline load. In PET they usually cannot, because the material is going back into a bottle or a food tray and the failure mode is a product recall rather than a bad batch. Intrinsic viscosity (IV) measures polymer chain length and is what determines whether flake can go back into bottle-grade production. It degrades with every heat history, so a load that has been through an extra processing step is a materially different product. PVC is the classic contaminant: at even a few hundred ppm it degrades during extrusion, releases HCl, yellows the melt and can damage equipment, which is why PVC is quoted in ppm and not as a percentage. Colour is the third lever. Clear and light-blue material commands the premium because it can be made into anything; mixed and green fractions are restricted to strapping, sheet and fibre outlets and price well below. Intrinsic viscosity (IV): dl/g. Bottle-grade resin typically sits around 0.72 to 0.84 dl/g; recycled flake is assessed against the intended outlet. PVC content: Reported in ppm. The most damaging single contaminant. Moisture: Percentage. Drives IV loss during extrusion and freight cost. Colour breakdown: Clear/natural, light blue, mixed, green, as percentages. Other polymers (PE, PP, PA): Caps, labels, sleeves and barrier layers. Glue, label and sleeve content: Full-sleeve bottles behave very differently from labelled ones in sorting. Metal content: Ferrous and non-ferrous, in ppm. Yellowness index / b-value: Optical quality; matters for clear applications. Bale weight, dimensions, baling wire: Loading, freight and the de-baling step at the recycler. Food-contact status: Whether the recycling process is authorised under Regulation (EU) 2022/1616 for food-contact use. Origin scheme: DRS/deposit-return material behaves differently from kerbside collection and is priced separately. ## PPWR applies from 12 August 2026, and it changes who needs your material Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, entered into force on 11 February 2025 and applies from 12 August 2026. It sets binding minimum recycled content per packaging type, which turns recyclate from something a brand owner buys when it is cheap into something they have to buy whatever it costs. Contact-sensitive PET packaging, excluding single-use beverage bottles: From 2030 30 %; From 2040 50 % Single-use plastic beverage bottles: From 2030 30 %; From 2040 65 % Contact-sensitive plastic packaging other than PET: From 2030 10 %; From 2040 25 % All other plastic packaging: From 2030 35 %; From 2040 65 % The trap in that table is the word post-consumer. Only post-consumer recycled material counts towards the Article 7 thresholds. Post-industrial scrap reintroduced during manufacturing does not, however genuinely recycled it is. A seller offering clean factory offcuts as compliance-grade recyclate is offering a good product against the wrong requirement, and a buyer who discovers that after contracting has a real problem. The practical effect for anyone holding PET is that provenance documentation is now part of the specification, not an administrative afterthought. Where the material was collected, and by whom, decides whether it can be counted at all. ## What a buyer measures on rPET flake and pellet Intrinsic viscosity is the number that decides the application. It tracks molecular weight, and PET loses it every time it goes through heat, so a flake that has been through one life too many will not blow into a bottle no matter how clean it looks. Intrinsic viscosity: Typical requirement 0.70 to 0.78 dL/g bottle grade; 0.73 to 0.80 for carbonated; above 0.80 for European carbonated and beer; Why it decides the sale Below the range the bottle fails on the blow-moulder, not in the lab Moisture: Typical requirement Dried to single-digit ppm before processing; Why it decides the sale As little as 30 ppm hydrolyses the chain at melt temperature and takes IV down with it PVC content: Typical requirement Single-digit ppm, often stated as parts per million; Why it decides the sale PVC decomposes at PET processing temperature and yellows the whole batch Colour and clarity: Typical requirement b* value stated; clear, light blue and mixed trade separately; Why it decides the sale Colour is not recoverable; a mixed bale prices as its worst fraction Polyolefin and label residue: Typical requirement Stated as ppm; Why it decides the sale Floats and specks; a sorting problem that arrives as a quality claim Provenance: Typical requirement Post-consumer, with chain of custody; Why it decides the sale Decides whether it counts under PPWR at all Sell the analysis, not the adjective. Words like clean, washed and food-grade mean different things to every party in this chain, and a buyer who has been disappointed once will not move on adjectives again. An IV figure, a PVC figure and a photograph of the bale get further in one message than a page of description. ## The other directive: single-use plastics, and the dates that already passed PPWR gets the attention, but the Single-Use Plastics Directive (EU) 2019/904 is already in force and it is the one that built the collection system PPWR now relies on. Tethered caps: caps and lids must stay attached to beverage containers up to 3 litres: Deadline 3 July 2024; Status In force PET beverage bottles to contain at least 25 % recycled plastic: Deadline 2025; Status In force All beverage bottles to contain at least 30 % recycled plastic: Deadline 2030; Status Approaching Separate collection of single-use plastic beverage bottles: 77 %: Deadline 2025; Status In force Separate collection: 90 %: Deadline 2029; Status Approaching Read the collection targets as a supply forecast, because that is what they are. A jump from 77 % to 90 % collection is a large increase in the volume of bottle material entering the market before 2029, at the same time as PPWR raises the demand for post-consumer recyclate. Supply and demand are both being legislated upward on overlapping timetables, and the two do not move at the same speed. Note also that SUPD and PPWR count differently in places. SUPD sets a recycled content target for bottles; PPWR sets targets by packaging category and counts only post-consumer material. Where both apply, comply with the stricter reading and say which one you are quoting. ## The specification, and why the same product has three of them There is no single world UCO specification. The traded grades differ by region, and the difference is not cosmetic: a cargo that is perfectly ordinary on one basis is off-spec on another. This is the single most common reason a first-time seller and a first-time buyer talk past each other. FFA (free fatty acid): European basis 5 % max; Asian (Straits) 5 % max; US Gulf Coast 15 % max MIU (moisture, impurities, unsaponifiables): European basis 2 % max; Asian (Straits) 2 % max; US Gulf Coast 2 % max Iodine value: European basis 70 min; Asian (Straits) 50 min; US Gulf Coast Reported Sulphur: European basis 50 ppm max; Asian (Straits) 50 ppm max; US Gulf Coast Reported Sustainability certification: European basis ISCC EU or equivalent; Asian (Straits) ISCC EU or equivalent; US Gulf Coast Scheme depends on outlet Read the FFA line again. A US Gulf Coast basis tolerates three times the free fatty acid of a European one. Material bought on the loose basis and offered on the tight one is not a bargain, it is a claim waiting to happen, and the person holding it when the analysis lands is usually the one who did not check which basis they were quoting. Beyond the traded parameters, a hydrotreater will want phosphorus, metals, chlorides and polyethylene content before it commits, because those govern catalyst life rather than product quality. A FAME plant cares far less. Same cargo, different questions, and it is worth knowing which buyer you are talking to before you send an analysis that answers the wrong ones. ## The regulation driving demand Recycled PET is one of the few commodities in this sector where the demand curve is written into law, and the dates are close enough now that converters are contracting rather than watching. * PPWR, Regulation (EU) 2025/40. In force since 11 February 2025 and applying from 12 August 2026. From 1 January 2030 it sets minimum post-consumer recycled content: 30 % for contact-sensitive PET packaging, 10 % for contact-sensitive plastic packaging other than PET, 30 % for single-use plastic beverage bottles, and 35 % for other plastic packaging. Targets step up again from 2040, with single-use plastic beverage bottles rising to 65 %. * Single-Use Plastics Directive. Already requires 25 % recycled content in PET beverage bottles from 2025, rising to 30 % for all plastic beverage bottles from 2030. * Regulation (EU) 2022/1616 governs recycled plastics intended for food contact. A recycling process must be authorised, and the authorisation attaches to the process, not to the company. This is the first thing to verify when food-grade rPET is offered. ## What we broker * Post-consumer PET bottle bales: clear/natural, light blue, mixed and green; kerbside and deposit-return origin. * Hot-washed PET flake: food-grade and non-food-grade, colour-sorted. * rPET pellets and granulate: including food-grade material from authorised processes. * PET production arisings: off-grade resin, preform and sheet rejects, purge and lump, edge trim. * PET trays and thermoformed fractions: a growing and genuinely difficult stream, priced separately from bottle material. ## How we work it We act for waste management companies and sorting facilities placing bales, and for recyclers, preform producers and packaging converters who need contracted volume to hit a recycled-content number they cannot miss. The two things that decide whether an offer moves are a current analysis and a representative sample. On bales that means IV, PVC in ppm, moisture and a colour breakdown; on flake and pellet it means a full certificate of analysis and, for food-grade, the authorisation reference for the recycling process. With that in hand a serious buyer will price within days. Without it, an offer circulates for weeks and quietly dies. Export routing also changed in 2026, see waste plastics for the Waste Shipment Regulation dates, which apply to PET as much as to polyolefins. ## Sources * Directive (EU) 2019/904 on single-use plastics: https://eur-lex.europa.eu/legal-content/EN/LSU/?uri=CELEX:32019L0904 * Intrinsic viscosity as a quality parameter for PET (measurement method): https://www.muser-my.com/wp-content/uploads/2018/11/C72IA036EN-A.pdf * Regulation (EU) 2025/40 on packaging and packaging waste (PPWR): https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng * Regulation (EU) 2024/1157 on shipments of waste, on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1157/oj * Regulation (EU) 2025/40 on packaging and packaging waste (PPWR): https://eur-lex.europa.eu/eli/reg/2025/40/oj ## Frequently asked questions Q: What is intrinsic viscosity and why does every rPET buyer ask for it? A: Intrinsic viscosity, in decilitres per gram, tracks the length of the polymer chains and therefore the strength of the material. Bottle grade needs roughly 0.70 to 0.78 dL/g, and above 0.80 for European carbonated drinks and beer. PET loses IV every time it goes through heat, so flake that has been through one life too many will not blow into a bottle no matter how clean it looks. Q: Why does a few parts per million of PVC ruin a batch? A: Because PVC decomposes at PET processing temperature and releases acid that degrades the polymer and yellows the whole melt. It is one of the few contaminants where a very small quantity does disproportionate damage, which is why buyers specify it in parts per million rather than as a percentage. Q: Does post-industrial scrap count towards the PPWR targets? A: No, and this is the trap that catches sellers out. Only post-consumer recycled material counts towards the Article 7 thresholds. Clean factory offcuts reintroduced during manufacturing do not, however genuinely recycled they are. Provenance documentation is therefore part of the specification, not an afterthought. Q: What IV is needed for bottle-grade rPET? A: Virgin bottle-grade PET resin typically sits around 0.72 to 0.84 dl/g, and recycled flake or pellet is assessed against the intended application rather than a single universal number. IV falls with every heat history, so material that has been through additional processing steps is genuinely a different product. Solid-state polycondensation is used to build IV back up for demanding outlets. Always confirm the specific buyer's requirement. Q: Why is PVC contamination measured in ppm rather than percent? A: Because the tolerance is that tight. PVC degrades at PET processing temperatures and releases hydrogen chloride, which yellows the melt, accelerates polymer degradation and can corrode equipment. Even a few hundred ppm causes visible quality problems in clear applications, so buyers specify it in parts per million and test for it independently. Q: What recycled content will EU packaging law require in 2030? A: Under the Packaging and Packaging Waste Regulation (EU) 2025/40, from 1 January 2030: 30 % post-consumer recycled content for contact-sensitive PET packaging, 10 % for contact-sensitive plastic packaging other than PET, 30 % for single-use plastic beverage bottles and 35 % for other plastic packaging. The targets rise again from 2040, with single-use plastic beverage bottles going to 65 %. Verify against the current Official Journal text before contracting. Q: What makes rPET food-grade? A: The recycling process must be authorised under Regulation (EU) 2022/1616 on recycled plastic materials intended to come into contact with food. The authorisation attaches to the specific decontamination process, so the right question to an offering party is which authorised process the material came from, not simply whether the company is certified. Input origin and traceability are assessed alongside it. Q: Do you handle PET trays as well as bottles? A: Yes. Tray and thermoform fractions are a separate market from bottle material, with different sorting behaviour, multilayer and barrier complications, and generally fewer outlets. They price independently and should be offered as their own stream rather than mixed into a bottle bale offer. Q: Can you place deposit-return scheme material? A: Yes. DRS material is usually cleaner and more consistent than kerbside collection and is priced separately for that reason. Buyers will still want the same analysis pack, IV, PVC in ppm, moisture and colour breakdown, because scheme origin sets expectations but does not replace testing. ============================================================================== # Vegetable and technical oil brokerage URL: https://www.sustainablecommodities.eu/markets/vegetable-oils We broker vegetable and technical oils, with the emphasis on grades that sit outside the food chain: technical and non-food grades, acid oils, soapstock, PFAD, palm acid oil and distillers corn oil, alongside crude and refined palm, soy, rape, sunflower and corn oil. Most of what we place is heading into an oleochemical, feed or energy outlet rather than a food one, which changes the specification that matters and the buyer that pays best. ## What we work with * Crude and refined oils: CPO, CPKO, RBD palm oil and olein, soybean, rapeseed/canola, sunflower and corn oil. * Technical and non-food grades: oils that are off-spec for food use, or produced deliberately for industrial and energy outlets. * Acid oils and soapstock: from chemical and physical refining, priced on total fatty acid content rather than on volume. * PFAD and palm acid oil (PAO): palm fatty acid distillate and the acid oil fraction; both with feedstock-status questions worth settling early. * Distillers corn oil (DCO): from bioethanol production, a significant and growing biodiesel feedstock. * Used and recovered vegetable oils: where these fall under waste rules, see used cooking oil instead. ## The cap that decides what a vegetable oil is worth in fuel For food and industrial buyers a vegetable oil is priced on quality. For a fuel buyer it is priced on quality and on which regulatory bucket it falls into, and the second one can be worth more than the first. Getting this wrong is the most expensive mistake on this page. Food and feed crop oils (rape, soy, sunflower, palm): Treatment in EU transport fuel Capped at 7 % of transport energy, and capped at the member state's 2020 share plus one point; What it means commercially The cap is the binding constraint, not demand. Volume above it has no mandate value High ILUC-risk palm oil: Treatment in EU transport fuel Frozen at 2019 levels and phasing down to zero by 2030; What it means commercially A term position built on it has a known end date Certified low ILUC-risk material: Treatment in EU transport fuel Exempt from the phase-down, but still inside the 7 % cap; What it means commercially The certification buys you time, not headroom. Without it the exemption does not exist Used cooking oil and waste-derived oils: Treatment in EU transport fuel Annex IX Part B, separate 1.7 % cap; What it means commercially A different market with different economics. See used cooking oil Technical and off-spec oils not fit for food: Treatment in EU transport fuel Depends entirely on the waste classification and the receiving permit; What it means commercially Settle this before pricing. See Annex IX feedstocks A crop oil and a waste oil are not competitors, they are different products with different ceilings. Sellers who move between the two without changing their price expectation are usually the ones who end up disappointed, and it is rarely the buyer's fault. On the physical side the screening is conventional and quick: FFA, moisture and impurities, peroxide value, colour, and for anything heading to a hydrotreater, phosphorus and metals. What takes the time is never the assay. It is proving where the oil came from. ## Technical corn oil, and why it is quoted on its own parameters Technical corn oil, TCO, and distillers corn oil, DCO, are the same stream under two names. It is the corn oil recovered from the stillage in dry mill bioethanol production: a non-food co-product, not a refined food oil that has been downgraded. Sellers in the Americas usually write TCO, European buyers often write DCO, and offers get missed because the two sides search for different words. It is quoted on its own parameter set rather than on a generic vegetable oil sheet, and two of those parameters are specific to this stream. Ask for all of them before you price anything. Free fatty acid: Usual method ISO 660; Why it is asked The main quality and price driver, and the first thing a pretreatment operator looks at. Moisture and volatile matter: Usual method ISO 662; Why it is asked Drives pretreatment cost and settlement weight. Sediment: Usual method ISO 15301; Why it is asked Carry-over from the stillage. Higher here than most buyers expect from an oil. Iodine value: Usual method AOCS Cd 1c-85; Why it is asked Corn oil is highly unsaturated, which shows up downstream in cold flow behaviour. Waxes: Usual method By agreement; Why it is asked Specific to this stream. Waxes cloud and drop out at low temperature and they are a plant question, not a storage question. Sulphur: Usual method By agreement; Why it is asked Decides whether a hydrotreater can take it without extra treatment. Phosphorus: Usual method AOCS Ca 12-55; Why it is asked Catalyst poison. Usually asked alongside sulphur rather than instead of it. Aflatoxin: Usual method AOAC 2013.05; Why it is asked A grain question that follows the oil. It is asked on corn streams and not on most others, and a seller who has never been asked for it has probably not sold into a regulated feed or food adjacent outlet. Waxes and aflatoxin are the two that catch people out. Neither appears on a standard vegetable oil sheet, both are routinely asked for on corn streams, and a seller who cannot produce them is looking at a delay rather than a rejection. Get them measured before you offer. On classification, TCO has a favourable position in several renewable fuel regimes because it is a genuine co-product rather than a crop oil, and that position is exactly what a buyer will want documented. Our Annex IX feedstocks page sets out how the categories work, and which feedstock makes which fuel covers where the stream ends up. ## The specification that decides the outlet The same tank of oil can be worth very different money depending on which outlet can take it, and the deciding parameters are usually the first four below. Free fatty acid content in particular is not a quality footnote, it determines whether the oil goes to refining, to oleochemicals or straight to an energy outlet. FFA (free fatty acid): As a percentage, stated as which acid. The primary value driver for anything off-food-grade. Moisture and impurities (M&I): Combined and separately; drives refining loss and settlement weight. Total fatty acid (TFA): Essential for acid oils and soapstock, where it is the pricing basis. Iodine value (IV): Degree of unsaturation; affects oxidative stability and cold-flow downstream. Colour: Lovibond, on a stated cell length. Peroxide value / anisidine: Oxidation history and storage condition. Phosphorus and gums: Refining behaviour and catalyst impact downstream. Sulphur: Critical where the oil is heading for hydrotreatment into HVO. Unsaponifiable matter: Ceiling on usable yield. Melting point / titre / cloud point: Handling, heated storage and which tanks can take it. MOSH/MOAH, PAH, pesticides: Where feed or food-adjacent outlets are in play; also dioxins for feed. Origin and certification: ISCC, RSPO or none, decides eligibility and price band, not just paperwork. ## EUDR: the date that now governs palm and soy The EU Deforestation Regulation applies to palm oil, soy, cattle, coffee, cocoa, rubber and wood and their derived products. After two postponements the application date now sits at 30 December 2026 for large operators and traders, and 30 June 2027 for micro and small operators. Two points matter commercially. First, the due diligence obligation falls primarily on whoever first places the relevant product on the EU market, not on everyone downstream, which concentrates the burden and the risk. Second, geolocation data for the plot of production is the practical bottleneck: it either exists in the chain or it does not, and it cannot be created retrospectively. If you are contracting palm or soy for delivery into 2027, settle the EUDR position at contract stage. The rules have been amended more than once and are still being simplified. Verify the current position against the Official Journal before relying on any summary, including this one. ## Contracts, quality and how cargo actually moves Most bulk vegetable oil business in Europe contracts on FOSFA terms, with the relevant contract form depending on origin, oil and shipment basis. Quality and condition are established by independent superintendents at load and discharge, with sealed retained samples held by both sides, and those retained samples are the single most useful thing anyone can have if a quality dispute arises later. Movement is by parcel tanker for bulk, flexitank or ISO tank for smaller lots, and drums or IBCs for specialty grades. Heated storage requirements and previous-cargo restrictions narrow the tank and vessel list quickly, so they belong in the first conversation rather than the fixture note. Where a parcel arrives out of specification, speed decides the loss. See off-spec and distressed cargoes. ## Sources * Document checklist: exactly which papers a European buyer asks for, per product: /markets/document-library * RED III implementation, food and feed crop caps by member state: https://uploads.transportenvironment.org/production/files/REDIII_implementation_briefing.pdf * Regulation (EU) 2023/1115 on deforestation free products (EUDR): https://eur-lex.europa.eu/eli/reg/2023/1115/oj * Directive (EU) 2018/2001 (RED II), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj * ISCC System, the certification scheme itself: https://www.iscc-system.org/ ## Frequently asked questions Q: Why is my vegetable oil worth less in fuel than I expected? A: Almost always because of the cap rather than the quality. Food and feed crop oils are limited to 7 % of transport energy under the Renewable Energy Directive, and further capped at the member state's 2020 share plus one percentage point. Volume above the cap has no mandate value. The oil is fine; the bucket is full. Q: Can palm oil still be sold into European fuel? A: High ILUC-risk palm oil is frozen at 2019 levels and phases down to zero by 2030, so a term position built on it has a known end date. Material certified as low ILUC-risk is exempt from the phase-down, but it still sits inside the 7 % cap. The certification buys you time, not headroom. Q: What is EUDR and does it affect my oil? A: The EU Deforestation Regulation requires proof that certain commodities, palm and soy among them, did not come from land deforested after the cut-off date, with geolocation data for the plots. If your oil is in scope, that evidence has to exist before a European buyer can place it, and assembling it after the fact is much harder than collecting it as you go. Q: What do buyers screen vegetable oil on? A: FFA, moisture and impurities, peroxide value and colour as standard. For anything going to a hydrotreater, add phosphorus and metals, because those govern catalyst life rather than product quality. See parameters explained. The assay is rarely what takes the time; proving where the oil came from is. Q: What is the difference between acid oil, soapstock and PFAD? A: Soapstock is the alkaline by-product of chemical refining. Acid oil is what you get when soapstock is acidulated, concentrating the fatty acids. PFAD, palm fatty acid distillate, comes from the physical refining of palm oil and is a distillate rather than an acidulation product. All three price on total fatty acid content rather than on tonnage, and all three carry their own questions about feedstock status under EU renewable fuel rules. Q: When does EUDR apply to palm and soy oil? A: From 30 December 2026 for large operators and traders, and 30 June 2027 for micro and small operators, following the postponement agreed in December 2025. The due diligence obligation sits primarily with whoever first places the product on the EU market. The practical bottleneck is plot-level geolocation data, which has to exist in the chain already. Verify against the current Official Journal text before contracting. Q: Do you broker food-grade vegetable oils? A: We can, but the majority of what we place is technical grade, non-food grade or a refining side stream heading into oleochemical, feed or energy outlets. That is where our buyer network is genuinely strong. If you have food-grade oil to place we will say plainly whether we are the right broker for it. Q: What is distillers corn oil and why is it in demand? A: DCO is the corn oil extracted from the stillage in dry-mill bioethanol production. It is a non-food co-product with a favourable feedstock classification in several renewable fuel regimes, which makes it attractive to biodiesel and renewable diesel producers. Sulphur, moisture and FFA are the parameters buyers screen on, particularly where the oil is going into hydrotreatment. Q: Which contract terms do you work on? A: FOSFA forms are standard for bulk vegetable oil in Europe, with the specific form depending on origin, oil and shipment basis. Quality and condition are settled by independent superintendents at load and discharge with sealed retained samples on both sides. Our own General Terms & Conditions govern the brokerage itself, not the underlying sale contract; they are linked from the footer of every page on this site. Q: Can you handle small parcels? A: Yes. Flexitank and ISO tank lots of roughly 20 to 25 tonnes are routine, and drums or IBCs work for specialty and technical grades. Below about a full container, freight usually dominates the economics, and we will say so rather than let you find out at the quoting stage. ============================================================================== # Used cooking oil (UCO) brokerage URL: https://www.sustainablecommodities.eu/markets/used-cooking-oil We broker used cooking oil between collectors and aggregators on one side and FAME, HVO and SAF producers on the other, across Europe and on import parcels. UCO sits in Annex IX Part B of the Renewable Energy Directive, and that is where the value comes from. Which means the certificate and the traceability behind it are part of the product, not paperwork attached to it. On what that is worth in practice: a cargo whose chain of custody will not survive an audit is worth a fraction of one that will, and the gap is far wider than most sellers expect. ## Reading a UCO offer: what 5/2/65/50 means A UCO parcel is quoted in the trade as a string of four numbers, for example 5/2/65/50. Everyone in the market uses it and almost nobody writes down what it means, which is a problem the first time you receive an offer. It is, in order: * FFA, free fatty acid, as a maximum percentage. * M&I, moisture and impurities, as a maximum percentage. * IV, iodine value, normally as a MINIMUM. * Sulphur, as a maximum in parts per million. So 5/2/65/50 is FFA 5 % max, moisture and impurities 2 % max, iodine value 65 minimum, sulphur 50 ppm max. A dash means no limit was agreed on that line: 10/2/-/50 is the same parcel with a looser FFA and no iodine requirement. Note that the third number runs the other way. FFA, M&I and sulphur are ceilings, iodine value is usually a floor, because a buyer making FAME wants unsaturation and a buyer feeding a hydrotreater often does not. Read the direction before you agree the number. ## The numbers behind those four, and what a buyer actually sets The table below is the range we see across offers and specifications from different counterparties. It is not one specification and it is not ours: acceptance limits are set by the receiving plant and belong in your contract. What it does show is which values are normal, so you can tell whether an offer is ordinary or unusual. FFA, free fatty acid: Range seen 3 %, 5 % and 7.5 % max are all common. Separate grades exist far higher, up to 30 %.; What it decides The main price driver. It rises with age and with how the oil was handled, so it is also a proxy for the collection chain. M&I, moisture and impurities: Range seen 2 % max, in every specification we see.; What it decides Settlement weight and pretreatment load. You pay freight on both. IV, iodine value: Range seen Minimum 50, 60, 70 or 80 depending on the buyer; sometimes a maximum of 120.; What it decides Unsaturation. Drives cold flow in FAME and hydrogen consumption in HVO, which is why the two routes ask for opposite things. Sulphur: Range seen 15 to 80 ppm max, and tightening.; What it decides The gate for HVO and SAF producers, where it poisons the hydrotreating catalyst. A FAME producer is far more relaxed about it. Phosphorus: Range seen 30 ppm at the tight end, 450 ppm where the buyer pretreats.; What it decides Catalyst poison, and a direct measure of how much pretreatment the receiver has to do. Density at 15 C: Range seen 0.86 to 0.90 g/cm3, or 900 to 920 kg/m3.; What it decides Volume to weight conversion, and a first check that the material is what it says it is. Flash point: Range seen Above 180 C.; What it decides Classification and transport. A low result points at solvent or mineral oil contamination. Total nitrogen: Range seen Reported rather than capped; results between roughly 130 and 460 mg/kg are normal.; What it decides A hydrotreatment constraint that buyers increasingly ask for. Two lines cause most of the arguments. Sulphur, because a parcel sold to a FAME producer at 80 ppm is unsellable to a hydrotreater at 15, and the seller often does not know which one he is talking to. And FFA, because it keeps rising while the oil sits: a number measured at loading is not the number on arrival, which is why the sampling point belongs in the contract and not in the covering email. For what each parameter physically means, see parameters explained. For why the test method belongs next to the limit, see test methods and analysis. ## Specification: what a producer screens on UCO is priced against a fairly settled set of parameters. The first three carry most of the value, and sulphur has become materially more important as hydrotreatment capacity has grown relative to transesterification. FFA (free fatty acid): Percentage as oleic. The primary quality and price driver. MIU (moisture, impurities, unsaponifiables): Combined, and normally also reported individually. Moisture: Karl Fischer or oven; settlement weight and processing yield. Total contamination / filterable solids: Food particles and fines. Iodine value (IV): Degree of unsaturation; drives cold-flow and oxidative stability in the finished fuel. Sulphur: Increasingly the gate for HVO and SAF producers, where it poisons hydrotreating catalyst. Phosphorus: Catalyst impact and pretreatment load. Polyethylene / polymer content: From packaging and fryer handling; a recurring problem in poorly managed collection. Mineral oil content: A fraud and contamination marker as much as a quality one. Titre / melting behaviour: Handling, heated storage and pumpability. Certification: ISCC EU or equivalent, with the correct scope and a valid proof of sustainability. ## Certification and the reason it is scrutinised UCO qualifies as an Annex IX Part B feedstock, and biofuels made from Part B feedstocks are subject to a cap: 1.7 % of transport energy per member state, with the possibility for a member state to request a higher limit where feedstock availability justifies it. That cap, plus the greenhouse-gas value of waste-based fuel, is what puts UCO at a premium to virgin oil. That premium is exactly why the category attracts scrutiny. The persistent concern across the market is virgin or palm-derived oil being presented as used, and it has had concrete consequences: following an anti-dumping investigation, the EU imposed definitive anti-dumping duties on biodiesel from China ranging from roughly 10 % to 35.6 % by Commission Implementing Regulation (EU) 2025/261, published on 11 February 2025. The practical effect for anyone trading UCO today is that buyers audit harder than they did five years ago. Collection-point-level records, consistent volumes that match the claimed collection base, and analysis that looks like used oil rather than fresh oil are what get a supplier through due diligence. Double counting is a separate question from the cap, and it is now member state specific. Several member states, including the Netherlands and Germany, have moved away from multipliers in their RED III implementation. Do not assume a multiplier applies in the destination market, check the national scheme. ## Where UCO goes For what the finished fuel then has to meet, see FAME biodiesel and HVO, bionaphtha and SAF. * FAME / UCOME producers: transesterification into biodiesel; the traditional and still the largest outlet. * HVO and renewable diesel producers: hydrotreatment; more sensitive to sulphur, phosphorus and metals, and generally paying for pretreated or low-contaminant material. * SAF producers: the HEFA route; the tightest specification of the three and the most demanding on documentation. * Oleochemical outlets: for material that does not qualify or does not fit the energy chain. ## Where the volume actually comes from and goes Useful orientation if you are new to this flow, because the trade routes are more concentrated than people expect. * Roughly 80 % of the world UCO market ends up in biofuels. The rest goes to oleochemical and industrial outlets. * Asia is by far the largest supplier, with most of that volume exported. Malaysia and Indonesia are the largest single origins, alongside significant volumes out of Russia and Saudi Arabia. * The Netherlands, Spain and Belgium together account for the overwhelming majority of EU imports, on the order of 97 %. Which is why sitting near the ARA range is not a detail for a broker in this product. * UCO is the primary feedstock for HEFA-SAF, HVO and UCOME worldwide, so these three demand streams compete for the same tonne. ## Non ISCC UCO, and why that market is growing Not every tonne of used cooking oil is certified, and there is a real and expanding market for the material that is not. It is worth understanding rather than dismissing. Certification costs money and takes time, and a great deal of genuine, well collected UCO sits with collectors who have not yet gone through the process, or whose certificate does not cover a particular activity or origin. That material cannot go into an EU renewable fuel claim, but it is not worthless: it has established outlets in oleochemicals, in industrial and technical applications, in energy recovery, and in markets outside the EU mandate framework. The practical point for a seller is that uncertified UCO trades in a different market against different buyers, and pretending otherwise wastes everybody's time. We will tell you plainly which market you are in. The practical point for a buyer is that non certified material can be a sensible route where the end use does not depend on counting the volume, and it frequently prices accordingly. One thing we will not do is move uncertified material into a chain where a certified claim is being made. That is precisely the behaviour that produced the fraud problem the whole sector is now paying for. ## Food waste oil and related streams Alongside classic fryer oil there is a wider family of oily waste streams coming out of food production and food service, and they are handled less consistently than UCO because they arrive in smaller, messier lots. * Food waste oil, recovered oil and fat from food manufacturing, processing and food service waste streams. * Grease trap and interceptor material, and the recovered oil fraction from it. Genuinely different from fryer oil in quality and in the pretreatment it needs. * Fat, oil and grease (FOG) from wastewater treatment. * Expired and off specification food oils, where the food outlet has closed but the material is intact. * Bakery and snack production residues carrying recoverable oil. ## How UCO actually ships, and in what parcel size Volume questions come before specification questions more often than people expect, because the parcel size decides which buyers can even look at it. Flexibag in a 20 ft container: 19 to 20 MT ISO tank, international movement: 20 to 21 MT per tank For a first trial most sellers think in one container. A buyer who works ISO tanks will usually want to know how many tanks a month you can hold, not what a single parcel weighs, so have that number ready as well. ## What a UCO buyer checks before they bid We act for collectors and aggregators who want a reliable home for regular volume rather than a marginally better price on a one-off load, and for producers who need predictable, certified, auditable supply. What we ask for up front is the certificate with its scope, a recent analysis, honest volumes per month and the logistics reality, road tanker, flexitank, ISO tank or parcel. What we will not do is present a cargo as certified when the certificate does not cover it. That protects the collector as much as the buyer: in this market a supplier's reputation for clean documentation is worth more than any single cargo. ## Sources * Document checklist: exactly which papers a European buyer asks for, per product: /markets/document-library * SPECIMEN safety data sheet: Used cooking oil (worked example, all 16 sections): /documents/sds-used-cooking-oil * S&P Global Commodity Insights, global biofuels specifications guide: https://www.spglobal.com/commodityinsights/PlattsContent/_assets/_files/en/our-methodology/methodology-specifications/global_biofuels.pdf * Directive (EU) 2018/2001 (RED II), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * Regulation (EC) No 1069/2009 on animal by-products: https://eur-lex.europa.eu/eli/reg/2009/1069/oj * ISCC System, the certification scheme itself: https://www.iscc-system.org/ ## Frequently asked questions Q: What ruins a load of used cooking oil? A: Water and soap residue from fryer cleaning, burned food particles, and above all any mineral oil contamination. That last one is the serious one: motor oil in a collection tank can turn an entire load from a saleable feedstock into a hazardous waste disposal cost, and the loss is the whole load rather than a discount on it. It is worth being strict with collection points about what goes in the drum, because you cannot separate it out afterwards. Q: How much used cooking oil does a restaurant actually produce? A: Far less than people expect individually, which is why this is an aggregation business rather than a single-site one. A typical restaurant produces a drum or two a month; a fast food outlet with high fryer turnover produces considerably more. The commercial reality is that no single kitchen is a cargo. Value is built by collectors who consolidate many small sources into container or tanker lots, and the cost of that logistics is most of the economics. Q: How is UCO priced? A: Against vegetable oil and biodiesel references, adjusted for quality, with certification status as a separate and substantial factor. Free fatty acid content, moisture, impurities and unsaponifiables all move the number, and an Annex IX Part B claim that survives an audit moves it a great deal more. That is why we say the certificate is part of the product: the same oil with and without a defensible chain of custody is two different commercial propositions. Q: What specification does UCO need to meet? A: There is no single universal trading spec, but the standard analysis is FFA, MIU (moisture, impurities and unsaponifiables), moisture separately, iodine value, sulphur, phosphorus and total contamination. FFA and MIU carry most of the price. Sulphur has become materially more important because HVO and SAF producers hydrotreat and sulphur poisons their catalyst. Each producer sets its own acceptance limits. Q: Is UCO an Annex IX Part A or Part B feedstock? A: Part B. Biofuels from Part B feedstocks, used cooking oil, and category 1 and 2 animal fats, are capped at 1.7 % of transport energy per member state, though a member state may request a higher cap where feedstock availability justifies it. Part A covers advanced feedstocks such as lignocellulosic material, manure, sewage sludge and algae, and is a separate target. Q: Does UCO still count double in the EU? A: That now depends on the member state. Multipliers were a feature of earlier implementations, and under RED III several member states, including the Netherlands and Germany, have moved away from them. Because it is set nationally, check the scheme in the destination market rather than assuming a multiplier applies. Q: Why is UCO from China subject to anti-dumping duties? A: The duties apply to biodiesel, not to the raw feedstock. Following an anti-dumping investigation into imports of HVO and FAME from China, the Commission imposed definitive duties of roughly 10 % to 35.6 % by Commission Implementing Regulation (EU) 2025/261, published on 11 February 2025. The investigation sat against a background of concern that palm-derived biodiesel was being presented as UCO-derived. Q: What certification do you need to sell UCO into the EU biofuel chain? A: ISCC EU is the most widely used voluntary scheme, with REDcert and others also recognised. What matters is that the certificate scope actually covers the material and the activity, and that a valid proof of sustainability accompanies each delivery. Buyers increasingly audit the collection base behind the certificate, not just the certificate itself. Q: Do you work with small collectors? A: Yes. Aggregating regular volume from smaller collectors into parcels that a producer can contract is one of the more useful things a broker does in this market. The requirement is certification and consistent, honest volumes, a collector who overstates monthly availability creates a problem that surfaces at the worst possible moment. Q: What is the Union Database for Biofuels (UDB)? A: The EU database that tracks sustainable fuel consignments through the supply chain, which went live in November 2024. It exists to make traceability verifiable rather than declared, and it was introduced substantially in response to concerns about mislabelled waste-based feedstock. If you are placing UCO into the EU chain, expect your data to be in it and expect buyers to check. Q: How much UCO fraud is there really? A: Estimates of mislabelling in global UCO trade have been put in the range of 20 to 30 %, which is why buyers audit as hard as they do and why the UDB was introduced. We are not in a position to verify any single market-wide number, but the practical consequence is not in dispute: a supplier who can evidence the collection base behind the certificate is in a materially stronger position than one who cannot. Q: Is Asian-origin UCO harder to place in Europe? A: It faces more scrutiny. Buyers generally require full chain-of-custody documentation proving waste origin, and some member states and some buyers apply additional checks for the most sensitive mandate applications. It moves, and a good deal of it does, but the documentation has to be genuinely solid rather than merely present. Q: What GHG saving does UCO-based fuel achieve? A: Waste-based feedstocks including UCO are commonly cited at up to around 88 % greenhouse gas saving against fossil diesel, though the figure that matters commercially is the actual number on the proof of sustainability accompanying your consignment, not a default or a headline. Where a buyer's claim depends on the saving, contract against the actual figure. Q: Do you trade non ISCC certified UCO? A: Yes, and that market is growing. Uncertified material cannot go into an EU renewable fuel claim, but it has real outlets in oleochemicals, industrial and technical applications, energy recovery and markets outside the EU mandate framework. It trades against different buyers at different levels, and we will tell you plainly which market you are in. What we will not do is move uncertified material into a chain where a certified claim is being made. Q: Do you handle food waste oil and grease trap material? A: Yes. Food waste oil from manufacturing and food service, grease trap and interceptor material, fat oil and grease from wastewater treatment, and expired or off specification food oils. These arrive in smaller and messier lots than fryer oil and need more pretreatment, so the buyer list is narrower, but there is a genuine market and a lot of this material is currently disposed of rather than sold. Q: Do you publish UCO prices? A: No. We do not publish price assessments, and we do not republish other people's. Market levels are discussed directly with counterparties. If you want a published assessment there are established price reporting agencies for that; what we offer is a read on where business is actually clearing. ============================================================================== # Animal fat and tallow brokerage URL: https://www.sustainablecommodities.eu/markets/animal-fats-and-tallow We broker animal fats and tallow across all three ABP categories into biodiesel, renewable diesel, oleochemical and, where the category permits, feed outlets. The first question is never the specification, it is the category under Regulation (EC) No 1069/2009, because that decides which outlets are legally available at all. Only once that is settled do FFA, titre, moisture and impurities decide the price. ## Category first, specification second The Animal By-Products Regulation sorts material into three categories by risk, and the category travels with the fat through the whole chain. Getting it wrong is not a commercial error, it is a regulatory one. * Category 1: the highest-risk material, including specified risk material. It is excluded from feed and from food, but it is not banned from use as a fuel feedstock: category 1 fat is a well-established biodiesel and renewable diesel input, subject to the processing, traceability and channelling requirements in the regulation. The common belief that category 1 cannot be traded at all is simply wrong, and it costs renderers money. * Category 2: including fallen stock and material unfit for consumption. Excluded from feed for farmed animals, available to oleochemical and energy outlets under the applicable conditions. * Category 3: derived from animals fit for human consumption at slaughter. The broadest set of outlets, including petfood and, subject to the species rules, some feed uses. Generally the highest value. ## Rendering, and what Category 3 actually means Rendering is the process that turns an animal by-product into two tradeable streams: the fat, and the protein meal left behind. The fat is what we broker. What decides its value is not the process but the category the raw material carried into it, and that category is set by law rather than by the renderer. The three categories are defined in Regulation (EC) No 1069/2009, the Animal By-Products Regulation, and each one has its own article. People quote the regulation number constantly and almost never the article, which is where the actual definition sits. Category 1: Defined in Article 8; What it is, in trade terms The highest risk class, including TSE-suspect material and specified risk material. Disposal and outlets are the most restricted. Category 2: Defined in Article 9; What it is, in trade terms Material that is not Category 1 but is not fit for the food chain either, including animals that died other than by slaughter for human consumption. Category 3: Defined in Article 10; What it is, in trade terms The low risk class. Material from animals that passed ante-mortem inspection at a slaughterhouse, including parts that were fit for human consumption but are not intended for it for commercial reasons. Category 3 is not the leftovers. Article 10(a) covers carcases and parts that are fit for human consumption and simply are not going there, which is why Category 3 fat competes with food and oleochemical outlets rather than only with fuel. That competition, not the specification, is usually what sets its price. Why a buyer asks whether it is porcine. Article 10(b)(iii) draws a line between ruminants that require TSE testing and animals that do not. Pigs and poultry sit on the side that does not, so porcine and poultry fat carry a different documentation burden from bovine material of the same category. A seller who answers 'animal fat, Category 3' when the buyer asked for species is answering a different question, and it costs time on both sides. What we ask for. The category, the species split, the processing method and the approval number of the plant. Those four settle most of what a buyer needs before the analysis is even opened, and a renderer who cannot produce them quickly is a renderer whose material will be slow to place. ## What each category actually looks like on an analysis Category decides where the fat may legally go. The analysis decides what it is worth once it is there. Both belong in the first message, because a buyer who gets one without the other cannot price it and will simply not reply. FFA: Cat 1 and Cat 2 (technical) Commonly up to 15 %, sometimes higher; Cat 3 (food-chain origin) Typically low single digits Moisture: Cat 1 and Cat 2 (technical) 1 % max; Cat 3 (food-chain origin) 0.5 % max is common Impurities and volatile matter: Cat 1 and Cat 2 (technical) 0.5 % max; Cat 3 (food-chain origin) 0.5 % max Titre: Cat 1 and Cat 2 (technical) 38 to 44 C depending on species mix; Cat 3 (food-chain origin) 38 to 44 C Sulphur and phosphorus: Cat 1 and Cat 2 (technical) Ask before offering to a hydrotreater; Cat 3 (food-chain origin) Usually lower Annex IX status: Cat 1 and Cat 2 (technical) Part B (b): listed; Cat 3 (food-chain origin) Not listed in Annex IX Typical outlets: Cat 1 and Cat 2 (technical) HVO, SAF, FAME, oleochemicals, energy; Cat 3 (food-chain origin) Petfood, feed, oleochemicals, FAME That Annex IX line is the one that moves money. Category 1 and category 2 animal fats are named in Annex IX Part B alongside used cooking oil. Category 3 is not in Annex IX at all. Two cargoes can look almost identical on the analysis sheet and be worth materially different amounts to a fuel producer, purely because of where the material came from and what the rendering plant is approved for. So the approval number of the establishment matters as much as the assay. A seller who cannot produce it is not necessarily doing anything wrong, but they are not yet sellable to a fuel buyer, and that is worth finding out in week one rather than after a vessel is fixed. ## What buyers screen on Titre deserves more attention than it usually gets in a first conversation. A high-titre tallow that solidifies in an unheated tank or a cold flexitank turns a straightforward delivery into an expensive salvage operation, and the cost lands on whoever did not raise it. ABP category: 1, 2 or 3, with the processing method and the approval number of the establishment. FFA (free fatty acid): Percentage. The main price driver within a category. Moisture, impurities and unsaponifiables (MIU): Combined and separately. Titre: Degrees C. Solidification behaviour; determines heated storage and handling. Colour: Lovibond or FAC, depending on the outlet. Iodine value: Unsaturation; drives cold-flow properties downstream. Sulphur and phosphorus: Critical for hydrotreatment into HVO or SAF. Peroxide value: Oxidation history and storage condition. Insoluble impurities: Filterable solids and protein carry-over. Species: Bovine, porcine, poultry or mixed. Decides feed eligibility and some market access. Certification: ISCC EU where the fat is heading into the biofuel chain. ## Where it goes Under EU renewable fuel rules, category 1 and 2 animal fats sit in Annex IX Part B alongside used cooking oil and share the 1.7 % transport-energy cap per member state. Category 3 is treated differently. This distinction moves real money, so it should be settled before a term contract is priced. * FAME producers: animal-fat methyl ester, with different cold-flow behaviour from UCOME because of the saturated fatty acid profile. * HVO and renewable diesel producers: hydrotreatment; more sensitive to sulphur, phosphorus and metals, and often paying for pretreated material. * Oleochemical producers: soaps, surfactants, lubricants, fatty acids and glycerine. * Feed and petfood: category 3 only, subject to species and processing rules. * Meat and bone meal (MBM): placed alongside the fat where a renderer wants both streams handled together. ## What an animal fat buyer checks before they bid We act for renderers with continuous production to place and for producers who need a specific category, a specific titre or a consistent sulphur figure, and those requirements narrow the market far more than most sellers expect. Rendering does not stop, which makes reliability of offtake worth more than a marginal price improvement on a single load. Most of what we do here is term rather than spot: matching continuous production to a buyer who can take it every week, with the category, analysis and heated-logistics reality agreed once rather than renegotiated every parcel. ## Sources * Document checklist: exactly which papers a European buyer asks for, per product: /markets/document-library * SPECIMEN safety data sheet: Animal fat and tallow (worked example, all 16 sections): /documents/sds-animal-fat * Regulation (EC) No 1069/2009, animal by-products: https://eur-lex.europa.eu/eli/reg/2009/1069/oj/eng * Regulation (EC) No 1069/2009 on animal by-products: https://eur-lex.europa.eu/eli/reg/2009/1069/oj * Directive (EU) 2018/2001 (RED II), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj * ISCC System, the certification scheme itself: https://www.iscc-system.org/ ## Frequently asked questions Q: What is the difference between category 1, 2 and 3 animal fat? A: The category is set by Regulation (EC) No 1069/2009 and reflects risk, not quality. Category 1 is the highest-risk material including specified risk material; category 2 includes fallen stock and material unfit for consumption; category 3 comes from animals fit for human consumption at slaughter. The category travels with the fat through the whole chain and decides where it may legally go. Getting it wrong is a regulatory error, not a commercial one. Q: Why is category 3 tallow often worth less into fuel than category 1? A: Because category 1 and 2 animal fats are named in Annex IX Part B alongside used cooking oil, and category 3 is not in Annex IX at all. Two cargoes can look nearly identical on the analysis and be worth materially different amounts to a fuel producer, purely because of origin. Category 3 has other outlets, including petfood and oleochemicals, which is why it is not simply the cheaper product. Q: What is titre and why does every buyer ask for it? A: Titre is the solidification temperature of the fatty acids, typically 38 to 44 C depending on species mix. It decides whether you need heated storage and heated lines. A high-titre tallow that solidifies in an unheated tank or a cold flexitank turns a routine delivery into an expensive salvage operation, and the cost lands on whoever did not raise it. Q: Is category 1 material banned from use? A: No, and this is a common misunderstanding. Category 1 is excluded from feed and from food, but it is not banned from energy or oleochemical use. It must be processed by an approved rendering plant and the establishment approval number travels with it. A seller who cannot produce that number is not doing anything wrong, but they are not yet sellable to a fuel buyer. Q: Can category 1 animal fat be used for biodiesel? A: Yes. Category 1 material is excluded from feed and food, but it is an established feedstock for biodiesel and renewable diesel, subject to the processing, traceability and channelling requirements of Regulation (EC) No 1069/2009. The widespread belief that category 1 fat cannot be traded at all is incorrect and costs renderers real money. Q: What is titre and why does it matter? A: Titre is the solidification temperature of the fatty acids, in degrees Celsius. It determines whether the fat can be handled in an unheated tank, a standard flexitank or a road tanker without heating, and in which season. A high-titre tallow that sets in transit turns a routine delivery into an expensive salvage job, so it belongs in the first conversation rather than the shipping instructions. Q: Do animal fats count towards the Annex IX Part B cap? A: Category 1 and 2 animal fats sit in Annex IX Part B alongside used cooking oil and share the 1.7 % transport-energy cap per member state, with the possibility of a member state requesting a higher limit. Category 3 is treated differently under the framework. The distinction has a direct effect on value, so settle it before pricing a term contract. Q: Do you broker meat and bone meal as well? A: Yes, and usually alongside the fat. A renderer generally wants both streams placed with as little friction as possible, and handling them together is more efficient than running two separate processes. Q: What certification is needed for animal fat into biofuel? A: ISCC EU is the usual route for material entering the EU biofuel chain, alongside the ABP documentation, category, processing method and the approval number of the establishment. Both are checked. A valid ISCC certificate does not substitute for correct ABP paperwork, and vice versa. ============================================================================== # POME, SBEO and SSAO brokerage URL: https://www.sustainablecommodities.eu/markets/pome We broker POME oil, SBEO and SSAO into European producers. These are three different products from three different places, and they get confused constantly: POME oil comes off palm oil mill effluent, SBEO is recovered from spent bleaching earth, and SSAO is soapstock acid oil from caustic refining. On what decides the value: national classification, more than the specification does. The same parcel can be treated differently in two member states, and that difference is often worth more than anything you can change at the mill. ## What POME oil, SBEO and SSAO actually are POME oil is the residual oil recovered from palm oil mill effluent, the waste water stream from crude palm oil extraction. It is not crude palm oil and not a refining side stream: it is oil recovered from a stream that would otherwise be treated as waste, which is precisely why it is attractive as a biofuel feedstock. It typically arrives with high free fatty acid content, significant moisture and solids, and needs pretreatment before use. SBEO, spent bleaching earth oil, is the oil recovered from spent bleaching earth. Bleaching clay is used during vegetable oil refining to strip colour pigments, oxidation products and trace contaminants, and the spent clay leaves the process holding a substantial share of its own weight in oil. Recovering that oil is what produces SBEO. Free fatty acid content is commonly in the region of 3 to 25 % with MIU around 3 %. SSAO, soapstock acid oil, is a different product and the two are frequently confused. It derives from the soapstock stream rather than from bleaching earth, carries a much higher free fatty acid content, commonly in the region of 50 to 70 %, and has a naturally low cloud point that makes it of interest for winter grade production. Quoting one when you mean the other is an easy way to lose a buyer's confidence. Both benefit from being residues rather than co-products. That distinction is the entire value proposition, and it is also the part most likely to be challenged. ## Where POME oil actually comes from Palm oil mill effluent is the wastewater a mill produces when it sterilises and presses fresh fruit bunches. A mill generates a great deal of it, and the residual oil carried in that stream is what the trade calls POME oil. It is recovered from the effluent ponds or by a separation step ahead of them, which is why quality varies so much between mills: recovery method and how long the material sat both leave a mark. Two things follow that catch people out. First, POME oil comes with high free fatty acid content and a heavy load of solids, water and dirt, because of where it has been. Second, and more importantly, it is genuinely a residue rather than something anyone sets out to make, which is exactly what an Annex IX claim rests on and exactly what an auditor will test. * Mill practice sets the ceiling. A mill with a proper oil recovery step produces a consistent stream. One scooping from ponds does not, and no amount of trading skill fixes that. * Storage time drives FFA upward. Hydrolysis continues in the tank. A figure measured at the mill three months ago describes a parcel that no longer exists. * Sludge, water and dirt are the real cost. You pay freight on all of it and the buyer pays to remove it, so the price per useful tonne can sit a long way from the headline price per tonne. ## Pretreated and refined POME, and what POME-FAD is Raw POME oil rarely goes straight into a hydrotreater. It is pretreated first, and understanding that sequence explains most of the products you will be offered under the POME name. * Degumming. Acid treatment, normally with phosphoric acid, conditions the phospholipids so they can be separated and at the same time precipitates metal contaminants. * Bleaching. Bleaching earth adsorbs the conditioned gums, residual soaps, colour bodies and remaining trace metals. Filtration then removes the spent earth along with everything it has picked up. That spent earth still holds oil, which is where SBEO comes from: see below. * Deacidification. Steam stripping in a packed column under vacuum takes the free fatty acids down to what the downstream process needs. Because POME oil starts high in FFA, this step carries a heavy load and a correspondingly large distillate stream. * That distillate is POME-FAD, the fatty acid distillate from POME pretreatment. It sits in the same specification family as PFAD and trades much like it. Anyone treating POME-FAD as a waste problem rather than a product is leaving money on the table. So when someone offers you *pretreated POME* or *refined POME*, ask which steps were actually done and what the resulting phosphorus, metals and FFA figures are. Those three words cover everything from a single settling step to a full degum, bleach and strip, and the price difference between them is the whole trade. The parameters that matter downstream are set out under HVO. ## SBEO: how oil is recovered from spent bleaching earth Bleaching earth leaves a refinery holding a significant amount of oil. Recovering it turns a disposal cost into a feedstock, which is the entire commercial logic of SBEO. * Solvent extraction is the normal route. The spent earth is agitated with a solvent, commonly n-hexane, at moderate temperature, typically in the region of 35 to 50 degrees Celsius, for a matter of tens of minutes. Solids and liquid are then separated and the solvent is recovered from the oil. * Solvent choice changes the product. More polar solvents extract more, but they also pull across more free fatty acid, so a higher yield can mean a lower grade. That trade-off is a real commercial decision at the plant, not a detail. * Other routes exist, including supercritical fluid extraction, membrane processes and subcritical water, which give better yields at lower temperature but at a capital cost most operators do not carry. * FFA in SBEO varies enormously, from low single figures on freshly processed earth to much higher on material that has sat. The earth itself keeps working on the oil, so age matters more here than for most feedstocks. Ask when the earth was generated, not just when the oil was extracted. ## SSAO and the soapstock splitting process SSAO is soapstock acid oil. It comes from the soapstock stream in vegetable oil refining, not from bleaching earth, and the two get confused constantly. Quoting one when you mean the other is a quick way to lose a buyer's confidence before you have started. Soapstock is what caustic refining produces when free fatty acids are neutralised: a heavy soapy phase separated from the oil. On its own it is difficult to move. Splitting it turns it into something tradeable. * Acidulation, also called soapstock splitting. A mineral acid, normally sulphuric, is added to bring the pH down to around 1.5, breaking the soaps back into free fatty acids and oil. Plants typically dose 10 to 15 percent above the theoretical requirement, calculated from the FFA content. * Heat and time. The mixture is heated with steam, commonly to about 85 to 88 degrees, and held for a couple of hours with mixing. * Separation. The aqueous phase is heavier, so the acid oil separates above it by gravity or with a centrifuge. * What comes out. A dark mixture of free fatty acids and glycerides, carrying traces of mineral acid, phospholipids and sterols. You will also hear it called acidulated soapstock, acid oil or olein depending on who is selling it. * Typical FFA runs high, commonly in the region of 50 to 70 percent for the material we see, and acid oils from some streams go higher still. The naturally low cloud point is what makes it interesting for winter grade production. Residual mineral acid and sulphur are the parameters that decide whether a parcel is welcome downstream, and they are the ones most often absent from an offer. A refined or further treated SSAO is a different and better product again, so be precise about which one you are selling. See esterified acid oils for what happens when that FFA is converted rather than removed. ## Classification: the part that decides the value POME and its derivatives appear in Annex IX of the Renewable Energy Directive, and the exact letter under which a given stream falls has been the subject of genuine and continuing debate. It matters enormously, because Part A and Part B carry different targets, different caps and different national treatment. Two practical warnings for anyone contracting POME into Europe. First, implementation is national. Member states transpose RED III themselves, and they have taken visibly different positions on multipliers, on caps and on which residues qualify. A cargo that works commercially in one market can be worth substantially less in the country next door. Second, national policy on POME has been actively changing, including restrictions being introduced in some markets on how POME-derived fuel can be counted towards obligations in coming years. Anyone signing a multi-year POME contract should verify the position in the specific destination market for the specific delivery years, in writing, rather than relying on how it worked last season. We will tell you what we understand the position to be and where we are not certain. On this product in particular, a broker who sounds completely confident about every member state is a broker to be careful with. ## Specification and handling Movement into Europe is normally by parcel tanker or ISO tank, with heated storage depending on the material. Pretreatment capacity at the receiving end is a real constraint, and it narrows the buyer list more than the specification does, a producer without pretreatment simply cannot take the cargo at any price. FFA (free fatty acid): Characteristically high; the primary quality parameter. Moisture and impurities (M&I): Drives pretreatment cost and settlement weight. Total fatty acid (TFA): The usable fraction, and often the pricing basis. Insoluble solids: Sludge and sediment carry-over from the effluent stream. Iodine value: Unsaturation; cold-flow behaviour downstream. Sulphur and phosphorus: Critical for hydrotreatment routes. Metals: Iron and others from the mill and from storage. Certification: ISCC EU with the correct scope, plus a valid proof of sustainability. Traceability: Mill of origin and the recovery route; audited in practice. ## What a POME buyer checks before they bid We act for mills, refiners and aggregators placing volume into Europe, and for European producers looking for certified supply they can actually run. Our first questions are about certification scope, traceability to the mill, and which destination market the cargo is aimed at, because if the classification does not work in that market, the specification does not matter. That order of questioning saves everyone a great deal of time. ## Sources * Directive (EU) 2018/2001 (RED II), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * Regulation (EU) 2023/1115 on deforestation free products (EUDR): https://eur-lex.europa.eu/eli/reg/2023/1115/oj * ISCC System, the certification scheme itself: https://www.iscc-system.org/ ## Frequently asked questions Q: What is POME-FAD? A: The fatty acid distillate that comes off when POME oil is deacidified during pretreatment. Because POME oil starts high in free fatty acid, the steam stripping step produces a substantial distillate stream, and that stream sits in the same specification family as PFAD and trades much like it. Treating it as a waste problem rather than a product is a common and expensive mistake. Q: What is the difference between SBEO and SSAO? A: Different streams entirely, and confusing them is a fast way to lose credibility. SBEO is spent bleaching earth oil, recovered by solvent extraction from the bleaching clay a refinery filters off after stripping colour and contaminants, with free fatty acid commonly around 3 to 25 per cent. SSAO is soapstock acid oil, produced by acidulating the soapstock that caustic refining generates, and it carries much higher free fatty acid. They price differently and they are pretreated differently, so name the one you actually have. Q: How is soapstock turned into acid oil? A: By acidulation, also called soapstock splitting. A mineral acid, normally sulphuric, is dosed to bring the pH to roughly 1.5, typically 10 to 15 percent above the theoretical requirement calculated from the FFA content. The mixture is heated with steam to around 85 to 88 degrees and held for a couple of hours with mixing. The aqueous phase is heavier, so the acid oil separates above it by gravity or centrifuge. What comes out is a dark mixture of free fatty acids and glycerides carrying traces of mineral acid, phospholipids and sterols. Q: What does pretreated or refined POME actually mean? A: Ask, because it covers everything from a single settling step to a full degum, bleach and steam strip, and the price difference between those is the whole trade. The useful question is not what it is called but what the phosphorus, metals and FFA figures are afterwards. Those three decide whether a hydrotreater will take it. Q: What is POME oil? A: POME oil is the residual oil recovered from palm oil mill effluent, the waste water stream from crude palm oil extraction. It is a residue rather than a primary product, which is what makes it valuable as a biofuel feedstock under EU renewable fuel rules. It typically has high free fatty acid content, significant moisture and solids, and requires pretreatment before use. Q: Is POME an Annex IX Part A or Part B feedstock? A: POME and its derivatives are listed in Annex IX, and the precise letter applying to a given stream has been the subject of continuing debate and revision. Because the consequences differ between Part A and Part B, and because implementation is national, the practical answer is to confirm the position for the specific stream in the specific destination member state before contracting. Q: Does POME-derived biofuel count towards EU targets everywhere? A: Not uniformly. Member states transpose the Renewable Energy Directive themselves and have taken different positions on multipliers, caps and residue eligibility, and some have been actively changing their treatment of POME. Verify the position for your destination market and for the specific delivery years, in writing. This is the single biggest commercial risk in a POME contract. Q: What is SBEO? A: Spent bleaching earth oil, the oil recovered from spent bleaching earth used in vegetable oil refining. Like POME it is a residue rather than a co-product, and like POME its value in the biofuel chain depends on its classification and on national implementation. Q: What certification does POME need? A: ISCC EU is the standard route into the EU biofuel chain, with the certificate scope covering the actual material and activity, and a valid proof of sustainability accompanying each delivery. Traceability back to the mill of origin is audited in practice, not just declared. Q: Can European producers actually run POME? A: Only those with adequate pretreatment capacity. High FFA, moisture and solids mean POME is not a drop-in feedstock, and the absence of pretreatment at the receiving end rules a buyer out regardless of price. This narrows the realistic buyer list considerably and is worth establishing before a cargo is offered widely. ============================================================================== # Spent bleaching earth oil (SBEO) brokerage URL: https://www.sustainablecommodities.eu/markets/spent-bleaching-earth-oil SBEO, spent bleaching earth oil, is the oil recovered from the clay used to bleach vegetable oils. Bleaching earth leaves a refinery holding a significant amount of oil, and recovering it turns a disposal cost into a feedstock. That is the entire commercial logic of the product. It is bought by the same European pretreatment and HVO producers that take POME oil and acid oils, it carries a specification with hard limits rather than a description, and under Annex IX it is a feedstock that requires assessment rather than an automatic listing. We broker it, and the first thing we ask a seller is not the FFA but the date the earth was generated. ## The specification a buyer actually works to SBEO is not sold on a description. It is sold against limits, with the test method named next to each one, and a buyer who does not get that table will assume the worst. The set below is the one we see in the market: nine parameters, each with its ISO, ASTM or UOP method. Moisture and volatile matter: Method ISO 662:2016; Units wt %; Limit Max 0.5 Insoluble impurities: Method ISO 663:2017; Units wt %; Limit Max 0.5 Unsaponifiable residue: Method ISO 3596:2000; Units wt %; Limit Max 1 Iodine value: Method ISO 3961:2018; Units g I2/100 g; Limit Max 70 Free fatty acid: Method ISO 660:2020; Units wt %; Limit Max 30 Total chlorides: Method UOP 779-08; Units wt ppm; Limit Max 20 Phosphorus (filtered): Method ASTM D5185; Units wt ppm; Limit Max 20 Sodium (filtered): Method ASTM D5185; Units wt ppm; Limit Max 25 Total metals: Method ASTM D5185; Units wt ppm; Limit Max 70 Two of those deserve a note. Total chlorides at max 20 ppm is tight, and it is a hydrotreatment limit rather than a quality preference: chlorides attack the catalyst and the metallurgy downstream, so a producer who says 20 means 20. Total metals at max 70 ppm is a sum, not a single element, and a cargo can pass on every individual metal and still fail the total. Ask your lab for the breakdown as well as the sum. For what each parameter physically means and how it is measured, our parameters explained page goes through them one by one, and test methods and analysis covers why the method reference belongs in the contract. ## Why the age of the earth decides the FFA This is the part that separates a seller who knows the product from one who is passing on a document. FFA in SBEO varies enormously, from low single figures on freshly processed earth to well beyond the max 30 wt % limit above on material that has been sitting. The reason is that the earth keeps working on the oil. Bleaching earth is an activated clay chosen precisely because it is chemically busy, and it does not stop being busy when the refinery is finished with it. Oil left in contact with it goes on hydrolysing, so the free fatty acid climbs while the material is in the pile. The practical consequence is that the date the earth was generated is a commercial fact, not a technical footnote. Two cargoes with the same extraction date can be a long way apart if one came off earth that was two weeks old and the other off earth that had been stockpiled for a season. Ask for both dates. A seller who only offers the extraction date is either not close to the plant or would rather you did not know. ## How the oil comes out of the earth, and why that changes the grade * Solvent extraction is the normal route. The spent earth is agitated with a solvent, commonly n-hexane, at moderate temperature, typically in the region of 35 to 50 degrees Celsius, for a matter of tens of minutes. Solids and liquid are separated and the solvent is recovered from the oil. * Solvent choice changes the product. More polar solvents extract more, but they also pull across more free fatty acid, so a higher yield can mean a lower grade. That is a real commercial decision at the plant, and it is worth asking about when the FFA comes back higher than you expected. * Other routes exist, including supercritical fluid extraction, membrane processes and subcritical water. They give better yields at lower temperature, at a capital cost most operators do not carry. * Residual solvent is a question a buyer will ask. It is not in the table above because it is usually handled as a separate declaration, but a producer taking the material into hydrotreatment will want to know the extraction route and what is left behind. ## Annex IX: SBEO requires assessment, and that is not the same as being listed Under the Annex IX framework, SBEO sits in the group that requires assessment rather than appearing as a straightforward listed feedstock. Our Annex IX feedstocks page sets out the full list and what each entry means. In practice this is where value is won and lost. A cargo whose classification has been settled with the certification body and the receiving member state is a different commercial proposition from one where that conversation has not happened, and the gap between them is not small. The classification travels with the material, so settle it before you offer, not after a buyer has shown interest. The certification side is ISCC EU with the correct scope. A supplier certified for used cooking oil does not automatically hold SBEO, and that is the gap that surfaces latest and hurts most. Our ISCC certificate scope page covers what to check on a certificate before you rely on it. ## SBEO, SSAO and POME oil are three different products They travel under names that get used loosely, and mixing them up in an offer is the fastest way to lose credibility with a buyer who knows the difference. * SBEO is recovered from the spent bleaching earth used in refining. * SSAO, soapstock acid oil, comes from splitting the soapstock produced when caustic refining neutralises free fatty acids. Different stream, different plant, different classification. * POME oil comes off palm oil mill effluent, at the mill rather than at the refinery. The full picture, including a diagram of where each stream arises in palm oil processing, is on our POME, SBEO and SSAO page. ## What we ask a seller before we take it to a buyer * The analysis, against the nine parameters above, with the methods named. * When the earth was generated, and separately when the oil was extracted. * The extraction route, and the solvent if solvent extraction was used. * Monthly volume behind it, not the volume of the first parcel. A buyer with pretreatment capacity is planning a slate, not a trial. * The certificate and its scope, and whether the Annex IX classification has been settled and with whom. * Where it loads and in what, since parcel size narrows the buyer list faster than the specification does. ## Sources * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * ISCC EU, the scheme used for Annex IX material: https://www.iscc-system.org/certification/iscc-certification-schemes/iscc-eu/ * ISO 660:2020, determination of acid value and acidity: https://www.iso.org/standard/75594.html * ISO 3961:2018, determination of iodine value: https://www.iso.org/standard/71868.html ## Frequently asked questions Q: What is SBEO? A: Spent bleaching earth oil: the oil recovered from the clay used to bleach vegetable oils. Bleaching earth leaves a refinery holding a significant amount of oil, and recovering it turns a disposal cost into a feedstock. Q: What is a normal FFA for SBEO? A: There is no single normal. A working specification puts the limit at max 30 wt % measured to ISO 660:2020, and material ranges from low single figures on freshly processed earth to well above that limit on earth that has been stockpiled. The age of the earth matters more here than for most feedstocks. Q: What is the difference between SBEO and SSAO? A: Different streams entirely. SBEO is recovered from spent bleaching earth. SSAO is soapstock acid oil, produced by splitting the soapstock from caustic refining. They have different classifications and different buyers, and confusing them in an offer costs you credibility immediately. Q: Is SBEO an Annex IX feedstock? A: It sits in the group that requires assessment rather than being a simple listed entry. That assessment, settled with the certification body and the receiving member state, is where a large part of the value sits. Q: What certification does SBEO need? A: ISCC EU with the correct scope for the material, plus a valid proof of sustainability. A certificate covering used cooking oil does not automatically cover SBEO. Q: Do you publish an SBEO price? A: No. We do not publish price assessments. What we can tell you is where a specific parcel is likely to clear, against its actual analysis, origin, volume and destination, because a number quoted without those is not a price. ============================================================================== # FAME biodiesel brokerage URL: https://www.sustainablecommodities.eu/markets/biodiesel-fame We broker FAME biodiesel between producers and blenders, traders and end users. On the standard: EN 14214 is the reference, and quoting EN 15940 instead tells a buyer immediately that you have the wrong product in mind. On what is actually traded, it is the ester plus the sustainability claim behind it: the same litres with and without a defensible chain of custody are two different products at two different prices. ## The specification that governs EN 14214 is the European standard for FAME as an automotive fuel. A few parameters do most of the work in a trading conversation, and the cold-flow properties are where most disputes actually start. Ester content: Minimum 96.5 % (m/m) under EN 14214. CFPP (cold filter plugging point): The grade marker. National annexes and seasonal requirements differ across Europe, this is the most common source of a rejected cargo. Cloud point / pour point: Storage and handling behaviour alongside CFPP. Oxidation stability: Induction period in hours; degrades in storage, so the date of the analysis matters as much as the number. Monoglycerides, di- and triglycerides: Filter blocking and cold performance; monoglycerides are watched especially closely in saturated-feedstock esters. Water content: Microbial growth and hydrolysis in storage. Acid value: Corrosivity and feedstock quality carry-over. Total contamination: Filterable solids. Sulphur: Low limits; also relevant to blend compliance. Iodine value: Unsaturation, tied to feedstock and to stability. Group I and II metals, phosphorus: Catalyst and after-treatment impact. Sterol glucosides: Not in the standard but a recognised cause of filter blocking; increasingly tested for. ## EN 14214 in full, with the test method for each line This is the specification a European FAME cargo is sold against. We publish it in full because the argument after a discharge is almost never about the headline number, it is about which method was used and whether both sides agreed on it beforehand. Ester content: Limit 96.5 % (m/m) min; Test method EN 14103 Density at 15 C: Limit 860 to 900 kg/m3; Test method EN ISO 3675, EN ISO 12185 Kinematic viscosity at 40 C: Limit 3.5 to 5.0 mm2/s; Test method EN ISO 3104 Flash point: Limit 101 C min; Test method EN ISO 2719 Sulphur: Limit 10.0 mg/kg max; Test method EN ISO 20846, EN ISO 20884 Carbon residue (10 % distillation residue): Limit 0.30 % (m/m) max; Test method EN ISO 10370 Cetane number: Limit 51.0 min; Test method EN ISO 5165 Sulphated ash: Limit 0.02 % (m/m) max; Test method ISO 3987 Water content: Limit 500 mg/kg max; Test method EN ISO 12937 Total contamination: Limit 24 mg/kg max; Test method EN 12662 Copper strip corrosion (3 h at 50 C): Limit Class 1; Test method EN ISO 2160 Oxidation stability at 110 C: Limit 8 hours min; Test method EN 14112, EN 15751 Acid value: Limit 0.50 mg KOH/g max; Test method EN 14104 Iodine value: Limit 120 g iodine/100 g max; Test method EN 14111, EN 16300 Linolenic acid methyl ester: Limit 12.0 % (m/m) max; Test method EN 14103 Polyunsaturated (>= 4 double bonds) methyl esters: Limit 1.00 % (m/m) max; Test method EN 15779 Methanol content: Limit 0.20 % (m/m) max; Test method EN 14110 Monoglyceride content: Limit 0.70 % (m/m) max; Test method EN 14105 Diglyceride content: Limit 0.20 % (m/m) max; Test method EN 14105 Triglyceride content: Limit 0.20 % (m/m) max; Test method EN 14105 Free glycerol: Limit 0.02 % (m/m) max; Test method EN 14105, EN 14106 Total glycerol: Limit 0.25 % (m/m) max; Test method EN 14105 Group I metals (Na + K): Limit 5.0 mg/kg max; Test method EN 14108, EN 14109, EN 14538 Group II metals (Ca + Mg): Limit 5.0 mg/kg max; Test method EN 14538 Phosphorus content: Limit 4.0 mg/kg max; Test method EN 14107, EN 16294 CFPP: Limit By national annex and season; Test method EN 116 The lines that actually fail in practice are few. Oxidation stability is the first, because it degrades in storage rather than at the plant, so a cargo that passed on loading can fail on discharge without anyone doing anything wrong. Cold flow is the second, and it is a calendar problem rather than a quality problem. Monoglycerides are the third, because they drive filter blocking at low temperature even when CFPP itself passes. If you are selling animal-fat or palm-derived FAME, look hard at cold flow and at the iodine value before you offer against a straight EN 14214 clause. The saturated profile that makes them stable makes them solid, and the two requirements pull in opposite directions. ## Feedstock decides more than chemistry Two cargoes can both meet EN 14214 and be worth materially different money, because the feedstock behind the ester determines what a blender can count against its obligation. * UCOME: from used cooking oil. Annex IX Part B feedstock, good cold-flow properties, and the most commonly traded waste-based grade. * TME: tallow methyl ester, from animal fat. High saturated content, so poorer cold-flow behaviour and normally blended or winterised; the ABP category behind it matters for eligibility. * RME: rapeseed methyl ester. The European crop-based benchmark, with the best cold-flow properties of the common grades and consequently the winter workhorse. * SME: soy methyl ester. Widely available, weaker cold-flow properties than RME. * PME: palm methyl ester. Poor cold-flow properties, restricted in several European markets, and subject to its own sustainability scrutiny. * Advanced FAME: from Annex IX Part A feedstocks, counting against the advanced sub-target and priced accordingly. Note that multipliers are now member state specific under RED III. Several markets, including the Netherlands and Germany, have moved away from double counting in their national implementation, so "double counting material" no longer means the same thing everywhere. Confirm the treatment in the destination market rather than assuming the historic position. ## Certification ISCC EU is the dominant scheme, with REDcert and others also recognised. What is traded is the ester plus the sustainability characteristics travelling with it on a proof of sustainability: the feedstock, the greenhouse-gas saving, the chain of custody. The recurring practical problems are mundane and expensive: a certificate whose scope does not cover the actual activity, a proof of sustainability with a greenhouse-gas figure that does not match what the buyer needs to claim, or a mass balance period that does not line up with the delivery. These are worth checking before the cargo moves, not at invoice stage. ## What a FAME buyer will ask you We work with producers placing output, blenders and distributors sourcing specific grades, and obligated parties who need a particular counting treatment rather than simply a particular product. Because we never take title, we have no position to defend and no incentive to push a summer-grade cargo into a winter market. Where a cargo lands outside specification, and CFPP and oxidation stability are the usual culprits, see off-spec and distressed cargoes, which is a genuine speciality of ours rather than an afterthought. ## Sources * Document checklist: exactly which papers a European buyer asks for, per product: /markets/document-library * SPECIMEN safety data sheet: FAME biodiesel (worked example, all 16 sections): /documents/sds-fame-biodiesel * EN 14214 biodiesel standard, full parameter table: https://dieselnet.com/tech/fuel_biodiesel_std.php * Directive (EU) 2018/2001 (RED II), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * ISCC System, the certification scheme itself: https://www.iscc-system.org/ ## Frequently asked questions Q: What is the minimum ester content under EN 14214? A: 96.5 % (m/m). It is one of the defining parameters of the standard. Always contract against the current version of EN 14214 and the applicable national annex, because seasonal and country-specific requirements sit on top of the base standard. Q: What is the difference between UCOME, RME and TME? A: The feedstock. UCOME is made from used cooking oil, RME from rapeseed oil and TME from tallow. They behave differently in cold weather, RME has the best cold-flow properties of the three and TME the worst, because of its high saturated fatty acid content, and they are counted differently against renewable fuel obligations, which is often the larger part of the price difference. Q: Why does CFPP cause so many rejected cargoes? A: Because the requirement is seasonal and national, and it moves. A cargo that is perfectly in-grade for one country in October can be out of grade in another the same week. Agree the exact CFPP requirement, the applicable national annex and the delivery window in writing, and treat a marginal figure on the certificate of analysis as a warning rather than a pass. Q: Does double counting still apply to FAME in the EU? A: It depends on the member state. Under RED III, national implementations diverge, and several markets, including the Netherlands and Germany, have moved away from multipliers. So a grade described as "double counting" needs to be checked against the destination market's current scheme rather than against how the market worked historically. Q: What certification do you need to trade FAME in Europe? A: ISCC EU is the most widely used voluntary scheme, with REDcert and others also recognised. Each delivery travels with a proof of sustainability carrying the feedstock, the greenhouse-gas saving and the chain of custody. Check that the certificate scope covers the actual activity and that the mass balance period lines up with the delivery. Q: Can you place off-spec FAME? A: Yes, and it is something we are asked for regularly. Off-spec biodiesel usually has a home, reblending, winterisation, downgrading to an industrial or heating outlet, but the options narrow every day the cargo sits. Speed matters more than price discovery once demurrage and storage are running. Q: What parcel sizes do you work with? A: From road tanker and ISO tank lots up to full barge and coaster parcels. The practical minimum is usually set by freight economics into the specific destination rather than by any rule of ours. ============================================================================== # HVO, SAF and bionaphtha brokerage URL: https://www.sustainablecommodities.eu/markets/hvo-saf-bionaphtha We broker HVO renewable diesel, sustainable aviation fuel and bionaphtha between producers, oil majors, distributors, aviation fuel suppliers and petrochemical buyers. These are hydrotreated products, so the conversation is different from FAME: they are chemically drop-in, which means the specification is rarely the obstacle and the feedstock traceability, the certification chain and the mandate treatment are. ## The three products * HVO / renewable diesel: hydrotreated vegetable oil, fats and waste oils. Specified under EN 15940 for paraffinic diesel. Chemically a hydrocarbon rather than an ester, so it has none of FAME's cold-flow, oxidation-stability or storage-life limitations, and HVO100 can be used neat in approved applications. * SAF, sustainable aviation fuel: most commonly via the HEFA route from fats and oils, certified under ASTM D7566 and, once blended and released to specification, handled as jet fuel. Blending limits apply by pathway. * Bionaphtha: the lighter co-product of the same hydrotreating process. It goes to steam crackers as a renewable feedstock for the petrochemical chain, or into gasoline blending, and its value depends heavily on whether the buyer can make a certified renewable claim on the polymer downstream. ## One plant, three cuts, three different markets A hydrotreater does not choose between HVO, SAF and bio-naphtha the way a factory chooses a product. It cracks and separates a barrel, and the operator shifts the yield within limits towards whichever cut pays best that month. Understanding that explains most of what looks like erratic availability. Carbon range: HVO Roughly C15 to C18; SAF Roughly C9 to C15; Bio-naphtha Roughly C5 to C9 Standard: HVO EN 15940; SAF ASTM D7566, then D1655; Bio-naphtha No fuel standard; sold on assay Typical buyer: HVO Distributors, terminals, fleets; SAF Fuel suppliers at airports; Bio-naphtha Steam crackers, gasoline blenders What they pay for: HVO Energy plus the certificate; SAF The mandate, which is a legal obligation; Bio-naphtha A renewable claim in plastic, or octane Demand driver: HVO RED III targets per member state; SAF ReFuelEU: 2 % now, 6 % by 2030, 70 % by 2050; Bio-naphtha PPWR and voluntary polymer commitments Blend limit: HVO Drop-in, usable neat; SAF 50 % under most D7566 annexes; Bio-naphtha Not applicable The practical consequence for a feedstock seller. You are not selling into three markets, you are selling into one plant that serves three. When SAF pricing runs, the operator swings towards kerosene and the diesel cut tightens; when it does not, the reverse. Asking a producer which cut they are maximising this quarter tells you more about your own price than any published number. And for a buyer: if you need one specific cut reliably, say so before you contract. A producer who can swing yield will, and a supply agreement that assumes a fixed split is a disagreement waiting for a bad month. ## Why demand is contracted rather than opportunistic The demand side of this market is written into regulation, which changes how it trades. ReFuelEU Aviation obliges fuel suppliers at EU airports to supply an increasing share of SAF, 2 % from 2025, rising to 6 % from 2030 and further thereafter, with a sub-obligation for synthetic fuels. Road transport obligations under RED III as transposed nationally do the equivalent job for HVO. The practical effect is that volume tends to be contracted forward by parties who must cover a legal obligation, rather than bought opportunistically on price. Spot availability is thinner than the headline production numbers suggest, and a seller who can offer certified volume in a specific delivery window has more than one offering a marginally better number. ## What actually gets checked The mistake we see most often is a seller offering "HVO" or "SAF" without being able to state the feedstock and the scheme in the first message. In this market that is not a detail to be filled in later, it is the product description, and its absence reads as inexperience to every serious buyer. Specification: EN 15940 for paraffinic diesel; ASTM D7566 with the relevant annex for SAF; jet specification once blended and released. Feedstock: Which oils and fats, and their Annex IX status. This drives eligibility and price more than any physical property. Certification scheme: ISCC EU, ISCC CORSIA, REDcert or RSB, with the correct scope for the product and the claim. Greenhouse gas saving: The actual figure on the proof of sustainability, not a default value, where the buyer's claim depends on it. Chain of custody: Mass balance and the accounting period, aligned to the delivery. Mandate treatment: How the volume counts in the specific destination member state, national, not EU-wide. Delivery basis: In-tank, ex-works, barge, truck, pipeline or book-and-claim where the scheme permits it. Blend ratio and release: For SAF, the blending limit for the pathway and who performs the release to jet specification. ## What an HVO or SAF buyer will ask you We work with producers placing volume, distributors and majors covering obligations, and petrochemical buyers looking for renewable cracker feed. Because we are independent and never take title, we can tell a buyer plainly when an offer will not stand up to their own compliance team, which, in a market where the certificate is most of the value, saves considerably more money than shaving the price. Where the feedstock behind the fuel is the starting point, see used cooking oil, animal fats and POME. ## Sources * Directive (EU) 2018/2001 (RED II), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * ISCC System, the certification scheme itself: https://www.iscc-system.org/ ## Frequently asked questions Q: What is the difference between HVO, SAF and bio-naphtha? A: They are three cuts from the same process. Hydrotreating fats and oils produces a range of paraffinic hydrocarbons, which are then separated: the diesel-range cut is HVO under EN 15940, the kerosene-range cut is SAF under ASTM D7566, and the light cut is bio-naphtha. A plant can shift the yield between them within limits, so which one you are offered often reflects the operator's economics rather than a fixed output. Q: Which of the three is worth the most? A: It moves, and it depends on the mandate rather than on the molecule. SAF usually carries the strongest premium because ReFuelEU obliges it and the alternatives are scarce. Bio-naphtha into a petrochemical cracker can beat gasoline blending because the buyer is purchasing a renewable claim rather than energy. HVO is the volume product. We would rather test all three routes for a parcel than assume. Q: Do these fuels need engine modifications? A: HVO does not: it is a drop-in paraffinic diesel and HVO100 runs neat in approved engines. SAF is blended up to 50 % and then certified as ordinary Jet A-1, so the aircraft never sees anything unusual. Bio-naphtha is not a finished fuel at all; it is a feedstock for cracking or a gasoline blend component. Q: Can one plant make all three at once? A: Yes, and most modern hydrotreaters do. That is why a producer's offer sheet often lists all three, and why a shortage in one cut can appear when the operator swings yield towards another. If you depend on a single cut, it is worth understanding what the plant does with the rest of the barrel. Q: What is the difference between HVO and FAME biodiesel? A: HVO is made by hydrotreating fats and oils and is a hydrocarbon; FAME is made by transesterification and is an ester. HVO is a drop-in fuel with excellent cold-flow properties and long storage stability, specified under EN 15940, and HVO100 can be used neat in approved applications. FAME is specified under EN 14214, is normally blended, and has cold-flow, oxidation-stability and storage-life limitations that HVO does not. Q: What is HEFA-SPK? A: HEFA, hydroprocessed esters and fatty acids, is the most commercially mature route to sustainable aviation fuel, using the same fats-and-oils feedstocks as HVO. It is certified under ASTM D7566, with a blending limit applying to the pathway. Once blended and released to specification, the fuel is handled as conventional jet fuel. Q: What does ReFuelEU Aviation require? A: It obliges aviation fuel suppliers at EU airports to supply a minimum share of SAF: 2 % from 2025, rising to 6 % from 2030 and increasing further thereafter, with a separate sub-obligation for synthetic aviation fuels. It is the main reason SAF tends to be contracted forward rather than bought on the spot market. Q: What is bionaphtha used for? A: It is the lighter co-product of hydrotreating, and it goes either to steam crackers as renewable feedstock for the petrochemical chain, or into gasoline blending. The cracker route generally pays better, because it lets the polymer producer downstream make a certified renewable claim, which means the certification chain, not the hydrocarbon, is what is really being bought. Q: Do you broker book-and-claim SAF? A: Where the applicable scheme and the buyer's own claim permit it, yes. Book-and-claim arrangements are scheme-specific and the rules differ between ISCC CORSIA, RSB and national systems, so the first question is always what the buyer actually needs to be able to claim, and to whom. Q: Is HVO available on the spot market? A: Less than the headline production figures suggest. A large share of European volume is contracted forward by parties covering a legal obligation, so genuine spot availability is thinner and more seasonal than it appears. Sellers with certified volume in a defined delivery window are in a stronger position than the raw supply numbers imply. ============================================================================== # Off-spec and distressed cargo brokerage URL: https://www.sustainablecommodities.eu/markets/off-spec-and-distressed-cargoes Off-spec is a speciality here, not an afterthought. On what usually happens: a parcel misses one number, the buyer walks, and the seller calls everyone at once, which tells the market the cargo is in trouble and takes the price down further. On what works: establish exactly which parameter failed and by how much, find out whether it can be blended, treated or sold to a buyer with a different limit, and approach a short list quietly. ## Why speed beats price discovery A distressed cargo has a cost of carry that most sellers underestimate in the first 48 hours. Demurrage on a parcel tanker, storage and heating at a terminal, quarantined tank capacity the terminal wants back, a container accruing detention, these run continuously while an owner shops the parcel around looking for a better number. In practice the difference between the best and second-best offer on an off-spec parcel is usually far smaller than the cost of taking an extra ten days to find it. We have seen owners lose more to demurrage than the entire spread they were negotiating over. The right instinct is to run a short, controlled process with buyers who are genuinely capable of taking the material, and to close. There is also a duty to mitigate. Where insurance or a contractual claim is in play, the cargo owner is generally expected to act reasonably to limit the loss, and a long unexplained delay in disposing of a deteriorating parcel is difficult to defend later. ## What we place * Off-spec FAME and biodiesel: CFPP outside the seasonal grade, oxidation stability failed, monoglycerides high, water or total contamination out, ester content below 96.5 %. * Off-spec vegetable and technical oils: FFA, moisture, colour, peroxide value or trace contamination outside contract. * Off-spec fats and tallow: MIU, titre or category documentation problems. * Commingled and cross-contaminated parcels: previous-cargo contamination, a wrong-tank transfer, or two grades mixed in a shore tank. * Heat-damaged and water-ingress cargo: including parcels affected in transit or in storage. * Recycled polymer loads that failed inbound inspection: moisture, contamination or polymer mix outside the agreed bale spec. * Pyrolysis oil outside acceptance limits: most often chlorine, silicon or water; see pyrolysis oil. * Slops, tank bottoms, wash water and interface material: where there is a legitimate recovery or energy outlet. ## How the routes usually work out Most distressed parcels have more than one possible home, and the right one depends on how far out of specification the material is and on what it would cost to correct. * Reblending or correction: the best outcome where it is feasible. Blending down into a larger compliant stream, winterising a cold-flow failure, drying a wet parcel, or filtering solids. * Reprocessing: back through a refiner, a re-refiner or a pretreatment unit that can bring the material back on-spec. * Downgrade to a lower-value outlet: industrial or heating fuel, oleochemical use, anaerobic digestion or, for some polymer loads, energy recovery. Lower value, but immediate and certain. * Salvage sale as-is: where the material has a buyer who can run it without correction and simply prices for the risk. * Disposal: the last resort, and the one worth the most effort to avoid, because it converts a discounted asset into a pure cost. ## What to send us, and what to protect Two things determine how fast a distressed parcel moves: the quality of the information, and whether the evidence has been preserved. Get both right in the first hours and the options stay open. Full analysis: The failing certificate of analysis and, where available, the load-port analysis for comparison. Retained samples: Sealed, properly labelled, held by both sides. The single most valuable thing in any later dispute, do not let them be discarded. Independent survey report: From a recognised inspection company, instructed early rather than after positions have hardened. Location and form: Vessel, shore tank, container, road tanker; and whether it can be moved at all in its current state. Quantity: Actual, with the measurement basis stated. Cost of carry: Demurrage rate, storage, heating and detention, the number that should be driving the decision. Certification status: Whether any proof of sustainability travels with the parcel and whether it survives the downgrade. Deadlines: Free time, laycan, terminal notice to vacate, any insurance notification period. ## Where we stop We are a broker. We place the cargo and we bring the buyers. We are not an insurance intermediary, a surveyor, an average adjuster or a law firm, we give no insurance or legal advice, and we do not act on the claim itself. In practice we work alongside those people rather than instead of them: the cargo owner's insurer, appointed surveyor, adjuster and lawyers handle the claim, and we handle the commercial disposal of the material, which is usually the part nobody else in that group is equipped to do quickly. See cargo claims and compromised parcels for how those two tracks fit together. ## Sources * Directive 2008/98/EC, the Waste Framework Directive: https://eur-lex.europa.eu/eli/dir/2008/98/oj * EU Customs Tariff (TARIC), for checking commodity codes: https://taxation-customs.ec.europa.eu/customs-4/calculation-customs-duties/customs-tariff/eu-customs-tariff-taric_en ## Frequently asked questions Q: How quickly can you place an off-spec cargo? A: With a full analysis and a clear location, we can normally be in front of credible buyers the same working day and have firm interest within one to three days, depending on the product and how far out of specification it is. The binding constraint is almost always how quickly the seller can decide, not how quickly the market can respond. Q: What happens to off-spec biodiesel? A: Usually one of three things: it is blended down into a larger compliant stream, it is corrected, winterised for a cold-flow failure, dried, filtered, or it is downgraded to an industrial or heating fuel outlet. Which is realistic depends on how far out it is and on which parameter failed. A marginal CFPP is very different from a failed ester content. Q: Do you buy distressed cargo yourselves? A: No. We are a broker and never take title. That matters more here than anywhere else: a party offering to buy your distressed parcel has every incentive to talk the value down, and we do not have that conflict. We are paid a commission on the concluded sale. Q: Should I keep the retained samples? A: Yes, without exception, and make sure they are sealed and properly labelled. Retained samples from load and discharge are the single most valuable piece of evidence in any quality dispute, and they are frequently discarded during the confusion of a rejection. Preserve them before anything else. Q: Can you help with the insurance claim? A: No, and we are careful about that line. We are not an insurance intermediary and we give no insurance advice. Your insurer, the appointed surveyor and, where relevant, the average adjuster handle the claim. What we do is the commercial side, placing the material with a buyer who can run it, quickly, which is usually the part of the process nobody else is set up to handle. Q: What if the cargo has lost its sustainability certification? A: That is common and needs to be established early, because it changes the buyer list entirely. Material that can no longer carry a valid proof of sustainability cannot go to a buyer whose economics depend on counting it, so it routes to industrial, oleochemical or energy outlets instead. Knowing this on day one avoids wasting days approaching buyers who were never able to take it. Q: Do you handle small quantities? A: Yes. A single road tanker or a handful of IBCs of off-spec material is a real problem for whoever is holding it, and it is often easier to place than a full parcel because more buyers can absorb it without disrupting their own operation. ============================================================================== # Compromised cargo: the commercial side of a claim URL: https://www.sustainablecommodities.eu/markets/cargo-claims A cargo claim is a commercial problem before it is a legal one. On what usually happens: discharge analysis disagrees with load, both sides dig in, and the parcel sits accruing demurrage while lawyers are appointed. On what actually settles it: the sealed samples taken jointly at load, the test method named in the contract, and an umpire laboratory agreed while everyone was still friendly. Send us the two analyses and the contract and you will get an honest read on where you stand. ## Two tracks, running at once When a cargo goes wrong, two processes start in parallel and they have different clocks. Confusing them is what costs owners money. The claim track is about establishing what happened, who is liable and what is recoverable. It is deliberate, evidence-driven and slow, and it belongs to the insurer, the appointed surveyor, the average adjuster and, where necessary, lawyers. It can run for months. The cargo track is about the physical material, which is sitting somewhere costing money every day and, in many cases, deteriorating. It needs to be resolved in days. The mistake we see most often is an owner allowing the cargo track to wait for the claim track. The claim does not move faster because the parcel is still in tank, but the loss grows every day it sits there. Preserving the evidence properly and disposing of the material promptly are compatible, and doing both is usually what a duty to mitigate looks like in practice. ## The four reasons a buyer stops paying, and what each one needs The stated reason is usually quality. The real reason is one of four, and telling them apart in the first week decides how the whole thing goes. The market moved against them: How you can tell The complaint arrives late, is vague, and grows when you push back; What it needs Hold the deadline. A protective arbitrator appointment alongside the conversation is normal practice, not an escalation Two honest analyses disagree: How you can tell Both sides have a certificate and the numbers are close; What it needs Find the umpire laboratory named in the contract. If none is named, agree one jointly before either side commissions more testing A document is wrong: How you can tell The objection is about paperwork, not the product; What it needs Usually the cheapest to fix and the fastest. Check the entity names first: certificate, invoice, bill of lading They cannot pay: How you can tell Silence, then a technical objection with no analysis behind it; What it needs Stop negotiating. This is a credit problem wearing a quality costume, and it is a lawyer's job, quickly The clock does not stop while you talk. Under FOSFA terms an arbitrator must be appointed within 90 days of completion of discharge for quality and condition claims, and within 120 days from the end of the delivery period for monetary claims. Those are general indications of how that regime commonly works; editions differ and your contract may say something else. Diary your own deadline on day one. We are brokers, not lawyers, and nothing here is legal advice. What we can do is tell you what the material is genuinely worth in its current condition and find the buyer who will take it that way. See trade dispute mediation. ## What we do, and what we do not The boundary matters, so it is worth stating plainly rather than in small print. We do: find buyers: Approach counterparties who can physically run the material in its actual condition, not in theory. We do: run a controlled process: A short, disciplined market approach rather than an open circulation that signals distress and kills the price. We do: advise on realistic outlets: Whether reblending, reprocessing, downgrade or as-is sale is the sensible route, based on what the market will actually take. We do: work alongside your advisers: Provide the commercial evidence, offers received, market context, that a surveyor or adjuster may need to see. We do: move fast: Same-day approach where the information pack is complete. We do NOT: give insurance advice: We are not an insurance intermediary and we are not authorised to advise on, arrange or mediate insurance. Speak to your broker or insurer. We do NOT: act as surveyor or adjuster: Condition, cause and quantum are for the appointed independent professionals. We do NOT: give legal advice: Liability, contract and recovery questions belong with your lawyers. We do NOT: take title: We are a broker throughout, paid a commission on the concluded sale, with no position in the cargo. ## Protect the evidence first Whatever happens commercially, the evidence has to survive, and in the confusion of a rejection it very often does not. This is the short list that matters, and it costs nothing to get right on day one. * Preserve the retained samples. Sealed, labelled, from both load and discharge, held by both sides. They are the most valuable evidence in any quality dispute and are routinely thrown away by mistake. * Get an independent surveyor instructed early, before positions harden. A survey commissioned after two weeks of argument carries much less weight. * Notify on time. Insurance policies and carriage contracts carry notification periods and time bars. Missing one is an avoidable, self-inflicted loss, check them immediately, with your own advisers. * Document the condition with dated photographs, tank temperatures, ullage reports and the terminal's own records. * Keep a running cost log: demurrage, storage, heating, detention. It supports the claim and, just as importantly, it tells you how much delay you can actually afford. * Do not blend or move the parcel before the evidence is secured. It can destroy both the claim and the ability to establish what happened. ## Where the material usually ends up The realistic outcomes are the same as for any distressed parcel: correction, reprocessing, downgrade to a lower-value outlet, sale as-is to a buyer who prices for the risk, or, last and worst, disposal. Which of these is available depends on the product, the failure and, quite often, on whether any sustainability certification survives the incident. That certification question is worth raising on day one. A parcel that can no longer carry a valid proof of sustainability is invisible to every buyer whose economics depend on counting it, so the buyer list changes completely, and approaching the wrong buyers for a week is pure lost time. The mechanics of each route are set out under off-spec and distressed cargoes. ## Frequently asked questions Q: How long do I have to bring a quality claim? A: It depends on the contract, and the deadlines are shorter than most people expect. Under FOSFA terms an arbitrator must be appointed within 90 days of completion of discharge for quality and condition claims, and within 120 days from the end of the delivery period for monetary claims. Negotiating does not stop that clock. Read your own contract and take professional advice on it; this is a general indication, not advice on your case. Q: The buyer says the cargo is off-spec. What do I do first? A: Establish which analysis governs and where it was taken, because loading and discharge figures diverge for legitimate reasons: moisture migrates, oxidation continues, and sampling methods differ. Then check whether the contract names an umpire laboratory. Do that before you argue about the number, because otherwise you are two parties quoting different tests at each other. Q: Can you help if we did not broker the cargo? A: Yes. We are called in by sellers and by buyers on trades we had nothing to do with, precisely because we have no position in the outcome. What we bring is knowing what off-spec material is genuinely worth and who will take it in that condition. See trade dispute mediation. Q: When should I stop negotiating and get a lawyer? A: Insolvency, suspected fraud, or an amount large enough that legal costs are worth it. Also when a contractual deadline is close: a protective appointment alongside the conversation is normal practice, not an escalation. We will tell you plainly when a case has passed the point where a broker is useful. Q: Are you an insurance broker? A: No. We are a commodity broker. We are not an insurance intermediary, we are not authorised to advise on, arrange or mediate insurance, and nothing on this site is insurance advice. Insurance questions belong with your own insurance broker or insurer. Q: So what exactly do you do when a cargo is damaged? A: The commercial disposal. We find buyers who can physically run the material in its actual condition, run a short controlled sale process rather than an open circulation that advertises distress, and get the parcel moved before storage and demurrage erode what is left. Your insurer, surveyor and adjuster handle the claim in parallel. Q: Should I wait for the insurer before selling the cargo? A: That is a question for your own insurer and advisers, and you should ask them immediately rather than assume. What we can say from experience is that the claim does not resolve faster because the parcel is still sitting in tank, while the loss grows every day it does. In most policies there is also a duty to take reasonable steps to mitigate. Preserving evidence and disposing of the material promptly are usually compatible, but confirm the position with your insurer first. Q: What is the most common mistake owners make? A: Losing the retained samples. They get discarded, unsealed or poorly labelled during the confusion of a rejection, and with them goes the best evidence of what the cargo was at load and at discharge. The second most common is running the commercial process too slowly and paying more in demurrage than the price difference being negotiated over. Q: Can you provide evidence for the claim? A: We can provide the commercial record of what we did, which buyers were approached, what offers came back, what the market context was, and that is often useful to a surveyor or adjuster assessing whether the loss was reasonably mitigated. We do not provide expert opinion on condition, cause or quantum; those are for the appointed independent professionals. Q: Does a general average declaration change how you work? A: It changes who bears the cost and adds the average adjuster to the group, but it does not change our role. The material still has to find a home, and that remains the commercial exercise. Contributions, security and adjustment are handled by your adjuster and insurers, not by us. ============================================================================== # Plastic pyrolysis oil (PPO / WPPO) brokerage URL: https://www.sustainablecommodities.eu/markets/plastic-pyrolysis-oil We broker plastic pyrolysis oil (PPO) into crackers, refiners and purifiers. On what decides it: chlorine, first and last. A cracker works to single-digit ppm and untreated oil from mixed plastic waste often arrives at hundreds or thousands. Everything between those two numbers is the deal. Silicon is the one people forget, and it is usually missing from the analysis rather than out of range. On fractions, our buyers take light and middle. If you cannot reach cracker grade, that is not the end of it: there is a purification step in between, and it is a different buyer with a different specification. ## Chlorine: the number the whole trade turns on PVC and chlorinated additives in the input plastic carry straight through pyrolysis into the oil. Untreated oil from mixed post-consumer feed routinely tests in the hundreds or low thousands of ppm. Steam crackers generally work to single-digit ppm on total chlorine, and some tighter still, because chloride causes corrosion in the furnace and downstream train and poisons catalyst in any hydrotreating step. Confirm the individual buyer's limit rather than trusting a market rule of thumb, they differ, and a plant will not bend the number for a trial cargo. There are four ways the gap gets closed, and they have very different costs: * Input sorting: keeping PVC out of the feed upstream. Cheapest and most durable, and the reason post-industrial feed prices above post-consumer. * In-process capture: chlorine scavengers or a dechlorination stage in the reactor train. * Post-treatment: adsorption, washing or a dedicated dechlorination unit on the produced oil. * Blending down: mixing into a much larger compliant stream. Works only where the receiving party has the volume and is willing, and it is the first thing a buyer withdraws when the market softens. ## The three fractions, and which two our buyers take Oil leaving the reactor is full range. Distillation splits it into three cuts with genuinely different homes and genuinely different prices, and a plant that can fractionate is in a stronger commercial position than one that cannot. Cut points vary by operator, so treat the temperatures below as the usual convention rather than a standard. * Light fraction, naphtha range, roughly C5 to C12, initial boiling point to around 180 C. This is the cut a steam cracker actually wants: most naphtha-like, lowest boiling, and where the circular polymer value sits. * Middle fraction, gasoil and diesel range, roughly C12 to C20, around 180 to 360 C. Routes to hydrotreating, to diesel blending, or to a cracker depending on how chlorine, sulphur and nitrogen come back. * Heavy fraction and residue, above roughly 360 C. Waxy and high boiling. Frequently recycled back into the reactor, otherwise placed as industrial fuel or as carbon black feedstock. ## The rest of the specification Chlorine gets the cargo considered. These decide whether it is accepted, and silicon in particular kills more deals than sellers expect because it is permanent, it does not wash out and it does not blend away. Total chlorine: Organic and inorganic reported separately where possible. The gate. Silicon: From siloxanes and antifoam. Permanent hydrotreating catalyst poison; screened even when not on the spec sheet. Nitrogen: Tracks polyamide, ABS and polyurethane in the input. Sulphur: Low from clean polyolefin feed; rises sharply with PET, PVC or rubber contamination. Bromine: Flame retardants, where WEEE plastics entered the mix. Metals (Na, Ca, Fe, Zn, Pb, K): Fouling and catalyst deactivation; zinc and lead point at tyre or e-waste input. Water (Karl Fischer): Phase separation, freight cost, corrosion. Distillation profile: Which cracker or refinery cut the oil competes against; naphtha-range material is the target. Diene value / MAV: Gum and fouling tendency in storage and preheat. TAN: Corrosivity in storage and transfer. Olefin content: Reactivity and stability during storage. Filterable solids / ash: Char carry-over from the reactor. ## ISCC PLUS mass balance is the product The commercial reason a cracker pays above fuel value for PPO is that it lets a polymer producer downstream sell a certified circular grade to a brand owner who has a recycled-content commitment. That claim travels on ISCC PLUS with mass balance chain of custody. Without it, the same molecules are a hydrocarbon and price like one. Three things go wrong often enough to be worth checking in week one: the pyrolysis unit sits outside the certified boundary; the certificate covers the wrong product group; or the mass balance accounting period does not line up with the delivery schedule. Any of the three collapses the premium at exactly the wrong moment. Downstream demand is underpinned by the recycled-content targets in the Packaging and Packaging Waste Regulation (EU) 2025/40, which applies from 12 August 2026 and sets binding minimum recycled content from 1 January 2030. Chemical recycling is one of the routes brand owners are counting on to get there, see waste PET for the parallel mechanical route. ## How a cracker qualification actually runs Nobody buys a bulk parcel of PPO on a certificate of analysis. The path is predictable and it is worth knowing before you start, because sellers who expect a purchase order in week two lose patience and lose the buyer. * Paper screening: full COA, the certificate and its scope, feedstock description, plant capacity and a realistic monthly volume. * Laboratory sample: typically a few litres to an IBC, into the buyer's own laboratory. They will re-test everything and they will find things your lab did not report. * Consistency check: three or more batches over time. This is where most plants fail: one flattering COA is worthless if batch two looks different. * Trial parcel: an isotank or small bulk lot, co-processed at low ratio. * Term discussion: only now, and only if the numbers held. * Expect months, not weeks. A plant that can show a stable rolling analysis across batches compresses this more than any commercial argument. Since 2025 there is finally a standard written for this material: ASTM D8577, Standard Guide for Waste Plastic Process Oil Analyses, covering composition, physical properties and contaminants. Before it existed the market borrowed crude oil and biomass methods that were never designed for plastic derived oil. Quoting D8577 tells a buyer you have done the work. Do not quote ASTM D7544 here: that is a biomass pyrolysis liquid specification for industrial burners, and it gets misapplied to PPO constantly. More on test methods. ## Waste status, classification and what we do Whether PPO moves as a waste or a product decides the paperwork, and it is decided nationally, see pyrolysis oil for the Waste Shipment Regulation and CN classification detail, which applies identically here. Settle it before fixing freight. We act for plant operators placing production and for crackers, refiners and traders sourcing feed. Because we never take title, we will tell a plant plainly when its chlorine number rules out the cracker route for now and the realistic outlet is a fuel or blending buyer, which is a far better conversation to have in month one than in month six. ## Oxygenates: the number nobody expects and everybody argues about A buyer looks at your analysis, sees the oxygen content higher than they wanted, and asks why. Producers often have no answer ready, which reads as evasion when it is usually just chemistry nobody explained. There are three normal causes and all three are addressable. * The plastic itself came with additives. LDPE and HDPE carry stabilisers, antioxidants and processing aids from their original manufacture. Those break down during pyrolysis and form oxygenated compounds. Your feed was never pure polyolefin, so your oil was never going to be pure hydrocarbon. * Light fractions collected into the tank blend. The light end is where the oxygenated molecules concentrate. If light ends are being swept into the main blend rather than separated, the oxygen figure rises without anything being wrong with the process. * Air ingress during condensation or handling. Even minor leakage promotes formation of light oxygenates. Inerting the condensation train, not just the storage tank, is the fix. The remedies follow directly: tighter control of light end collection, and better inerting during condensation. Being able to say that to a buyer, with a plan attached, changes the conversation from a failed analysis into a process discussion. Buyers are far more forgiving of a producer who knows why their number is what it is. ## Where the contamination actually comes from Post consumer mixed plastic waste arrives carrying a great deal that is not plastic, and each category lands somewhere different in your oil. Organic matter: Food residues, mud, soil, paper and cardboard. Drives oxygen, water, ash and solids, and contributes to fouling. Plastic additives: Fillers, plasticisers, inks, labels and colour pigments. Contribute oxygenates, metals and ash. Pigments in particular carry metals you will see in an ICP scan. PVC and chlorinated content: Even small fractions drive chlorine, which is the parameter that decides whether a cracker will look at the oil at all. Sorting upstream beats treating downstream every time. Metals: From labels, closures, residues and pigments. A refiner cares particularly about silicon, which poisons catalyst and is the parameter most often missing from a thin analysis. Unrecovered non plastics: Whatever the sorting line did not take out. Shows up as solids and ash, and is the cheapest thing on this list to fix, because it is fixed with sorting rather than chemistry. The pattern worth internalising: almost every difficult number in a plastic pyrolysis oil analysis traces back to what went into the reactor, not to what happened inside it. Money spent on the sorting line usually buys more specification improvement than money spent on the process. See waste plastics for what a clean, repeatable bale looks like. ## The quality panel buyers actually ask for There is no single published specification for this material, so what counts is what buyers request in practice. This is the panel that comes back again and again, with the method named beside each line. Run it once, properly, and you can answer nearly any enquiry without going back to the laboratory. Density at 15 degrees C: ASTM D4052 Pour point: ASTM D97 Initial boiling point: ASTM D86 Final boiling point: ASTM D86 or ASTM D7169 Reid vapour pressure: ASTM D323 Total acid number, mg KOH/g: ASTM D664 Sulphur, ppm: ASTM D5453 Nitrogen, ppm: ASTM D4629 Total oxygen, ppm: ASTM D5291 Total halogens: ASTM D7359 Bromide value: the companion to the halogen figure Total metals: ICP-MS or ICP-OES Phosphorus: ICP-MS or ICP-OES Silicon: ICP-MS or ICP-OES Two things worth knowing before you commission it. Total halogens is not the same as chlorine, and a buyer working to a chlorine limit will want the chlorine figure specifically, so agree which one you are quoting. And distillation methods are not interchangeable: an initial boiling point run on D86 will not line up with one run on another method, so put the method next to the number or the comparison is meaningless. More on that under test methods. ## Sources * Document checklist: exactly which papers a European buyer asks for, per product: /markets/document-library * SPECIMEN safety data sheet: Plastic pyrolysis oil (worked example, all 16 sections): /documents/sds-pyrolysis-oil * Regulation (EU) 2024/1157 on shipments of waste, on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1157/oj * Regulation (EU) 2025/40 on packaging and packaging waste (PPWR): https://eur-lex.europa.eu/eli/reg/2025/40/oj * Regulation (EC) No 1907/2006 (REACH), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2006/1907/oj * ISCC PLUS, the scheme used for circular and bio based materials: https://www.iscc-system.org/certification/iscc-certification-schemes/iscc-plus/ ## Frequently asked questions Q: How much oil do I get from a tonne of plastic? A: For a clean polyolefin feed, liquid yields in the region of 70 to 80 percent by weight are reported, with the rest going to gas and char. The polyolefin content of the feed is the main driver: the cleaner and more polyolefin-rich the input, the higher the liquid yield. A mixed post-consumer feed carrying PVC, PET, labels, moisture and dirt will come in well below that, and the material you did not want does not simply disappear, it lands in your chlorine and ash figures. Q: What is the calorific value of plastic pyrolysis oil? A: Commonly reported in the range of about 38 to 43 MJ/kg, which puts it in the same territory as conventional fuels. But treat calorific value as the least interesting number on your analysis. Nobody buying for a cracker is paying for energy content, they are paying for a hydrocarbon they can process, and that conversation is decided by chlorine, silicon and consistency. Energy content only leads the discussion when the oil is going to a burner, which is the lowest value outlet. Q: How is plastic pyrolysis oil priced? A: Off a reference, usually naphtha, with an adjustment for quality and a separate premium where the material carries a recognised certification. That structure matters more than any number we could quote here: the reference moves, so a price agreed today is really a formula, not a figure. Certified oil meeting cracker specification and uncertified crude oil going to a burner are different products with a wide gap between them, and the gap is worth more than most producers assume. Q: What tests should I run on plastic pyrolysis oil? A: Density at 15 degrees by ASTM D4052, pour point by D97, initial and final boiling point by D86 with D7169 as the alternative for the back end, Reid vapour pressure by D323, total acid number by D664, sulphur by D5453, nitrogen by D4629, total oxygen by D5291, total halogens by D7359 with the bromide value alongside, and total metals, phosphorus and silicon by ICP-MS or ICP-OES. That is the panel buyers keep asking for. Run it once properly and you can answer almost any enquiry without going back to the lab. Q: Is total halogens the same as chlorine? A: No, and agreeing one while meaning the other is a routine source of argument. Total halogens covers fluorine, chlorine, bromine and iodine together. A buyer working to a chlorine limit wants chlorine specifically. Quote which one you have measured and by which method, and if there is a bromide figure alongside, say so. Q: Why is the oxygen or oxygenate content of my plastic pyrolysis oil so high? A: Three normal causes. The plastic itself carried stabilisers, antioxidants and processing aids from its original manufacture, and those break down during pyrolysis into oxygenated compounds. Light fractions, where oxygenates concentrate, are being captured into the tank blend instead of separated. And air ingress during condensation or handling promotes light oxygenate formation. The fixes are tighter light end collection and better inerting of the condensation train. Being able to explain this to a buyer, with a plan, changes the conversation completely. Q: What contaminates plastic pyrolysis oil, and where does it come from? A: Almost all of it arrives with the feed rather than being created in the reactor. Organic matter such as food residue, soil, paper and cardboard drives oxygen, water, ash and solids. Plastic additives, meaning fillers, plasticisers, inks, labels and pigments, drive oxygenates, metals and ash. PVC drives chlorine. Metals come from labels, closures and pigments, and silicon in particular ends conversations with refiners. Money spent on the sorting line usually buys more specification than money spent on the process. Q: Which fraction of plastic pyrolysis oil are you buying? A: Light and middle fraction, for buyers of ours. The light cut, naphtha range to around 180 C, is what a steam cracker actually wants. The middle cut, roughly 180 to 360 C, routes to hydrotreating, diesel blending or a cracker depending on how chlorine, sulphur and nitrogen come back. We will still look at full range undistilled oil, but the fractionated cuts place faster and at better levels. Q: What are the three fractions of plastic pyrolysis oil? A: Light, naphtha range roughly C5 to C12 up to about 180 C. Middle, gasoil and diesel range roughly C12 to C20 between about 180 and 360 C. Heavy and residue, above roughly 360 C, waxy and often recycled back into the reactor or placed as industrial fuel or carbon black feedstock. Cut points vary by operator, so these are conventions rather than a standard. Q: Is it worth fractionating before selling? A: Usually yes, if the capital is there. A plant that can deliver a defined light or middle cut is selling a product a cracker or hydrotreater can take directly, instead of a full range oil the buyer has to work out what to do with. It widens the buyer list and shortens qualification. Q: What chlorine level does a steam cracker accept in plastic pyrolysis oil? A: Generally single-digit ppm on total chlorine, with some plants tighter still. Untreated oil from mixed post-consumer feed commonly tests in the hundreds or low thousands of ppm because of PVC and chlorinated additives. Always confirm the specific buyer's limit, there is no single industry figure, and plants do not relax it for trial cargoes. Q: How is chlorine removed from plastic pyrolysis oil? A: Four routes, in rough order of cost-effectiveness: sorting PVC out of the input upstream; capturing chlorine in-process with scavengers or a dechlorination stage; post-treating the produced oil by adsorption, washing or a dedicated unit; or blending into a much larger compliant stream. Input sorting is the most durable, which is why post-industrial feed prices above post-consumer. Q: What is the difference between PPO and bionaphtha as circular cracker feed? A: Both go to a steam cracker and both carry a certified renewable or circular claim, but they are different products. PPO is derived from waste plastic and supports a circular (recycled-content) claim. Bionaphtha is a bio-based co-product of hydrotreating fats and oils and supports a bio-based claim. Brand owners' targets often specify which one they need, so they are not interchangeable. See bionaphtha. Q: Do I need ISCC PLUS to sell plastic pyrolysis oil? A: Not to sell it as fuel. You need it for the cracker route, because ISCC PLUS with mass balance chain of custody is what allows the polymer producer downstream to sell a certified circular grade. Check that the pyrolysis unit is inside the certified boundary, that the product group is right, and that the mass balance period matches your delivery schedule. Q: How long does it take to qualify with a steam cracker? A: Months rather than weeks. The sequence is paper screening, laboratory sample, a consistency check across three or more batches, a trial parcel co-processed at low ratio, and only then a term discussion. The step that fails most often is consistency, a single good COA counts for very little if the next batch looks different. Q: Why is silicon such a problem? A: It comes from siloxanes and antifoam agents in the input and it permanently poisons hydrotreating catalyst. Unlike water or solids it cannot be filtered out, and unlike chlorine it cannot realistically be blended away. Any buyer with a hydrotreater tests for it whether or not it appears on the offered specification, and a failure usually ends the conversation. Q: Is there a standard specification for PPO? A: There is no universal trading specification. ASTM D8577 is a standard guide for characterising waste plastic process oil and is a sensible basis for a COA. In practice every buyer applies its own acceptance limits, so the question that matters is not whether the oil meets a standard but whether a specific plant can run it. ============================================================================== # Tyre pyrolysis oil (TPO) brokerage URL: https://www.sustainablecommodities.eu/markets/tyre-pyrolysis-oil We broker tyre pyrolysis oil (TPO), including heavy fraction and non-distilled material, which is where a lot of the real trade sits. On outlets: the aromatic content that rules TPO out of a steam cracker is exactly what a carbon black producer wants, so being turned down by one does not mean being turned down by the market. On specification, sulphur and chlorine lead, with water and sediment close behind. Tell us the fraction, the assay and the monthly volume, and we will tell you which of the two routes you are actually in. ## Why TPO is its own market End-of-life tyres are rubber, carbon black, steel and textile, with sulphur from vulcanisation and zinc from the vulcanisation activator. Pyrolysis carries all of that into the products. The oil comes out strongly aromatic, with sulphur typically in the region of 0.5 to 1.2 %, a characteristic limonene fraction, and zinc and other metals that a polyolefin-derived oil simply does not have. That chemistry closes the steam cracker door and opens others. Aromaticity that is a problem for a cracker is an asset for carbon black feedstock and for fuel blending, where aromatic content contributes to the calorific and handling properties a blender wants. It also means a tyre pyrolysis plant sells three products, not one, oil, recovered carbon black (rCB) and steel, and the economics of the plant usually depend on placing all three. We are happy to look at the oil in that context rather than in isolation. ## Where TPO actually goes * Carbon black production: as a feedstock component, where the aromatic content is the point. Generally the highest-value outlet for good, consistent material. * Industrial and boiler fuel: cement kilns, lime kilns and industrial burners, blended or neat depending on the permit and the burner. * Marine fuel blending: as a blend component into residual grades. Sulphur is the binding constraint: the global limit is 0.50 % m/m outside emission control areas and 0.10 % inside them, so TPO at 0.5 to 1.2 % is a blend component into a compliant pool, never a finished bunker fuel on its own. Any offer describing untreated TPO as a compliant marine fuel should be treated with real caution. * Refinery upgrading: hydrotreating or co-processing into a refinery cut, where sulphur and metals are managed by the refinery's own units. * Distillation into cuts: some operators fractionate on site and sell a light aromatic cut separately, which reaches buyers the whole oil cannot. ## RED III splits TPO in two, and that changes the economics This is the development most people in tyre pyrolysis have not fully priced in, and it is worth reading twice. A tyre is part natural rubber and part synthetic. The natural rubber carries biogenic carbon; the synthetic rubber carries fossil carbon. Both end up in the oil, and until recently only one of them counted for anything. Under RED III both do, through two different doors. * The biogenic fraction is treated as an advanced biofuel, aligned with Annex IX Part A feedstocks, which is the category that carries dedicated quotas and, where a member state still applies them, multipliers. Published estimates put the biogenic share of tyre-derived oil in the region of 40 to 50 %, concentrated up from the natural rubber content of the tyre. * The fossil fraction is no longer worthless in energy accounting. It can contribute to national climate targets through the recycled carbon fuel route, provided it meets the threshold. See recycled carbon fuels. * The greenhouse gas thresholds differ per door: broadly 70 % saving for recycled carbon fuels and 65 % for advanced biofuels from newer installations. Verify the figure that applies to your installation and delivery years before you build a case on it. ## Which means you now have to measure the biogenic share If the two fractions are accounted for separately, somebody has to say where the line is. That is done with radiocarbon analysis, carbon-14 testing, which distinguishes biogenic carbon from fossil carbon because fossil carbon has no measurable C14 left. Practically, this is a new line item for a tyre pyrolysis plant and a new question on every offer. A plant that can show a credible, repeatable biogenic percentage from a recognised laboratory is selling something different from a plant that cannot, and the difference is not cosmetic: it decides which of the two doors the cargo can walk through, and therefore what it is worth. If you are producing TPO and have not had the biogenic content measured, that is the single most useful thing you can do before your next conversation with a buyer. Ask us and we will tell you who tests it. ## Fractions, and what our buyers are asking for Not every tyre pyrolysis plant distils, and there is a real market on both sides of that choice. As with plastic-derived oil, cut points differ by operator, so the temperatures below are the usual convention rather than a specification. * Non-distilled TPO, also called whole or raw TPO. The full range oil straight from the reactor, with no fractionation. Simplest to produce, and there is genuine demand for it in industrial fuel and in upgrading. We have active interest in non-distilled TPO. * Heavy fraction TPO, above roughly 350 C. Strongly aromatic, higher sulphur, high in the polycyclic content that carbon black producers are looking for. This is the cut our buyers ask for most. * Middle fraction, gasoil and diesel range, into fuel blending and refinery upgrading. * Light fraction, naphtha range, carrying the characteristic limonene content that comes from the rubber. ## Specification Sulphur: Typically 0.5 to 1.2 %. The parameter that determines which fuel outlets are legally and technically available. Density and calorific value: Blending arithmetic and burner suitability. Flash point: Storage classification, transport and terminal acceptance. Distillation profile (IBP/FBP): Which cut the oil competes with and whether fractionation is worthwhile. Water (Karl Fischer): Phase separation, freight cost, burner stability. Ash and filterable solids: Char carry-over from the reactor. Metals, zinc especially: Zinc from the vulcanisation activator is characteristic of TPO; also Fe, Na, Ca, Pb. Aromatic content: The value driver for carbon black feedstock. Limonene fraction: Characteristic of tyre-derived oil; relevant where a specialty buyer is separating it. Viscosity: Pumping, heated storage and blend behaviour. TAN: Corrosivity in storage and transfer. Chlorine: Usually low relative to plastic-derived oil, but still tested where a refinery outlet is in play. ## Waste status and how we work it End-of-life tyres are a regulated waste stream and the resulting oil carries the same waste-or-product question as any other pyrolysis oil, decided nationally. One practical difference is worth knowing: the plastic-waste export restrictions in the EU Waste Shipment Regulation (EU) 2024/1157 target plastic waste, and rubber is not plastic, so tyre-derived streams do not sit under that particular prohibition. The general waste shipment regime still applies. See pyrolysis oil for the wider framework and CN classification. We act for tyre pyrolysis operators placing oil, and where useful, rCB alongside it, and for carbon black producers, blenders and refiners looking for consistent aromatic feed. As with every pyrolysis product, consistency across batches is worth more than a single good analysis, and we will say so before taking a plant to market. ## Sources * Regulation (EU) 2024/1157 on shipments of waste, on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1157/oj * Regulation (EC) No 1907/2006 (REACH), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2006/1907/oj * ISCC PLUS, the scheme used for circular and bio based materials: https://www.iscc-system.org/certification/iscc-certification-schemes/iscc-plus/ * Pyrum Innovations, end of life tyre pyrolysis: https://www.pyrum.net/en/ ## Frequently asked questions Q: What is the difference between tyre pyrolysis oil and plastic pyrolysis oil? A: They are different products with different buyers and prices. TPO is strongly aromatic with sulphur typically around 0.5 to 1.2 % and characteristic zinc content, and goes to carbon black production, fuel blending or refinery upgrading. Plastic pyrolysis oil from polyolefins is naphtha-like and paraffinic, and its premium outlet is a steam cracker under ISCC PLUS mass balance. Quoting one against the other signals inexperience immediately. Q: Which tyre pyrolysis oil fractions are you looking for? A: Heavy fraction TPO and non-distilled TPO. The heavy cut, above roughly 350 C, is strongly aromatic with the polycyclic content carbon black producers want, and it is what our buyers ask for most. Non-distilled or whole TPO straight from the reactor also has genuine demand in industrial fuel and upgrading, so a plant without a distillation column is not shut out. Q: What is non-distilled TPO? A: The full range oil as it leaves the reactor, with no fractionation. Also called whole or raw TPO. It is the simplest product for a plant to make and there is a real market for it, which matters because a lot of tyre pyrolysis operators do not have a distillation column and assume that rules them out. It does not. Q: Why do carbon black producers want the heavy fraction? A: Because the aromatic and polycyclic content that makes the heavy cut unsuitable for a steam cracker is exactly what carbon black feedstock needs. It is the clearest example in this market of a property being a defect in one outlet and the whole point in another. Q: Can tyre pyrolysis oil be used as marine fuel? A: Only as a blend component. The global marine sulphur limit is 0.50 % m/m outside emission control areas and 0.10 % inside them, and TPO typically runs 0.5 to 1.2 % sulphur, so untreated TPO cannot be a compliant finished bunker fuel on its own. It can be blended into a compliant pool. Treat any offer presenting neat TPO as a compliant marine fuel with real caution. Q: Why does tyre pyrolysis oil contain zinc? A: Zinc oxide is used as a vulcanisation activator in tyre manufacture, so zinc is present in the rubber and carries into the pyrolysis products. It is characteristic of tyre-derived oil and is one of the markers that distinguishes TPO from polyolefin-derived oil in a laboratory. Q: Is TPO suitable for steam crackers? A: Not as a drop-in feed. Its aromaticity, sulphur and metals are wrong for that application, which is exactly why the carbon black and fuel routes exist. Upgrading into a refinery stream is possible where the refinery's own hydrotreating and metals management can handle it, but that is a refinery decision, not a trading assumption. Q: Do you also place recovered carbon black? A: Yes, and it usually makes sense to look at it together with the oil. A tyre pyrolysis plant's economics generally depend on placing oil, recovered carbon black and steel, and treating the oil in isolation gives a misleading picture of what the plant needs commercially. Q: Does the EU plastic waste export ban affect tyre-derived streams? A: No. The plastic-waste export restrictions in Regulation (EU) 2024/1157 apply to plastic waste, and rubber is not plastic, so tyre-derived streams do not fall under that particular prohibition. The general waste shipment regime still applies to whatever is classified as waste, so the waste-or-product question still has to be settled. ============================================================================== # Recovered carbon black (rCB) brokerage URL: https://www.sustainablecommodities.eu/markets/recovered-carbon-black We broker recovered carbon black (rCB) from tyre pyrolysis, alongside the oil from the same plant. The thing to understand first is that rCB is not one product: the difference between material that a rubber compounder qualifies and material that ends up as a fuel is ash content, residual volatiles and consistency, not the process that made it. Ash comes from the inorganic fillers and the zinc oxide in the original tyre and it cannot be pyrolysed away, only separated. Send us the ash, the toluene transmittance, the particle size distribution and three consecutive batch reports, and we will tell you which market you are in. ## Why the plant economics run through rCB, not the oil A tyre pyrolysis plant makes roughly three saleable outputs: oil, recovered carbon black and steel. By mass the solid fraction is the largest of the three, and it is usually the one that decides whether the plant works commercially. Operators who arrange the oil first and treat the char as a residue tend to find out late that the residue was the business. That is also why we prefer to look at both together. An oil enquiry from a plant with no home for its solid output is a different conversation from one where both streams are placed, and pretending otherwise wastes everyone's time. See tyre pyrolysis oil for the liquid side. ## Ash is the number that decides the market A tyre is not just rubber and carbon black. It carries silica, zinc oxide from the vulcanisation activator, and other inorganic fillers. Pyrolysis removes the organic fraction and concentrates everything inorganic into the solid product. Ash content is therefore set by the feedstock, not by the reactor, and no amount of process tuning removes it. That single fact explains most of the price spread in this market. Material with low, stable ash competes with virgin furnace black in rubber compounding. Material with high ash competes with fuel. The processing route in between, milling, classification and pelletising, is about particle size and handling, not about ash. * Ash content is the first screen for almost every buyer, and it is where feedstock selection shows up. Mixed or dirty tyre input carries straight through to the number. * Toluene transmittance indicates residual hydrocarbon left on the surface. Low values mean the char was not fully devolatilised and will smell, smoke or bleed into the compound. * Particle size and structure determine whether it disperses. Unmilled char with agglomerates behaves nothing like a milled and classified grade even at the same ash. * Sulphur and zinc come from the tyre and matter to compounders working to their own limits. * Consistency across batches is what actually closes a term contract. One good report is a sample; three matching reports is a supplier. ## The standards exist now, and buyers use them For years rCB was traded on ad hoc datasheets, which made comparison impossible. ASTM Committee D36 was formed in 2017 specifically for this material and there is now a usable set of standards. Quoting them is the cheapest credibility a seller can buy. * ASTM D8178 sets the terminology, including what may and may not be called recovered carbon black. * ASTM D8466 is the guide to which carbon black test methods apply to rCB, which matters because not all of them transfer unchanged. * ASTM D8474 determines composition by thermogravimetric analysis: organic residue, total carbon and ash in one run. * ASTM D8621 covers ash content specifically. * ASTM D8585 addresses shelf life, which is more relevant than it sounds for material that sits in a warehouse before qualification finishes. There is also a classification convention: an R for recovered, followed by two numbers, the first for the class of toluene transmittance and the second for the class of inorganic content. Refined grades are compared against the semi-reinforcing virgin series, broadly the N500 to N700 range, rather than against the reinforcing grades used in tyre treads. ## Where it goes, and what each market weighs first Six industries buy this material in Europe and they do not want the same thing. The single most useful correction to make early: tyres are the largest outlet but not the first one. In a tyre, rCB is a partial replacement inside a formulation that takes quarters to qualify. In several non-tyre applications it can carry the full filler load, and the qualification is measured in weeks. * Non-tyre rubber goods, shoe soles, conveyor belts, rubber flooring and mats, seals, hoses and vibration dampers. Usually the realistic first market. Weighs ash and dispersion: grit shows up as a visible surface defect in a moulded part. * Plastics, masterbatch and compounds, bought as black pigment and filler. Weighs dispersion above all; agglomerates give streaks and specks that cannot be hidden. * Printing inks and coatings, pays best per tonne, screens hardest. Weighs grit, jetness and tint strength, because a press stoppage costs far more than the pigment. Needs a milled and classified grade, not raw char. * Asphalt and bitumen, researched and trialled rather than routinely supplied. Pyrolytic carbon black has been compared against commercial N550 as a binder modifier, with reported gains in stiffness, high-temperature deformation resistance and rutting on heavily trafficked sections. Not the same thing as crumb-rubber-modified bitumen, which uses ground rubber. * Tyre manufacturers, the largest volumes and the hardest door. Weighs consistency across batches more than any single result. * Distributors of rubber and plastics raw materials, how most smaller compounders actually buy. One agreement reaches customers that would otherwise be hundreds of separate qualifications. * Fuel and cement, the floor. Clears material, does not pay for a milling line. Which of these is open to you is decided by ash and by consistency, not by ambition. For who sits in each route, what they screen on and how to approach them, see who buys recovered carbon black in Europe. ## The buyers behind those routes * Tyre manufacturers, the outlet with the most attention and the hardest qualification. Bridgestone and Michelin published joint guidelines for rCB in a 2023 white paper, aimed at making requirements comparable between manufacturers rather than each writing its own. Several producers hold multi-year offtake agreements with tyre makers. * Non-tyre rubber compounders, conveyor belt, hose, seals, mats and moulded goods. Often the realistic first market: the volumes are smaller but the qualification is achievable and the tolerance on ash is wider. * Plastics and masterbatch, where the material is used as a black pigment and filler and dispersion behaviour matters more than reinforcement. * Coatings, inks and construction products, where colour strength and consistency lead. * Carbon black producers themselves, some of whom have taken equity stakes or offtake positions in rCB rather than treating it purely as competition. * Fuel and cement, the floor of the market. It clears material but it does not pay for a milling line. ## Two things moving the European market in 2026 First, the carbon accounting argument has become a purchasing argument. Virgin furnace black is made by burning oil, and its footprint is high. The published work from tyre manufacturers puts the reduction from using rCB instead at up to around 85 % on that specific input. For a buyer with a product carbon footprint target, that is a lever with few alternatives, and it is why qualification programmes exist at all. Second, virgin carbon black is an oil product. It is made by burning heavy aromatic feedstock, so its cost tracks the oil market and its footprint is high by construction. That is a structural position, not a cycle. Note what this does NOT mean: carbon black is not on the CBAM list. CBAM covers cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, and nothing in that list is carbon black, so anyone telling you the carbon border levy is about to reprice your filler is mistaken. What both do is the same thing: they widen the gap between rCB that a compounder can qualify and rCB that can only be burned. The premium sits on consistency, and consistency is a plant decision made years earlier, at the point where the feedstock contract is signed. ## What we ask for A plant that can answer those six points is taken seriously immediately. A plant that cannot is not being judged on its material, it is being judged on whether the material can be relied on, and that is a fair question. * Ash content, with the method stated. * Toluene transmittance, or an honest statement that it has not been measured. * Particle size distribution, and whether the material is milled, classified, pelletised or raw char. * Three consecutive batch reports, not the best one. * Feedstock, whether the input is sorted passenger car tyres, truck tyres or mixed. This predicts the ash before any laboratory does. * Monthly tonnage and the form it ships in, big bags, bulk or pellets. ## Sources * ASTM D8178, standard terminology relating to recovered carbon black: https://www.astm.org/d8178-19.html * ASTM D8474, compositional analysis of rCB by thermogravimetry: https://store.astm.org/d8474-22.html * ASTM D8621, standard test methods for rCB ash content: https://store.astm.org/d8621-25.html * Bridgestone and Michelin, joint white paper on recovered carbon black: https://www.bridgestoneamericas.com/content/dam/corpcomm/americas/press-assets/2023/bridgestone-michelin-publish-rcb-white-paper/110623-bridgestone-michelin-publish-rcb-white-paper.pdf * Regulation (EU) 2023/956 establishing the carbon border adjustment mechanism: https://eur-lex.europa.eu/eli/reg/2023/956/oj * Pyrum Innovations, end of life tyre pyrolysis: https://www.pyrum.net/en/ ## Frequently asked questions Q: What is recovered carbon black? A: The solid carbonaceous product recovered from the pyrolysis of end-of-life tyres, after the organic fraction has been driven off as oil and gas. ASTM D8178 sets the terminology, including what may properly be called recovered carbon black rather than char. In practice the distinction is processing: raw reactor char is not the same product as milled, classified and pelletised rCB, even from the same reactor. Q: What ash content do buyers want? A: Lower and, above all, stable. Ash comes from silica, zinc oxide and other inorganic fillers in the original tyre, so it is set by the feedstock and cannot be pyrolysed away. Rubber compounding applications screen on it first. Rather than quoting a single figure that varies by application, the useful answer is that ash decides which market you are in, and feedstock decides your ash. Q: Can recovered carbon black replace virgin carbon black completely? A: Not one for one across all grades. rCB is generally compared against the semi-reinforcing virgin series rather than the reinforcing grades used in tyre treads, and most compounders use it as a partial replacement in a formulation rather than a straight substitution. That is still a large market, and it is the realistic target for a producer starting out. Q: Which ASTM standards apply to rCB? A: D8178 for terminology, D8466 as the guide to which carbon black test methods transfer, D8474 for compositional analysis by thermogravimetry, D8621 for ash content and D8585 for shelf life. ASTM Committee D36 was formed in 2017 for this material. Quoting the method alongside the number on a datasheet is what separates a serious offer from a generic one. Q: What does toluene transmittance measure? A: Residual hydrocarbon left on the surface of the material after pyrolysis. A low value means incomplete devolatilisation, which shows up later as odour, smoke during compounding or migration into the finished product. It is one of the two numbers in the R classification, alongside inorganic content. Q: Do you place rCB separately from the oil? A: Yes, but we would rather look at both. A tyre pyrolysis plant's economics generally depend on placing oil, recovered carbon black and steel, and by mass the solid product is the largest of the three. Treating either stream in isolation gives a misleading picture of what the plant actually needs. Q: Is raw char the same thing as rCB? A: No, and conflating them causes most of the disappointment in this market. Raw char straight from the reactor contains agglomerates and steel fragments and behaves nothing like a milled and classified grade in a compound, even at identical ash. The question a buyer is really asking is not what your reactor produces but what leaves your milling line. Q: Why does feedstock matter so much? A: Because ash is inherited, not created. Sorted passenger car tyres, truck tyres and mixed end-of-life material each carry a different inorganic load, and that load arrives in your product unchanged. A plant that fixed its feedstock contract without thinking about ash has already decided which market it can sell into, usually without knowing it. Q: What volumes are worth discussing? A: Regular monthly tonnage in a consistent form matters more than size. Buyers qualifying a new filler are committing formulation work, so what they are buying is reliability over time. A modest steady volume with three matching batch reports is a stronger position than a large one-off parcel. ============================================================================== # Who buys recovered carbon black in Europe URL: https://www.sustainablecommodities.eu/markets/who-buys-recovered-carbon-black-in-europe Recovered carbon black is bought by six different industries in Europe, and they do not want the same material. Tyre manufacturers take the largest volumes and apply the hardest qualification. Non-tyre rubber goods, shoe soles, conveyor belts, mats, seals, vibration dampers, are where most new producers actually get qualified first, because the tolerance is wider and rCB can go in at much higher loadings, in some applications replacing the virgin grade entirely. Plastics and masterbatch buy it as pigment and filler. Printing inks and coatings pay the most per tonne and screen the hardest on grit and consistency. Asphalt is real but still largely at research and trial scale. And the carbon black producers themselves have taken positions rather than treating rCB purely as competition. ## Why the volume and the entry point are not the same market Read this first: this is a market map built from public sources, not a client list. Naming a company here says nothing about whether we work with them, and we do not claim to represent any of them. It exists because "who actually buys this" is the question we are asked most often, and there is no honest public answer to it anywhere else. The number that frames everything else: installed rCB capacity in Europe is in the region of 20,000 tonnes a year, while estimated European demand sits between 250,000 and 550,000 tonnes. Announced new capacity across the industry is roughly 232,000 tonnes. Even if all of it is built, the gap does not close. That shortage is not evenly distributed, and this is the part that matters for a producer deciding where to start. Tyre manufacturers want the volume and have the multi-year contracts, but their qualification is a formulation project measured in quarters. The non-tyre industries qualify faster, buy smaller parcels, and in several applications can take rCB at loadings a tyre plant would never consider. ## Tyres: the largest volume and the longest road The most visible outlet and the hardest. Bridgestone and Michelin published joint guidelines for rCB in a 2023 white paper, aimed at making requirements comparable between manufacturers rather than each writing its own. Multi-year offtake agreements exist between producers and tyre makers, Pyrum with Pirelli under the European tyre-to-tyre initiative, and Scandinavian Enviro with tyre manufacturers including Michelin and Nokian. * What they screen on: ash first, then consistency across batches, then residual volatiles. A single good report is a sample, not a supplier. * What they compare against: generally the semi-reinforcing virgin series, broadly N500 to N700, rather than the reinforcing grades used in treads. * How long it takes: quarters, not weeks. The material has to survive a formulation trial, and formulation work is expensive for the buyer. * Why it is still worth pursuing anyway: the multi-year offtake agreements in this market sit here, and the tonnages are an order of magnitude above what a single non-tyre compounder takes. ## Non-tyre rubber: where a new producer actually gets qualified first This is the route most new producers underestimate, and it is usually where they get qualified first. Shoe soles, conveyor belts, rubber flooring and mats, seals and gaskets, vibration dampers, hoses and moulded technical goods. The reason it works is loading. In several of these applications rCB is not a partial substitution for a virgin grade but can carry the full filler load, because the mechanical demands are lower than a tyre tread and the appearance requirements are modest. Rubber flooring, vibration dampers and general rubber compounds are cited in the industry as applications where recovered material can go in at very high proportions. * What they screen on: ash and dispersion. Grit and agglomerates show up as surface defects in a moulded part, which is visible and therefore rejected. * Volumes: smaller per customer, but there are many customers, and repeat business starts sooner. * How you reach them: mostly not directly. See route 6. ## Plastics and masterbatch: dispersion decides, not reinforcement Here rCB is bought as a black pigment and a filler rather than as a reinforcing agent, which changes what matters. Dispersion behaviour leads, because a poorly dispersing black shows up as streaks or specks in a moulded or extruded part and there is no way to hide it. The commercial argument is the same one that drives the tyre programmes: a converter with a product carbon footprint target has few levers on a filler, and this is one of them. * What they screen on: dispersion, grit, and consistency of undertone. * What kills a trial: agglomerates. Unmilled or poorly classified material behaves nothing like a properly processed grade even at identical ash. ## Inks and coatings: pays the most per tonne, forgives the least The most demanding of the pigment routes and the one that pays best per tonne. An ink formulator is buying optical performance and press behaviour, and both are unforgiving. The specification language is different here, so it is worth knowing what a buyer in this market is actually asking about: * Jetness, the depth and intensity of the black. Driven by particle size and structure: finer, evenly distributed particles give a deeper black. * Tint strength, an indicator of hiding power under given processing conditions. * Grit, the parameter that most often rules a recovered material out. Printing needs clean filtration, and a press stoppage costs far more than the pigment. * Surface area and structure, carbon blacks for printing ink typically sit around 50 to 200 m²/g BET, with roughly 50 to 80 m²/g the practical balance between jetness and workable viscosity. Oil absorption in the region of 80 to 140 cm³/100 g is quoted for high print density. The honest reading for a producer: this route rewards a milled, classified and tightly controlled product, and it is not a home for raw char. But it is the route where a small, consistent volume earns a real premium instead of a commodity price. ## Asphalt: researched and documented, not yet a volume outlet Genuine, researched, and still mostly at trial and pilot scale rather than routine commercial supply, which is worth saying plainly rather than presenting it as an established outlet. Pyrolytic carbon black has been tested as a bitumen modifier and as a filler in road pavement, and compared directly against commercial N550 in that role. The published findings point the same way: it increases the stiffness and elasticity of the binder, improves resistance to deformation at high temperature, and reduces rutting potential on heavily trafficked sections. In warm climates that combination is exactly what a binder specification is reaching for. * Do not confuse it with crumb rubber. Rubber-modified bitumen uses ground rubber granulate from the same tyre; this is the carbon black recovered by pyrolysis. Different material, different dosing, different supply chain. Quoting one when a buyer means the other ends the conversation. * What they screen on: consistency and handling more than optical properties. Ash tolerance is generally wider here than in rubber compounding. * Where it stands: promising and documented, but a producer should treat it as a development conversation rather than a volume outlet today. ## The distributors are the route, not a detour around it Most non-tyre rubber and plastics buyers do not purchase carbon black directly from a producer. They buy through rubber and plastics raw material distributors, who hold stock in Europe, carry the technical service, and help a compounder select and formulate. Names active in this space include Weber & Schaer, Biesterfeld, Lehmann & Voss and HSH Chemie. For a producer this changes the shape of the sales problem entirely. One distributor agreement reaches hundreds of compounders that would each be a separate qualification. It is the route Wastefront took, with a strategic offtake and on-sale agreement covering a minimum share of the output from its Sunderland plant. * What they screen on: whether the material is consistent enough to put their own name behind, and whether supply is reliable enough to promise to a customer. * What they add: European stock, technical service and formulation support, which is precisely what a small producer cannot offer on its own. ## The carbon black industry bought in rather than fought back Established producers have not treated rCB purely as a competitor. Circtec works in partnership with Birla Carbon, and legacy producers including Cabot and Orion have hedged through equity stakes or offtake positions rather than standing outside the market. For a seller this is worth knowing because it is a different kind of counterparty: they understand the product technically better than anyone, they will test it properly, and they are not easily impressed by a datasheet. ## Fuel and cement set the floor, and a floor is not a plan Combustion in a cement kiln or industrial burner clears material and sets a floor under the price. It does not pay for a milling line, and a producer whose only outlet is this one has a disposal route rather than a product. It is listed here because it is real and because knowing your floor is useful. It is not listed as an ambition. ## How to approach any of them * Lead with ash, and state the method. It is the first screen in almost every route and it is set by your feedstock, not your reactor. * Send three consecutive batch reports, not the best one. Every buyer in this market has been shown a good single result by someone who could not repeat it. * Say what leaves your milling line, not what leaves your reactor. Raw char and a milled, classified grade are different products. * Name the ASTM methods. D8178 for terminology, D8466 for which carbon black test methods apply, D8474 for composition by thermogravimetry, D8621 for ash. It costs nothing and it separates a serious offer from a generic one. * Ask which route the buyer is in before quoting. An ink formulator and a cement kiln are asking about the same tonne of material and mean nothing alike. ## A note on accuracy Capacity figures, offtake agreements and company positions move. Projects are announced and do not get built; agreements are signed and quietly lapse. Everything above is drawn from what companies and researchers have published themselves, and it is a map rather than a live position. Check anything you intend to act on. ## Sources * ASTM D8178, standard terminology relating to recovered carbon black: https://www.astm.org/d8178-19.html * ASTM D8474, compositional analysis of rCB by thermogravimetry: https://store.astm.org/d8474-22.html * Bridgestone and Michelin, joint white paper on recovered carbon black: https://www.bridgestoneamericas.com/content/dam/corpcomm/americas/press-assets/2023/bridgestone-michelin-publish-rcb-white-paper/110623-bridgestone-michelin-publish-rcb-white-paper.pdf * Rheological properties of bitumen modified with pyrolytic carbon black: https://www.sciencedirect.com/science/article/abs/pii/0016236196001433 * Bitumen modified with waste rubber pyrolytic carbon black: https://www.sciencedirect.com/science/article/abs/pii/S0950061821004578 * Weibold, recovered carbon black and its market potential: https://weibold.com/recovered-carbon-black-and-its-market-potential * Pyrum Innovations, end of life tyre pyrolysis: https://www.pyrum.net/en/ ## Frequently asked questions Q: Who actually buys recovered carbon black in Europe? A: Six routes: tyre manufacturers, non-tyre rubber goods, plastics and masterbatch, printing inks and coatings, asphalt and bitumen at trial scale, and the carbon black producers themselves. Distributors sit across most of them and are how a small producer reaches the many smaller compounders. Fuel and cement form the floor. Q: Can recovered carbon black be used in shoe soles? A: Yes, and non-tyre rubber goods like footwear soles, conveyor belts, mats, seals and vibration dampers are usually the fastest market for a new producer to qualify in. The mechanical and appearance demands are lower than a tyre tread, so rCB can go in at much higher loadings, in several applications carrying the full filler load. Q: Can rCB be used in printing ink? A: Yes, and it is the route that pays best per tonne, but it is also the most demanding. An ink buyer screens on jetness, tint strength, dispersion speed and above all grit, printing needs clean filtration and a press stoppage costs far more than the pigment. Carbon blacks for printing ink typically sit around 50 to 200 m²/g BET surface area. This route needs a milled and classified product, not raw char. Q: Is recovered carbon black used in asphalt? A: It has been researched and trialled rather than routinely supplied. Pyrolytic carbon black has been compared against commercial N550 as a bitumen modifier, and the published work reports increased stiffness and elasticity of the binder, better resistance to deformation at high temperature, and reduced rutting on heavily trafficked sections. Treat it as a development conversation rather than a volume outlet today. Q: What is the difference between rCB in asphalt and crumb rubber modified bitumen? A: They are different materials from the same tyre. Crumb rubber modified bitumen uses ground rubber granulate; rCB is the carbon black recovered by pyrolysis after the rubber has been broken down. Different dosing, different handling and a different supply chain. Quoting one when the buyer means the other signals inexperience immediately. Q: How much recovered carbon black does Europe need? A: Estimated European demand is in the range of 250,000 to 550,000 tonnes a year against installed capacity of roughly 20,000 tonnes. Announced additional capacity across the industry is about 232,000 tonnes, so even if all of it is built the gap does not close. The constraint on this market is supply of consistent material, not demand. Q: Do I have to sell to a tyre manufacturer to be taken seriously? A: No, and aiming there first is the most common way to lose a year. Tyre qualification is a formulation project measured in quarters. Non-tyre rubber, plastics and inks qualify faster and start repeat business sooner, and a track record in those markets makes the tyre conversation easier rather than harder. Q: Why do distributors matter for a small producer? A: Because most non-tyre compounders buy through them rather than direct. A distributor holds European stock, carries the technical service and helps a compounder formulate, all things a small producer cannot offer. One distributor agreement reaches customers that would otherwise be hundreds of separate qualifications. Q: What single number decides which route is open to me? A: Ash content. It comes from the inorganic fillers and zinc oxide in the original tyre, it is concentrated by pyrolysis, and it cannot be processed away. Low and stable ash opens rubber compounding and the pigment routes; high ash leaves fuel. Your feedstock contract decided this before your reactor did. ============================================================================== # What your ISCC certificate actually covers URL: https://www.sustainablecommodities.eu/markets/iscc-certificate-scope A certificate number proves you are certified. The annex proves what you are certified FOR, and only the second one matters for a specific cargo. Material may only be handled as sustainable if it is included in the certificate annex of the system user. Two valid certificates can still fail to line up: if your annex covers a material your buyer's annex does not, they cannot receive it as sustainable, and the sustainability declaration is worthless to them. That is not a paperwork detail, it is the difference between a certified cargo and an ordinary one, and the price gap between those two is the whole point of being certified. ## The annex is the document, not the certificate Almost every scope problem starts the same way: someone checks that the counterparty holds a valid certificate, sees a number and an expiry date, and stops there. The certificate says the company passed an audit. The annex says which materials and which activities that audit covered. Material can only be handled as sustainable if it appears in the annex of the system user's certificate. Parts of a supply chain that are not certified cannot handle material as sustainable and may not issue sustainability declarations at all. * Check the annex, not the front page. Ask for it explicitly; it is a separate list and it is not always sent along. * Check the activity too. Producing, trading with storage, trading without storage and warehousing are different scopes. * Check the date against your laycan. A certificate that expires between loading and discharge is a problem you want to find now. ## "Entirely or partly of animal origin", what that line means This wording turns up on certificates for used cooking oil and related materials, and it causes more confusion in practice than almost any other phrase on the document. It is a description of what the certified material may contain. UCO collected from kitchens and restaurants will in practice contain animal-derived fat, so the scope has to say so. The consequence is downstream: your buyer needs a scope that allows them to receive that same description. A buyer whose annex covers only vegetable-origin material cannot take it as sustainable, even though the cargo is genuinely certified and genuinely sustainable. Neither party is doing anything wrong in that situation. The two scopes simply do not overlap, and the cargo has to find a buyer whose scope does. The animal by-product rules run alongside this and are a separate question again, see used cooking oil for the material and proof of sustainability for what has to be on the declaration itself. ## Two certified companies can still fail to trade This is the part that surprises people who are new to certified trade. Both sides hold valid certificates, both are audited, both act in good faith, and the sustainability claim still cannot pass between them. Where it usually goes wrong: * The material is not on the buyer's annex. They can buy the cargo; they cannot book it as sustainable. * The product group is different. Similar-looking products are not interchangeable: FAME from used cooking oil and FAME from rapeseed are not physically identical and do not belong to the same product group. Physical, chemical and RED-category criteria all have to be met together before materials may be grouped. * The chain of custody method does not line up. Mass balance, segregation and controlled blending have to be coherent from end to end, not chosen separately by each party. * A link in the chain is not certified at all. Any entity taking legal ownership has to be certified, or the chain of custody breaks at that point. The expensive version of this is when it surfaces at the buyer's audit rather than at the seller's. By then the cargo has moved, the invoice is out, and the claim is being unwound after the fact. ## Trading without storage is still a scope A persistent misunderstanding among traders who never physically touch the material: that not handling it means not needing certification. Since 1 August 2023, materials for traders, both paper traders and traders with storage, as well as warehouses and logistic centres have to be included in the annex of the certificate. Taking legal ownership is what triggers the requirement, not taking physical possession. For a trading company this has a practical consequence worth planning around: your annex has to be broad enough to cover everything you might take title to, and extending it is an audit matter with a lead time, not a phone call. ## Why the GHG number can fail even when the scope fits A separate question that arrives in the same conversation often enough to belong here: a cargo can be in scope, correctly certified, and still not meet the greenhouse gas saving the buyer needs. The saving is calculated over the whole chain, collection, processing, transport, and any losses along the way, against a fossil comparator. Long shipping legs and energy-intensive processing eat into it. Which threshold applies depends on the installation and the route, and the buyer's own obligation may require more than the legal minimum. So "why can you not reach 65%" is usually not a dispute about honesty. It is arithmetic over a specific chain, and the honest answer is to show the calculation rather than argue about the number. ## What to ask before you commit Five questions, answerable in one email, and they prevent the failure that otherwise surfaces months later at somebody's audit. * Send me your annex, not your certificate. The number tells me you are certified; the annex tells me whether we can trade. * Which exact material description do you hold? Word for word, as it appears on the annex. * What is your chain of custody method? And does it match what my side uses. * Does your scope cover the activity you will perform on this cargo? Storing, blending and reselling are not the same entry. * What GHG value are you working to, and who calculated it? ## Sources * ISCC EU 203, traceability and chain of custody: https://www.iscc-system.org/wp-content/uploads/2024/01/ISCC_EU_203_Traceability_and_Chain-of-Custody_v4.1_January2024-1.pdf * ISCC EU mass balance guidance: https://www.iscc-system.org/wp-content/uploads/2025/12/ISCC-EU-Mass-Balance-Guidance-Document_Version-1.2_Final_22122025.pdf * List of materials eligible for ISCC EU certification: https://www.iscc-system.org/wp-content/uploads/2026/02/ISCC_EU_material_list_260206.pdf * ISCC EU, the scheme itself: https://iscc-system.org/certification/certification-schemes/iscc-eu/ ## Frequently asked questions Q: Does my ISCC certificate cover this product? A: Only if the material appears in the annex of your certificate. The certificate itself shows that you were audited; the annex shows for which materials and which activities. Material that is not in the annex may not be handled as sustainable, and an uncertified part of a supply chain may not issue sustainability declarations at all. Q: What does "entirely or partly of animal origin" mean on a certificate? A: It describes what the certified material may contain. Used cooking oil collected from kitchens will in practice contain animal-derived fat, so the scope says so. The consequence sits downstream: your buyer needs a scope that allows them to receive that same description. A buyer whose annex covers only vegetable-origin material cannot take it as sustainable, even though your cargo is properly certified. Q: Can two certified companies still be unable to trade certified material? A: Yes, and it happens regularly. Both certificates can be valid while the scopes do not overlap: the material is not on the buyer's annex, the product groups differ, the chain of custody methods do not line up, or a link in the chain is not certified. Nobody is at fault; the trade simply cannot carry the sustainability claim. Q: Are FAME from used cooking oil and FAME from rapeseed the same product group? A: No. They are not physically identical and they do not belong to the same product group. Physical characteristics, chemical characteristics and the RED category all have to be met together before materials may be grouped, so similar-sounding products cannot be substituted for one another under a single entry. Q: I am a trader and never handle the material. Do I still need certification? A: Yes, if you take legal ownership. Since 1 August 2023 materials for traders, paper traders as well as traders with storage, and for warehouses and logistic centres have to be included in the certificate annex. Legal ownership is what triggers it, not physical possession, and a chain of custody breaks at any uncertified link. Q: What happens if the scope does not match? A: The cargo can still be sold, but not as sustainable material. The sustainability declaration cannot be issued or cannot be accepted, so the buyer books ordinary material and the premium disappears. The worst case is that it surfaces at the buyer's audit after delivery, when the claim has to be unwound after the fact. Q: Why can a supplier not reach a 65% GHG saving? A: Because the saving is calculated over the whole chain against a fossil comparator, and collection, processing, transport and losses all count against it. A long shipping leg or energy-intensive processing can put a genuinely sustainable cargo below a threshold. Ask for the calculation rather than the number; a supplier who can show it is usually telling the truth. Q: What should I ask a counterparty before committing? A: Their annex rather than their certificate, the exact material description as it appears on it, their chain of custody method, whether their scope covers the activity they will perform on this cargo, and what GHG value they work to and who calculated it. Five questions, one email, and they prevent the failure that otherwise appears months later at an audit. ============================================================================== # Which feedstock makes which fuel URL: https://www.sustainablecommodities.eu/markets/which-feedstock-makes-which-fuel A waste lipid can usually become more than one fuel, and the classification decides more about its value than the chemistry does. Used cooking oil, animal fat, POME and acid oils all feed the same two processing routes, hydrotreatment (HVO, and via the same units SAF) and esterification (FAME), but they do not carry the same regulatory weight. Annex IX Part A materials get dedicated quotas; Part B sits under a national cap; food and feed crops sit outside both and under their own limit. Two cargoes with an identical fatty acid profile can therefore be worth very different amounts, and the cheapest way to lose money in this market is to assume the chemistry settles it. ## There are two processing routes, and they take different material Almost everything below runs through one of two conversions, and knowing which one a buyer operates tells you most of what they will screen on. * Hydrotreatment produces HVO (renewable diesel), and the same units with a different cut produce SAF on the HEFA route and bionaphtha as a co-product. It handles a wide range of fats and oils, but the catalyst is unforgiving: phosphorus, metals and chlorine are what fail a cargo here. * Esterification produces FAME (biodiesel), named after its input, UCOME from used cooking oil, RME from rapeseed, TME from tallow, SME from soy. It tolerates higher free fatty acid content than hydrotreatment does, which is why acid oils and lower grades find a home here. That difference is why the same tonne can be attractive to one plant and worthless to another, without anything being wrong with it. ## The routes, per material The classification column is the one that moves money. A material that qualifies under Annex IX Part A can fill a quota that Part B cannot, and neither can be filled by a crop-based oil. See Annex IX feedstocks for the lists themselves. Used cooking oil (UCO): HVO, SAF, FAME (UCOME), oleochemicals | Annex IX Part B | Part B sits under a national cap, so the value moves with how full that cap is Animal fat, category 3: HVO, SAF, FAME (TME), oleochemicals, feed and pet food | Annex IX Part B | Contested between four industries; feed and pet food bid against fuel Animal fat, category 1 and 2: HVO, FAME, technical uses | Annex IX Part B | Feed and food routes are closed by the animal by-product rules POME (palm oil mill effluent): HVO, SAF | Annex IX Part A | Part A carries dedicated quotas, and with them the sharpest scrutiny on origin Acid oils and soapstock: FAME, oleochemicals | Depends on origin | High free fatty acid content generally rules out the hydrotreatment route Crude tall oil (CTO): HVO, bionaphtha, oleochemicals | Annex IX Part A as a processing residue | The oleochemical industry competes hard for the same volume Vegetable oils (rape, soy, palm, sunflower): FAME (RME, SME), HVO | Not Annex IX, food and feed crop | Sits under the crop cap, so it cannot fill an advanced quota Plastic pyrolysis oil (PPO): Steam cracker feed, bionaphtha | Recycled carbon fuel, not Annex IX | Chlorine and silicon; the cracker route needs ISCC PLUS mass balance Tyre pyrolysis oil (TPO): Carbon black feedstock, industrial and marine fuel blending, refinery upgrading | Split: biogenic share as Annex IX Part A, fossil share as recycled carbon fuel | Aromaticity and sulphur close the steam cracker door and open the carbon black one ## Why SAF is not simply HVO with a different label The HEFA route to aviation fuel runs through the same hydrotreatment step, which is why the two products keep appearing together. But the specification and the obligation behind them are different, and so is the competition for the molecule. ReFuelEU sets a rising blending obligation for aviation with a separate sub-mandate for synthetic fuel that HEFA cannot fill, that gap is the commercial ground under eSAF. For a feedstock seller the practical consequence is that aviation and road transport are bidding for the same hydrotreated molecules under different rules, and which of them pays more moves with policy rather than with chemistry. ## The question behind almost every enquiry Measured over our own incoming mail, the great majority of questions about HVO and SAF are not about who buys the product. They are about the feedstock: which one, what it qualifies as, and what certification comes with it. The three that follow are the ones worth settling before anything else. * What is it, exactly, and where did it come from? The origin decides the classification, and the classification decides the value. * What does the certificate cover? Not the certificate number, the annex. See ISCC certificate scope; a scope that does not match your counterparty's ends the trade regardless of quality. * What is the greenhouse gas saving, and who calculated it? Two identical cargoes with different transport legs are not worth the same. ## Sources * Directive (EU) 2018/2001 (RED II) Annex IX, consolidated on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj * Directive (EU) 2023/2413 (RED III): https://eur-lex.europa.eu/eli/dir/2023/2413/oj * Regulation (EU) 2023/2405 (ReFuelEU Aviation): https://eur-lex.europa.eu/eli/reg/2023/2405/oj * Regulation (EC) No 1069/2009 on animal by-products: https://eur-lex.europa.eu/eli/reg/2009/1069/oj * ISCC EU, the scheme used across these routes: https://iscc-system.org/certification/certification-schemes/iscc-eu/ ## Frequently asked questions Q: Can used cooking oil become SAF? A: Yes, through the HEFA route, the same hydrotreatment that produces HVO, with a different cut. UCO also goes to FAME as UCOME and into oleochemicals. It is classified under Annex IX Part B, which sits under a national cap, so its value moves with how full that cap is rather than with the chemistry alone. Q: What is the difference between HVO and FAME as an outlet for my material? A: They are different conversions with different tolerances. Hydrotreatment produces HVO and, with a different cut, SAF and bionaphtha; its catalyst is unforgiving on phosphorus, metals and chlorine. Esterification produces FAME and tolerates a much higher free fatty acid content, which is why acid oils and lower grades find a home there and not in a hydrotreater. Q: Can POME go to aviation fuel? A: Yes, POME feeds both HVO and SAF through hydrotreatment. It is classified under Annex IX Part A, which carries dedicated quotas, and with them the sharpest scrutiny on origin documentation of any feedstock in this market. Expect the traceability questions to be harder than the specification questions. Q: Why is my rapeseed oil worth less than used cooking oil for biofuel? A: Because it is not a waste. Crop-based oils sit outside Annex IX and under the crop cap, so they cannot fill an advanced quota that a waste feedstock can. That is a regulatory difference, not a quality one, and it is the clearest example in this market of classification deciding value ahead of chemistry. Q: Which category of animal fat can go to fuel? A: All three, but the alternatives differ. Category 1 and 2 are limited to fuel and technical uses because the animal by-product rules close the feed and food routes. Category 3 can additionally go to feed and pet food, which is exactly why it is the contested one: four industries bid for the same material. Q: Does crude tall oil go to biofuel or to chemicals? A: Both, and they compete. CTO feeds hydrotreatment for HVO and bionaphtha, and it is a long-standing oleochemical raw material. As a processing residue it falls under Annex IX Part A. Which route wins on a given parcel is usually a price question rather than a technical one. Q: Is SAF just HVO sold to airlines? A: The HEFA route runs through the same hydrotreatment step, so the products are related, but the specification and the obligation behind them differ. ReFuelEU sets a separate synthetic sub-mandate that HEFA cannot fill, and aviation and road transport bid for the same hydrotreated molecules under different rules. Q: What decides whether a route is open to my cargo? A: Three things, in this order: what the material actually is and where it came from, what your certificate scope covers, and what the greenhouse gas calculation over your specific chain produces. Specification matters, but it is rarely the thing that closes a door that classification has not already closed. ============================================================================== # HVO and renewable diesel brokerage URL: https://www.sustainablecommodities.eu/markets/hvo HVO is a hydrocarbon, not an ester: which is why it behaves so differently from FAME and why the conversation moves so quickly past the specification. Made by hydrotreating vegetable oils, waste oils and fats, it is specified under EN 15940 for paraffinic diesel, and HVO100 can be used neat in approved applications. We broker it between producers, majors, distributors and large fleet users. What is actually being traded is the feedstock and the certificate: two identical litres of EN 15940 fuel can be worth materially different money depending on what they were made from and what the buyer can count. ## Why HVO is easy to handle and hard to buy Technically it is the most forgiving renewable fuel on the market. It has no ester content, so none of FAME's characteristic problems: no oxidation stability limit that degrades in the tank, no microbial growth driven by water absorption, no sterol glucoside filter blocking, no seasonal blending gymnastics. Cold-flow properties can be set very low in production, storage life is long, and it is a genuine drop-in for approved applications. Commercially it is the opposite of easy. Much of the European volume is contracted forward by parties covering a legal obligation under national RED III implementations, so genuine spot availability is thinner and more seasonal than headline production figures suggest. A seller holding certified volume in a defined delivery window has more than the raw supply numbers imply, and a buyer who waits for a soft spot market often waits a long time. ## EN 15940, and what a real HVO cargo looks like HVO is not EN 590 diesel and does not try to be. It is specified under EN 15940, the standard for paraffinic diesel, which recognises two classes and allows up to 7.0 % (V/V) FAME. Quoting the class is not pedantry: an engine approval or a fuel clause written against class A will not accept class B. Cetane number: Class A / Class B 70 min / 51 min; Typical HVO cargo Above 70 FAME content: Class A / Class B Up to 7.0 % (V/V) permitted; Typical HVO cargo Nil unless blended Density at 15 C: Class A / Class B Outside the EN 590 band by design; Typical HVO cargo 770 to 790 kg/m3 Kinematic viscosity at 40 C: Class A / Class B Per standard; Typical HVO cargo 2.0 to 4.0 mm2/s Sulphur: Class A / Class B Per standard; Typical HVO cargo 5 mg/kg max Flash point: Class A / Class B Per standard; Typical HVO cargo Above 70 C Total aromatics: Class A / Class B Paraffinic by definition; Typical HVO cargo 1 % (m/m) max Polycyclic aromatics: Class A / Class B Paraffinic by definition; Typical HVO cargo 0.02 % max Water content: Class A / Class B Per standard; Typical HVO cargo 200 mg/kg max Ash: Class A / Class B Per standard; Typical HVO cargo 0.001 % (m/m) max Copper strip corrosion: Class A / Class B Class 1; Typical HVO cargo Class 1 CFPP and cloud point: Class A / Class B By national annex and season; Typical HVO cargo -15 C summer, -34 C winter grades Density is where HVO surprises people who buy it like diesel. At around 780 kg/m3 against roughly 835 for EN 590, a tonne of HVO is more litres and a litre carries less energy. Contract in the unit you are actually settling in, and say so in the offer, because a volumetric price and a mass price are not the same trade and the gap is not small. The other thing worth settling early is the winter grade. HVO reaches very low CFPP values, but that is a production choice with a yield cost behind it, not a free property of the molecule. A buyer asking for -34 C in July should expect to be told what it costs. ## HVO against FAME, side by side The most common question we get, and the one where a wrong assumption costs the most. They are both made from the same feedstocks and they are not the same product at all: FAME is an ester, HVO is a hydrocarbon. Chemistry: FAME (biodiesel) Fatty acid methyl ester, contains oxygen; HVO (renewable diesel) Paraffinic hydrocarbon, no oxygen Standard: FAME (biodiesel) EN 14214; HVO (renewable diesel) EN 15940 Blend limit: FAME (biodiesel) Commonly 7 % (B7) in ordinary diesel; higher blends need approval; HVO (renewable diesel) Drop-in. Can be used neat (HVO100) in approved engines Density at 15 C: FAME (biodiesel) 860 to 900 kg/m3; HVO (renewable diesel) 770 to 790 kg/m3 Cetane number: FAME (biodiesel) 51 minimum; HVO (renewable diesel) 70 or above for class A Storage stability: FAME (biodiesel) Ages. Oxidation stability 8 h minimum and falls in storage; HVO (renewable diesel) Very stable. No esters to hydrolyse Cold flow: FAME (biodiesel) Feedstock dependent; saturated feedstocks give poor CFPP; HVO (renewable diesel) Excellent, and tunable in production at a yield cost Water and microbial growth: FAME (biodiesel) Hygroscopic; tank hygiene matters; HVO (renewable diesel) Not hygroscopic Materials compatibility: FAME (biodiesel) Attacks some elastomers; copper catalyses oxidation; HVO (renewable diesel) Behaves like fossil diesel Feedstock tolerance: FAME (biodiesel) Tolerant. Can run high FFA material after pretreatment; HVO (renewable diesel) Fussy. Sulphur, phosphorus, silicon and metals govern acceptance Capital cost of the plant: FAME (biodiesel) Low. Many small producers; HVO (renewable diesel) High. Few, large producers Iodine value ceiling: FAME (biodiesel) Yes: 120 max under EN 14214; HVO (renewable diesel) No equivalent limit; unsaturation is hydrogenated away Read the last two rows together, because that is the whole feedstock story. A FAME plant will take material an HVO plant refuses, but EN 14214 then caps what that material may be: highly unsaturated oils cannot make compliant European FAME. An HVO plant has no iodine value problem at all, but it will reject the same cargo on silicon or phosphorus. That is why the same parcel is worth different money to the two of them, and why the right question is never simply what is the price. For a buyer the practical split is this: if you need a drop-in fuel for an existing fleet with no tank changes and long storage, that is HVO. If you are blending to a mandate at B7 and price is the driver, that is FAME. See FAME biodiesel and parameters explained. ## The eight ASTM D7566 routes, and why the annex number matters SAF is not one product. ASTM D7566 approves synthesised blending components under eight separate annexes, and each annex is a different production route with its own feedstock, its own cost base and its own blend ceiling. An airline buying SAF is buying an annex, not a concept. A1, FT-SPK: Route Fischer-Tropsch synthetic paraffinic kerosene; Feedstock in practice Gasified biomass, MSW, coal or gas A2, HEFA-SPK: Route Hydroprocessed esters and fatty acids; Feedstock in practice UCO, animal fats, vegetable oils. The route that carries almost all real volume today A3, SIP: Route Synthesised iso-paraffins; Feedstock in practice Fermented sugars A4, SPK/A: Route Fischer-Tropsch with aromatics; Feedstock in practice As A1, with aromatics retained A5, ATJ-SPK: Route Alcohol to jet; Feedstock in practice Ethanol or iso-butanol A6, CHJ: Route Catalytic hydrothermolysis jet; Feedstock in practice Fats and oils A7, HC-HEFA-SPK: Route Hydrocarbon HEFA; Feedstock in practice Algal oil A8, ATJ-SKA: Route Alcohol to jet, synthetic kerosene with aromatics; Feedstock in practice Ethanol Most annexes cap out at 50 % blend. That ceiling is a certification limit on the finished fuel, not a shortage of ambition, and it is why 100 % SAF flights are demonstrations rather than routine operations. If a conversation assumes neat SAF into an existing fleet, that assumption is worth correcting early. For a feedstock seller the practical consequence is narrow and useful: A2 (HEFA) is where your material goes. UCO, category 1 and 2 animal fats and certain vegetable oils feed that route. If someone offers you a SAF offtake for a feedstock that no approved annex accepts, the offtake is not real yet. ## Specification and grades Standard: EN 15940 for paraffinic diesel. Class A and B differ in cetane and density ranges. HVO100 vs blend component: Neat use in approved applications, or blending into fossil diesel at a stated ratio. CFPP / cold-flow grade: Set in production by isomerisation. Summer and winter grades; confirm the destination requirement. Cetane number: Characteristically high, typically well above fossil diesel. Density: Lower than fossil diesel; relevant to volumetric fuel consumption and to blend calculations. Sulphur: Very low. Feedstock: UCO, animal fat, POME, technical vegetable oils. Determines Annex IX status and therefore value. Certification: ISCC EU or REDcert, with a valid proof of sustainability per delivery. GHG saving: The actual figure on the PoS where the buyer's claim depends on it, not a default value. Mandate treatment: How the volume counts in the specific destination member state, national, not EU-wide. Delivery basis: In-tank, ex-works, barge, truck or pipeline. OEM approval: For neat HVO100 in a fleet, the engine manufacturer's approval position matters to the end user. ## Feedstock decides the value This is where HVO deals are won and lost. The physical fuel is fungible; the sustainability characteristics travelling with it are not. Material made from an Annex IX Part B feedstock such as used cooking oil or category 1 and 2 animal fat sits under the 1.7 % of transport energy cap per member state. Material from Part A feedstocks counts against the advanced sub-target instead. Crop-based feedstock is a different category again. Two warnings that save real money. First, multipliers are now member state specific under RED III, the Netherlands and Germany have moved away from double counting in their national implementations, so a grade described as "double counting" means nothing until you name the destination market. Second, check the mass balance accounting period against your delivery schedule; a certificate that is valid but out of period is a problem discovered at the worst possible time. Feedstock detail lives on the source pages: used cooking oil, animal fats and POME. ## What an HVO buyer will ask you We work with producers placing output, distributors and majors covering obligations, and larger fleet and industrial users buying HVO100 directly. Because we are independent and never take title, we can tell a buyer plainly when an offered parcel will not survive their own compliance review, which in a market where the certificate carries most of the value saves far more than negotiating the price. Related products from the same hydrotreating process: bionaphtha and SAF. ## What an HVO plant actually demands of a feedstock This is the part producers ask us about most and find hardest to get a straight answer on. A hydrotreater runs at high temperature and pressure over an expensive catalyst, and that catalyst is the whole economics of the plant. Phosphorus and metals poison it, and the damage is cumulative rather than recoverable: every tonne of dirty feed shortens the run. That is why pretreatment exists and why a buyer will interrogate your contaminant figures far harder than your FFA. Phosphorus: Commonly capped in the region of 30 ppm, with tighter operations wanting 15, 5 or lower still. Comes from phospholipids, which is exactly what degumming is there to remove. Alkali and alkaline earth metals: Sodium, potassium, calcium and magnesium. Typically limited to around 10 ppm total, often 5 or 1 for tighter units. Sodium and potassium arrive with caustic refining and catalyst residues; calcium and magnesium with the feedstock itself. Other metals: Iron, copper and the rest, on a similar order to the alkali metals. Iron often signals tank and pipework condition rather than the feedstock. Silicon: Very tight, commonly a few ppm and often 1. Usually arrives from antifoam agents used upstream, which is a nasty surprise because nobody thinks of antifoam as contamination. Nitrogen: Far more tolerant, with limits in the hundreds of ppm, but it consumes hydrogen and affects the catalyst, so it is priced rather than ignored. Water and impurities: You pay freight on both, and they drive the pretreatment load. Report them or a buyer will assume the worst. For scale: untreated fats, oils and greases can arrive carrying anywhere from a few ppm to a thousand ppm phosphorus and up to several hundred ppm total metals. The gap between that and the figures above is what pretreatment costs, and it is the single biggest reason two parcels of nominally the same product are quoted at very different prices. If you are selling, put phosphorus, the metals scan and silicon on your analysis unprompted. Almost nobody does, and it changes how you are read. ## Sources * Document checklist: exactly which papers a European buyer asks for, per product: /markets/document-library * SPECIMEN safety data sheet: HVO renewable diesel (worked example, all 16 sections): /documents/sds-hvo-renewable-diesel * EN 15940:2023, paraffinic diesel fuel requirements: https://standards.iteh.ai/catalog/standards/cen/81f825ab-600a-4696-802c-34829c64a642/en-15940-2023 * Directive (EU) 2018/2001 (RED II), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * ISCC System, the certification scheme itself: https://www.iscc-system.org/ ## Frequently asked questions Q: Where can I follow HVO market news and developments? A: This page carries a rolling news window with HVO and renewable diesel developments from public industry sources, updated continuously. For how HVO is actually quoted and what moves the price, see prices and market reads; for the feedstock side, the HVO, SAF and bionaphtha overview ties the three products together. Q: What is the difference between HVO and biodiesel? A: Chemistry, and it drives everything else. HVO is a paraffinic hydrocarbon with no oxygen in the molecule, made by hydrotreating. FAME biodiesel is an ester and does contain oxygen. That is why HVO drops straight into any diesel engine without modification while FAME is normally blended at low percentages, why HVO stores far better, and why they are sold against different standards: EN 15940 for HVO, EN 14214 for FAME. Quoting the wrong standard in an offer signals inexperience faster than almost anything else. Q: Does HVO perform better in cold weather? A: Yes, and by a wide margin. HVO can be produced to a cold filter plugging point well below minus twenty degrees, while FAME typically starts causing trouble somewhere between minus five and plus fifteen depending on the feedstock, which is exactly why the cold flow additive market exists on the FAME side. See additives and blending for what actually moves those numbers and, more importantly, whether your contract even allows you to move them. Q: How long does HVO keep in storage? A: Considerably longer than FAME, because there is no ester group to oxidise and it does not pick up water the same way. Suppliers quote storage lives in years rather than months, against roughly a year for conventional diesel. Treat the headline figures as supplier claims rather than guarantees and check the conditions attached, but the direction is not in dispute and it matters if you are holding stock through a season. Q: What contaminant limits does an HVO producer apply? A: Every plant sets its own and the contract governs, but the shape is consistent. Phosphorus is commonly capped around 30 ppm and often much lower. Alkali and alkaline earth metals, meaning sodium, potassium, calcium and magnesium, are typically limited to roughly 10 ppm in total and often 5 or 1. Other metals such as iron and copper sit on a similar order. Silicon is tighter still, frequently a few ppm or 1. Nitrogen is more tolerant, in the hundreds of ppm. These are catalyst poisons and the damage accumulates, which is why buyers interrogate them harder than they interrogate FFA. Q: Why does silicon matter so much in HVO feedstock? A: Because it poisons the hydrotreatment catalyst and the limits are among the tightest on the whole list, often a single ppm. The awkward part is where it comes from: antifoam agents used upstream, which nobody thinks of as contamination. It is one of the most common reasons a parcel that looked fine on paper fails at the gate, and one of the parameters most often missing from an analysis. Q: What is the difference between HVO and FAME biodiesel? A: HVO is a hydrocarbon made by hydrotreating fats and oils; FAME is an ester made by transesterification. HVO is specified under EN 15940, has excellent cold-flow properties, long storage life and no oxidation stability or microbial growth problems, and HVO100 can be used neat in approved applications. FAME is specified under EN 14214, is normally blended, and carries seasonal cold-flow and stability constraints that HVO does not. Q: What is HVO100? A: Neat HVO, 100 % hydrotreated vegetable oil with no fossil diesel blended in, used directly as a fuel in applications approved for it. Because it is a paraffinic hydrocarbon under EN 15940 rather than an ester, many diesel engines can run it, but the engine manufacturer's approval position is what matters to a fleet operator and should be checked rather than assumed. Q: Why is HVO hard to buy on the spot market? A: Because much of the European volume is contracted forward by parties covering a legal obligation under national RED III implementations. Genuine spot availability is thinner and more seasonal than headline production capacity suggests, which puts sellers holding certified volume in a defined delivery window in a stronger position than the raw supply numbers imply. Q: Does HVO count double towards renewable fuel targets? A: That depends on the member state and on the feedstock. Under RED III, national implementations diverge and several markets, including the Netherlands and Germany, have moved away from multipliers. Confirm the treatment in the specific destination market for the specific feedstock rather than relying on how the market worked historically. Q: What cold-flow properties can HVO achieve? A: Cold-flow behaviour is set during production through isomerisation, and HVO can be produced to very low CFPP values, considerably lower than FAME can reach without additives or winterisation. The practical answer is that you specify the grade you need for the destination and season and the producer makes it, rather than discovering a limitation after delivery. Q: Which feedstocks is HVO made from? A: Used cooking oil, animal fats, POME, technical and non-food vegetable oils, and crop oils. The feedstock determines the Annex IX classification and therefore the value, which is why the first question on any HVO offer should be what it was made from and under which certification scheme. ============================================================================== # Sustainable aviation fuel (SAF) brokerage URL: https://www.sustainablecommodities.eu/markets/saf We broker SAF and its feedstocks. On the specification: ASTM D7566 governs, organised as annexes per production pathway with a blend limit for each, and once correctly blended the fuel is treated as meeting ASTM D1655. On the commercial side, this is a mandate-driven market rather than a price-driven one, which changes who you should be talking to and when. Happy to look at where your material fits if it is useful. ## The obligation that makes the market ReFuelEU Aviation obliges aviation fuel suppliers at EU airports to supply a minimum share of SAF: 2 % from 2025, rising to 6 % from 2030 and further thereafter, with a separate sub-obligation for synthetic aviation fuels. That single fact explains most of how this market behaves. Because the obligation is legal and the penalties are real, volume is contracted forward by parties who must cover it. Spot SAF is scarce, and "available now" offers deserve more scrutiny than they usually receive, in a mandate-driven market, genuinely uncommitted volume is the exception. Alongside the EU obligation sits CORSIA, the ICAO global scheme, which uses its own eligibility rules and its own certification. A batch qualifying under one framework does not automatically qualify under the other, and conflating them is a common and expensive mistake. ## The eight approved routes, and where the volume actually is SAF is not one product. ASTM D7566 approves synthesised blending components under eight separate annexes, each a different production route with its own feedstock and cost base. An airline buying SAF is buying an annex. A1, FT-SPK: Route Fischer-Tropsch synthetic paraffinic kerosene; Feedstock in practice Gasified biomass, municipal waste, coal or gas A2, HEFA-SPK: Route Hydroprocessed esters and fatty acids; Feedstock in practice UCO, category 1 and 2 animal fats, vegetable oils. Carries almost all real volume today A3, SIP: Route Synthesised iso-paraffins; Feedstock in practice Fermented sugars A4, SPK/A: Route Fischer-Tropsch with aromatics retained; Feedstock in practice As A1 A5, ATJ-SPK: Route Alcohol to jet; Feedstock in practice Ethanol or iso-butanol A6, CHJ: Route Catalytic hydrothermolysis jet; Feedstock in practice Fats and oils A7, HC-HEFA-SPK: Route Hydrocarbon HEFA; Feedstock in practice Algal oil A8, ATJ-SKA: Route Alcohol to jet with aromatics; Feedstock in practice Ethanol Most annexes cap at 50 % blending. That is a certification limit on the finished fuel, not a shortage of ambition: neat paraffinic fuel lacks the aromatics that seals in older aircraft fuel systems rely on to swell. It is why 100 % SAF flights are demonstrations rather than routine operations. For a feedstock seller the consequence is narrow and useful: A2 is where your material goes. If someone offers you a SAF offtake for a feedstock no approved annex accepts, that offtake is not real yet. See demand outlook for the mandate schedule that creates the demand. ## Specification, pathways and blending SAF is not one product but a family of certified production pathways, each an annex to ASTM D7566, each with its own maximum blending ratio into conventional jet fuel. Once blended within the limit and released, the resulting fuel meets the conventional jet specification and is handled identically, same tanks, same hydrant, same aircraft. * HEFA-SPK (Annex A2): synthesized paraffinic kerosene from hydroprocessed esters and fatty acids, from fats, oils and greases. Blends at up to 50 %. The commercially mature pathway and the overwhelming majority of what trades today. Also written HEFA, and the two names mean the same fuel. * Alcohol-to-jet (ATJ): from ethanol or isobutanol. * Fischer-Tropsch (FT-SPK): from gasification of biomass or waste. * Synthetic / e-SAF (PtL): from renewable hydrogen and captured CO2. The subject of the separate ReFuelEU sub-obligation and, today, very limited volume. * Each pathway has a defined maximum blend ratio under its D7566 annex. Confirm the ratio for the specific pathway rather than assuming a single figure applies across all of them. Pathway and D7566 annex: HEFA, ATJ, FT-SPK or synthetic, with the applicable blending limit. Neat or blended: Neat SAF before blending, or blended and released to jet specification. Certification scheme: ISCC EU, ISCC CORSIA, RSB, matched to the claim the buyer needs to make. Framework: ReFuelEU, CORSIA or a voluntary corporate claim. Not interchangeable. GHG saving: The actual figure on the proof of sustainability. Feedstock: Annex IX status; drives eligibility and the cap that applies. Delivery point: Airport, terminal or refinery gate; who performs the blend and the release. Physical or book-and-claim: Whether the molecules and the claim travel together, and whether the buyer's framework permits separation. Chain of custody: Mass balance and the accounting period. ## Book-and-claim, and where it does not work Because SAF is physically scarce and airports are not evenly supplied, book-and-claim structures let a buyer fund SAF delivered elsewhere and claim the environmental attribute. That is legitimate and useful, but it is scheme-specific, and the rules differ between ISCC CORSIA, RSB and national systems. The right first question is therefore never "can I buy book-and-claim SAF" but "what exactly does the buyer need to claim, to whom, and under which framework". A corporate voluntary claim, a CORSIA offsetting claim and a ReFuelEU compliance obligation are three different things, and a structure that satisfies one may be worthless for another. ## What a SAF buyer will ask you We work between producers placing volume, aviation fuel suppliers covering the ReFuelEU obligation, airlines and corporate buyers. We are candid about what we can and cannot verify. SAF attracts a great deal of speculative offering, volumes that do not exist, pathways that are not certified, and documentation that will not survive an auditor. Where we cannot establish the pathway, the scheme and the chain of custody, we say so rather than pass the offer on. In this market a broker's value is largely in what they decline to forward. The feedstock side is on used cooking oil, animal fats and POME; the sister products from the same process are HVO and bionaphtha. ## Sources * IATA, SAF technical certification fact sheet: https://www.iata.org/contentassets/d13875e9ed784f75bac90f000760e998/saf-technical-certifications.pdf * ASTM D7566 approved SAF pathways, annex by annex: https://velocys.com/astm-approved-saf-pathways/ * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * ISCC System, the certification scheme itself: https://www.iscc-system.org/ ## Frequently asked questions Q: What feedstock can actually be used to make SAF today? A: In practice, whatever ASTM D7566 Annex A2 accepts, because HEFA is the only approved route carrying real volume. That means used cooking oil, category 1 and 2 animal fats, certain vegetable oils and other lipids. The other seven annexes are approved but small: Fischer-Tropsch needs gasified biomass, alcohol-to-jet needs ethanol or iso-butanol, and the algae route barely exists commercially. If someone offers you a SAF offtake for a feedstock no annex accepts, that offtake is not real yet. Q: Why is SAF capped at 50 % blending? A: Because that is the certification limit for most approved synthetic blending components under ASTM D7566. The blended product is then certified as conventional Jet A-1 under ASTM D1655. The limit exists because pure paraffinic fuel lacks the aromatics that seals in older aircraft fuel systems rely on to swell. That is why 100 % SAF flights are demonstrations rather than routine operations, and it is worth correcting early when a conversation assumes neat SAF into an existing fleet. Q: How much SAF does Europe actually have to buy? A: ReFuelEU Aviation obliges fuel suppliers at EU airports to blend 2 % from 2025, 6 % by 2030, 20 % by 2035 and 70 % by 2050. Inside that there is a separate synthetic fuel sub-mandate of 1.2 % by 2030 rising to 35 % by 2050. Read the sub-mandate carefully: it is carved out of the total, so the bio-based share grows more slowly than the headline suggests. See our demand outlook. Q: Is SAF the same as HVO? A: No, though they are made the same way and often in the same plant. Both are produced by hydrotreating fats and oils. HVO is a diesel-range paraffinic fuel specified under EN 15940; SAF is the kerosene fraction, specified under ASTM D7566 and then D1655. A producer choosing between them is choosing which cut to maximise, and that choice follows the price spread and the mandate, not the chemistry. Q: Can I sell my feedstock directly to an airline? A: Almost never. Airlines buy jet fuel from fuel suppliers, and the mandate sits on the supplier rather than the airline. Your material goes to a refiner or a hydrotreater who produces the SAF component, which then gets blended and certified. Understanding that chain saves a lot of wasted approaches: the person who wants your used cooking oil is three steps upstream of the airline whose name is in the headline. Q: What is HEFA SAF? A: HEFA, hydroprocessed esters and fatty acids, is the commercially mature route to sustainable aviation fuel, made from the same fats and oils used for HVO. It is certified under ASTM D7566 with a defined maximum blending ratio into conventional jet fuel, and it accounts for the overwhelming majority of SAF trading today. Q: What does ReFuelEU Aviation require? A: Aviation fuel suppliers at EU airports must supply a minimum share of SAF: 2 % from 2025, rising to 6 % from 2030 and increasing further thereafter, with a separate sub-obligation for synthetic aviation fuels. It is the main reason SAF is contracted forward rather than bought spot. Q: Can SAF be used neat in aircraft? A: Not under current certification. Each ASTM D7566 pathway carries a maximum blending ratio into conventional jet fuel, and once blended within that limit and released, the fuel meets the conventional jet specification and is handled identically. Confirm the limit for the specific pathway rather than assuming one figure applies to all of them. Q: What is book-and-claim SAF? A: A structure where a buyer funds SAF physically delivered elsewhere and claims the environmental attribute, used because SAF is scarce and unevenly distributed across airports. It is scheme-specific, the rules differ between ISCC CORSIA, RSB and national systems, so the first question is always what the buyer needs to claim and under which framework. Q: Is CORSIA the same as the EU SAF mandate? A: No, and treating them as interchangeable is a costly mistake. CORSIA is the ICAO global scheme with its own eligibility criteria and certification; ReFuelEU Aviation is an EU supply obligation. A batch that qualifies under one does not automatically qualify under the other, so the framework has to be named before anything else is agreed. Q: Why are so many SAF offers not real? A: Because demand is mandated and supply is scarce, which attracts speculative offering: volumes that do not exist, pathways that are not certified, and paperwork that will not survive an audit. We decline to forward offers where we cannot establish the pathway, the certification scheme and the chain of custody, in this market that filtering is a large part of what a broker is for. ============================================================================== # Bionaphtha brokerage URL: https://www.sustainablecommodities.eu/markets/bionaphtha Bionaphtha is the light co-product of hydrotreating fats and oils into HVO and SAF, and it has two possible homes with very different economics. Into a steam cracker it becomes certified renewable feedstock for bio-based polymers, and the premium comes from the claim a brand owner can make downstream. Into gasoline blending it is a good blend component and prices much closer to fossil naphtha. We broker it between producers and both sets of buyers, and which route is open depends almost entirely on the certification. ## Two routes, two prices Physically bionaphtha is a paraffinic light hydrocarbon in the naphtha range, and it is a perfectly ordinary cracker or blending feed. Commercially it is two different products. The petrochemical route is where the value is. A cracker takes bionaphtha under ISCC PLUS mass balance, and the polymer producer downstream sells a certified bio-based grade to a brand owner with a renewable-content commitment. The molecules are indistinguishable from fossil-derived ones once cracked; what is really being bought and sold is an auditable chain of custody. The gasoline route is straightforward and always available: a blend component with good properties and no certification requirement beyond the fuel regime. It sets the floor price. If the certification does not support the petrochemical claim, this is where the product goes, and the difference between the two outcomes is the entire commercial question. ## Two outlets, two completely different prices Bio-naphtha comes off an HVO or SAF unit as a co-product, and where it goes next decides what it is worth. There are two real outlets and they value it for opposite reasons, which is why a single price question is usually the wrong question. What the buyer is buying: Petrochemical cracker feed Renewable carbon that ends up in plastic; Gasoline blending Energy content and octane behaviour What they pay for: Petrochemical cracker feed The certificate and the mass balance claim; Gasoline blending The molecule Key parameters: Petrochemical cracker feed Paraffinicity, sulphur, chlorides, metals, final boiling point; Gasoline blending RVP, octane, oxygenate content Certification: Petrochemical cracker feed ISCC PLUS is usually the currency; Gasoline blending ISCC EU or the national fuel scheme Who signs: Petrochemical cracker feed A polymer producer or their broker; Gasoline blending A blender or trader The plastics route is normally where the value is, because a polymer producer under recycled and renewable content pressure is buying a claim they cannot easily get elsewhere, while a gasoline blender is buying a barrel they can get anywhere. That is not a rule and it moves with the market, but it is the first thing to test rather than the last. Sulphur and chlorides matter more than sellers expect on the cracker route. A cracker is protecting furnace tubes and downstream catalyst, and the tolerances are tighter than a fuel blender's. Get those two numbers before offering, because they decide which conversation you are allowed to have. ## Bio-based is not the same as circular This distinction catches people out constantly, and it matters because brand owners' commitments usually specify one or the other. Bionaphtha supports a bio-based claim: the carbon originated in biomass. Plastic pyrolysis oil supports a circular claim: the carbon came from recycled plastic waste. Both go into the same steam cracker, both travel on mass balance chain of custody, and both produce polymer that is chemically identical to conventional. But a converter with a *recycled content* target under the Packaging and Packaging Waste Regulation cannot satisfy it with bio-based material, and a brand owner with a *renewable feedstock* commitment may not want circular. So the first question on any bionaphtha enquiry is not price or volume but which claim the end buyer needs to make. See plastic pyrolysis oil for the circular side of the same cracker. ## What gets agreed Certification scheme and scope: ISCC PLUS for the petrochemical route; ISCC EU or REDcert where a fuel outlet applies. Claim type: Bio-based, and whether the downstream buyer needs bio-based specifically rather than circular. Mass balance period: The accounting window, aligned to the delivery schedule. Feedstock: Which fats and oils; Annex IX status where a fuel outlet is in play. GHG saving: The figure on the proof of sustainability where the claim depends on it. Distillation range and PIONA: Paraffins, isoparaffins, olefins, naphthenes, aromatics, cracker yield depends on it. Sulphur and nitrogen: Very low from hydrotreated origin; still verified. Metals and silicon: Carry-over from feedstock pretreatment. RVP and density: Relevant where gasoline blending is the outlet. Delivery basis: Parcel tanker, barge, isotank; terminal and tank availability. ## What a bionaphtha buyer will ask you We act for HVO and SAF producers placing the naphtha co-product, which is often treated as an afterthought internally despite being a genuine value stream, and for crackers, polymer producers and blenders sourcing it. Producers frequently undersell this material simply by offering it into the fuel pool because that is the easy call. Where the certification supports a petrochemical claim, the difference is worth the effort of finding the right buyer, and that is exactly the kind of introduction a broker exists to make. The sister products from the same process: HVO and SAF. ## Sources * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * ISCC PLUS, the scheme used for circular and bio based materials: https://www.iscc-system.org/certification/iscc-certification-schemes/iscc-plus/ ## Frequently asked questions Q: What is bio-naphtha used for? A: Two things, and they pay differently. As a petrochemical cracker feedstock it becomes renewable plastic, and the buyer is purchasing a certified claim under mass balance. As a gasoline blend component it is bought for energy and octane. The plastics route is usually where the value is, because a polymer producer under recycled and renewable content pressure cannot easily get that claim elsewhere. Q: Is bio-naphtha the same as renewable naphtha? A: Yes, the terms are used interchangeably. It is the light paraffinic cut from hydrotreating fats and oils, produced alongside HVO and SAF in the same plant. Because it is a co-product, availability follows the operator's HVO and SAF economics rather than demand for naphtha itself. Q: What does a cracker screen bio-naphtha on? A: Paraffinicity, sulphur, chlorides, metals and the final boiling point. Sulphur and chlorides matter more than sellers expect: a cracker is protecting furnace tubes and downstream catalyst, and its tolerances are tighter than a fuel blender's. Get those two numbers before offering, because they decide which conversation you are allowed to have. Q: What is bionaphtha? A: The light hydrocarbon co-product of hydrotreating fats and oils into HVO renewable diesel or HEFA SAF. It is a paraffinic naphtha-range material that can be cracked into bio-based petrochemicals or blended into gasoline. It is bio-based rather than recycled, which determines which downstream claims it can support. Q: What is the difference between bionaphtha and plastic pyrolysis oil? A: The origin of the carbon and therefore the claim. Bionaphtha comes from biomass and supports a bio-based claim; plastic pyrolysis oil comes from waste plastic and supports a circular or recycled-content claim. Both feed the same steam crackers under mass balance chain of custody and both yield chemically identical polymer, but they are not interchangeable for a buyer with a specific target to meet. Q: Why does bionaphtha sell at a premium to fossil naphtha? A: Only when it goes to a steam cracker under ISCC PLUS mass balance, because that lets the polymer producer downstream sell a certified bio-based grade to a brand owner with a renewable-content commitment. The premium is for the auditable chain of custody, not for the hydrocarbon. Into gasoline blending it prices much closer to fossil naphtha. Q: What certification does bionaphtha need for the petrochemical route? A: ISCC PLUS with mass balance chain of custody is the standard route in Europe. Check that the certificate scope covers the actual product and activity and that the mass balance accounting period lines up with the delivery schedule, a valid certificate that is out of period causes exactly the same problem as no certificate. Q: Can bionaphtha be used in gasoline? A: Yes. It is a good blend component and this route is always available, which is why it effectively sets the floor price. It requires no certification beyond the applicable fuel regime, so it is where the material goes when the petrochemical claim cannot be supported. Q: Do producers undervalue their bionaphtha? A: Frequently, yes. It is a co-product rather than the main output, so it often gets offered into the fuel pool by default because that is the simplest call internally. Where the certification supports a petrochemical claim, finding the right cracker or polymer buyer is worth the effort, and that introduction is precisely what a broker is for. ============================================================================== # Annex IX Part A and Part B feedstock lists URL: https://www.sustainablecommodities.eu/markets/annex-ix-feedstocks Annex IX is where the value sits, and where most of the arguments start. On Part A: double counting where a member state allows it, which is why the letter your feedstock sits under matters more than the tonne. On Part B: UCO and animal fats, capped in most member states. On what we see go wrong, it is almost never the material and almost always the documentation behind the claim. Send us the certification chain and we will tell you whether it holds. ## Annex IX Part A, the complete list The full list, in order, as set out in Directive (EU) 2018/2001. Part A is the advanced category and counts towards the advanced sub-target rather than the general one. (a): Algae if cultivated on land in ponds or photobioreactors (b): Biomass fraction of mixed municipal waste, but not separated household waste (c): Biowaste from private households subject to separate collection (d): Biomass fraction of industrial waste not fit for use in the food or feed chain (e): Straw (f): Animal manure and sewage sludge (g): Palm oil mill effluent and empty palm fruit bunches (h): Tall oil pitch (i): Crude glycerine (j): Bagasse (k): Grape marcs and wine lees (l): Nut shells (m): Husks (n): Cobs cleaned of kernels of corn (o): Biomass fraction of wastes and residues from forestry and forest-based industries: bark, branches, pre-commercial thinnings, leaves, needles, tree tops, saw dust, cutter shavings, black liquor, brown liquor, fibre sludge, lignin and tall oil (p): Other non-food cellulosic material (q): Other ligno-cellulosic material except saw logs and veneer logs Two of those entries are routinely cited wrongly. POME is at (g), not (h); (h) is tall oil pitch. And (f) is a single entry covering animal manure and sewage sludge, not two. If you are writing a sustainability declaration, the letter is the thing an auditor checks. Note also that tall oil appears inside (o), while tall oil pitch has its own entry at (h). Those are different positions for two different products off the same mill. See crude tall oil. ## Annex IX Part B, the complete list Part B is two entries long. That is the whole list, and it carries most of the volume in the European waste-based market. (a): Used cooking oil (b): Animal fats classified as categories 1 and 2 in accordance with Regulation (EC) No 1069/2009 Everything else you may have been told is in Part B is not in Part B. Category 3 animal fat is not there. Fish oil is not there. Acid oils are not there by name. That does not always mean the material has no route, but it does mean the route has to be established rather than assumed. ## The 2024 amendment, and why it matters this year Commission Delegated Directive (EU) 2024/1405 of 14 March 2024 amended Annex IX to add further feedstocks. Member States were required to transpose it by 14 September 2025, so it is now live in national law rather than pending. * It adds feedstocks to Part A exclusively where they are used to produce aviation fuel, and to Part B where they are used for other biofuels. The same material can therefore sit in a different part depending on where it ends up, which is unusual and easy to miss. * It brings in intermediate crops and non-food and feed crops grown on severely degraded land, which is a genuine widening rather than a tidying up. * Definitions for several of the new entries were contested at the time and guidance was requested from the Commission. Do not assume your certifier reads a new entry the way you do. The practical rule has not changed: the letter and the part are decided by your certification body against the current consolidated text, not by a website. What we can tell you is where a product usually lands and what normally goes wrong, which is what the rest of this page is for. ## Where our products actually sit The question we are asked most often, in one place. Read the middle column as where material of this type is usually placed, not as a ruling. Used cooking oil: Usual position Part B (a); What decides it Straightforward. Collection documentation is the real work Animal fat cat 1 and cat 2: Usual position Part B (b); What decides it The ABP category and the establishment approval Animal fat cat 3: Usual position Not in Annex IX; What decides it Food-chain origin. A different market, priced differently POME: Usual position Part A (g); What decides it Must be effluent, not diverted crude palm oil Empty palm fruit bunches: Usual position Part A (g); What decides it Same entry as POME Crude glycerine: Usual position Part A (i); What decides it Crude, not refined Tall oil pitch: Usual position Part A (h); What decides it Pitch specifically, not crude tall oil Tall oil: Usual position Within Part A (o); What decides it As a forestry residue, inside the composite entry SSAO (soapstock acid oil): Usual position Requires assessment; What decides it An acid oil from refining. Usually argued under Part A (d) as industrial waste not fit for food or feed, but the assessment is stream-specific and certifiers do not all treat it the same way SBEO (spent bleaching earth oil): Usual position Requires assessment; What decides it Same logic and the same uncertainty as SSAO PFAD and POME-FAD: Usual position Requires assessment; What decides it Treatment differs by member state and has changed over time Fish oil from processing residues: Usual position Requires assessment; What decides it Not named as its own entry Pyrolysis oil from waste plastic: Usual position Not in Annex IX at all; What decides it Non-renewable carbon. Governed by the recycled carbon fuel rules instead The pattern is worth naming. The clean cases are the ones written into the list by name. Everything derived from a refining step, an acid oil or a residue-of-a-residue, sits in an assessment rather than in a letter, and that is where deals stall. If your material is in the lower half of that table, budget time for the certifier at the start rather than discovering it after a buyer has been found. ## Multipliers, caps and why the same cargo is worth different money by country This is the part that surprises people who assume a directive means one rule. * The 1.7 % Part B cap is a volume ceiling, applied per member state. It limits how much used cooking oil and category 1 and 2 animal fat can count, regardless of how much is available. * Multipliers are a separate question and are national. Double counting was a feature of earlier implementations. Under RED III several member states, including the Netherlands and Germany, have moved away from it in national law. Do not assume double counting applies where you are selling. * Part A has its own sub-target, which is why advanced material and Part B material do not compete for the same slot even when they compete for the same truck. * Italy runs its own national certification system, the Sistema Nazionale di Certificazione administered by GSE, alongside the recognised voluntary schemes. Italy transposed RED III with effect from February 2026. Renewable share in transport by 2030: At least 29 % of final energy consumption in transport, or the greenhouse gas route below. Article 25. Greenhouse gas intensity reduction by 2030: At least 14,5 %, as the alternative to the 29 % share. A member state picks one route, and which one it picked changes what your cargo is worth there. Article 25. Annex IX Part A and RFNBO combined: At least 1 % in 2025 and 5,5 % in 2030. Article 25. Of which renewable fuels of non-biological origin: At least 1 percentage point in 2030. Article 25. Cap on Annex IX Part B: 1,7 % of the energy supplied to transport. This is the ceiling that decides how much used cooking oil and category 1 and 2 animal fat can count at all. Article 27. Member states outside that cap: Cyprus and Malta, and no others. Article 27. Can the 1,7 % cap be raised?: Yes. A member state may increase it where justified, taking into account the availability of Part B feedstock. It has to notify the Commission with reasons, and the increase needs Commission approval. So the cap is a default, not a wall. Article 27. Do recycled carbon fuels count towards the target?: Not automatically. The directive says member states MAY take recycled carbon fuels into account when calculating the greenhouse gas intensity reduction. Whether your RCF cargo counts is therefore a national question, not an EU one. Article 27. The practical consequence for a seller is simple and slightly uncomfortable: the destination country changes the value of your cargo more than the assay does. Before you accept a price, know which member state the material is being counted in and under which mechanism. We will tell you what we know, and we will tell you when it is a question for the buyer's compliance desk rather than for us. ## Part A: advanced feedstocks Feedstocks for the production of biogas for transport and advanced biofuels. These count towards the advanced sub-target rather than the general one. (a): Algae if cultivated on land in ponds or photobioreactors (b): Biomass fraction of mixed municipal waste, but not separated household waste subject to recycling targets (c): Biowaste from private households subject to separate collection (d): Biomass fraction of industrial waste not fit for use in the food or feed chain, including material from retail and wholesale and the agro-food and fish and aquaculture industry, and excluding Part B feedstocks (e): Straw (f): Animal manure and sewage sludge (g): Palm oil mill effluent and empty palm fruit bunches (h): Tall oil pitch (i): Crude glycerine (j): Bagasse (k): Grape marcs and wine lees (l): Nut shells (m): Husks (n): Cobs cleaned of kernels of corn (o): Biomass fraction of wastes and residues from forestry and forest-based industries: bark, branches, pre-commercial thinnings, leaves, needles, tree tops, saw dust, cutter shavings, black liquor, brown liquor, fibre sludge, lignin and tall oil (p): Other non-food cellulosic material (q): Other ligno-cellulosic material except saw logs and veneer logs ## Part B: used cooking oil and animal fats Part B is two entries long, and it carries most of the volume in the European waste-based market. (a): Used cooking oil (b): Animal fats classified as categories 1 and 2 in accordance with Regulation (EC) No 1069/2009 ## Three traps that cost real money Category 3 animal fat is not in Part B. It is treated differently from categories 1 and 2, which is worth settling before a term contract is priced: see animal fats and tallow. Note also what is not in Annex IX at all. Fuels made from non-renewable waste such as non-recyclable plastic sit outside this list entirely, under the separate recycled carbon fuel rules: see recycled carbon fuels. And one case that sits on both sides of the line. A tyre is part natural rubber and part synthetic, so tyre pyrolysis oil carries biogenic and fossil carbon together. Under RED III the biogenic fraction is treated as an advanced biofuel aligned with Part A, while the fossil fraction goes the recycled carbon fuel route. Which means a single cargo can use both frameworks at once, provided the biogenic share is measured by radiocarbon analysis. See tyre pyrolysis oil. * The letters move. Annex IX has been amended, and a letter that was correct under RED II is not necessarily the same letter under the current consolidated text. Quoting a letter from an old contract template into a new one is a recurring and avoidable error. Reference the feedstock by name as well as by letter. * Multipliers are national now. Double counting was a feature of earlier implementations. Under RED III several member states, including the Netherlands and Germany, have moved away from multipliers. "Double counting material" means nothing until you name the destination market. * The cap and the multiplier are different things. The 1.7 % Part B limit is a cap on volume contribution. Any multiplier is a separate accounting question. Confusing the two produces netback numbers that are wrong by a wide margin. ## Sources * Annex IX to Directive (EU) 2018/2001, full text: https://www.legislation.gov.uk/eudr/2018/2001/annex/IX * Commission Delegated Directive (EU) 2024/1405 amending Annex IX: https://eur-lex.europa.eu/eli/dir_del/2024/1405/oj/eng * Directive (EU) 2018/2001 (RED II), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * Directive 2008/98/EC, the Waste Framework Directive: https://eur-lex.europa.eu/eli/dir/2008/98/oj ## Frequently asked questions Q: Someone asked me for "annex 9" and "euro 1" documents. What do they mean? A: Ask them, because those two words are used for different things and getting it wrong holds up a cargo. EUR.1 is a movement certificate used to claim preferential origin under a trade agreement, and it has nothing to do with sustainability. "Annex 9" is ambiguous: people use it for evidence that the feedstock sits on the Annex IX list, and people also use it for the waste shipment paperwork, whose annexes are numbered differently again. We have seen a buyer ask this question about a contract they had already approved, which tells you how common the confusion is. Get the document named exactly, in writing, before you agree the payment terms. Q: How do I prove which part my material falls under? A: Not by asserting it. The evidence sits in the chain: the certificate scope of the party that produced it, the Sustainability Declaration that travels with the consignment, and the audit trail behind both. A buyer's compliance desk books against the declaration, so that document has to carry the category and be consistent with the certificate behind it. See Proof of Sustainability for what has to be on it. If your material is genuinely eligible but the paperwork does not show it, the problem is fixable; if the chain has a gap, it usually is not fixable after the fact. Q: Is a waste code the same thing as an Annex IX classification? A: No, and they answer different questions. Annex IX decides what a fuel can be counted as under the Renewable Energy Directive. A waste code comes from waste legislation and decides how the material may be moved and handled. A parcel can need both, and some member states lead with the waste code: on the Polish market it is regularly the first thing a buyer asks about, before certification comes up at all. If a counterparty asks for a waste code and you answer with an Annex IX category, you have not answered the question. Q: Does double counting still apply in the Netherlands and Germany? A: No, and that is a change worth checking your pricing against. RED III made double counting a member state choice, and the two historically largest markets for double-counted volumes, the Netherlands and Germany, have dropped the multiplier in their transposition. In those markets an Annex IX Part A claim has to earn its value on the market alone, so check the transposition in the member state of consumption rather than assuming the multiplier from older guidance. Q: Is Annex 9A the same as Annex IX Part A? A: Yes. The lists are one and the same, written three ways: Annex IX Part A under Directive (EU) 2018/2001 (RED II), carried over into RED III, Directive (EU) 2023/2413, and often written as Annex 9A or Annex 9 Part A in software, permits and older correspondence. Part B is the same list that gets called Annex 9B. If a counterparty argues about the number instead of the entry, they are arguing about stationery. What matters is the exact entry letter, and the certification behind it, because that is what decides whether double counting applies in your member state. Q: What is the difference between Annex IX Part A and Part B? A: Part A lists advanced feedstocks, mostly lignocellulosic material, wastes and residues, and counts towards the advanced sub-target. Part B contains only two entries, used cooking oil and category 1 and 2 animal fats, and biofuels from Part B are capped at 1.7 % of transport energy per member state. The split determines which target a fuel serves and therefore what it is worth. Q: Is crude glycerine an Annex IX feedstock? A: Yes. Crude glycerine appears in Annex IX Part A, at point (i) in Directive (EU) 2018/2001. That places it in the advanced category rather than the capped Part B category, which is a meaningful commercial difference. Check the current consolidated text for the applicable letter, because Annex IX has been amended. Q: Which part is POME in? A: Palm oil mill effluent and empty palm fruit bunches appear in Annex IX Part A, at point (g) in Directive (EU) 2018/2001. Because the Annex has been amended since, confirm the current letter before writing it into a contract, and confirm how the destination member state actually treats POME: national implementations diverge. Q: Is category 3 animal fat in Annex IX? A: No. Part B covers animal fats classified as categories 1 and 2 under Regulation (EC) No 1069/2009. Category 3 is treated differently, which has a direct effect on value and should be settled before pricing a term contract. Q: Does Annex IX material still count double? A: That now depends on the member state. Under RED III national implementations diverge, and several markets including the Netherlands and Germany have moved away from multipliers. The 1.7 % Part B cap is a separate matter from any multiplier, and confusing the two produces badly wrong netback calculations. Q: Is tyre pyrolysis oil in Annex IX? A: Partly, and it is the most interesting case in the list. A tyre is part natural rubber and part synthetic, so the oil carries biogenic and fossil carbon together. Under RED III the biogenic fraction is treated as an advanced biofuel aligned with Annex IX Part A, while the fossil fraction can go the recycled carbon fuel route. One cargo, two frameworks, with the split established by radiocarbon analysis. Q: Where is the official list? A: Annex IX to Directive (EU) 2018/2001, as amended, including by Directive (EU) 2023/2413. The list above is reproduced for orientation. For anything you are contracting on, use the current consolidated text in the Official Journal. ============================================================================== # Recycled carbon fuels (RCF) URL: https://www.sustainablecommodities.eu/markets/recycled-carbon-fuels Recycled carbon fuels are liquid or gaseous fuels made from waste or exhaust gas of non-renewable origin, where the waste is no longer suitable for material recycling. In practice that means non-recyclable plastic waste and unavoidable industrial waste gases, usually converted by pyrolysis or gasification. The critical point, and the one that catches people out: an RCF is not a renewable fuel. It sits outside Annex IX entirely and is accounted for under its own rules, with a 70 % greenhouse gas saving threshold set by Delegated Regulation (EU) 2023/1185. ## What qualifies, and what does not * Non-recyclable waste. The waste has to be genuinely unsuitable for material recycling. Material that could have been mechanically recycled does not become an RCF feedstock because someone chose not to recycle it. * Unavoidable industrial waste gases. Gases produced inevitably and unintentionally as a by-product of an industrial process, for example steel mill off-gases. Deliberately produced gas does not qualify. * Non-renewable origin. This is what separates RCF from biofuels. Biogenic carbon routes go to Annex IX; fossil-origin carbon in waste goes to RCF. * Typically thermochemical. Pyrolysis and gasification are the usual conversion routes, which is why this category matters so much to anyone in plastic pyrolysis oil. * The fossil half of tyre pyrolysis oil. Synthetic rubber is fossil carbon, so the non-biogenic fraction of TPO falls here while the biogenic fraction is treated as an advanced biofuel. That makes tyre-derived oil the clearest example of one cargo using two frameworks at once. See tyre pyrolysis oil. ## Why a recycled carbon fuel is not a biofuel, and what that costs This is the distinction that catches people out. A fuel made from non-recyclable plastic waste is not a biofuel and is not in Annex IX. It is a recycled carbon fuel, governed by its own rules, and it does not automatically count towards the same targets. Assuming otherwise has underwritten more than one business plan that did not survive contact with a fuel supplier's compliance desk. Carbon origin: Waste-based biofuel Biogenic waste or residue; Recycled carbon fuel Non-renewable waste, typically non-recyclable plastic; Fossil Crude Listed in Annex IX: Waste-based biofuel Yes, Part A or Part B; Recycled carbon fuel No; Fossil No GHG saving threshold: Waste-based biofuel Per RED, by plant commissioning date; Recycled carbon fuel 70 % against a 94 gCO2e/MJ fossil comparator; Fossil Not applicable Counts towards the renewable target: Waste-based biofuel Yes; Recycled carbon fuel Member state discretion; not automatic; Fossil No Typical products: Waste-based biofuel HVO, FAME, biomethane, SAF; Recycled carbon fuel Pyrolysis-derived naphtha and fuels; Fossil Refinery slate The 70 % threshold is the gate. A recycled carbon fuel has to demonstrate at least a 70 % greenhouse gas saving against a fossil comparator of 94 gCO2e/MJ, and the methodology for that is set out in Commission Delegated Regulation (EU) 2023/1185. That calculation is a project-level exercise, not a product property, so two plants running the same feedstock can land on different sides of it. There is a second route that avoids the question entirely: sell the pyrolysis oil as a chemical feedstock rather than as a fuel. A steam cracker taking it towards new polymer is working under mass balance and recycled content rules instead, which is a different conversation with different economics. See plastic pyrolysis oil. ## The threshold and the accounting Delegated Regulation (EU) 2023/1185 sets both the methodology and the bar: an RCF must deliver at least a 70 % greenhouse gas saving against the fossil comparator. In practice that translates to total life-cycle emissions of no more than roughly 28.2 g CO2e per MJ, the same reference point applied to renewable fuels of non-biological origin. Because an RCF is not renewable, it does not count towards renewable energy targets in the way a biofuel does. Member states may allow RCFs to count towards a greenhouse gas intensity reduction target, and national treatment varies a lot. This is the first thing to establish before contracting: name the destination member state and confirm in writing how it treats RCF, for the delivery years in question. Certification runs through the voluntary schemes, with REDcert and ISCC both operating RCF and RFNBO scope. As with everything else in this chain, check that the certificate scope actually covers the product and the activity. ## Four categories that people mix up, and the 70 percent trap Almost every argument we hear about recycled carbon fuels comes from someone using the word for something that is not one. The categories are legally distinct, they are accounted for differently, and a volume in the wrong box is worth a different amount of money. Biofuel: From biomass. Counts towards renewable targets, and if the feedstock sits in Annex IX Part A it can be double counted where a member state allows it. See Annex IX feedstocks. Recycled carbon fuel (RCF): From non renewable waste streams that are not suitable for material recovery, or from unavoidable industrial process and exhaust gases. Defined in Article 2(35) of RED. NOT renewable, so it does not count towards a renewable target. A member state MAY allow it against a greenhouse gas intensity target, and national treatment varies. RFNBO: Renewable fuel of non biological origin: hydrogen and its derivatives made with renewable electricity. Renewable, but under its own strict additionality and correlation rules. Low carbon fuel: Low carbon hydrogen and synthetic fuels derived from it, governed separately under the gas market rules rather than under RED. Delegated Regulation (EU) 2025/2359 sets the methodology here and expressly EXCLUDES recycled carbon fuels, because those stay under RED. Here is the trap. A 70 percent greenhouse gas saving threshold appears in more than one of these regimes, so people assume the regimes are interchangeable. They are not. For RCF the threshold comes from Delegated Regulation (EU) 2023/1185 and is measured against a fossil comparator of 94 grams CO2 equivalent per megajoule, which puts the ceiling at roughly 28.2 grams per megajoule for the finished fuel. Meeting 70 percent under one regime tells you nothing about your position under another, and the certification scope on your certificate has to match the category you are actually selling into. ## Why this matters commercially For a plastic pyrolysis operator there are two entirely different business models sitting on the same reactor, and the choice is usually made too late. * The petrochemical route. The oil goes to a steam cracker under ISCC PLUS mass balance and becomes certified circular polymer. The value is in the recycled-content claim a brand owner needs. Annex IX and RCF are both irrelevant here, because nothing is being burned. * The fuel route. The oil becomes a transport fuel, and then RCF rules decide whether it counts for anything. Meet the 70 % threshold and get national recognition, and it has value; miss either, and it is simply a hydrocarbon competing on energy content. * These two routes reward different things. The petrochemical route rewards low chlorine and a clean chain of custody. The fuel route rewards a defensible greenhouse gas calculation. A plant that has not decided which it is aiming at tends to be weak at both. ## Sources * Directive (EU) 2018/2001 (RED II), Article 2(35), on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj * Delegated Regulation (EU) 2023/1185, the RCF threshold and methodology: https://eur-lex.europa.eu/eli/reg_del/2023/1185/oj * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * ISCC PLUS, the scheme used for circular and bio based materials: https://www.iscc-system.org/certification/iscc-certification-schemes/iscc-plus/ ## Frequently asked questions Q: Do recycled carbon fuels double count under RED III? A: No. Recycled carbon fuels count once towards the transport target: they sit outside Annex IX, so there is no double counting and no advanced biofuel multiplier, wherever you are in the EU. The nuance is the same cargo can carry both frameworks: the fossil fraction of tyre pyrolysis oil counts as an RCF while the biogenic fraction of the very same oil can be an advanced biofuel under Annex IX Part A. Which is why the biogenic share, measured by carbon-14, is part of the product rather than a nice extra. Q: What is the difference between a recycled carbon fuel and a biofuel? A: Feedstock origin, and it changes how the volume counts. A biofuel comes from biomass and counts towards renewable targets. A recycled carbon fuel comes from non renewable waste streams not suitable for material recovery, or from unavoidable industrial process gases, and is defined in Article 2(35) of RED. An RCF is not renewable, so it cannot count towards a renewable target. A member state may allow it against a greenhouse gas intensity target instead, and that decision is national. Q: Does the 70 percent threshold for recycled carbon fuels mean the same as the 70 percent for low carbon fuels? A: No, and this catches people out. For recycled carbon fuels the threshold comes from Delegated Regulation (EU) 2023/1185, measured against a fossil comparator of 94 grams CO2 equivalent per megajoule. The separate methodology for low carbon fuels, in Delegated Regulation (EU) 2025/2359, expressly excludes recycled carbon fuels: those stay under RED. Same number, different regime, different certification scope. Check that your certificate covers the category you are actually selling into. Q: Is pyrolysis oil from plastic a recycled carbon fuel? A: It can be, if it goes to fuel and the waste stream genuinely was not suitable for material recovery. That last condition is the one that gets skipped. If the material could have been recycled, the RCF route is not automatically open, and the same oil sent to a cracker for new polymer is a different proposition commercially and legally. See plastic pyrolysis oil. Q: What is a recycled carbon fuel? A: A liquid or gaseous fuel produced from waste or exhaust gas of non-renewable origin, where the waste is no longer suitable for material recycling. Typical examples are fuels from non-recyclable plastic waste and from unavoidable industrial waste gases, usually made by pyrolysis or gasification. Q: Is a recycled carbon fuel a renewable fuel? A: No, and this is the most common misunderstanding. RCFs are made from non-renewable carbon and sit outside Annex IX entirely. They are accounted for under their own rules, and member states may allow them to count towards a greenhouse gas intensity target rather than a renewable energy target. National treatment varies. Q: What greenhouse gas saving does an RCF have to achieve? A: At least 70 % against the fossil comparator, under the methodology in Delegated Regulation (EU) 2023/1185. That corresponds to total life-cycle emissions of no more than about 28.2 g CO2e per MJ, the same reference point used for renewable fuels of non-biological origin. Q: Is plastic pyrolysis oil an RCF? A: It can be, when it is used as a fuel and meets the RCF criteria and threshold. It is not an RCF when it goes to a steam cracker as circular feedstock, because it is not being used as a fuel at all. Those are two different business models on the same product and they reward different things. Q: Can RCF be certified? A: Yes. The voluntary schemes operate RCF scope, with REDcert and ISCC both active in this area alongside RFNBO certification. Check that the certificate scope covers the specific product and activity, and that the greenhouse gas calculation will stand up to audit. Q: Do all member states recognise RCF? A: No, and treatment differs considerably. Because RCFs are not renewable fuels, whether and how they count is a national decision. Establish the position for your destination market and delivery years in writing before contracting. This is the single biggest commercial risk in an RCF deal. ============================================================================== # Crude and refined glycerine brokerage URL: https://www.sustainablecommodities.eu/markets/glycerine We broker crude, technical and refined glycerine between biodiesel producers and the refiners, oleochemical plants and biogas operators who take it. On what decides the price: five numbers, and an offer without them is an enquiry rather than an offer. Glycerol content, water, ash, MONG and residual methanol. On the paperwork, crude glycerine sits in Annex IX Part A, which a surprising number of producers still treat as a disposal problem. ## Two products, several markets The gap between crude and refined is refining capacity, and it is not evenly distributed. A producer sitting near a refiner has options a producer in the wrong location does not, which is often worth more than a point of purity. * Crude glycerine, typically around 80 % glycerol, straight from transesterification. Carries salts, methanol and organic residue. Outlets: advanced biofuel and biogas routes, glycerine refiners, and industrial use. * Technical and refined glycerine, typically 99 % and above, after refining and distillation. Outlets: chemicals, resins, antifreeze, personal care, tobacco humectants and animal feed. * USP and pharmaceutical grade, the highest specification, with its own documentation requirements and a much narrower buyer list. ## Crude, technical and refined, and the gap between them Glycerine is sold in three broad conditions and they are barely the same trade. Crude glycerine comes off a biodiesel plant as a co-product and is priced as a problem to be solved; refined glycerine is a pharmacopoeia-grade chemical. The distance between them is a refinery, and it shows in the price. Glycerol content: Crude (biodiesel co-product) 80 % min is the common basis; 85 and 88 % also trade; Refined USP / EP 99.5 % min Water: Crude (biodiesel co-product) Roughly 10 to 15 %; Refined USP / EP Per pharmacopoeia Ash: Crude (biodiesel co-product) 2 to 8 %; Refined USP / EP Effectively nil Salt (NaCl or K salts): Crude (biodiesel co-product) Up to about 4 %; Refined USP / EP Effectively nil Methanol: Crude (biodiesel co-product) Below 0.5 % in well-stripped material; Refined USP / EP Nil MONG (matter organic non-glycerol): Crude (biodiesel co-product) The line that decides the discount; Refined USP / EP Not applicable pH: Crude (biodiesel co-product) Stated on the offer; alkaline unless neutralised; Refined USP / EP Per pharmacopoeia Colour: Crude (biodiesel co-product) Dark, variable; Refined USP / EP Water white MONG is the number that gets argued about. It is everything organic that is not glycerol: soaps, residual esters, free fatty acid carry-over. A refiner prices high-MONG material down hard because it is what fouls the process, so a seller quoting only glycerol content is quoting half the specification. Methanol matters for a different reason. Above roughly half a percent it turns a routine bulk liquid into a classification and transport question, and that is a conversation to have before the truck is booked rather than at the gate. The same applies to whether the material is palm, rapeseed, soy or mixed origin, because the certification route follows the feedstock. ## What buyers screen on Glycerol content (purity): Percentage. The headline number: roughly 80 % for crude, 99 %+ for refined grades. MONG: Matter organic non-glycerol. The organic impurity load, and the key indicator of refining difficulty. Ash / salt content: Sodium or potassium salts from the catalyst. Drives refining cost and rules out some outlets outright. Methanol: Residual from transesterification. A safety, transport and classification issue as much as a quality one. Water content: Settlement weight and processing yield. pH: Handling, storage and materials compatibility. Colour: APHA or Gardner. Matters most for refined and technical grades. Chlorides and sulphates: Corrosion and downstream process impact. Feedstock origin: Vegetable, animal or used cooking oil origin. Decides certification and, for some outlets, acceptability. Certification: ISCC EU where the glycerine is heading into the biofuel or biogas chain. Heavy metals, DEG/MEG: For refined, food and pharmaceutical grades. ## The Annex IX angle worth knowing Crude glycerine sits in Annex IX Part A at point (i) in Directive (EU) 2018/2001. Part A is the advanced category, which is a different and generally more favourable position than the Part B category that used cooking oil and category 1 and 2 animal fats occupy under a 1.7 % cap. This matters because a good deal of crude glycerine is still sold as a low-value disposal problem by producers who treat it as waste from the biodiesel plant rather than as a listed advanced feedstock. Where the certification supports it, the biogas and advanced biofuel routes can pay materially better than the industrial default. Annex IX has been amended since 2018, so confirm the current letter before writing it into a contract. The full lists are on our Annex IX reference page. ## What a glycerine buyer will ask you We act for biodiesel and oleochemical producers with continuous co-product to place, and for refiners, biogas operators and chemical buyers sourcing it. Glycerine production does not stop while a seller shops for a better number, so most of what we do here is term rather than spot: a reliable home for every batch, with the analysis, certification and tank logistics agreed once. ## The grades, and the one number that decides the price Glycerine is sold across a very wide quality range and the words people use for it are loose. What is not loose is the arithmetic. Crude glycerine: Straight from the biodiesel reactor. Typically 50 to 85 percent glycerol, with water, methanol, catalyst salts and MONG making up the rest. The 80 percent plus material trades readily; below that the conversation gets harder quickly. Technical grade: Purified, commonly around 98 to 99 percent, for industrial use where pharmacopoeia compliance is not required. Refined / USP / pharmacopoeia: Over 99.5 percent, for pharmaceutical, food and personal care use. A different market with different qualification requirements. MONG: Matter Organic Non-Glycerol, and the number that most often decides whether a parcel moves. Calculated rather than measured directly: MONG = 100 minus glycerol, minus water, minus ash. ISO 2464 covers the calculation. It sweeps up free fatty acids, mono and diglycerides and everything else organic that is not glycerol. Methanol: Residual from the transesterification. Well processed material keeps it below about 0.5 percent. It matters for classification and transport as well as for the buyer's process. Ash: Catalyst salts, sodium or potassium depending which alkoxide the plant runs. See additives and blending on why that choice was made upstream. The practical read: a crude glycerine offer without glycerol content, water, ash, MONG and methanol on it is not an offer, it is an enquiry. Those five figures let a buyer calculate what they are actually paying for, and supplying them unprompted marks you out immediately. ## Sources * Document checklist: exactly which papers a European buyer asks for, per product: /markets/document-library * SPECIMEN safety data sheet: Crude glycerine (worked example, all 16 sections): /documents/sds-crude-glycerine * Glycerine grade specifications, crude through USP: https://www.srsbiodiesel.com/technologies/glycerin-purification/glycerin-specifications/ * Directive (EU) 2018/2001 (RED II), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * ISCC System, the certification scheme itself: https://www.iscc-system.org/ ## Frequently asked questions Q: What is MONG in glycerine and why does everyone ask about it? A: MONG is Matter Organic Non-Glycerol: everything organic in the parcel that is not glycerol, such as free fatty acids and mono and diglycerides. It is calculated rather than measured, as 100 minus glycerol, minus water, minus ash, with ISO 2464 covering the calculation. Buyers ask because it tells them what they are paying to remove. A high MONG figure moves a parcel from a refining feed to a biogas or disposal conversation. Q: What should be on a crude glycerine offer? A: Five numbers, and without them it is an enquiry rather than an offer: glycerol content, water, ash, MONG and residual methanol. Add origin, monthly volume and certification status and a buyer can price it on the spot. Typical crude from biodiesel runs 50 to 85 percent glycerol, with the 80 percent plus material moving much more easily than material below that. Q: Is crude glycerine an Annex IX feedstock? A: Yes. Crude glycerine is listed in Annex IX Part A at point (i) of Directive (EU) 2018/2001, which places it in the advanced feedstock category rather than the capped Part B category. Annex IX has been amended since, so confirm the current letter against the consolidated text before contracting. Q: What is MONG in a glycerine specification? A: Matter organic non-glycerol: the organic impurity content beyond glycerol and water. It is the best single indicator of how difficult and expensive the material will be to refine, which is why refiners price against it directly rather than against purity alone. Q: What purity is crude glycerine? A: Typically around 80 % glycerol, though it varies with the plant and the feedstock. Refined and technical grades run 99 % and above. The gap between the two is refining capacity, and access to a refiner is often worth more to a producer than a point of purity. Q: Why does methanol content matter? A: It is residual from transesterification and it is a safety, transport and classification issue as much as a quality one. Buyers and terminals both ask about it early, and a high figure narrows the list of parties who can legally handle the cargo. Q: Can glycerine go to biogas? A: Yes, and it is a well-established outlet. Crude glycerine is a readily digestible, energy-dense co-substrate for anaerobic digestion. Whether it is worth more there than in a refining or chemical outlet depends on purity, salt content, certification and location. Q: Do you handle refined and pharmaceutical grade? A: Yes, though the buyer list narrows sharply as the specification tightens, and USP and pharmaceutical grades carry documentation requirements well beyond a normal certificate of analysis. Tell us the grade and the intended use and we will say plainly whether we are the right broker for it. ============================================================================== # Fusel oil brokerage URL: https://www.sustainablecommodities.eu/markets/fusel-oil Fusel oil is the higher-alcohol fraction separated during ethanol distillation, made up mainly of amyl alcohols with smaller amounts of propanol, butanol and isobutanol. Volumes are meaningful wherever fuel ethanol is made at scale, and it is one of those co-products that gets sold cheaply because the producer treats it as a distillation nuisance rather than a chemical feedstock. We place it into mineral processing, solvent and chemical outlets, and we have people close to the Brazilian production base. ## What it is Fusel oil forms during fermentation and is drawn off during rectification. Composition depends on the feedstock (sugarcane, corn, grain, cassava), the yeast and the distillation configuration, so no two producers offer quite the same material. Typical yields run in the low single digits relative to ethanol output, which still adds up to substantial tonnage at a large plant. The commercially interesting fraction is the amyl alcohols, principally isoamyl alcohol. Higher alcohols of this type are used across mineral processing, solvents, flavours and fragrances, and as chemical intermediates. Fusel oil is traded both as a crude mixture and, where a producer has the capability, as separated fractions that command considerably more. ## What fusel oil is, and why it has two completely different buyers Fusel oil is the higher-alcohol fraction drawn off during ethanol distillation: mostly iso-amyl alcohol with propanol, butanol and traces of ester and water. It is a by-product, which means the volume exists whether or not anyone wants it, and that shapes the whole market. Iso-amyl alcohol content: What it decides Value for the refining route; Note The fraction a solvent or fragrance buyer is chasing Water content: What it decides Whether it needs drying before use; Note Usually the first thing a buyer asks after purity Ethanol carry-over: What it decides Excise and classification questions; Note Can turn a simple movement into a duty conversation Colour and odour: What it decides Suitability for the higher-value outlets; Note Fragrance and solvent buyers are far fussier than fuel buyers Origin feedstock: What it decides Certification route if it goes to fuel; Note Grain, cane and beet distilleries give different profiles Two buyers, and they want opposite things. A refiner separating iso-amyl alcohol for solvents, fragrances and specialty chemicals pays for purity and consistency. A fuel or energy buyer pays for calorific value and takes it as it comes. The first pays much better and is far harder to satisfy. Because it is a co-product, the seller usually has continuous arisings and no natural home for them. That makes reliability of offtake worth more than a marginal price improvement on one load, which is why most of what we do here is term rather than spot. ## Where it goes One point we will not overstate. Fusel oil is sometimes presented as a direct substitute for mercury in gold recovery. The accurate version is narrower: mercury amalgamation is being displaced by gravity and flotation processing, and flotation needs frothers, which is where higher alcohols come in. If your interest is specifically the mercury-free gold route, tell us and we will work from your own technical requirement rather than from a marketing claim. * Mineral processing and mining reagents. Higher alcohols are an established class of flotation frother, and the aliphatic alcohol frothers in general industrial use, MIBC most prominently, sit in the same chemical family. This is the outlet where fusel oil volume tends to find a home. * Solvents and coatings. Amyl alcohols and their esters, particularly amyl acetate. * Chemical intermediates. Feedstock for esterification and further upgrading into higher-value chemicals. * Flavours and fragrances. For refined and separated fractions meeting the relevant purity and documentation requirements. ## Specification and handling It moves in drums, IBCs, isotanks and bulk depending on volume and destination. Because it is a flammable liquid, transport classification and terminal acceptance are worth settling early rather than at the booking stage. Alcohol breakdown: Percentages of isoamyl, amyl, isobutyl, butyl and propyl alcohol. The core of the offer. Ethanol content: Residual ethanol carried over from rectification. Water content: Often significant in crude fusel oil, and it drives both freight cost and buyer interest. Acidity: Handling, storage and downstream processing. Colour and appearance: Indicator of impurity load. Density and refractive index: Routine identity checks. Feedstock origin: Sugarcane, corn, grain or cassava. Affects the alcohol profile and some market access. Flash point and classification: Flammable liquid: decides packaging, transport and terminal acceptance. Crude or fractionated: Whether the material is the raw mixture or separated fractions. The price difference is large. ## What a fusel oil buyer will ask you We act for ethanol producers and distilleries placing a co-product they often have not marketed properly, and for reagent and chemical buyers sourcing higher alcohols. Our presence in Brazil matters here, because that is where a large share of world sugarcane ethanol, and therefore fusel oil, is produced. The first thing we ask for is the alcohol breakdown. Without it an offer is just a barrel of mixed alcohols, and it prices like one. ## Composition, and why the buyer decides what it is worth Fusel oil is the higher alcohol fraction drawn off during ethanol distillation. It is not one substance but a mixture, and which buyer wants it depends entirely on what dominates that mixture. * Isoamyl alcohol is usually the largest single component and the reason the chemical market is interested at all. Where it is high and the parcel is clean, the flavour, fragrance and solvent routes open up and they pay considerably better than fuel. * Other higher alcohols, chiefly propanol and butanol isomers, in proportions that vary with the feedstock and the distillation. * Residual ethanol and water, which matter more than people expect. A wet parcel is a diluted parcel, and water drives both freight cost per useful tonne and the buyer's separation cost. * Origin matters because it predicts composition. Cane, grain and beet ethanol produce recognisably different fusel profiles. So the single most useful thing you can put on a fusel oil offer is a composition breakdown rather than just a volume and a price. Sellers who quote only tonnage get fuel-level bids; sellers who quote the alcohol split and the water content get to have the chemical conversation. It is the same parcel and a different price. ## Sources * Directive (EU) 2018/2001 (RED II), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj * EU Customs Tariff (TARIC), for checking commodity codes: https://taxation-customs.ec.europa.eu/customs-4/calculation-customs-duties/customs-tariff/eu-customs-tariff-taric_en ## Frequently asked questions Q: What should a fusel oil offer contain? A: A composition breakdown, not just tonnage. Isoamyl alcohol content above all, then the other higher alcohols, residual ethanol and water, plus the ethanol feedstock the fusel came from, because cane, grain and beet give recognisably different profiles. Sellers who quote only volume get fuel-level bids. Sellers who quote the alcohol split get to have the chemical conversation, which pays better. Q: Why does the water content of fusel oil matter so much? A: Because you pay freight on it and the buyer pays to remove it. A wet parcel is a diluted parcel, so the price per useful tonne can be a long way from the headline price per tonne. It is one of the easiest things to measure and one of the most commonly left off an offer. Q: What is fusel oil? A: The higher-alcohol fraction separated during ethanol distillation, consisting mainly of amyl alcohols with smaller amounts of propanol, butanol and isobutanol. It forms during fermentation and is drawn off during rectification. Composition varies with the feedstock, the yeast and the distillation setup. Q: What is fusel oil used for? A: Mineral processing and mining reagents, solvents and coatings, chemical intermediates, and, for refined fractions, flavours and fragrances. Higher alcohols are an established class of flotation frother, which is the outlet that tends to absorb volume. Q: Does fusel oil replace mercury in gold mining? A: Not directly, and we would rather be precise about this than repeat a claim we cannot support. What is accurate is that mercury amalgamation is being displaced by gravity and flotation processing, and flotation requires frothers, a role filled by higher alcohols of the type fusel oil contains. If mercury-free gold recovery is your specific application, work from your own technical requirement and we will source against it. Q: Is fusel oil sold crude or refined? A: Both. Crude fusel oil is the raw mixture as drawn from the still. Where a producer can fractionate, separated cuts such as isoamyl alcohol command considerably more. The right question for a seller is whether fractionation is available nearby, because it often changes the economics more than price negotiation does. Q: Where does most fusel oil come from? A: Wherever fuel ethanol is produced at scale, with Brazilian sugarcane ethanol a major source alongside corn and grain ethanol elsewhere. We have people in Brazil, which helps on both origination and verification. Q: How is fusel oil shipped? A: Drums, IBCs, isotanks or bulk depending on volume and destination. It is a flammable liquid, so transport classification, packaging and terminal acceptance should be settled early rather than discovered at the booking stage. ============================================================================== # Storage, tank capacity and logistics URL: https://www.sustainablecommodities.eu/markets/storage-and-logistics We help counterparties find tank storage, using terminal contacts built over years. On when it matters: storage is usually the thing holding a deal up rather than price, and a seller who can name a tank is in a different conversation from one who cannot. On freight, we arrange flexitanks, isotanks and containers through forwarding partners and we make the introduction rather than marking up their invoice, so you see the quote they gave. ## Why storage decides deals A surprising number of trades die not on price but on the absence of a tank. A seller with product and no home for it discounts; a buyer with demand and no capacity cannot lift. In waste-based feedstocks the problem is sharper than in conventional oil products for three reasons. * Certification. For material moving in the biofuel chain, the storage point usually has to sit inside a certified chain of custody. An ISCC certified tank is a much smaller universe than a tank. * Heating and product compatibility. High-titre tallow, palm stearin and many fats need heated storage. Previous-cargo restrictions narrow the list again, and for some material a dedicated tank is the only honest answer. * Segregation versus mass balance. Whether the product must be physically segregated or can sit in a mass balance system changes both the cost and the list of terminals that can take it. ## How these products actually move, and who moves them Most sellers underestimate this part, and it is where a good price turns into a bad month. The mode is decided by volume, temperature and the receiving terminal, not by preference. ISO tank container: When it fits 20 to 26 tonnes, deep sea or short sea; What decides it Heating coils if the product has a titre. Cleaning certificate for the previous cargo. Availability of the right tank type in the right port Flexitank: When it fits Around 20 tonnes, one-way, cheaper than an ISO tank; What decides it No heating. A high-titre fat in a flexitank in winter is a salvage job. Also single use, so it suits one-off and trial cargoes Bulk road tanker: When it fits 25 to 30 tonnes within Europe; What decides it Heated and insulated for fats. The previous three loads matter: a food-grade or feed-grade destination will demand that record Parcel tanker / barge: When it fits From a few hundred tonnes upwards; What decides it Terminal slots, shore tank availability and the loading window. The cheapest per tonne and the least forgiving on timing We do not own trucks, tanks or ships, and we do not want to. We work with established European forwarders and bulk hauliers, and we introduce them rather than invoicing their work through us. You see the quote they gave, not a marked-up version of it. That matters more than it sounds: a broker who makes money on freight has a reason to prefer the wrong mode. For anything crossing a border there is a second layer beyond the truck: the waste classification, the receiving installation's permit, and for animal by-products the establishment approval and the border control post. Ask us before the vessel is fixed rather than after. See storage and logistics and Annex IX feedstocks. ## What we can help with * Finding capacity for biofuels, waste-based feedstocks, vegetable and technical oils, glycerine and chemicals. * Heated and specialised storage, including for high-titre fats and products with previous-cargo restrictions. * Certified storage where the chain of custody has to be maintained. * Short-term and transit storage for cargoes in motion, including distressed parcels that need somewhere to go quickly: see off-spec and distressed cargoes. * Freight optimisation: intermodal routing, bulk versus container, flexitank versus isotank, and the parcel size that actually works for a given lane. * Supply chain analysis where the question is not one shipment but whether a route makes sense at all. ## How do I actually find tank storage in ARA? You call people who already know which tanks are free, because there is no public list. Terminals do not publish availability, capacity turns over quietly between existing customers, and by the time something appears on a website it is usually gone. That is the whole reason this service exists. What we do is short-circuit the part where you email fifteen terminals and hear back from four of them in three weeks. * Give us the product, the volume, the window and the temperature. With those four we can make useful calls the same day. Without them we are asking terminals a vague question and they deprioritise it. * Say early if certification has to be maintained. ISCC certified capacity is a much smaller universe than capacity, and finding out at the end that the tank cannot hold your chain of custody wastes everyone a fortnight. * Be honest about throughput. Terminals often care more about turns per year than about tonnage, because a tank that fills and empties six times earns them more than one that sits full. A modest volume with good throughput is a more attractive customer than a large volume that never moves. * Expect to compromise on location before you compromise on tank type. Heated capacity for high-titre fats in a specific port on a specific date is sometimes simply not there, and a terminal an hour further out with the right heating usually beats waiting. * Ask about previous cargo. For anything food-adjacent or specification-sensitive, the tank's history matters as much as its size. ## What to tell us Product: Including whether it is classified as a waste and whether it is hazardous. Volume and tank size: Total tonnes and the working parcel size. Location: Preferred port or range, and how much flexibility there is. Duration: Spot, transit, seasonal or term. Terminals price these very differently. Temperature: Ambient or heated, and the temperature to be maintained. Certification: Whether ISCC or another certified chain of custody must be maintained through storage. Segregation: Dedicated tank, segregated, or mass balance acceptable. Throughput: Expected turns per year. This often matters more to a terminal than the tonnage. Timing: When capacity is needed. Lead times are long and getting longer. ## How we work We are a broker, not a terminal operator and not a freight forwarder. What we bring is the contacts and the sense of who actually has space for what, which saves a great deal of calling around. The commercial relationship is between you and the terminal. We are equally willing to say when the answer is no. Capacity for some products in some locations simply is not available at any sensible price, and telling you that in week one is more useful than a month of hopeful enquiries. ## Tankage by product: diesel, Jet A-1, SAF, HVO and the heated ones Not every tank can take every product, and the differences are exactly where bookings fail. This is what we match against when we go looking for capacity on your behalf. Gasoil and diesel (EN 590): Unheated standard cargo tanks, clean coating, water-tight | Tank history: a tank recently on B100 or FAME puts renewable content into a diesel cargo, and the specification does not forgive it HVO and renewable diesel: Unheated, diesel-like handling | FAME contamination again: EN 15940 leaves no room for it, so terminal line history is checked before the cargo is Jet A-1: Certified jet tankage with dedicated lines and filtration, microseparation, careful conductivity handling after additives | Any cross-contamination means re-certification of the whole parcel; specification per ASTM D1655 or DefStan 91-091 SAF (HEFA-SPK): Drop-in with conventional jet: storage and blending can be shared | Segregation is mostly documentary under mass balance, but the blending paperwork and the certified boundary must be in order before the truck rolls UCO, tallow, POME and other feedstocks: Heated tankage with insulation, temperature management throughout | Temperature at discharge: a feedstock that has set in the tank costs days, not degrees Pyrolysis oil: Heated and insulated, sometimes nitrogen blanketed, material-compatible lining | Stability over time and compatibility with what sat in the tank before it The pattern is simple to state and easy to get wrong: diesel, HVO and Jet A-1 want clean and unheated, feedstocks want heat, and pyrolysis oil wants heat and patience. SAF is the polite exception, because it behaves like the jet it blends into and the complexity sits in the mass balance documents rather than in the tank. Tell us the product, the volume and the window, and we will come back with capacity that actually fits it, not just capacity that exists. ## Sources * Regulation (EU) 2024/1157 on shipments of waste, on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1157/oj * ISCC System, the certification scheme itself: https://www.iscc-system.org/ ## Frequently asked questions Q: Can you find storage for diesel, Jet A-1 or SAF as well, or only feedstocks? A: All of it. Clean unheated tankage for diesel and HVO, certified jet capacity with dedicated filtration for Jet A-1, and SAF that blends into conventional jet under mass balance. The same terminal contacts that find heated feedstock capacity find the clean tanks; what changes is the tank history and specification checks we run before a booking. Q: Do I need heated storage for my cargo? A: For animal fats and tallow, almost certainly: titre is typically 38 to 44 C and the material solidifies below it. Palm and palm stearin also need heat in a temperate climate. Vegetable oils and used cooking oil usually do not, though UCO thickens in cold weather. The number to ask for is titre or cloud point, not a general opinion. Q: What goes wrong most often in the logistics of these products? A: Solidification in an unheated tank or flexitank, and it is nearly always avoidable. The second is a mismatch between the analysis basis and the settlement basis, mass against volume, which matters most for HVO because its density is around 780 kg/m3 against roughly 835 for diesel. Both are cheap to prevent and expensive to fix. Q: Do you mark up freight? A: No. We introduce forwarders and inspection companies rather than invoicing their work through us, so you see the quote they gave. We are paid a commission on business that concludes, which is also why we are still reachable when a discharge analysis comes back wrong. Q: Can you find tank storage for us? A: Yes. We help counterparties find tank capacity for biofuels, waste-based feedstocks, vegetable and technical oils, glycerine and chemicals, using long-standing terminal contacts. We are a broker rather than a terminal operator, so the commercial relationship is between you and the terminal. Q: Do you have access to ISCC certified storage? A: We can approach terminals with certified capability. Whether a certified tank is available for your product, volume and window is a separate question, and certified capacity is materially scarcer than ordinary capacity. Tell us early that certification has to be maintained, because it changes the list of options entirely. Q: Can you arrange heated storage? A: We can look for it. Heated capacity for high-titre fats, palm stearin and similar products is genuinely tight in most European hubs, and previous-cargo restrictions narrow it further. Give us the titre and the required maintenance temperature at the start rather than at the booking stage. Q: Do you handle freight as well? A: We advise on freight optimisation and supply chain analysis: intermodal routing, bulk versus container, flexitank versus isotank, and the parcel size that works for a given lane. We are not a freight forwarder and do not issue bills of lading. Q: What if I need storage urgently for a cargo that has been rejected? A: Tell us immediately, because that situation is time-critical and the options narrow every day. Short-term and transit storage for distressed parcels is something we deal with regularly alongside placing the material itself. Q: How do I find tank storage in Rotterdam, Antwerp or Amsterdam? A: Through people who already know what is free, because there is no public list. Terminals do not publish availability and capacity turns over quietly between existing customers. Give us the product, the volume, the window and the required temperature and we can make useful calls the same day. That is faster than emailing fifteen terminals and hearing back from four. Q: What information does a terminal need before quoting? A: Product and whether it is classified as waste or hazardous, volume and working parcel size, location flexibility, duration, temperature, whether a certified chain of custody must be maintained, whether segregation is required, expected throughput in turns per year, and your timing. Throughput often matters more to a terminal than tonnage, because a tank that turns six times a year earns more than one that sits full. Q: Can you find storage at short notice for a rejected cargo? A: That is one of the situations we deal with most, and speed matters more than price because demurrage and detention run continuously. Tell us immediately rather than after a week of trying: the options narrow every day and short-term transit capacity gets taken. Q: Where do you have terminal contacts? A: Principally the ARA range, where most of this product moves, alongside other European hubs and, through our team and partners, further afield. Tell us the product and the range and we will say honestly whether we can help. ============================================================================== # Co-processed naphtha and kerosene URL: https://www.sustainablecommodities.eu/markets/co-processed-fuels Co-processing is a refinery running bio feedstock through its existing units alongside crude oil. The renewable and fossil molecules come out inseparably mixed, so the renewable share is established by mass balance accounting rather than by physical segregation. For aviation this route is limited: ASTM D1655 Annex A1 permits co-processing at up to 5 %, well below the 50 % blending limit available to HEFA-SPK produced as a standalone fuel. The attraction is that co-processing needs no new plant, so it delivers renewable volume from existing refineries. ## How it differs from a standalone renewable fuel This distinction is worth getting right, because the two are frequently conflated in offers and they are not the same product. * Standalone HVO or HEFA-SPK is made in a dedicated unit from bio feedstock only. The product is physically renewable throughout, and for aviation it blends into conventional jet at up to 50 % under ASTM D7566 Annex A2. See HVO and SAF. * Co-processed fuel comes out of a conventional refinery that fed bio material in alongside crude. The molecules cannot be separated, so the renewable share is an accounting claim. For jet, co-processing is capped at 5 % under ASTM D1655 Annex A1. * The commercial consequence: a co-processed barrel and a standalone barrel can both be genuinely renewable and still not be interchangeable, because the buyer's compliance framework may treat them differently. ## Metallic octane boosters, and why they travel Metal based octane improvers are a real and active trade, but almost none of it is European road fuel, and the reason is regulatory rather than technical. MMT (manganese): Methylcyclopentadienyl manganese tricarbonyl. Effective anti knock, and it also protects valve seats in older engines on unleaded petrol. In the EU the Fuel Quality Directive caps it at 2 mg of manganese per litre, down from 6 mg in 2011. That cap binds long before the dose that would move octane usefully, which is why the volume goes to markets without the cap. Ferrocene (iron): Dicyclopentadienyl iron, CAS 102-54-5, an orange crystalline solid known as an octane improver since the 1950s. It also promotes smokeless combustion by catalysing soot oxidation, which is why it appears in burner and heavy fuel applications as well as petrol. Less studied than MMT, and several bodies advocate a precautionary approach to both. The deposit question, for both: Metal in the fuel means metal in the engine. Manganese and iron both contribute to combustion chamber and exhaust deposits. Ferrocene oxidises to iron oxide and leaves a characteristic red deposit; at high dose it has been associated with valve stem wear. Dose discipline is not optional with these products. Labelling: Fuel containing metallic additives has to be labelled as such under the EU rules. Worth knowing before you plan a blend for a European destination. Commercially this is why our octane booster business runs to West Africa, the Caucasus and similar markets rather than into the EU pool. We hold or can place stock close to those markets and we can move product by air when a blending window is closing. Customs classification matters here too: anti knock preparations sit under CN 3811 11 and 3811 19, apart from other additives under CN 3811 90, and getting that wrong stops a container. ## What co-processing actually is, and why the accounting is the hard part Co-processing means feeding renewable material into an existing oil refinery alongside fossil crude, rather than building a dedicated plant. The chemistry is the easy part. The accounting is where the deals are won and lost. A refinery that puts, say, five per cent used cooking oil into its hydrotreater does not get a separate stream of renewable diesel out of the other end. It gets one blended product. The renewable share has to be attributed rather than measured, and how you are allowed to attribute it is a regulatory question with real money attached. What happens: Dedicated plant Feedstock converted in a purpose-built unit; Co-processing Renewable feedstock fed into an existing refinery unit with fossil; Blending Finished renewable fuel mixed with fossil fuel Capital needed: Dedicated plant High; Co-processing Low. The unit already exists; Blending None Output: Dedicated plant Physically separate renewable product; Co-processing One blended product; renewable share attributed; Blending Known blend of two finished fuels The hard part: Dedicated plant Financing and feedstock security; Co-processing Proving the renewable share to a certifier; Blending Logistics and specification Method of proof: Dedicated plant Mass balance, straightforward; Co-processing Radiocarbon testing (ASTM D6866) or a yield model, depending on the scheme; Blending Documentation ASTM D6866 is the physical check. It measures the biogenic carbon fraction using carbon-14: fossil carbon has none left, biogenic carbon does. That gives an independent measurement of the renewable share of a co-processed product, which is exactly what a sceptical buyer or auditor wants. Why this matters commercially even if you never run a refinery: co-processing is the cheapest way for existing capacity to enter this market, and it competes for the same feedstock as the dedicated plants. When a large refiner starts co-processing, waste feedstock demand rises without any new plant being announced. That is a supply-side pressure most sellers do not see coming. ## The products * Co-processed kerosene, into aviation, subject to the 5 % limit and to whether the buyer's scheme recognises co-processed material for the claim it needs to make. * Co-processed naphtha, into steam crackers as renewable petrochemical feedstock or into gasoline blending. This competes directly with bionaphtha, and the difference is in the accounting rather than in the hydrocarbon. * Co-processed diesel and gasoline components, into road fuel pools under national renewable fuel obligations. ## What has to be agreed The recurring problem is a seller who can state the renewable percentage but not the method or the scheme behind it. In co-processed material the accounting is not supporting documentation, it is the product, and a buyer's compliance team will treat a missing method as a missing product. Renewable share: The percentage claimed, and the method used to establish it. Mass balance method: Energy, mass or carbon basis, and the accounting period. Certification scheme: ISCC EU, ISCC CORSIA, REDcert or RSB, with co-processing explicitly inside the certified scope. Scheme recognition: Whether the buyer's specific framework accepts co-processed material for the claim being made. Bio feedstock: What went in, and its Annex IX status. GHG saving: The figure on the proof of sustainability for the renewable share. Specification: ASTM D1655 for jet, with Annex A1 governing co-processing; the relevant road or petrochemical spec otherwise. Destination treatment: How the national scheme in the delivery market counts it. ## How anyone proves a co-processed molecule is renewable This is the awkward heart of co-processing. Once bio feedstock has gone through a refinery alongside fossil feed, the product coming out is molecularly identical to conventional fuel. You cannot separate the renewable molecules because in any meaningful sense there are none: there is one stream with a renewable share. So the claim rests on two things working together, and both have to be sound or neither is. * Mass balance accounting. The certified bookkeeping that tracks how much renewable feed went in and allocates a corresponding share of output. This is what a scheme audits. See ISCC certification. * Radiocarbon verification. Biogenic carbon carries carbon-14; fossil carbon, being millions of years old, does not. Measuring the carbon-14 fraction tells you the biogenic share of a sample directly, whatever the paperwork says. ASTM D6866 is the standard method, with EN 16640 as the broader European framework and DIN 51637 written specifically for liquid fuels and blends. The commercially important point: radiocarbon testing is the independent check on the mass balance. A refiner or an auditor can measure whether the renewable share you claim is actually in the barrel. If you are buying co-processed material, knowing that this test exists and can be run is worth more than any amount of assurance in an e-mail. ## Sources * ASTM D6866, biobased content by radiocarbon: https://dieselnet.com/tech/fuel_biodiesel_std.php * Directive (EU) 2018/2001 (RED II), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * ISCC System, the certification scheme itself: https://www.iscc-system.org/ ## Frequently asked questions Q: How can anyone tell a co-processed fuel apart from fossil fuel? A: Chemically you cannot, and that is the point: after co-processing the molecules are identical. What you can do is measure the biogenic share. Biogenic carbon contains carbon-14, fossil carbon does not, so a radiocarbon measurement gives the renewable fraction of a sample directly. ASTM D6866 is the standard method, with EN 16640 as the wider European framework and DIN 51637 aimed specifically at liquid fuels and blends. That measurement is the independent check on the mass balance paperwork. Q: Is a co-processed fuel worth the same as HVO? A: Usually not, and treating them as interchangeable is a common and expensive error. HVO is a distinct product made in a dedicated unit and sold against EN 15940. A co-processed fuel is conventional fuel carrying a certified renewable share. They are accounted for differently, they price differently, and a buyer with a mandate to meet cares intensely about the difference. Q: What is co-processing? A: A refinery running bio feedstock through its existing units alongside crude oil, so renewable and fossil molecules come out inseparably mixed. The renewable share is established by mass balance accounting rather than by physical segregation. Its attraction is that it produces renewable volume from existing plant without new investment. Q: What is the co-processing limit for jet fuel? A: ASTM D1655 Annex A1 permits co-processing at up to 5 %. That is considerably lower than the 50 % blending limit available to HEFA-SPK produced as a standalone fuel under ASTM D7566 Annex A2, and it is the main technical constraint on the co-processed aviation route. Q: Is co-processed kerosene the same as SAF? A: It is renewable aviation fuel, but it is not the same product as standalone HEFA-SPK and the two are not always interchangeable for compliance purposes. The limits differ, the accounting differs, and whether a buyer's framework recognises co-processed material for its specific claim has to be confirmed rather than assumed. Q: What is the difference between co-processed naphtha and bionaphtha? A: Bionaphtha is the co-product of a dedicated hydrotreating unit running bio feedstock only. Co-processed naphtha comes from a conventional refinery that fed bio material in alongside crude, so its renewable share is a mass balance claim. Both can go to a steam cracker; which one a polymer producer can use depends on what its own customers require. Q: How is the renewable share verified? A: Through mass balance accounting under a recognised voluntary scheme, with co-processing explicitly inside the certified scope. The method, whether energy, mass or carbon basis, and the accounting period both have to be stated. A renewable percentage without a stated method is not a usable claim. Q: Do all schemes accept co-processed fuel? A: Not uniformly, and this is where deals fail. Recognition depends on the scheme and on the framework the buyer is claiming under. Establish what the end buyer actually needs to claim, and to whom, before agreeing anything else. ============================================================================== # Fish oil and marine fat brokerage URL: https://www.sustainablecommodities.eu/markets/fish-oil-and-marine-fats We broker fish oil and marine fats from fish processing residues into fuel and oleochemical outlets. The parameter that decides everything is the iodine value: fish oil is far more unsaturated than other feedstocks, which usually rules out FAME and points the material at hydrotreatment. The largest export origin is South East Asia, where pangasius processing in the Mekong Delta produces fat as a by-product at scale; Peru and Chile supply anchovy-derived oil, and northern Europe supplies herring and whitefish streams. We never take title. ## Why fish oil goes to hydrotreatment and not to FAME This is the single most useful thing to know about the product, and it saves a lot of wasted conversations. Fish oil carries long-chain polyunsaturated fatty acids, the same omega-3 chains that make it valuable in feed and nutrition. That unsaturation is measured as iodine value, and it is high. EN 14214 caps iodine value at 120 g iodine per 100 g for fatty acid methyl ester. Fish oil normally sits well above that. The standard itself acknowledges the problem: its iodine value calculation procedure expressly does not apply to esters made from fish oil. Untreated fish oil methyl ester is therefore not a route to a compliant European FAME, and no amount of blending optimism changes that. * Hydrotreatment works, and is the normal route. Hydrogenation saturates those double bonds, bringing iodine value, oxidation stability and acid value into range. That is why HVO and SAF producers are the natural buyers rather than FAME plants. * Oxidation stability is the other consequence. The same double bonds oxidise, so fish oil ages faster than most feedstocks. Storage time, temperature and whether the parcel was blanketed are fair questions. * Sulphur and phosphorus decide whether a hydrotreater will take it. Marine streams are not always low in either, and a catalyst bed is expensive. * Free fatty acid tells you how the fish was handled. High FFA usually means the raw material sat warm before rendering, and it moves the price more than sellers expect. ## What a buyer screens on Fish oil is assayed like any other fat, with two differences: iodine value carries more weight than anywhere else, and the feed market is always sitting underneath as an alternative buyer. Iodine value: What it decides FAME or hydrotreatment; Note The parameter that governs. Above 120 the EN 14214 route closes FFA (free fatty acid): What it decides Price within the grade; Note Reflects how quickly the raw material was processed Moisture and impurities: What it decides Yield and claim risk; Note Marine streams carry more solids than vegetable oils Oxidation stability, peroxide value: What it decides Whether it survives the voyage; Note Ask about blanketing and antioxidant addition Sulphur and phosphorus: What it decides Hydrotreater acceptance; Note Governs catalyst life, not product quality Species and stream: What it decides Certification and outlet; Note Pangasius, anchovy, herring and whitefish behave differently ABP category and approval number: What it decides Whether it may legally move; Note Processing residues sit under animal by-product rules The feed market sets the floor, and that is unusual. Most waste feedstocks have no competing buyer worth the name. Fish oil does: aquafeed and omega-3 refiners want the same barrel, and they pay for exactly the unsaturation a fuel producer has to hydrogenate away. When feed demand is strong, fuel buyers cannot compete, and a seller should know which of the two markets they are in before they start negotiating. ## Where it comes from, and what that means for documents Origin drives the paperwork more than it drives the chemistry. * South East Asia is the largest export origin. Pangasius processing in the Vietnamese Mekong Delta generates fat as a by-product at real scale, moving in bulk and in flexitank. Most enquiries we see originate here. * South America, principally Peru and Chile, supplies anchovy-derived oil, though most of that volume is committed to omega-3 and feed. * Northern Europe supplies herring, mackerel and whitefish streams, usually already inside the EU animal by-product framework. Annex IX status is the question to settle first, and it does not have a single answer. Fish oil is not named as its own entry the way used cooking oil is. Whether a given stream qualifies, and under which entry, depends on the stream, the certification body's view and the member state's implementation. Do not price a term contract on an assumption here. Get it confirmed in writing by the certifier before volume is committed, because the difference between qualifying and not qualifying is larger than any negotiation on price. See Annex IX feedstocks. For material from outside the EU there is a second layer: animal by-product import rules, the approval status of the establishment, and the border control post. None of it is exotic, but all of it takes longer than a first-time exporter expects. ## What a fish oil buyer will ask you We act for processors with continuous arisings who want a reliable home for them, and for hydrotreaters and oleochemical producers who need a consistent stream rather than an occasional parcel. Most of the work is not finding a counterparty. It is getting the documentation into a state a European buyer can accept, which for a first-time exporter is genuinely the hard part. We say early and plainly whether a stream is placeable as it stands, because the alternative is everyone spending three months finding out it was not. * On feedstocks and fuels we never take title and we do not trade our own book. Additives are the one exception. * We introduce, we do not intermediate the cargo. Buyer and seller contract directly. * We say no when it is no. A stream without a credible certification route is not a deal waiting to happen. ## Sources * Document checklist: exactly which papers a European buyer asks for, per product: /markets/document-library * EN 14214 biodiesel standard, full parameter table: https://dieselnet.com/tech/fuel_biodiesel_std.php * Upgrading the oxidative stability of fish oil biodiesel (peer-reviewed): https://sciencedirect.com/science/article/pii/S2589014X21003169 * Regulation (EC) No 1069/2009, animal by-products: https://eur-lex.europa.eu/eli/reg/2009/1069/oj/eng ## Frequently asked questions Q: Can fish oil be used to make biodiesel? A: Not straightforwardly, and this is the most common misunderstanding about the product. Fish oil is highly unsaturated, so its iodine value normally exceeds the 120 g iodine per 100 g ceiling EN 14214 sets for fatty acid methyl ester. The standard goes further and states that its iodine value calculation procedure does not apply to fish oil esters at all. The practical route is hydrotreatment, which saturates the double bonds and produces HVO or SAF rather than FAME. Q: Is fish oil an Annex IX feedstock? A: It is not listed as its own entry the way used cooking oil is. Whether a particular stream qualifies, and under which entry, depends on the stream itself, the certification body's assessment and the member state's implementation. Get it confirmed in writing by your certifier before committing volume. We would rather say that than give you a confident answer that turns out to be worth nothing. Q: What iodine value does fish oil have? A: Higher than vegetable oils and much higher than animal fats, because of the long-chain polyunsaturated fatty acids that make fish oil valuable in nutrition. The exact figure varies by species, season and processing, which is why it belongs on the analysis rather than in a general statement. What matters commercially is that it usually sits above the EN 14214 limit. Q: Where does fish oil for biofuel come from? A: The largest export origin is South East Asia, where pangasius processing in the Vietnamese Mekong Delta produces fat as a by-product at scale. Peru and Chile supply anchovy-derived oil, though most goes to omega-3 and feed. Northern Europe supplies herring, mackerel and whitefish streams already inside the EU animal by-product framework. Q: Why is fish oil sometimes more expensive than other waste feedstocks? A: Because it has a competing buyer that most waste feedstocks do not. Aquafeed producers and omega-3 refiners want the same material, and they pay for exactly the unsaturation a fuel producer has to hydrogenate away. When feed demand is firm, fuel buyers cannot compete. Establish which of the two markets you are in before negotiating. Q: What documents do I need to export fish oil to Europe? A: At minimum: the animal by-product category and the approval number of the processing establishment, the health certificate, the analysis, and a sustainability certification if the material goes into fuel. For a first-time exporter the documentation is usually the bottleneck rather than the product, so start on it in parallel with the commercial discussion rather than after it. Q: Do you buy fish oil? A: No. We are brokers and we never take title. We introduce a seller to a buyer who can genuinely take the material, and the two of you contract directly. Q: Can you place off-spec or oxidised fish oil? A: Sometimes, and it is worth asking rather than assuming. Oxidised material no longer acceptable to a feed buyer may still be usable to a hydrotreater or an oleochemical producer, because they are buying carbon chains rather than nutritional quality. Send the analysis and we will tell you honestly whether there is a home for it. ============================================================================== # Crude tall oil (CTO) brokerage URL: https://www.sustainablecommodities.eu/markets/crude-tall-oil We broker crude tall oil (CTO) from kraft pulping into fuel and oleochemical outlets. On what sets the value: the split between fatty acids and rosin acids, plus the unsaponifiables, and none of it is negotiable because the wood and the mill decide it. On where it goes, the chemical market can often pay more for rosin rich material than the fuel market will, so if you are being offered CTO at a fuel price it is worth asking what the rosin content is first. ## CTO, TOFA and pitch are three different products Fuel-quality CTO is generally characterised by a relatively high fatty acid content, up to around 65 %, an acid number below roughly 135 mg KOH/g and rosin acid below about 23 %. Softwood-only pulping gives higher yields and higher rosin content than mixed wood. Confirm the individual buyer's limits: these are market conventions, not a specification. * Crude tall oil (CTO), the raw by-product from the pulp mill after acidulation of tall oil soap. This is what trades in bulk. * Tall oil fatty acid (TOFA), the distilled fatty acid fraction. The largest downstream product group and the one oleochemical buyers want. * Tall oil rosin (TOR), the rosin acid fraction, into adhesives, inks and sizing. * Distilled tall oil (DTO), an intermediate fraction. * Tall oil pitch (TOP), the heavy distillation residue. Lower value, and with a different regulatory position from CTO itself. ## What is actually in a parcel of crude tall oil Crude tall oil is a kraft pulping co-product, not a crop, and its composition moves with the wood species and the mill. That variability is the whole commercial story: two parcels from different mills are not interchangeable, and a buyer who has qualified one is not automatically a buyer for the other. Resin (rosin) acids: Typical range 26 to 42 %; Why a buyer cares Drives value for rosin derivatives; abietic, dehydroabietic, isopimaric and pimaric acids Fatty acids: Typical range 36 to 48 %; Why a buyer cares Oleic, linoleic, palmitic. The fraction a fuel or oleochemical buyer is chasing Neutrals and unsaponifiables: Typical range 10 to 38 %; Why a buyer cares The wide end of this range is what makes a parcel hard to place Sulphur: Typical range Report it; Why a buyer cares Kraft origin means sulphur is present; it governs whether a hydrotreater can take the material Water and ash: Typical range Report both; Why a buyer cares Ordinary quality parameters, and ordinary sources of dispute The rosin-to-fatty-acid ratio decides which industry you are selling to. Rosin-rich material goes towards adhesives, inks and sizing; fatty-acid-rich material goes towards fuel and oleochemicals. A seller who reports only a single acid value has not told a buyer which of those two markets they are in. Crude tall oil also sits in a live policy argument. It has established chemical uses, and diverting it to fuel is contested by the industries that have used it for decades. That is worth knowing before building a long-term position on it, and it is the sort of thing we would rather say out loud than leave a client to discover. ## The Annex IX distinction most sellers get wrong This is worth reading carefully, because it moves money and it is consistently mishandled in offers. Tall oil pitch appears in Annex IX Part A as its own entry, point (h) in Directive (EU) 2018/2001. Tall oil itself appears inside point (o), the entry covering the biomass fraction of wastes and residues from forestry and forest-based industries, which lists bark, branches, thinnings, leaves, needles, tree tops, saw dust, cutter shavings, black liquor, brown liquor, fibre sludge, lignin and tall oil. So both routes exist, but they sit in different places and a contract that cites the wrong letter invites an audit finding. Annex IX has been amended since 2018, so check the current consolidated text before writing a letter into a contract. Full lists on our Annex IX reference page. ## Specification Acid number (AN): mg KOH/g. The headline quality figure. Fatty acid content: Percentage. What the oleochemical and fuel buyers are both really buying. Rosin acid content: Percentage. High rosin favours the oleochemical route; fuel buyers generally want it lower. Unsaponifiables / neutrals: The non-usable fraction. Drives yield. Water and sediment: Settlement weight and handling. Ash and inorganics: Sodium and other carry-over from the mill. Sulphur: Present from the kraft process. Critical where the CTO is going into hydrotreatment for HVO or SAF. Viscosity and pour point: Heated storage and pumping. Wood origin: Softwood, hardwood or mixed. Drives the rosin/fatty acid split and therefore the buyer. Certification: ISCC EU where the CTO enters the biofuel chain. ## What a crude tall oil buyer will ask you We act for pulp mills placing CTO, for tall oil refiners sourcing it, and for fuel producers looking for Annex IX qualifying volume. Because supply is structurally limited by pulp production rather than by demand, term relationships matter more here than spot opportunism, and a mill that keeps its analysis consistent is in a genuinely strong position. Sulphur deserves a specific mention. A mill selling into the oleochemical chain may never have been asked for it; a hydrotreating buyer will ask first. Having the number ready shortens the conversation considerably. ## What is actually in it, and what it splits into Crude tall oil is a by-product of kraft pulping of coniferous wood, recovered from the black liquor soap. Its value sits in the ratio between two acid families, and that ratio is set by the wood and the mill rather than by anything a trader can influence. * Fatty acids become tall oil fatty acid (TOFA) on distillation, and TOFA is the fraction most relevant as a biofuel and oleochemical feedstock. * Rosin acids become tall oil rosin (TOR), used in adhesives, inks and sizing. A high rosin fraction pulls a parcel toward the chemical market rather than the fuel market. * Unsaponifiables, mostly sterols and hydrocarbons, which dilute both outlets and are the parameter buyers scrutinise. * Pitch, the distillation residue, which finds energy outlets. * Acid number is the headline figure on any CTO offer, alongside moisture, ash and unsaponifiable content. Quote it and the sulphur figure together and you have said most of what a buyer needs. Worth knowing commercially: CTO sits at the intersection of a fuel market and a chemical market that compete for the same barrels, and the chemical market can often pay more for the rosin rich material. If you are being offered CTO as a straightforward biofuel feedstock at a fuel price, ask what the rosin content is before you assume that is the best home for it. ## Sources * Crude tall oil composition and derivatives: https://www.sciencedirect.com/topics/chemistry/tall-oil * Directive (EU) 2018/2001 (RED II), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj ## Frequently asked questions Q: What determines the value of a crude tall oil parcel? A: The split between fatty acids and rosin acids, plus the unsaponifiable content, and none of it is negotiable because it is set by the wood species and the mill. A fatty acid rich parcel leans toward fuel and oleochemical outlets; a rosin rich one leans toward adhesives, inks and sizing, where the chemical market can often pay more. Quote acid number, moisture, ash, unsaponifiables and sulphur and a buyer can work with it. Q: What is crude tall oil? A: A by-product of the softwood kraft pulping process, recovered by acidulating tall oil soap. It is a mixture of fatty acids, rosin acids and neutral unsaponifiable material. Supply is limited by pulp production volumes rather than by demand, which is why biofuel and oleochemical buyers end up competing for the same barrel. Q: Is crude tall oil an Annex IX feedstock? A: Tall oil appears within Annex IX Part A point (o), the entry covering the biomass fraction of wastes and residues from forestry and forest-based industries, which explicitly lists tall oil. Tall oil pitch has its own separate entry at point (h). Those are two different positions and citing the wrong one invites an audit finding. Do not assume a parcel qualifies on the strength of the product name either: qualification depends on the certification chain and the documentation behind that specific volume, so check that the scope on the certificate covers both the product and the activity. Q: What acid number does fuel-quality CTO need? A: Fuel-quality CTO is generally characterised by an acid number below roughly 135 mg KOH/g, fatty acid content up to around 65 % and rosin acid below about 23 %. These are market conventions rather than a formal specification, so confirm the individual buyer's acceptance limits. Q: What is the difference between CTO, TOFA and tall oil pitch? A: CTO is the raw by-product from the mill. TOFA is the distilled fatty acid fraction and the largest downstream product group. Tall oil pitch is the heavy distillation residue, lower in value and with its own separate Annex IX entry. They trade separately and at very different prices. Q: Why do biofuel and oleochemical buyers compete for CTO? A: Because supply is fixed by how much softwood pulp is produced, not by how much anyone wants. Renewable diesel and SAF producers value CTO as an Annex IX qualifying feedstock, while oleochemical producers need it for TOFA and rosin. Both are bidding for the same limited volume, which is the defining feature of this market. Q: Do you handle tall oil pitch as well? A: Yes. Pitch is a genuine market in its own right, lower in value than CTO but with its own buyers, and it carries a separate Annex IX position at point (h). It is worth offering as its own stream rather than as an afterthought to a CTO offer. ============================================================================== # CNSL brokerage: cashew nut shell liquid URL: https://www.sustainablecommodities.eu/markets/cnsl CNSL is the dark, viscous phenolic liquid held in the cashew nut shell, and it is one of the few genuinely large-volume natural sources of long-chain phenols: anacardic acid, cardanol and cardol. That chemistry is why it is bought by resin, coatings and friction material manufacturers rather than purely as an energy product. We broker technical, acid and distilled grades out of Vietnam and Africa, which are the two origins we actually work. ## The grades, and why they price so differently The gap between technical CNSL and distilled cardanol is the single largest value step in this chain. A processor with a column is in a different business from one without. * Technical CNSL (tCNSL), produced by thermal processing of the shells at roughly 180 to 200 °C. During roasting the anacardic acid decarboxylates to cardanol, so technical CNSL is cardanol-rich: typically in the region of 60 % cardanol with cardol, methylcardol and a polymer fraction making up the balance. This is the workhorse grade. * Acid grade / natural CNSL, cold-extracted, retaining anacardic acid rather than converting it. A different chemistry and a different buyer. * Distilled and refined CNSL, and separated cardanol, where a processor has a distillation column. Much higher value, and the direction processors have been investing in. * Residue and pitch fractions, into fuel and lower-value outlets. ## Where it goes * Friction materials. Brake linings and clutch facings, one of the classic and still substantial CNSL outlets. * Phenolic resins and coatings. Cardanol-based resins, with the long unsaturated side chain giving flexibility that petroleum phenol does not. * Anti-corrosion coatings and paints, drawing on the natural phenolic properties. * Surfactants and plasticisers, as a bio-based chemical intermediate. * Epoxy curing agents, a growing cardanol application. * Bunker blending. CNSL does get blended into marine fuel, and it is an outlet a lot of sellers overlook, but be realistic about it: a blend carrying CNSL is contentious and some receivers will simply refuse it on that basis alone. Sulphur and the applicable marine limits govern how much can go in, and the CNSL content itself governs whether anyone will take it. Establish the receiver's position before you build a cargo around this route. If a parcel is already stuck, see off-spec and distressed cargoes. * Fuel, for residue fractions and off-specification material, where chemical outlets are not available. ## CNSL as a maritime biofuel, and why the debate is not settled Shipping needs low sulphur, low carbon liquid fuel in volumes that the existing biofuel pool cannot supply, and cashew shells keep getting nominated as a candidate. It is worth understanding the argument properly, because it decides whether your parcel has a second outlet or only one. The case for it. The shell is roughly 70 to 75 percent of the weight of the nut and is largely a disposal problem today, so the feedstock is real and additional rather than diverted from food. It is unusually rich in extractable material, on the order of 58 percent by weight against 2 to 15 percent for wood, which is why the oil comes off in commercially interesting yield. Reported energy content runs to around 35.8 MJ/kg for heat-treated shells, against roughly 23.6 MJ/kg for raw shells, which puts the treated material in the same neighbourhood as conventional marine fuel. It is naturally low in sulphur, which is the whole point given the sulphur limits shipping now works under. Blend trials at around 20 percent CNSL have been reported as behaving broadly like diesel. The case against it, which you will hear from the receiving side. Three things, and they are the same three that make buyers hesitate on the chemical side. * Acidity, and the corrosion that follows. CNSL is acidic by nature. That is a materials question for pumps, lines and engine components, not a paperwork question, and it is the single most common reason a receiver declines a CNSL-bearing blend. * Polymeric content. CNSL polymerises. In a resin plant that is the product. In a fuel system it is a fouling and stability risk, and it is why storage time and temperature history matter more here than for most cargoes. * Feedstock variability. Composition moves with origin, season and extraction method. A fuel buyer specifying a repeatable blend needs consistency more than they need a good single result. Our honest read: this is a genuine and growing conversation, not a solved route. Treat marine as a second outlet worth testing rather than the plan you build a cargo around, and establish the receiver's position in writing before you fix anything. Where it does work, it tends to be blended rather than burned neat, and the acid value is the number the conversation turns on. ## The purity problem, and why half this market argues This is the single most useful thing to understand about CNSL, and almost nobody writes it down. CNSL is the raw material. Cardanol is what you get when you distil it. Sell into the oleochemical sector and you are expected to deliver cardanol at a stated purity, commonly 95 % or higher, often 98 %. Sell into the energy sector and the discipline collapses: material gets offered as "cardanol" at nothing like that purity, sometimes around half, with no percentage stated at all. That is not a technicality, it is the whole argument. Two offers both called cardanol can be completely different products, and the seller who quotes cheapest is frequently the one who has not distilled properly. Always ask for the purity percentage in writing. If it is not on the offer, it is not a specification, it is a hope. The other half of the problem is anacardic acid. It is the fraction that causes most of the downstream trouble, and material sold as CNSL without that fraction properly handled will make problems for whoever receives it. Distillation solves both issues at once: you get cardanol at high purity plus a residual CNSL fraction, and you get material a serious buyer can actually use. It costs more, because distillation costs more than the CNSL going into it. That cost difference is exactly why the shortcut exists. ## Specification Grade: Technical, acid/natural, distilled or cardanol. Cardanol content: Percentage. The principal value driver. Cardol content: Percentage. Affects downstream behaviour and is usually specified separately. Anacardic acid: Present in cold-extracted material, largely converted in technical grade. Polymer content: The heavier fraction; drives viscosity and processing behaviour. Moisture: Settlement weight and stability. Viscosity: Handling, pumping and heated storage. Iodine value: Degree of unsaturation of the side chain. Ash and insolubles: Shell carry-over from extraction. Total sulphur: By ASTM D4294. Distilled cardanol comes in very low, which is part of why it works as a bio-phenol feedstock. Metals by ASTM D5185: Calcium, iron, magnesium and phosphorus, in mg/kg. A low-metal result is the mark of properly distilled material and is what a hydrotreating or chemical buyer screens on. Anacardic acid: The fraction that causes downstream problems. Ask explicitly whether it has been handled, because it is often not mentioned at all. Colour: Matters increasingly as processors compete on ultra-light distilled grades. Origin: We source from Vietnam and from Africa. Those are the two origins we actually work, rather than a list of every country that grows cashews. ## What a CNSL buyer will ask you We act for cashew processors and CNSL distillers placing volume, and for resin, friction material and coatings manufacturers sourcing it. A great deal of CNSL is still sold as a generic dark oil with no analysis, which is the cheapest way to sell a chemical feedstock. The first thing we ask for is the grade and the cardanol percentage, because without those an offer competes on price alone against material that may be substantially different. It moves in drums, flexitanks, isotanks and bulk depending on volume and origin, generally with heated handling given the viscosity. ## Sources * IMO, the MARPOL convention on pollution from ships: https://www.imo.org/en/About/Conventions/Pages/International-Convention-for-the-Prevention-of-Pollution-from-Ships-(MARPOL).aspx * EU Customs Tariff (TARIC), for checking commodity codes: https://taxation-customs.ec.europa.eu/customs-4/calculation-customs-duties/customs-tariff/eu-customs-tariff-taric_en ## Frequently asked questions Q: Can CNSL be used as a marine or bunker fuel? A: It is blended into marine fuel and the interest is growing, because cashew shells are an abundant residue, naturally low in sulphur, and heat-treated shells have been reported at energy content around 35.8 MJ/kg against roughly 23.6 MJ/kg raw. Blend trials around 20 percent CNSL have been reported as behaving broadly like diesel. But it is not a settled route. High acidity brings corrosion risk, the polymeric content brings fouling and stability risk, and composition varies with origin and extraction. Plenty of receivers refuse a CNSL-bearing blend on that basis alone. Establish the receiver's position before you build a cargo around it. Q: Why do some receivers refuse CNSL in a bunker blend? A: Three reasons, and they are technical rather than commercial. CNSL is acidic, which is a corrosion question for pumps, lines and engine components. It polymerises, which is a fouling and stability risk in a fuel system even though it is exactly what a resin plant wants. And its composition varies with origin, season and extraction method, which makes a repeatable blend harder to guarantee. Acid value is usually the number the conversation turns on. Q: Is CNSL sustainable as a fuel feedstock? A: The feedstock argument is strong. The shell is around 70 to 75 percent of the weight of the nut, it is largely a disposal problem today, and it competes with no food use, so the volume is genuinely additional. Whether a given parcel qualifies under a specific scheme is a separate question and depends on the certification chain, not on the material being a residue. Ask about the paperwork before you assume the claim. Q: What is CNSL? A: Cashew nut shell liquid: the dark, viscous, caustic liquid contained in the cashew nut shell. It is a natural source of long-chain phenols, principally anacardic acid, cardanol and cardol, which is why it is valued as a chemical feedstock rather than simply as an energy product. Q: What is the difference between technical CNSL and natural CNSL? A: Technical CNSL is produced by thermal processing of the shells at roughly 180 to 200 °C, during which anacardic acid decarboxylates into cardanol, giving a cardanol-rich product typically around 60 % cardanol. Natural or acid grade CNSL is cold-extracted and retains anacardic acid. They are different chemistries with different buyers. Q: What is cardanol used for? A: Phenolic resins, epoxy curing agents, friction materials such as brake linings, anti-corrosion coatings, surfactants and plasticisers. The long unsaturated side chain gives properties petroleum-derived phenol does not, which is the basis of most cardanol applications. Q: What is the difference between CNSL and cardanol? A: CNSL is the raw material as it comes out of the shell. Cardanol is what you get when you distil it. The oleochemical sector expects cardanol at a stated purity, commonly 95 % or higher and often 98 %. In the energy sector material is regularly offered as cardanol at far lower purity with no percentage stated at all. They are not the same product and they should not carry the same name. Q: Why do two cardanol offers differ so much in price? A: Usually purity, and usually undeclared. Distillation costs more than the CNSL going into it, so properly distilled high-purity cardanol is genuinely more expensive. The cheap offer is often material that has not been distilled to the purity the name implies. Ask for the purity percentage in writing: if it is not on the offer it is not a specification. Q: What is anacardic acid and why does it matter? A: It is the fraction of CNSL that causes most of the downstream trouble. Material sold without that fraction properly handled creates problems for whoever receives it, and it is frequently not mentioned on an offer at all. Distillation deals with it, which is one of the reasons distilled product is worth the difference. Ask explicitly whether it has been addressed. Q: Can I really put CNSL in a marine fuel blend? A: It happens, but do not build a cargo around it without checking. A blend carrying CNSL is contentious and some receivers refuse it on that basis alone, regardless of whether the sulphur arithmetic works. Establish the receiving party's position first, then do the blend calculation. Q: Where do you source CNSL from? A: Vietnam and Africa. Those are the two origins we actually work, and we would rather say that than list every country that grows cashews. Both regions have processors investing in distillation capacity to compete on the higher-value light-coloured grades. Q: Can CNSL be used in bunker fuel? A: Yes, and it is an outlet a lot of sellers overlook. CNSL works as a blend component in marine fuel, which absorbs material that would otherwise sit. How much can go in is governed by sulphur and the applicable marine limits, so it is a blend calculation rather than a straight substitution. Q: Can CNSL be used as a fuel? A: Residue and pitch fractions and off-specification material do go to fuel outlets. For on-specification technical CNSL and distilled cardanol the chemical outlets pay considerably better, so selling good material as fuel is usually leaving money on the table. Q: What should be on a CNSL offer? A: Grade, cardanol percentage, cardol percentage, polymer content, moisture and viscosity, plus origin. A great deal of CNSL is offered as a generic dark oil with no analysis, and it prices accordingly, well below what the same material would fetch properly documented. ============================================================================== # Acid oils and esterified acid oils URL: https://www.sustainablecommodities.eu/markets/esterified-acid-oils Acid oils are the concentrated fatty acid streams that come out of vegetable oil refining, and esterified acid oils are those streams upgraded by esterification into material a biodiesel plant can actually run. Two things govern the trade. Commercially, total fatty acid is the pricing basis, not tonnage: you are buying the usable fraction, not the drum. Regulatory, the origin of the parent oil decides the Annex IX position and therefore much of the value. ## The family, and where esterification fits The technical reason esterification exists: conventional transesterification uses a base catalyst, and base catalysts do not tolerate high free fatty acid, which saponifies instead of converting. Acid-catalysed esterification converts the FFA to methyl ester first, so a stream that would ruin a batch becomes a feedstock. That single processing step is the difference between a disposal problem and a traded commodity. * Soapstock, the alkaline by-product of chemical refining. Not yet an acid oil. * Acid oil, soapstock acidulated so the fatty acids are released and concentrated. This is the traded product. * Palm acid oil (PAO) and palm fatty acid distillate (PFAD), from palm refining. PFAD comes from physical refining and is a distillate rather than an acidulation product, which is a genuine distinction rather than a labelling one. * Esterified acid oil (EAO), acid oil that has been esterified, converting the free fatty acids into methyl esters. This is what makes very high FFA material usable in a conventional biodiesel plant. ## What decides the price Total fatty acid (TFA): The pricing basis. Everything else is secondary. FFA content: Percentage, and which acid it is stated as. Ester content: For esterified material: how far the conversion went. Moisture and impurities (M&I): Settlement weight and processing yield. Unsaponifiable matter: The ceiling on usable yield. Sulphur: Critical where the material is heading to hydrotreatment. Acid value: Corrosivity and residual conversion. Iodine value: Unsaturation; drives cold-flow downstream. Phosphorus and metals: Pretreatment load and catalyst impact. Parent oil origin: Palm, soy, rape, sunflower, corn or mixed. Decides certification and Annex IX position. Residual methanol: For esterified material: safety, transport and classification. Certification: ISCC EU with the scope covering the actual material. ## The classification question worth settling first Acid oils sit in an awkward place. Whether a given stream counts as a residue, a co-product or a processing by-product affects how it is treated under EU renewable fuel rules, and that treatment is decided nationally rather than at EU level. This is not a technicality. The same tank of acid oil can be economic in one member state and not in the next, and the answer can change between delivery years. Before signing anything multi-year, confirm the position for the specific stream in the specific destination market, in writing. We will tell you what we understand it to be and where we are not certain, which on this product is more often than either of us would like. Related: vegetable and technical oils for the wider refining side stream picture, and Annex IX for the lists. ## What esterification actually changes, and what it does not An acid oil is a by-product of vegetable oil refining, and its defining problem is free fatty acid content: high FFA means a conventional transesterification plant cannot process it without losing yield to soap. Esterification converts those free fatty acids into esters, which is why the product exists at all. * FFA comes down, usable yield goes up. That is the whole commercial proposition, and it is a real one. * Moisture and impurities still matter, and esterification does not fix them. A low FFA figure on a wet, dirty parcel is not the good news it looks like. * Sulphur and phosphorus carry through from the original refining stream and are what a downstream hydrotreater will actually complain about. * Metals likewise. Esterification is a chemical conversion of one component, not a purification of the whole parcel. This is the misunderstanding we correct most often on this product. * The certification chain is separate again. Whether the volume qualifies under Annex IX depends on documentation, not on the processing step: see Annex IX feedstocks. The practical test when someone offers you esterified acid oil: ask for FFA, moisture, impurities, sulphur and phosphorus together. If only the FFA figure comes back, you are being shown the one number the process was designed to improve, and the rest of the parcel is still an open question. For where the parent stream comes from, see vegetable oils. ## TFM, and why it is the number a soap buyer asks for first Acid oils, PFAD and palm acid oil do not only go to fuel. The oleochemical and soap markets buy them too, and they measure quality differently. If you only ever quote FFA you will never hear from that side of the market. Total Fatty Matter, TFM, is the figure they work from. It is the total percentage by mass of fatty matter that can be separated out after splitting the sample with a mineral acid: fatty acids, rosin acids, unsaponified matter and unsaponifiables, with water, fillers and impurities excluded. * TFM answers a different question from FFA. FFA tells you how much of the material is free acid. TFM tells you how much of the parcel is usable fatty matter at all. A parcel can have respectable FFA and disappointing TFM, and it is the TFM that decides what a soap plant will pay. * PFAD commonly trades against a TFM minimum, often around 70 percent, alongside its FFA specification. * Palm acid oil is usually quoted on FFA as palmitic, with a 50 percent minimum being a familiar figure, plus moisture and impurities. * For context on where the number came from: soap noodles are traded on TFM, typically 78 percent minimum, and the ISO benchmark for a good quality soap sits above 76 percent. That is the market your material is feeding. Practical advice, and it costs you nothing: put TFM alongside FFA, moisture and impurities on every acid oil and PFAD offer. It opens the oleochemical route as well as the fuel route, and when both are bidding you find out what your parcel is genuinely worth rather than what one buyer feels like paying. ## Sources * Directive (EU) 2018/2001 (RED II), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2018/2001/oj * ISCC System, the certification scheme itself: https://www.iscc-system.org/ ## Frequently asked questions Q: What is TFM and why do buyers ask for it? A: Total Fatty Matter: the total percentage by mass of fatty matter that can be separated after splitting the sample with a mineral acid, counting fatty acids, rosin acids, unsaponified matter and unsaponifiables, and excluding water, fillers and impurities. It answers a different question from FFA. Free fatty acid content tells you how much is free acid; TFM tells you how much of the parcel is usable fatty matter at all. Soap and oleochemical buyers work from TFM, and PFAD commonly trades against a TFM minimum of around 70 percent. Q: Should I quote TFM as well as FFA? A: Yes, on every acid oil and PFAD offer, along with moisture and impurities. It costs nothing and it opens the oleochemical and soap route in parallel with the fuel route. Two markets bidding on the same parcel is how you find out what it is actually worth. Q: Does esterification clean up an acid oil? A: It converts free fatty acids into esters, which raises usable yield and is a genuine improvement. It does not purify the parcel. Moisture, impurities, sulphur, phosphorus and metals carry straight through from the original refining stream, and those are what a downstream hydrotreater will complain about. Treating a low FFA figure as proof of a clean parcel is the most common mistake on this product. Q: What should I ask for when buying esterified acid oil? A: FFA, moisture, impurities, sulphur and phosphorus, together and from the same dated analysis. If only the FFA figure comes back, you are being shown the one number the process was designed to improve. Add the certification scope and the origin of the parent refining stream and you have enough to price it properly. Q: What is an esterified acid oil? A: An acid oil that has been through esterification, converting its free fatty acids into methyl esters. This matters because conventional base-catalysed transesterification cannot handle high free fatty acid content, which saponifies instead of converting. Esterification turns a stream that would ruin a batch into a usable biodiesel feedstock. Q: How is acid oil priced? A: On total fatty acid content, not on tonnage. You are buying the usable fraction, so a lower-TFA parcel at a lower headline price is frequently the more expensive option. Always compare on a TFA basis rather than on price per tonne. Q: What is the difference between acid oil, soapstock and PFAD? A: Soapstock is the alkaline by-product of chemical refining. Acid oil is soapstock that has been acidulated to release and concentrate the fatty acids. PFAD, palm fatty acid distillate, comes from physical refining and is a distillate rather than an acidulation product. All three price on fatty acid content. Q: Do acid oils qualify under Annex IX? A: It depends on the specific stream and on national implementation. Whether a stream is treated as a residue, a co-product or a processing by-product affects its position, and member states have taken different views. Confirm the treatment for your stream in your destination market, in writing, before contracting on a multi-year basis. Q: Why does the parent oil origin matter? A: Because it decides both the certification route and, in many cases, the Annex IX position and the market access. Palm-origin acid oil and corn-origin acid oil can be technically similar and commercially very different. Always state the parent oil on the offer. Q: Can you place high FFA material that nobody else wants? A: Often, yes. High FFA is a problem for a conventional biodiesel plant and not necessarily for an esterification plant, an oleochemical buyer or an energy outlet. The useful question is not how bad the FFA is but which processing route is available nearby, because that decides whether it is a discount or a disposal cost. ============================================================================== # Where we work: projects and counterparties worldwide URL: https://www.sustainablecommodities.eu/markets/global-coverage This trade is inherently cross-border. Feedstock is collected where people live and eat, processed where there is capacity, and consumed where there is a mandate, and those are rarely the same place. We work on pyrolysis oil projects and feedstock flows across Europe, the Middle East, Asia and the Americas, with team members in the Netherlands, Brazil, Scotland, England and the Czech Republic, and counterparty relationships considerably wider than that. ## Pyrolysis oil projects Pyrolysis is being built out in very different regulatory and commercial environments at the same time, and the questions differ by region. We are involved with projects and counterparties in: * United Kingdom: our own brokers in England and in Scotland. UK counterparties are covered from the UK, not from the continent. * Middle East: Saudi Arabia, the United Arab Emirates, Qatar. * Asia: India, China, South Korea, Thailand, Vietnam, Malaysia, Indonesia. * Europe: Spain, Romania, Serbia, Hungary, Poland, the Czech Republic, Germany, the United Kingdom, Scandinavia, Turkey, Georgia. * Americas: United States, Brazil, Chile. ## What actually decides whether a corridor works People ask which countries we cover. The honest answer is that the country is rarely the constraint. Four other things are, and they are worth checking in this order. 1. Certification: The question Is there a scheme certificate the buyer accepts, and does its scope cover what you actually do?; What goes wrong A trader certified without storage cannot claim material through a rented tank. Buyers check the scope, not just the certificate 2. Chain of custody: The question Can you show where the material came from, in documents?; What goes wrong This is the most common failure, and it fails late: after the buyer is interested and before the vessel is fixed 3. Names must match: The question Certificate, invoice, bill of lading and the shipper: same legal entity?; What goes wrong A mismatch stops the buyer's compliance desk cold, and no amount of explaining moves it 4. The receiving permit: The question Is the destination installation permitted to accept this material under this classification?; What goes wrong The waste code follows the receiving permit, not the product. Get it in writing Trade measures change the arithmetic, not the legality. Anti-dumping duties, export rebates and quota changes move which origins clear economically, and they change more often than the underlying rules. Last year's calculation on a corridor is usually stale. Where we work in practice: South East Asia and China for used cooking oil and fish oil, South America for animal fats and vegetable oils, North America for UCO and pyrolysis oil, and across Europe for everything. Contracts are in English on standard forms. We work in English and Dutch and we do not claim languages we do not have. ## Why the region changes the deal The same tonne of pyrolysis oil is a different commercial proposition depending on where it is produced and where it lands. * Waste status and shipment. In the EU, whether the oil is a waste governs the entire paperwork chain, and since 2026 plastic waste movement itself has changed sharply. See waste plastics. * Which claim is available. A circular polymer claim needs ISCC PLUS mass balance and a cracker. A fuel claim runs through the recycled carbon fuel rules. See plastic pyrolysis oil and recycled carbon fuels. * Offtake proximity. A project without a realistic buyer within sensible freight distance has a different business case from one next to a cracker, regardless of how good the oil is. * Feedstock security. Input quality, particularly PVC content, is decided by the local collection and sorting system, and that varies enormously between the regions above. ## Feedstock and fuel flows Alongside pyrolysis we work the established flows: used cooking oil and animal fats into European fuel production, POME and residues out of Southeast Asia, vegetable and technical oils, glycerine, fusel oil out of the ethanol producing regions, and finished FAME, HVO and SAF into obligated markets. Our own people sit in the Netherlands, Brazil, the Czech Republic and the United Kingdom, where we have brokers in both Scotland and England. That matters most for origination and for verification: someone who can visit a site, look at a tank and ask the awkward question in person is worth a great deal more than another email chain. ## Everyone here has their own patch, and their own languages We are deliberately not a company where everybody does everything badly. Each of us covers a region and a set of products properly, and that is also why we can answer in more languages than a desk this size usually can. Netherlands, the desk: Founder and broker. Pyrolysis oil, waste-based feedstocks, renewable fuels, additives and off-spec placement. Works in English, Dutch and Frisian. United Kingdom, England: UK counterparties and the British market, covered from the UK rather than from the continent. United Kingdom, Scotland: Northern UK and Scandinavian-facing business. Works in English and French, which also opens France, Belgium, Switzerland and francophone West Africa. Brazil: Latin American origination: ethanol co-products, acid oils, fats and pyrolysis projects. Works in Portuguese, including Brazilian Portuguese, and English. Czech Republic: Central and Eastern Europe, and the certification route. Works in Czech, Polish, Russian and English, which covers Poland, Slovakia, the Baltics and a good deal of the CIS-facing trade. ## The languages we actually work in Across the team: English, Dutch, Frisian, French, Portuguese including Brazilian Portuguese, Polish, Czech and Russian. Write in any of those and you will get an answer from someone who speaks it. We do not work in German, and we say so rather than promise it. For anything technical the working vocabulary is English anyway: Annex IX, ISCC, CIF, FOB and CFPP have no useful local equivalents. Summaries in fourteen further languages are on our international page. ## What we do not claim We are a brokerage, not a multinational with offices everywhere. Where we have depth, we have real depth. Where we do not, we will say so and either work through a partner or tell you plainly that you need someone else. That is a more useful answer than a map with pins on every continent. ## Frequently asked questions Q: Which countries do you work with? A: We broker between Europe and wherever the material or the buyer genuinely is: South East Asia and China for used cooking oil and fish oil, South America for animal fats and vegetable oils, North America for UCO and pyrolysis oil, and across Europe for everything. What decides whether a corridor works is not the country but whether the certification, the documents and the receiving permit line up. Q: Do you handle the export documentation? A: We do not issue documents, and no broker should claim to. What we do is tell you which documents a European buyer will demand before they engage, and introduce you to the inspection companies, laboratories and forwarders who produce them. For a first-time exporter the paperwork is usually the bottleneck rather than the product. Q: What is the most common reason a cross-border deal fails? A: Certification, not price. A seller with excellent material and no accepted scheme certificate cannot sell into European fuel at all, and finding that out after a vessel is fixed is expensive. The second most common reason is a documentation mismatch: the name on the certificate is not the name on the invoice, and the buyer's compliance desk stops the whole thing. Q: Do you speak the language of my market? A: We work in English and Dutch. For everything else we work through the counterparty's own commercial language, which in this trade is almost always English, and we do not pretend otherwise. Contracts in this market are in English on standard forms. Q: Where do you have people on the ground? A: The Netherlands, Brazil, the Czech Republic and the United Kingdom, with brokers in both Scotland and England. Counterparty relationships extend considerably further, across the Middle East, Asia and the Americas, but those five are where our own team sits. Q: Do you work on pyrolysis oil projects outside Europe? A: Yes. We are involved with pyrolysis projects and counterparties in Saudi Arabia, the UAE, Qatar, India, China, South Korea, Thailand, Vietnam, Malaysia, Indonesia, Turkey, Georgia, the United States, Brazil and Chile, alongside European projects. Q: Can you help a project that is still in development? A: Often the most useful stage to involve a broker. The questions that decide a project's economics, which buyers can actually run the output, what the chlorine specification has to be, whether the waste status works for the intended destination, are cheaper to answer before the plant is built than after. Q: Do you arrange international shipping? A: We advise on freight optimisation and supply chain routing and we can help find storage, but we are a broker rather than a freight forwarder and we do not issue bills of lading. See storage and logistics. Q: Which languages do you work in? A: Across the team: English, Dutch, Frisian, French, Portuguese including Brazilian Portuguese, Polish, Czech and Russian. That covers most of Europe, francophone West Africa, Latin America and a good deal of CIS-facing business. We do not work in German, and we say so rather than promise it. Q: Can you place cargo in regions where you have no team? A: Sometimes, through partners and counterparty relationships. But we will tell you honestly when a region is outside what we can genuinely cover, rather than take an instruction we cannot execute. ============================================================================== # Fuel additives and blending components URL: https://www.sustainablecommodities.eu/markets/additives-and-blending We do more than introduce buyers and sellers: we also supply additives and blending chemicals, and it is a real part of what we do rather than a sideline. Cold flow additives such as pour point depressants and CFPP improvers, octane improvers, antioxidants, static dissipaters, process chemicals such as potassium hydroxide and methanol, and the two alkoxide catalysts that actually run a biodiesel plant, KM32 and NM30. Additive stock is held worldwide through our supply network, and with ATEX-certified injection equipment a cargo can be treated in a shore tank, on the vessel or at anchorage, including during STS and OPL operations. Where useful we pair that with the theoretical blend calculation and a hand blend tested at a partner laboratory, so the additive is chosen against a measured result rather than a datasheet. On additives we may be your counterparty rather than your broker. Everywhere else on this site we broker: we never take title and we do not trade our own book. Additives are the exception, because here we also buy and sell for our own account. We say which of the two applies before anything is agreed, and it is written into our terms as article 4.7. ## What we supply * Pour point depressants (PPD), to lower the temperature at which a fuel stops flowing. Widely used in gasoil and in biodiesel blends heading into cold climates. * CFPP improvers and cold flow additives, targeting the cold filter plugging point specifically. This is the parameter that most often puts a FAME cargo out of grade, so it is where additive treatment earns its money. See FAME biodiesel. * Potassium hydroxide (KOH), the alkaline catalyst used in transesterification. * Methanol, the alcohol that makes a fatty acid methyl ester a methyl ester in the first place. * KM32, potassium methylate 32 % in methanol. The transesterification catalyst you reach for when the feedstock is not clean vegetable oil. Potassium methylate is the more reactive alkoxide, gives cleaner glycerol phase separation and a higher yield, and is the usual choice for plants running used cooking oil, animal fats and other lower grade material. The dividing line the catalyst producers themselves use is free fatty acid of about 1.0 %: below that the cheaper sodium methylate does the job, above it potassium methylate is offered. In other words, exactly the feedstocks we broker. We supply it into North African markets including Tunisia, so the route and the paperwork are familiar rather than theoretical. * NM30, sodium methylate 30 % in methanol. The global workhorse catalyst for biodiesel and the cheaper of the two. Effectively water free, which keeps purification cost down and yield consistent. Where the feedstock is clean enough, this is usually the economic choice. * Other performance additives on request: antioxidants for oxidation stability, biocides for microbial contamination in storage, lubricity improvers, cetane improvers, demulsifiers and anti-foam. ## Start here if additives are new to you Most people arrive at this subject with a problem, not a product name. So here is the plain version, because almost nobody writes it down. * What is a PPD? A pour point depressant. Diesel, gasoil and biodiesel contain paraffin waxes. As the fuel cools, those waxes crystallise, the crystals grow and link up, and eventually the fuel stops flowing. A PPD does not stop wax forming: it changes the shape and size of the crystals so they stay small and separate, and the fuel keeps flowing at a lower temperature. * Why does my diesel go cloudy, then waxy, then solid? Three different temperatures, in this order. Cloud point is where the first wax crystals become visible and the fuel turns hazy. CFPP, cold filter plugging point, is where enough wax has formed to block a filter, and this is the one that actually stops an engine or a pump. Pour point is where it stops flowing at all. Nothing is wrong with the fuel; it is chemistry doing what it always does, and it is treatable. * What are flocs, and why is my tank full of them? Wax crystals that have clustered into visible flakes, usually after a cargo has sat cold or been cooled and rewarmed. They block filters and look alarming in a sample bottle. A wax anti-settling additive keeps them dispersed instead of dropping to the bottom of the tank, and warming plus the right dose usually recovers the parcel. Do not write a cargo off because it looks bad in the cold. * What is an octane booster? An additive that raises the octane number of gasoline, meaning its resistance to knocking under compression. In customs terms these are anti-knock preparations and they sit in their own heading. * What is a cetane improver? The diesel equivalent, in reverse: it shortens ignition delay so the fuel burns more readily. * Why does biodiesel need an antioxidant? FAME oxidises in storage, particularly warm storage, and oxidation stability is a specification limit under EN 14214. An antioxidant slows that down. Stability that was fine at loading can be out of specification two months later, which is why the date on the analysis matters as much as the number. ## Treating an off-spec cargo instead of writing it off This is where additives and our off-spec work meet, and it is the most useful thing on this page. A parcel that fails on cold flow, oxidation stability or appearance is very often treatable, and treating it is almost always worth more than discounting it. We will run the theoretical blend calculation, arrange a hand blend at a partner laboratory, and tell you honestly whether the treatment brings the parcel into specification or whether it needs a different home instead. Both answers are useful; only one of them is the answer people expect. What we will not do is sell you a drum of additive on the hope that it works. If the parcel cannot be corrected, it goes to off-spec and distressed cargoes and we place it instead. ## The full additive range, and the customs codes that go with it Additives are one of the few things we supply rather than broker, so it is worth setting out the range properly. The customs classification matters more than people expect: it decides duty, and getting it wrong on an export declaration holds a container at the border. Pour point depressants (PPD): Lower the temperature at which a fuel stops flowing. The workhorse for gasoil and biodiesel blends going into cold climates. Normally CN 3811 90. CFPP and cold flow improvers: Target the cold filter plugging point specifically. The parameter that most often puts a FAME cargo out of grade. Normally CN 3811 90. Octane improvers and anti-knock preparations: Raise the octane number of gasoline. These sit in their own customs heading, CN 3811 11 and 3811 19, separate from other additives, which is exactly the distinction people get wrong on a declaration. We are actively looking for octane boosters and for buyers of them. Antioxidants: Oxidation stability, which degrades in storage and is a recurring cause of off-spec FAME. Normally CN 3811 90. Cetane improvers: Raise the cetane number of diesel and biodiesel blends. Lubricity improvers: Restore lubricity lost when sulphur is removed from a fuel. Biocides: Microbial contamination in storage, a real problem in tanks holding FAME blends. Demulsifiers and anti-foam: Water separation and handling. Detergents and deposit control: Injector and combustion chamber cleanliness. Corrosion inhibitors: Tank, pipeline and injection system protection. Dyes and markers: Fiscal marking and product identification. Process chemicals: Potassium hydroxide, methanol, and the alkoxide catalysts KM32 and NM30 covered above. ## What the treatments achieve, in numbers Buyers usually ask the same question first: what does a treatment cost compared with blending the problem away. The honest answer is that treat rates sit in parts per million while blendstock sits in whole percentages of the cargo, so the additive route almost always wins on arithmetic before quality even enters the discussion. These are the indicative ranges we work from; the final dosage is always confirmed by a laboratory trial on the actual base fuel, and treatment must comply with the specification and the legislation of the destination market. PPD for fuel oil: 200 to 1,000 ppm | Pour point reduction of 6 to 12 °C with density and sulphur unchanged, against adding gasoil or cutting with lighter streams MMT for gasoline: 8 to 20 mg/l | RON uplift of roughly +0.3 to +2.0, against expensive reformate, alkylate or MTBE; EU road use is restricted, see MMT above Ferrocene for gasoline: 10 to 25 ppm | Similar octane uplift on markets where iron-based additives meet the destination specification CFPP improver for gasoil: 200 to 1,200 ppm | CFPP improvement of 5 to 18 °C, against kerosene blending with its seasonal availability and its price Antioxidant for gasoline and gasoil: 50 to 200 ppm | Protection against gum formation and ageing on long voyages and in warm climates, against selling aged stock at a discount Static dissipater additive: 1 to 5 ppm | Immediate conductivity improvement for safe, compliant loading and discharge at full pumping rate And the range goes beyond chemicals: ATEX-certified pumping and injection equipment is available for dosing directly into shore tanks, vessels and barges, including during ship to ship transfers and OPL anchorage operations, so a cargo can be treated while it is already afloat. Where an additive is not available locally, the full import chain is arranged: logistics, customs clearance and the regulatory requirements of the destination region. ## Raw materials and blending components, and why some of them are hard Behind the finished additives sits a raw material trade, and this is where most of the surprises live. Three components come up constantly, and each one is difficult for a completely different reason. Knowing which reason you are dealing with saves weeks. * MMT, methylcyclopentadienyl manganese tricarbonyl. A manganese-based octane booster, and also used to protect valve seats in older engines running on unleaded petrol, where it does the job lead used to do. In the EU it is capped by the Fuel Quality Directive at 2 mg of manganese per litre, down from 6 mg in 2011, because burning it releases manganese and leaves deposits that degrade emission control systems. Outside the EU it is unrestricted in most of the world, which is exactly why the trade runs the way it does. If someone offers you MMT for a European blend, check the manganese arithmetic before anything else. * BHT, butylated hydroxytoluene. A straightforward and widely traded antioxidant, used to hold oxidation stability in fuels and in a great many other products. The easy one of the three. * Toluene. Technically a useful octane and solvent component, and commercially a headache, because it is a Category 3 drug precursor under EU rules. Trade inside the EU falls under Regulation (EC) No 273/2004 and trade with countries outside the EU under Regulation (EC) No 111/2005, which means documented operators and import or export authorisations from the competent authority. Exporters routinely decline it, and they are not being difficult: the paperwork genuinely is strict. Anyone who offers to move it without those authorisations is offering you a problem, not a solution. ## Getting it there, including when it has to be there tomorrow Additives move as classified dangerous goods more often than not, and that shapes everything about how they travel. This is not a product you hand to a general courier. * Packaging: drums, IBCs, ISO tanks or bulk depending on volume and product. IBCs in a container are the common format for export lots. * Classification: IMO and ADR classification, UN number, packing group and the safety data sheet travel with the goods. A shipment that arrives without them does not get loaded. * Sea freight for volume, on lanes out of the ARA range and Antwerp to most destinations. * Air freight when the plant is down. A refinery or blender waiting on an additive is losing more per day than the freight costs. Where a product can be flown as classified dangerous goods, we will arrange it. Tell us the deadline rather than the budget and we will tell you what is possible. * Customs and documentation: the correct CN heading, the certificate of analysis, the safety data sheet and the export paperwork, prepared before the truck arrives rather than at the gate. * Delivery on board. Additives can be supplied to a vessel alongside rather than to a shore tank, which is sometimes the only practical route when a cargo needs treating before discharge. * West Africa, with stock on the ground. Through our partners we hold local additive stock in the region rather than shipping every drum from Europe, and we have inspection and laboratory support there for feedstocks and finished product. That matters because the alternative is a three week lead time on a problem that needs solving this week. ## Handling and safety Several of these are hazardous or corrosive substances. Methanol is toxic and highly flammable, potassium hydroxide is corrosive, and both carry classification, packaging and transport obligations. Supply runs with the safety data sheet, the correct transport classification and documentation to match, and we will not cut corners on that to save a day. ## How we actually do it This part is worth stating plainly, because additive supply works differently from our brokerage and people reasonably ask which hat we are wearing. * On the brokerage side we introduce buyer and seller and take a commission. We do not take title. * On the additive side we arrange supply against a firm requirement, which is a supply transaction rather than an introduction. Payment terms are agreed per transaction and prepayment is normal for the trade, particularly on first business and on smaller lots. * Documentation travels with the product: specification or certificate of analysis, safety data sheet, classification and the transport paperwork the mode requires. * Volumes run from drums and IBCs up to isotank and bulk, depending on the product and the destination. ## Before the chemistry: are you even allowed to add anything? This is the question people ask last and should ask first. We regularly see supply contracts with a clause along the lines of *the product deliverable under this agreement shall not contain any cold flow improvers or additives, with the exception of oxidation stability improvers*. Some go further and require prior written approval for any additive at all. That clause exists for good reasons and it bites hard. * Certification and traceability. Under a mass balance scheme, what goes into the tank has to be accounted for. An undeclared additive is a compliance problem long before it is a quality problem. * Downstream processing. A buyer who is going to hydrotreat or crack the material may have catalyst that will not tolerate what you added, and they will not find out until it is in their unit. * Analytical fingerprints. Additives show up. A cold flow improver changes the cold properties without changing the underlying material, which is precisely what a buyer testing for feedstock quality is trying to see through. * The oxidation stability carve out. Where additives are banned, oxidation stability improvers are very often the one permitted exception, because they preserve the material rather than mask its properties. That distinction is the whole logic of the clause: preserving is allowed, flattering is not. So the practical order is: read the contract, ask before you dose, and get the approval in writing. An additive that fixes a number and voids a contract has not fixed anything. If the cargo is already off specification and you are looking for a way out, off-spec and distressed cargoes is the more honest route. ## Blending advice, which is usually the more useful half Selling somebody an additive is easy. Telling them whether it will fix the problem is the part that matters, and it is frequently the answer that saves the most money. * Theoretical blend calculation, working out what a proposed blend will do to the key parameters before anything is moved. * Hand blends and sample testing with partner laboratories, so the decision rests on a measured result rather than on a supplier datasheet. * Additive requirement assessment, including the case where the honest answer is that no additive will bring the material into specification and the parcel needs a different home. That situation is covered under off-spec and distressed cargoes. * Specification interpretation, particularly around seasonal and national cold flow requirements, which differ across Europe and move with the calendar. ## Sources * Document checklist: exactly which papers a European buyer asks for, per product: /markets/document-library * Regulation (EC) No 1907/2006 (REACH), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2006/1907/oj * European Chemicals Agency (ECHA), the REACH authority: https://echa.europa.eu/ * EU Customs Tariff (TARIC), for checking commodity codes: https://taxation-customs.ec.europa.eu/customs-4/calculation-customs-duties/customs-tariff/eu-customs-tariff-taric_en ## Frequently asked questions Q: Can you treat a cargo that is already at sea? A: Yes, and it is asked more often than any other additive question. With ATEX-certified pumping and injection equipment we can dose into shore tanks, vessels and barges, including during ship to ship transfers and OPL anchorage operations. The compliance work happens before the hose goes in: the additive must meet the destination specification and legislation, and the dosage is confirmed by laboratory trial. Q: Are MMT and ferrocene allowed in EU road gasoline? A: No, not meaningfully: EN 228 restricts metallic additives, and MMT's manganese deposits degrade emission control systems, so for European road blends these products are off the table. Outside the EU they are unrestricted in most of the world, which is exactly the market they serve. We check the destination specification and the local law before anything is quoted. Q: Which is cheaper, additive treatment or blending the problem away? A: Almost always the additive, and it is not close. Treat rates sit between 1 and 1,200 ppm depending on the treatment, while the traditional fix adds whole percentages of gasoil, kerosene or premium gasoline to the cargo. The additive route also leaves density, sulphur and volume untouched, so the entire cargo is upgraded instead of diluted. Q: How do we know the dosage before committing? A: A laboratory hand blend on your actual base fuel, at a partner laboratory, is how every serious treatment starts. Datasheet numbers are indicative; wax composition, stream history and the existing additive package all move the treat rate. We run the trial, you see the measured result, and only then is anything ordered. Q: Do you supply fuel additives as well as broker cargo? A: Yes. Additive and blending chemical supply is a genuine part of what we do alongside the brokerage. On the brokerage side we introduce buyer and seller and take a commission without taking title. On the additive side we arrange supply against a firm requirement, which is a supply transaction rather than an introduction. Q: What is a PPD, in plain language? A: A pour point depressant. Diesel, gasoil and biodiesel contain paraffin waxes that crystallise as the fuel cools; the crystals grow, link up and eventually stop the fuel flowing. A PPD does not prevent wax forming, it changes the crystal shape and size so they stay small and separate and the fuel keeps flowing at a lower temperature. Q: How do I stop diesel from waxing or flocculating? A: Know which of the three temperatures you are fighting first. Cloud point is where wax becomes visible, CFPP is where it blocks a filter and actually stops the engine, and pour point is where it stops flowing entirely. A cold flow improver or PPD treats the CFPP, and a wax anti-settling additive keeps flocs dispersed instead of dropping out in the tank. Dose rate depends on the base fuel, so a hand blend test beats a datasheet. Do not write a cargo off because it looks bad cold. Q: Can an additive save an off-spec cargo? A: Often, and it is usually worth more than discounting the parcel. Cold flow failures and oxidation stability failures are the two most treatable. We run the theoretical blend calculation, arrange a hand blend at a partner laboratory, and tell you honestly whether treatment brings it into specification. If it does not, we place the parcel instead rather than sell you a drum on hope. Q: Do you supply additives in Africa? A: Yes. Through our partners we hold local additive stock in West Africa rather than shipping every drum from Europe, and we have inspection and laboratory support in the region for both feedstocks and finished product. For urgent cases we also fly product in as classified dangerous goods, and additives can be delivered to a vessel alongside rather than to a shore tank. Q: What is MMT, and can I use it in Europe? A: MMT is methylcyclopentadienyl manganese tricarbonyl, a manganese-based octane booster that also protects valve seats in older engines running unleaded petrol. In the EU it is capped by the Fuel Quality Directive at 2 mg of manganese per litre, reduced from 6 mg in 2011, because combustion releases manganese and the deposits degrade emission control systems. Outside the EU it is unrestricted in most countries. So the honest answer for a European blend is: check the manganese arithmetic first, because the cap binds long before anything else does. Q: Why will nobody quote me toluene? A: Because it is a Category 3 drug precursor under EU rules. Trade within the EU falls under Regulation (EC) No 273/2004 and trade with third countries under Regulation (EC) No 111/2005, which requires documented operators and import or export authorisations from the competent authority. Suppliers who decline are not being awkward, the controls are genuinely strict. Treat anyone who offers to move it without those authorisations as a risk rather than a find. Q: What is BHT used for in fuel? A: Butylated hydroxytoluene is an antioxidant. It slows the oxidation that degrades fuel in storage, which matters most for FAME and FAME blends where oxidation stability is a specification limit that quietly falls over time. It is the straightforward one among the common raw materials, widely traded and without the regulatory complications of MMT or toluene. Q: Do you supply octane boosters? A: Yes, and we are actively looking for both supply and buyers. Octane improvers and anti-knock preparations sit in their own customs headings, CN 3811 11 and 3811 19, separate from other fuel additives under CN 3811 90. That distinction matters on an export declaration and is one of the more common classification errors we see. Q: Can you get an additive to us urgently? A: Often yes, including by air where the product can travel as classified dangerous goods. A blender or refinery waiting on an additive usually loses more per day than the freight costs, so tell us the deadline rather than the budget and we will tell you what is genuinely possible. Sea freight in IBCs or ISO tanks for volume, air for the emergency. Q: What customs code applies to fuel additives? A: Broadly CN heading 3811. Anti-knock preparations and octane improvers fall under 3811 11 and 3811 19; other prepared additives for oils generally under 3811 90. Confirm the exact code with your customs agent for your specific product and destination, because a wrong heading holds the container and can change the duty. Q: Do you supply catalysts into North Africa? A: Yes. We supply KM32 into North African markets including Tunisia for biodiesel production, so the shipping route, the documentation and the payment practice are familiar to us rather than something we would be working out for the first time on your order. Q: What is KM32? A: Potassium methylate 32 % solution in methanol, also written potassium methoxide. It is a transesterification catalyst for biodiesel production. Compared with the sodium equivalent it is more reactive, separates the glycerol phase more cleanly and gives a higher yield. The practical dividing line used in the industry is free fatty acid content of about 1.0 %: below that sodium methylate is the economic choice, above it potassium methylate is offered. That threshold is exactly why KM32 is the catalyst for plants running used cooking oil and animal fats rather than clean vegetable oil. Q: What is NM30, and how do I choose between NM30 and KM32? A: NM30 is sodium methylate 30 % solution in methanol, the most widely used biodiesel catalyst worldwide and the cheaper of the two. The practical dividing line is free fatty acid content around 1.0 %: below that NM30, above that KM32 for the extra reactivity, the cleaner glycerol separation and the yield. Both are effectively water free, which keeps purification cost down. Q: How are methylate catalysts shipped and stored? A: Carefully. They are dissolved in methanol, so the flammability and toxicity of methanol travel with them, and the alkoxide itself is corrosive and highly moisture sensitive: contact with water or humid air degrades it and generates the corresponding hydroxide. They move under nitrogen blanket in dedicated equipment, with the safety data sheet and full transport classification. This is not a product to improvise on. Q: Which additives do you handle? A: Pour point depressants, CFPP and cold flow improvers, potassium hydroxide, methanol, and named grades including KM32 and NM30. On request also antioxidants, biocides, lubricity improvers, cetane improvers, demulsifiers and anti-foam. Tell us the base fuel and the target specification rather than the product name and we can usually be more useful. Q: Why does a biodiesel producer need potassium hydroxide and methanol? A: Both are process chemicals for transesterification, the reaction that turns oils and fats into fatty acid methyl esters. Methanol is the alcohol that supplies the methyl group, and potassium hydroxide is a commonly used alkaline catalyst. Neither is an additive to the finished fuel; they are inputs to making it. Q: What are your payment terms for additive supply? A: Agreed per transaction. Prepayment is normal for this trade, particularly on first business and on smaller lots, which is standard practice in chemical supply rather than anything unusual to us. Q: Can you tell me whether an additive will fix my off-spec cargo? A: Often, and we would rather answer that honestly than sell you a drum. We can run a theoretical blend calculation and arrange a hand blend tested at a partner laboratory. Sometimes the answer is that no additive brings the material into specification, in which case the parcel needs a different outlet rather than a treatment. Q: Do you handle the hazard classification and transport paperwork? A: Supply runs with the safety data sheet, the correct classification and the transport documentation the mode requires. Methanol is toxic and highly flammable and potassium hydroxide is corrosive, so this is not paperwork to be improvised at the loading bay. ============================================================================== # ISCC certification: how it works and how we help URL: https://www.sustainablecommodities.eu/markets/iscc-certification We introduce you to a certification body and stay involved through the audit, rather than handing you over at the door. On the two schemes: ISCC EU is for the Renewable Energy Directive, ISCC PLUS for circular and bio-based materials, and picking the wrong one costs you the audit. On what fails an audit in practice, it is almost never the sustainability criteria. It is the mass balance bookkeeping, a certificate whose scope does not cover the product or the activity, and a missing self declaration at the point of origin. What we cannot do is issue certificates ourselves, and neither can any broker. ## Which scheme you need Pick the wrong scheme, or the right scheme with the wrong scope, and you pay for an audit that does not let you do the business you wanted. That is the single most common and most expensive mistake we see, and it is entirely avoidable with one conversation before you sign the certification contract. * ISCC EU, for biofuels and bioliquids placed on the EU market under the Renewable Energy Directive. If you want your material counted towards a member state obligation, this is the one. * ISCC PLUS, for the non-fuel world: circular and bio-based polymers, chemicals, food and feed. This is the scheme behind a certified circular polymer claim, and therefore behind the value in plastic pyrolysis oil. * ISCC CORSIA, for aviation under the ICAO scheme. Separate from ISCC EU and not interchangeable with it, which catches people out on SAF. ## The four ISCC schemes, and which one your business actually needs ISCC is not one certificate. It is a family, and they are not interchangeable. Holding ISCC PLUS and being asked for ISCC EU means another audit, another fee and a delay measured in months, so this is worth twenty minutes before it is worth twenty thousand euro. ISCC EU: What it proves Compliance with the EU Renewable Energy Directive: sustainability and GHG criteria for biofuels, bioliquids and biomass fuels; Who needs it Anyone whose material ends up in EU transport or energy targets. The default for UCO, animal fats, POME and FAME into Europe ISCC PLUS: What it proves The same discipline applied outside the RED: bio-based and recycled content in markets the Directive does not reach; Who needs it Chemicals, plastics, packaging, textiles, food and feed. The currency for pyrolysis oil into a cracker ISCC CORSIA: What it proves Sustainability and GHG criteria for aviation fuel under the ICAO CORSIA scheme; Who needs it SAF supply chains on international flights ISCC EU RFNBO: What it proves Renewable fuels of non-biological origin, meaning hydrogen and e-fuels; Who needs it Power-to-X projects, not conventional feedstock trade National schemes: GSE-SNC (IT), KZR INiG (PL), 2BSvs (FR), REDcert (DE): What it proves The same RED compliance, recognised nationally or by the Commission; Who needs it Italy's Sistema Nazionale di Certificazione, run by GSE, is the one most often missed. Italy transposed RED III with effect from February 2026. A buyer there may want SNC rather than, or alongside, a voluntary scheme The short version: EU for fuel, PLUS for plastic, CORSIA for aviation. If the same material might go to two of those, say so at the audit stage rather than afterwards, because adding a scope later is a new audit and not an amendment. One thing sellers routinely underestimate: a certificate is issued to a scope, and the scope names the activities and the sites. A trader certified without storage cannot suddenly claim material through a tank they have just rented. Buyers check this, and they check it before the first cargo rather than the tenth. ## What the process actually looks like It is less mysterious than people expect, and the timeline is more predictable than the cost. 1. Registration: Register with ISCC and choose a recognised certification body. The scope you declare here governs everything after. 2. Preparation: Documented management system, mass balance bookkeeping, supplier self-declarations, GHG calculation method. 3. Optional pre-audit: Worth it if you are starting from scratch. It turns audit findings into a to-do list instead of a failure. 4. Certification audit: On site. Document review plus examination of how the system works in practice, not just on paper. 5. Report and certificate: Audit report, then the certificate with your scope, product groups and validity. Typical timeline: Roughly 6 to 10 weeks if you are reasonably organised. Closer to 3 or 4 months from a standing start with suppliers new to self-declaration forms. Typical audit fee: Commonly in the region of EUR 2,500 to 6,000 for a single site trader, scaling with scope and supplier count. Your own preparation is the biggest variable you control. Annual surveillance: Certification is not one and done. Budget for the recurring audit. ## Which scope does my activity actually need? Scope is where a first audit most often turns into two. These four cases cover almost everything a collecting point runs into. Collecting point that treats UCO mechanically: No separate treatment plant scope, provided the treatment stays within the conditions ISCC sets for it. Storage on your own site: No warehouse scope. Any external storage facility: Warehouse scope is required. Buying UCO from other certified suppliers: Trader with storage. This is the one people miss: the moment you buy certified material rather than only collect it, your scope changes. ## How many sites get audited, and how long does it take? The numbers below are the ones that decide your preparation, and they are the questions we get asked most often by a collecting point that is about to start. How many points of origin get visited?: The square root of the number of points of origin, multiplied by two. Twenty five PoO means five visits; one hundred means ten. Which points of origin fall inside the sample?: Those supplying more than 5 MT per month, or more than 60 tonnes per year. How many PoO do I have to list for the first audit?: Not all of them. Around ten in one area is workable, and further PoO can be added during the certification period. How long does preparation take?: Roughly two months of realistic preparation. The certification itself then depends on your certification body, and auditor availability is usually the binding constraint. When is the first surveillance audit?: Six months from the date the certificate is issued. And if I also handle virgin oils?: An additional surveillance audit applies at three months. What is the ISCC turnover fee based on?: The general turnover of the company, not only the turnover of the collection activity. That surprises people who expect it to scale with the certified volume. Can I collect household UCO?: Yes, documented in line with ISCC 203. ## What actually fails an audit From what we see on the trading side, failures cluster in a few places and almost none of them are exotic. * Mass balance that does not reconcile. Incoming and outgoing quantities, and the accounting period, have to line up. Spreadsheets that are rebuilt after the fact do not survive an auditor. * Scope that does not cover the activity. Trading with storage is not the same scope as trading without. First point of collection is different again. * Supplier documentation gaps. Self-declarations missing, incomplete or signed by someone with no authority to sign them. * Traceability that stops at the first tier. Increasingly buyers and auditors want to see the collection base, not just your immediate supplier. See used cooking oil on why that scrutiny exists. * GHG figures that cannot be reproduced. Using a default value and then claiming an actual value, or the reverse. * Union Database entries that do not match the physical paperwork. ## How we help, and what it costs you We are a broker, so we are honest about our position here. We do not audit, we do not issue certificates, and we are not a consultancy dressed as one. What we do is introduce you to Silk Road Certification in Poland, our certification partner, who handle ISCC EU and ISCC PLUS. We make the introduction, help you frame the scope so it matches the business you actually want to do, and stay reachable while it runs. We are paid a commission on that introduction, and we would rather say so plainly than have you wonder. The reason we bother: a counterparty who cannot certify is a counterparty we cannot trade with. Getting people certified is not a side business, it is how the market we work in gets bigger. The certifier is not the only introduction that matters. Most collecting points do not get stuck on the audit itself, they get stuck on what comes before it: the sustainability handbook, the mass balance template, the list of points of origin, the signed self declarations, and knowing what an auditor will actually open first. We can also introduce you to someone who has sat on both sides of that table and prepares the file with you. Ask, and say where you are and what you collect. ## Italy runs its own scheme, and we trade material under it Alongside the recognised voluntary schemes, Italy operates a national certification system, the Sistema Nazionale di Certificazione administered by GSE. It is usually shortened to the Italian National Scheme, or INS. This matters commercially rather than academically. Material certified under INS is not automatically interchangeable with ISCC material in a buyer's book, and the two do not always carry the same value on the same day. We trade both, and the questions we ask a seller before quoting are always the same three: * Which scheme is the certificate actually under, and does the receiving party in the destination country accept it for the use they have in mind. * What is in the scope, product by product. A supplier certified for used cooking oil and spent bleaching earth oil does not automatically hold food waste oil, and that is the gap that shows up latest and hurts most. * What monthly volume actually sits behind the certificate, as opposed to what the certificate allows in theory. If you hold INS material and are not sure how a European buyer will price it against ISCC, that is a fair question to put to us before you go to market. It is also the question we put to the buyer on your behalf. ## Sources * ISCC, which certification is right for me: https://contact.iscc-system.org/support/solutions/articles/103000349213-which-certification-is-right-for-me- * ISCC System, the certification scheme itself: https://www.iscc-system.org/ * ISCC system documents and audit procedures: https://www.iscc-system.org/certification/iscc-documents/ * ISCC PLUS, the scheme used for circular and bio based materials: https://www.iscc-system.org/certification/iscc-certification-schemes/iscc-plus/ * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj ## Frequently asked questions Q: How can I check that a counterparty's ISCC certificate is valid? A: Certificates carry a validity window and a scope, and both trip people up more often than price ever does. ISCC publishes its certificate holders through its own lists, so check two things before relying on a copy in your inbox: that the validity end date covers your delivery window, and that the scope and the certified product group actually include the material you are buying. A certificate that is in scope but expired is the most common reason a deal that was agreed falls apart at the audit. And a certificate belongs to one company at one location: a group certificate does not automatically cover a sister site. Q: How long does ISCC certification take? A: Once your preparation is genuinely done, the audit to certificate step commonly runs four to eight weeks. From a standing start, six to ten weeks end to end is a fair planning assumption, and closer to three or four months if your suppliers have never filled in a self-declaration. It stretches if your documentation is incomplete or your supply chain has more links than you first described. The audit itself is short; the preparation is what takes the time. Q: What happens if the audit finds problems? A: You get a list of corrective measures, and the usual window to implement them is forty days. The certificate is only issued once they are actually closed out, not when you promise to close them. This is why we push people to run an internal check before the real audit: the findings are almost always the same ones, and finding them yourself costs weeks rather than a failed audit. Q: Who actually issues the certificate, ISCC? A: No, and this trips people up. ISCC runs the scheme but does not audit. You contract directly with an independent recognised Certification Body, and they do the audit and issue the certificate. That means choosing the body is a real decision: their experience with your specific product and region affects how smoothly it goes. We make the introduction and stay involved rather than handing you over. Q: How much work is it internally? A: More than most first-timers budget for. For a first certification, expect something in the order of 80 to 250 person-hours across operations, quality and administration, depending on how much of your record keeping already exists in usable form. The audit fee is rarely the expensive part. The expensive part is discovering that your mass balance bookkeeping has to be rebuilt from scratch three weeks before the auditor arrives. Q: What does ISCC certification cost? A: Certification body audit fees commonly land in the region of EUR 2,500 to 6,000 for a single site trader, scaling with scope, number of sites and supplier count, plus the ISCC system fee and recurring surveillance audits. How well prepared you are is the biggest cost variable you actually control. Get a quote for your own scope rather than budgeting off a general figure. Q: What is the difference between ISCC EU and ISCC PLUS? A: ISCC EU covers biofuels and bioliquids placed on the EU market under the Renewable Energy Directive, so it is what you need for material to count towards a member state obligation. ISCC PLUS covers the non-fuel world: circular and bio-based polymers, chemicals, food and feed. A certified circular polymer claim runs on ISCC PLUS, not ISCC EU. Q: Do I need ISCC to sell used cooking oil? A: To sell into the EU biofuel chain, effectively yes: uncertified material cannot enter a renewable fuel claim. There is a real and growing market for non certified UCO in oleochemical, industrial and energy outlets, but it trades against different buyers at different levels. We will tell you plainly which market you are in. Q: Can you get us ISCC certified? A: We do not audit and we do not issue certificates, so no broker can. What we do is introduce you to Silk Road Certification in Poland, our certification partner for ISCC EU and ISCC PLUS, help you get the scope right before you commit, and stay involved. We are paid a commission on the introduction and we say so up front. Q: What is mass balance in ISCC? A: A chain of custody method where certified and non certified material may be physically mixed, but the certified quantity is tracked through the books and can only be sold on as certified once. Incoming and outgoing quantities and the accounting period have to reconcile. A mass balance that is reconstructed after the fact is the most common audit failure we hear about. Q: How do I get ISCC certified, step by step? A: Register with ISCC and choose a recognised certification body, deciding your scope carefully because it governs everything after. Put a documented management system, mass balance bookkeeping, supplier self-declarations and a GHG calculation method in place. Take the optional pre-audit if you are starting from scratch, because it turns audit findings into a to-do list instead of a failure. Then the on-site certification audit, the report, and the certificate. Roughly 6 to 10 weeks if you are organised, 3 to 4 months from nothing. Q: Which certification body should I use? A: Any ISCC-recognised body can certify you, and several are active in this space including Control Union, SGS, DNV, DEKRA and Normec. We work with Silk Road Certification in Poland and will make the introduction. What matters more than the name is that your scope is framed correctly before you sign the certification contract, because a scope that does not cover the business you want to do is an expensive thing to discover afterwards. Q: Do I need to be certified to buy, or only to sell? A: Both sides of a certified transaction need to be in the system for the sustainability characteristics to pass down the chain. If you are buying certified material and want to pass the proof of sustainability on, you need your own certificate with the right scope. If you are the final user and not passing anything on, the position differs, so check it rather than assume. Q: What is the most common reason an ISCC audit fails? A: Scope and mass balance. Either the certificate scope does not actually cover the activity the company wants to do, which is discovered too late, or the mass balance does not reconcile because it was kept as an afterthought rather than as a live record. ============================================================================== # REACH and product compliance for waste-derived materials URL: https://www.sustainablecommodities.eu/markets/reach-compliance Let us be straight: REACH is not our core business. We are a commodity brokerage, not a regulatory consultancy. But REACH decides whether some of what we broker can legally be placed on the EU market, and the question gets asked far too late far too often. Three points cover most situations: waste is outside REACH until end-of-waste; Annex V exempts a list that includes vegetable and animal fats and oils, many fatty acids and glycerol; and pyrolysis oil, as a UVCB, generally is not exempt. ## The three things that decide it That last point is the one that surprises people. A pyrolysis project can solve chlorine, solve certification, find a cracker, and then discover that the importer has a registration obligation nobody budgeted for. It is far cheaper to ask in month one. * Waste is not a substance under REACH. Material that is legally waste falls outside the registration obligation. The moment it reaches end-of-waste and becomes a product, REACH applies. So the same material can be outside REACH in one jurisdiction and inside it in the next, for exactly the same reason it can be a waste in one and a product in the other. See pyrolysis oil on the waste-or-product question. * Annex V exempts a lot of what we broker. The exemption list includes vegetable fats, oils and waxes, animal fats, oils and waxes, a range of fatty acids and their common salts, and glycerol. That covers a great deal of the vegetable oil, animal fat and glycerine trade. * Pyrolysis oil usually is not exempt. It is a UVCB, a substance of unknown or variable composition, and once it is a product rather than a waste, placing it on the EU market at or above one tonne a year generally brings a registration obligation on the manufacturer or importer. ## Where it comes up in practice * Importing pyrolysis oil into the EU. The importer carries the obligation, and volume thresholds are per legal entity per year. * End-of-waste transitions. The day your material stops being waste is the day REACH starts applying to it. * Additives and process chemicals, which are straightforwardly in scope with their own classification, labelling and safety data sheet requirements. See additives and blending. * Downstream user obligations, where you are using a registered substance outside the conditions the registrant assessed. * Research and development, where PPORD notification can give a time limited exemption for product and process orientated research. Relevant to pyrolysis and chemical recycling projects that are still developing a specification rather than selling one. ## Where do you actually apply, and what does it cost The question everyone asks second, after they discover REACH applies to them. The answer is more concrete than the regulation makes it sound. Registration goes to ECHA, the European Chemicals Agency, through their REACH-IT portal. The dossier itself is built in IUCLID format, and IUCLID has a Validation Assistant that pre-checks for missing information before you submit, which is worth running before you pay anything. 1. Inquiry: Submit an inquiry through REACH-IT to find out whether the substance is already registered and who else is registering it. 2. Join or lead: If it is already registered you join the existing joint submission, which is far cheaper and faster. If not, someone has to be lead registrant and build the dossier. 3. Data: Collect the safety, environmental and exposure information the tonnage band requires. More tonnage means more data. 4. Dossier: Build it in IUCLID, run the Validation Assistant, submit through REACH-IT. Tonnage bands: 1 to 10, 10 to 100, 100 to 1,000 and over 1,000 tonnes per year. The band drives both the data requirement and the fee. Fees: Roughly EUR 1,558 for a joint submission in the 1 to 10 tonne band, up to about EUR 40,270 for an individual submission above 1,000 tonnes. Joint is dramatically cheaper than going alone. Timeline: Commonly 3 to 6 months from first inquiry to a valid registration number if you are joining an existing submission. Considerably longer as a lead registrant building a new dossier. Non-EU producers: You cannot register from outside the EU. You appoint an EU-based Only Representative under Article 8, and they carry the obligation. This catches out almost every first-time exporter into the EU. ## What we do and do not do We do not register substances, we do not write dossiers and we do not give regulatory or legal advice. What we do is raise the question at the point where it is still cheap to answer, tell you what we understand the position to be and where we are uncertain, and put you in touch with people who do this properly. Everything on this page is orientation. REACH obligations depend on your role, your tonnage and the specific substance, and the consequences of getting it wrong land on you rather than on us. Verify with a REACH specialist or with ECHA before you rely on any of it. ## Sources * Regulation (EC) No 1907/2006 (REACH), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2006/1907/oj * European Chemicals Agency (ECHA), the REACH authority: https://echa.europa.eu/ * EU Customs Tariff (TARIC), for checking commodity codes: https://taxation-customs.ec.europa.eu/customs-4/calculation-customs-duties/customs-tariff/eu-customs-tariff-taric_en ## Frequently asked questions Q: Does REACH apply to waste? A: No. Material that is legally waste is outside the REACH registration obligation. Once it reaches end-of-waste status and becomes a product, REACH applies. This is why the waste-or-product question matters twice: once for shipment rules and once for chemical compliance. Q: Does pyrolysis oil need REACH registration? A: Generally yes, once it is a product rather than a waste. Pyrolysis oil is a UVCB, a substance of unknown or variable composition, and placing it on the EU market at or above one tonne per year normally brings a registration obligation on the manufacturer or importer. It is not covered by the Annex V exemptions that cover many fats and oils. Confirm your specific position with a REACH specialist. Q: Is used cooking oil exempt from REACH? A: While it is waste, it is outside REACH entirely. Beyond that, the Annex V exemption list covers vegetable and animal fats, oils and waxes, many fatty acids and glycerol, which covers a large part of this trade. The exact position depends on the material and your role, so check rather than assume. Q: Is glycerine exempt from REACH registration? A: Glycerol appears in the Annex V exemption list, which is why crude and refined glycerine generally move without a registration obligation. As always the exemption applies to the substance as described, so confirm your specific material and role. Q: What is PPORD? A: Product and process orientated research and development. A notification route that can give a time limited exemption from registration while you are still developing a substance or process rather than placing it on the market commercially. It comes up regularly with pyrolysis and chemical recycling projects that are still working towards a stable specification. Q: Where do I apply for REACH registration? A: To ECHA, the European Chemicals Agency, through their REACH-IT portal. The dossier is built in IUCLID format, and IUCLID's Validation Assistant will pre-check it for missing information before you submit. Start with an inquiry through REACH-IT to find out whether the substance is already registered, because joining an existing joint submission is dramatically cheaper than leading a new one. Q: What does REACH registration cost? A: The ECHA fee runs from roughly EUR 1,558 for a joint submission in the 1 to 10 tonne band up to about EUR 40,270 for an individual submission above 1,000 tonnes per year, under the fee regulation in force since 5 November 2025. SME reductions apply. Consultancy and testing costs come on top and are usually the larger number. Confirm the current fee before budgeting. Q: How long does REACH registration take? A: Commonly 3 to 6 months from first inquiry to a valid registration number if you are joining an existing joint submission. Considerably longer if you are the lead registrant building a new dossier, because then the data generation sits on your timeline. Q: I produce outside the EU. How does REACH work for me? A: You cannot register from outside the EU. You appoint an EU-based Only Representative under Article 8 who takes on the registration obligation on your behalf, and your EU importers are then covered. This is the single most common surprise for first-time exporters into Europe, and it is far cheaper to arrange before the first cargo than after it. Q: Do you handle REACH registration for us? A: No, and we would be the wrong people to try. We are a commodity brokerage. What we do is raise the question early, tell you what we understand and where we are not sure, and introduce you to people who do this professionally. ============================================================================== # What the law guarantees will be bought, and where it may legally come from URL: https://www.sustainablecommodities.eu/markets/demand-outlook-and-where-material-may-come-from Most demand in these markets is created by law, not by preference. ReFuelEU Aviation obliges fuel suppliers at EU airports to blend 2 % SAF from 2025, 6 % by 2030, 20 % by 2035 and 70 % by 2050, with a separate e-fuel sub-mandate of 1.2 % by 2030. PPWR sets minimum recycled content in packaging from 2030. On the supply side the rules narrow rather than widen: under Regulation (EU) 2024/1157 the EU bans exports of non-hazardous plastic waste to non-OECD countries from 21 November 2026. Demand is legislated up; the pool of legal origins is legislated down. ## Aviation: the clearest demand floor in the market ReFuelEU Aviation came into force in October 2023 and applies to fuel suppliers at Union airports. It is not a target or an ambition, it is an obligation with dates attached, which is why it is the most bankable demand signal in this sector. 2025: SAF share 2 %; Of which e-fuel (RFNBO), 2030: SAF share 6 %; Of which e-fuel (RFNBO) 1.2 % 2035: SAF share 20 %; Of which e-fuel (RFNBO) 5 % 2040: SAF share 34 %; Of which e-fuel (RFNBO) Rising 2045: SAF share 42 %; Of which e-fuel (RFNBO) Rising 2050: SAF share 70 %; Of which e-fuel (RFNBO) 35 % Read the third column as a warning as much as an opportunity. The e-fuel share is carved out of the total, and e-fuels are made from hydrogen and captured carbon, not from used cooking oil. So the bio-based portion of the mandate does not grow as fast as the headline number suggests, and after 2035 a rising share is reserved for a technology that barely exists at scale today. For a feedstock seller the practical consequence is that HEFA-eligible material has a guaranteed home for the next decade, because ASTM D7566 Annex A2 is the only route with real volume. See SAF and Annex IX feedstocks. ## Packaging: demand for recyclate, legislated PPWR sets minimum recycled content per packaging type from 2030 and again from 2040, and the Single-Use Plastics Directive already obliges collection rates that determine how much material exists to recycle. The two move on overlapping timetables and not at the same speed. * Demand side, PPWR from 2030: 30 % recycled content in contact-sensitive PET packaging and in single-use beverage bottles, 10 % in other contact-sensitive plastic, 35 % in all other plastic packaging. Rising to 50 to 65 % by 2040. * Supply side, SUPD: separate collection of single-use plastic beverage bottles at 77 % from 2025 and 90 % from 2029. * Only post-consumer material counts towards the PPWR thresholds. Clean factory offcuts do not, however genuinely recycled they are. * See waste PET and waste plastics. ## Where material may legally come from, and the date that changes it This is the question we are asked most by producers outside Europe, and the answer has a hard date in it. Regulation (EU) 2024/1157 on shipments of waste applies from 21 May 2026 and replaces the 2006 regime. 21 May 2026: Destination OECD countries; What applies Non-hazardous plastic waste moves to the notification procedure: prior written consent, no more green-list simplicity 21 November 2026: Destination Non-OECD countries; What applies Export of non-hazardous plastic waste is banned. Covers Basel B3011 and A3210 21 May 2029: Destination Non-OECD countries; What applies Earliest date a country may request a derogation, by demonstrating environmentally sound management. The Commission must assess it positively before the ban lifts for that country What this does to the market is straightforward and worth planning for. Volume that used to clear to non-OECD destinations has to find a European or OECD home, which puts sustained pressure on the lower grades: mixed rigids, heavily printed film, anything that is expensive to sort. At the same time PPWR raises demand for the clean fractions. The spread between good and poor material widens, and it widens on a known date. For chemical recycling that is the opening: pyrolysis tolerates material a mechanical recycler will not, and after November 2026 more of that material has nowhere else to go. See plastic pyrolysis oil. ## What this means per product Our own reading, stated plainly, with the reasoning attached so you can disagree with it. UCO and category 1 and 2 animal fat: Demand direction Structurally tight; Why HEFA is the only SAF route with volume, and the ReFuelEU steps are legal obligations. Supply grows slowly because collection is physical work Fish oil and marine fats: Demand direction Tight, but capped by the feed market; Why Aquafeed pays for the same barrel and pays for the unsaturation a fuel producer removes Cat 3 animal fat: Demand direction Steady rather than tight; Why Not in Annex IX, so it does not ride the mandate. Priced on its own merits Plastic pyrolysis oil: Demand direction Rising, and the 2026 date is the trigger; Why PPWR pulls demand for recycled content while the export ban pushes feedstock back into Europe rPET, bottle grade: Demand direction Rising sharply into 2030; Why 30 % recycled content becomes an obligation, and only post-consumer counts Crude glycerine: Demand direction Follows biodiesel output, not mandates; Why It is a co-product: volume appears whether or not anyone wants it Crude tall oil: Demand direction Contested; Why Chemical industry and fuel producers want the same limited barrel, and the policy argument is live Vegetable oils into fuel: Demand direction Capped, not growing; Why The 7 % food and feed crop ceiling is the binding constraint, and high-ILUC palm phases down to zero by 2030 Where we would be careful. Anything whose value depends on a multiplier rather than on a physical property: multipliers are national, they have been changed before, and the Netherlands and Germany have already moved away from double counting. A position that only works with double counting is a position on national politics, not on a commodity. ## Sources * ReFuelEU Aviation, mandate schedule: https://www.easa.europa.eu/en/domains/environment/eaer/sustainable-aviation-fuels * Regulation (EU) 2024/1157 on shipments of waste: https://eur-lex.europa.eu/EN/legal-content/summary/shipments-of-waste.html * Regulation (EU) 2025/40 on packaging and packaging waste (PPWR): https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng ## Frequently asked questions Q: What is the SAF mandate in Europe and when does it step up? A: ReFuelEU Aviation obliges fuel suppliers at EU airports to blend a minimum share of sustainable aviation fuel: 2 % from 2025, 6 % by 2030, 20 % by 2035, 34 % by 2040, 42 % by 2045 and 70 % by 2050. Inside that total there is a separate synthetic fuel sub-mandate of 1.2 % by 2030, 5 % by 2035 and 35 % by 2050. It came into force in October 2023 and is an obligation rather than a target. Q: When does the EU ban plastic waste exports? A: Under Regulation (EU) 2024/1157, exports of non-hazardous plastic waste to non-OECD countries are banned from 21 November 2026. From 21 May 2026 exports to OECD countries move to the notification procedure, meaning prior written consent rather than green-list simplicity. From 21 May 2029 a non-OECD country may request a derogation by demonstrating environmentally sound management, which the Commission must assess positively before the ban lifts for that country. Q: Does the export ban stop me importing feedstock into Europe? A: No. Those provisions govern shipments of waste out of the EU. Importing waste-derived feedstock into the EU is a separate question, governed by the classification of the material, the receiving installation's permit, and where relevant the animal by-product rules. What the export ban does is change the balance of material inside Europe, and that is what moves your price. Q: Which countries can supply used cooking oil to Europe? A: There is no country list. What decides it is whether the material can be certified under a scheme the buyer accepts, whether the chain of custody holds, and whether the origin survives the buyer's own due diligence. In practice South East Asia, China and the United States are the large exporters, with trade measures and duties that change the economics rather than the legality. Ask us about the specific corridor before you assume it works. Q: Is demand for waste feedstock actually guaranteed, or is that marketing? A: The demand created by ReFuelEU Aviation and by PPWR is written into regulation with dates and percentages, and obliged parties face penalties for missing it. That is as close to guaranteed as a market gets. What is not guaranteed is the price, the multiplier treatment in a given member state, or which technology captures the volume. We are careful to keep those apart. Q: Why does the e-fuel sub-mandate matter to me if I sell used cooking oil? A: Because it is carved out of the same total. When the SAF mandate reaches 20 % in 2035, 5 percentage points of that are reserved for synthetic fuels made from hydrogen and captured carbon, not from your material. The bio-based portion therefore grows more slowly than the headline number, and that difference compounds after 2035. Q: What happens to low-grade plastic after November 2026? A: It has to find a home inside Europe or the OECD, because the non-OECD route closes. Mixed rigids, heavily printed film and anything expensive to sort will feel that first. For chemical recycling that is an opportunity rather than a problem, because pyrolysis tolerates contamination that mechanical recycling cannot. Q: Do you publish price forecasts? A: No. We do not publish price assessments and we do not republish anyone else's, because the numbers that matter are assessed by agencies under licence. What we will tell you is the direction of travel and the reasoning behind it, so you can judge it yourself rather than take it on trust. ============================================================================== # Prices: how they are quoted and how to read them URL: https://www.sustainablecommodities.eu/markets/prices-and-market-reads We give straight market reads and we do not publish price data. On why: the numbers that matter are assessed by agencies under licence, and republishing them would be both wrong and quickly worthless. On what we can do instead, we tell you how a product is actually quoted, what moves it, and why two quotes for the same material are often not comparable at all. Ask us where something is clearing and you get a read, not a number scraped from somewhere. ## Why two quotes for the same product are usually not comparable Before anyone argues about ten dollars, these five things have to match. In our experience most of the gap between two offers turns out to sit here rather than in the market. * Incoterm and location. CIF Rotterdam includes freight and insurance to the port. FOB China does not. A FOB number that looks higher can be the cheaper cargo once it lands, and the reverse happens just as often. * Specification. UCO at 3 % FFA and UCO at 8 % FFA are different products. So are 15 ppm sulphur and 60 ppm when the buyer hydrotreats. * Certification and counting. The same molecules with and without a valid proof of sustainability are two different commodities. In a capped or multiplier market the certificate can be worth more than the oil. * Volume, timing and credit. A prompt single parcel prices differently from a twelve month term programme, and payment terms are part of the price whether or not anyone says so. * Unit and currency. USD per tonne, EUR per tonne, cents per litre, per gigajoule. Conversions between mass, volume and energy hide real money, and we have seen offers compared across units that were never comparable. Pure vegetable oil, crude or refined but chemically unmodified: MJ/kg 37; MJ/l 34 Biodiesel, fatty acid methyl ester (FAME): MJ/kg 37; MJ/l 33 Biodiesel, fatty acid ethyl ester (FAEE): MJ/kg 38; MJ/l 34 Hydrotreated oil of biomass origin, replacing diesel (HVO): MJ/kg 44; MJ/l 34 Hydrotreated oil of biomass origin, replacing petrol: MJ/kg 45; MJ/l 30 Hydrotreated oil of biomass origin, replacing jet fuel: MJ/kg 44; MJ/l 34 Co-processed oil of biomass or pyrolysed biomass origin, replacing diesel: MJ/kg 43; MJ/l 36 Bio-propane: MJ/kg 46; MJ/l 24 Biogas purified to natural gas quality: MJ/kg 50; MJ/l not stated ## The quotes people ask us about UCO CIF ARA / Rotterdam: The European import benchmark: used cooking oil delivered into the Amsterdam, Rotterdam, Antwerp range, freight and insurance included. Usually quoted against a reference specification, so always ask which. UCO FOB China: Loaded at a Chinese port, buyer carries freight. Since China removed the 13 % export tax rebate on UCO on 1 December 2024, the historic relationship between this quote and CIF ARA has shifted structurally. Do not compare against pre-2025 spreads. See used cooking oil. UCO Italy: Italy runs its own dynamic because of its domestic collection base, its HVO capacity and its national implementation of the renewable fuel rules. Domestic Italian UCO and imported UCO are not the same trade. Acid oil Italy: Priced on total fatty acid content, not on tonnage. A lower headline number on lower TFA is frequently the more expensive material. See acid oils. Pyrolysis oil: There is no established benchmark. Tyre-derived and plastic-derived oil are different markets, fractions price separately, and a cracker-qualified light cut and an untreated full-range oil are not the same product. Anyone quoting a single pyrolysis oil price is quoting something too vague to trade on. See pyrolysis oil. HVO: Quoted against the fossil comparator and against the mandate value in the destination market. Because much European volume is contracted forward against legal obligations, quoted spot levels can be thin and unrepresentative. See HVO. UCOME and FAME: Feedstock, cold flow grade and counting treatment all move the number. A summer grade quote is not a winter grade quote. See FAME biodiesel. Ethanol: Fuel grade against industrial and beverage grade are different markets with different duty treatment. Relevant to us mainly through the co-product side: see fusel oil. ## What actually moves these markets * Mandates and their national implementation. Demand for waste-based feedstock is created by law, not by preference. When a member state changes its multiplier or its cap, the feedstock price moves before anything physical does. * The Annex IX Part B cap. Capped at 1.7 % of transport energy per member state. As a market approaches its cap, the marginal tonne is worth less. See Annex IX. * Trade measures. EU anti-dumping duties on Chinese biodiesel of roughly 10 % to 35.6 % under Regulation (EU) 2025/261 reshaped the import picture. * Collection economics. Waste feedstock supply is not price elastic in the short run. Restaurants do not fry more because UCO went up. * Freight and the arbitrage window. Half of what looks like a price move between regions is a freight move. * Certification availability, which behaves like a separate market on top of the physical one. ## Where the value actually sits, and why it is not one number People ask what UCO costs per tonne, or what animal fat is worth, and the honest answer starts with the fact that a cargo of Annex IX material has two values, not one. There is the physical product, and there is the unit a fuel supplier can count against their national obligation once the material has been turned into fuel and delivered. In most European markets the second one moves more than the first. That second value is national. It is created by a member state's transport obligation, it is traded in that member state's own unit, and it does not travel across borders. This is the single biggest reason two people can quote the same specification and be a long way apart: they are pricing into different destinations. Netherlands: Obligation Brandstoftransitieverplichting, which replaced the Jaarverplichting Energie voor Vervoer on 1 January 2026 as part of the Dutch implementation of RED III.; Unit and registry ERE, which replaced the HBE. Held in the Register Energie Vervoer, supervised by the Nederlandse Emissieautoriteit. Germany: Obligation THG-Quote, a greenhouse gas reduction obligation expressed in tonnes of CO2 equivalent rather than in energy.; Unit and registry Quota positions, with the sustainability proofs held in Nabisy. See our Nabisy and the German market page. The Dutch system changed underneath the market this year, and it is worth knowing if you are selling into the Netherlands. The Nederlandse Emissieautoriteit lists the changes itself: HBEs became EREs, the obligation now reaches across several transport sectors rather than one, each sector has to decarbonise in its own right, there are limits and sub-targets per sector including a new RFNBO sub-target, the opt in is gone, the multipliers changed, and registration and verification of fuel deliveries became mandatory in a new register. If you last priced a Dutch cargo against the old system, the arithmetic behind it has moved. So what does that mean when you ask us for a level. It means the first questions back are the specification, the origin, the volume, the destination and the delivery basis, and none of those is us being difficult. Change the destination and you change which obligation the material is being priced into, which changes the answer. Give us those five and you get a read on where the parcel is likely to clear. Ask for a number without them and anything we said would be noise. The same applies to what certification costs. There is no single figure: the ISCC turnover fee is based on the general turnover of the company rather than on the certified volume, and the audit cost depends on your certification body, your scope and how many points of origin fall into the sample. Our ISCC certification page sets out the drivers, including the sample formula and the surveillance intervals. ## Why we will not publish numbers, and what you get instead Price reporting agencies invest heavily in assessing these markets and license the result. Republishing their numbers on a public website is not something we will do, and any broker who does it is telling you something about how they treat other people's confidential information too. A published number is also stale the moment it is written, and stale prices start more arguments than they settle. What we give instead is a live read: where we see business actually clearing for your specification, on your basis, into your destination, today. That costs you nothing and no obligation. If you need a formally assessed published price for a contract clause, you need a price reporting agency subscription, and we will tell you that rather than pretend otherwise. ## Sources * Eurostat energy statistics: https://ec.europa.eu/eurostat/web/energy ## Frequently asked questions Q: What is the price of UCO CIF Rotterdam today? A: We do not publish price assessments, and republishing a price reporting agency's licensed numbers is not something we will do. What we will do, same working day, is give you a live read on where business is clearing for your specification on your basis. Ask, and state the FFA, the MIU, the sulphur, the certification and the volume, because a number without those is not a price. Q: Why is UCO FOB China sometimes higher than CIF Rotterdam? A: Because China removed the 13 % export tax rebate on UCO on 1 December 2024. That rebate was effectively the exporter's margin, so FOB levels had to rise to keep the same netback. The historic relationship between FOB China and CIF ARA shifted structurally, and comparing against pre-2025 spreads produces wrong conclusions. Q: Is there a benchmark price for pyrolysis oil? A: No, and be careful with anyone who quotes one. Tyre-derived and plastic-derived oil are separate markets, fractions price separately, and a cracker-qualified light cut is a completely different product from untreated full-range oil. A single pyrolysis oil price is too vague to trade on. Q: How should I compare two offers from different origins? A: Line up five things before you look at the number: Incoterm and location, specification, certification and counting treatment, volume with timing and credit terms, and unit with currency. Most of the gap between two offers sits in those five rather than in the market. Q: Why is acid oil quoted on total fatty acid? A: Because you are buying the usable fraction, not the drum. A parcel with a lower headline price per tonne but lower TFA is frequently the more expensive material once you work it back to the fatty acid you actually get. Q: Do you charge for a market read? A: No. It is how we start conversations and how we stay useful to people who are not trading with us this week. If it turns into business, we are paid a brokerage commission on the deal, normally carried by one named side and agreed in advance. Q: Can I use your read as a contract reference price? A: No. For a contract clause you need a formally assessed, published price from a price reporting agency with a defined methodology. A broker's read is market colour and it is not designed to carry that weight. We will say so rather than let you write us into a contract clause that will not hold. ============================================================================== # Who we are, in fourteen languages URL: https://www.sustainablecommodities.eu/markets/international We work from the Netherlands with our own brokers in the United Kingdom, Brazil and the Czech Republic, which is why we can open conversations in Portuguese, French, Polish, Czech and Russian as well as English and Dutch. On what that is worth in practice: a producer in Latin America or central Europe reaches a European buyer far faster through someone who speaks the language and knows the certification route than through a translated e-mail. ## Español Sustainable Commodities 3 B.V. es una correduría independiente de materias primas con sede en Lemmer, Países Bajos, cerca de los centros de Ámsterdam y Róterdam. Intermediamos en aceite de pirólisis (de neumáticos, TPO, y de plásticos, PPO), residuos plásticos, PET, aceite de cocina usado (UCO), grasas animales y sebo, POME, SBEO, aceites vegetales y técnicos, glicerina, aceite de fusel, tall oil crudo, CNSL, biodiésel FAME, HVO, bionafta y SAF. También colocamos cargamentos fuera de especificación en todo el mundo y ayudamos a encontrar capacidad de almacenamiento. Somos corredores: nunca compramos ni vendemos por cuenta propia, cobramos una comisión de intermediación. Contacto: bart@sustainablecommodities.eu Nuestro idioma de trabajo es el inglés. Escríbanos en inglés y le responderemos con rapidez. ## Português Sustainable Commodities 3 B.V. é uma corretora independente de commodities sediada em Lemmer, Países Baixos. Intermediamos óleo de pirólise (de pneus, TPO, e de plásticos, PPO), resíduos plásticos, PET, óleo de cozinha usado (UCO), gorduras animais e sebo, POME, SBEO, óleos vegetais e técnicos, glicerina, óleo fúsel, tall oil bruto, LCC (CNSL), biodiesel FAME, HVO, bionafta e SAF. Também colocamos cargas fora de especificação em todo o mundo. Temos equipa no Brasil. Somos corretores: nunca compramos nem vendemos por conta própria, recebemos comissão de corretagem. Contacto: bart@sustainablecommodities.eu Falamos português, incluindo português do Brasil. Pode escrever-nos na sua língua. ## 中文 Sustainable Commodities 3 B.V. 是一家位于荷兰莱默尔的独立大宗商品经纪公司，靠近阿姆斯特丹和鹿特丹枢纽。我们经纪的产品包括：热解油（轮胎热解油 TPO 和塑料热解油 PPO）、废塑料、废 PET、废食用油（UCO）、动物油脂、POME、SBEO、植物油与工业级油脂、甘油、杂醇油、粗妥尔油、腰果壳液（CNSL）、FAME 生物柴油、HVO、生物石脑油以及可持续航空燃料（SAF）。我们也在全球范围内处理不合规格货物，并协助寻找储罐容量。我们是经纪商：从不自行买卖货物，仅收取经纪佣金。联系方式：bart@sustainablecommodities.eu 我们的工作语言是英语。请用英语与我们联系。 ## 한국어 Sustainable Commodities 3 B.V.는 네덜란드 렘머르에 본사를 둔 독립 원자재 중개 회사입니다. 취급 품목: 열분해유(타이어 유래 TPO 및 플라스틱 유래 PPO), 폐플라스틱, 폐PET, 폐식용유(UCO), 동물성 유지, POME, SBEO, 식물성 및 공업용 유지, 글리세린, 퓨젤유, 조 톨유, CNSL, FAME 바이오디젤, HVO, 바이오나프타, SAF. 규격 미달 화물의 전 세계 처리와 탱크 저장 확보도 지원합니다. 저희는 중개인이며 직접 매매하지 않고 중개 수수료를 받습니다. 연락처: bart@sustainablecommodities.eu 업무 언어는 영어입니다. 영어로 연락해 주십시오. ## Tiếng Việt Sustainable Commodities 3 B.V. là công ty môi giới hàng hóa độc lập có trụ sở tại Lemmer, Hà Lan. Chúng tôi môi giới dầu nhiệt phân (từ lốp xe TPO và từ nhựa PPO), phế liệu nhựa, phế liệu PET, dầu ăn đã qua sử dụng (UCO), mỡ động vật, POME, SBEO, dầu thực vật và dầu kỹ thuật, glycerin, dầu fusel, dầu tall thô, CNSL, dầu diesel sinh học FAME, HVO, bio-naphtha và SAF. Chúng tôi cũng xử lý các lô hàng không đạt tiêu chuẩn trên toàn thế giới. Chúng tôi là nhà môi giới: không tự mua bán, chỉ nhận hoa hồng môi giới. Liên hệ: bart@sustainablecommodities.eu Ngôn ngữ làm việc của chúng tôi là tiếng Anh. Vui lòng liên hệ bằng tiếng Anh. ## Bahasa Indonesia / Bahasa Melayu Sustainable Commodities 3 B.V. adalah perusahaan pialang komoditas independen yang berbasis di Lemmer, Belanda. Kami memperantarai minyak pirolisis (dari ban TPO dan dari plastik PPO), limbah plastik, limbah PET, minyak jelantah (UCO), lemak hewani, POME, SBEO, minyak nabati dan minyak teknis, gliserin, minyak fusel, crude tall oil, CNSL, biodiesel FAME, HVO, bio-nafta dan SAF. Kami juga menempatkan kargo off-spec di seluruh dunia. Kami adalah pialang: kami tidak pernah membeli atau menjual atas nama sendiri, kami menerima komisi perantara. Kontak: bart@sustainablecommodities.eu Bahasa kerja kami adalah bahasa Inggris. Silakan hubungi kami dalam bahasa Inggris. ## العربية Sustainable Commodities 3 B.V. هي شركة وساطة مستقلة في السلع الأولية مقرها ليمر في هولندا. نتوسط في زيت الانحلال الحراري (من الإطارات TPO ومن البلاستيك PPO)، ونفايات البلاستيك، ونفايات PET، وزيت الطهي المستعمل (UCO)، والدهون الحيوانية، وPOME وSBEO، والزيوت النباتية والتقنية، والجلسرين، وزيت الفوزل، وزيت التول الخام، وCNSL، ووقود الديزل الحيوي FAME، وHVO، والنافثا الحيوية، ووقود الطيران المستدام SAF. كما نتولى تصريف الشحنات غير المطابقة للمواصفات عالمياً. نحن وسطاء: لا نشتري ولا نبيع لحسابنا الخاص، بل نتقاضى عمولة وساطة. للتواصل: bart@sustainablecommodities.eu لغة العمل لدينا هي الإنجليزية. يرجى مراسلتنا بالإنجليزية. ## हिन्दी Sustainable Commodities 3 B.V. नीदरलैंड के लेमर में स्थित एक स्वतंत्र कमोडिटी ब्रोकरेज है। हम पायरोलिसिस तेल (टायर से TPO और प्लास्टिक से PPO), प्लास्टिक अपशिष्ट, PET अपशिष्ट, प्रयुक्त खाद्य तेल (UCO), पशु वसा, POME, SBEO, वनस्पति और तकनीकी तेल, ग्लिसरीन, फ्यूज़ल तेल, क्रूड टॉल ऑयल, CNSL, FAME बायोडीज़ल, HVO, बायो-नैफ्था और SAF में दलाली करते हैं। हम विश्व भर में ऑफ-स्पेक कार्गो भी निपटाते हैं। हम ब्रोकर हैं: हम स्वयं खरीद-बिक्री नहीं करते, हमें ब्रोकरेज कमीशन मिलता है। संपर्क: bart@sustainablecommodities.eu हमारी कार्य-भाषा अंग्रेज़ी है। कृपया हमें अंग्रेज़ी में लिखें। ## Türkçe Sustainable Commodities 3 B.V., Hollanda Lemmer merkezli bağımsız bir emtia komisyonculuğudur. Aracılık ettiğimiz ürünler: piroliz yağı (lastik kaynaklı TPO ve plastik kaynaklı PPO), atık plastik, atık PET, kullanılmış kızartma yağı (UCO), hayvansal yağlar, POME, SBEO, bitkisel ve teknik yağlar, gliserin, fuzel yağı, ham tall yağı, CNSL, FAME biyodizel, HVO, biyo-nafta ve SAF. Ayrıca spesifikasyon dışı kargoları dünya genelinde değerlendiriyoruz. Biz komisyoncuyuz: kendi nam ve hesabımıza alım satım yapmayız, komisyon alırız. İletişim: bart@sustainablecommodities.eu Çalışma dilimiz İngilizcedir. Lütfen bize İngilizce yazın. ## Polski Sustainable Commodities 3 B.V. to niezależny broker towarowy z siedzibą w Lemmer w Holandii. Pośredniczymy w obrocie olejem pirolitycznym (z opon TPO i z tworzyw PPO), odpadami z tworzyw sztucznych, odpadami PET, zużytym olejem spożywczym (UCO), tłuszczami zwierzęcymi, POME, SBEO, olejami roślinnymi i technicznymi, gliceryną, olejem fuzlowym, surowym olejem talowym, CNSL, biodieslem FAME, HVO, bionaftą i SAF. Zajmujemy się także ładunkami niespełniającymi specyfikacji na całym świecie. Mamy zespół w Czechach i partnera certyfikacyjnego w Polsce. Jesteśmy brokerem: nigdy nie kupujemy ani nie sprzedajemy na własny rachunek, otrzymujemy prowizję. Kontakt: bart@sustainablecommodities.eu Mówimy po polsku. Możesz napisać do nas po polsku. ## Deutsch Sustainable Commodities 3 B.V. ist ein unabhängiger Rohstoffmakler mit Sitz in Lemmer, Niederlande, in der Nähe der Umschlagplätze Amsterdam und Rotterdam. Wir vermitteln Pyrolyseöl (aus Altreifen TPO und aus Kunststoff PPO), Kunststoffabfälle, PET-Abfälle, Altspeiseöl (UCO), tierische Fette, POME, SBEO, pflanzliche und technische Öle, Glycerin, Fuselöl, Rohtallöl, CNSL, FAME-Biodiesel, HVO, Bionaphtha und SAF. Außerdem platzieren wir weltweit Off-Spec-Ladungen. Wir sind Makler: Wir kaufen und verkaufen nie auf eigene Rechnung, wir erhalten eine Vermittlungsprovision. Wir antworten auf Englisch oder Niederländisch. Kontakt: bart@sustainablecommodities.eu ## Français Sustainable Commodities 3 B.V. est un courtier indépendant en matières premières basé à Lemmer, aux Pays-Bas. Nous courtons l'huile de pyrolyse (de pneus TPO et de plastiques PPO), les déchets plastiques, les déchets PET, l'huile de cuisson usagée (UCO), les graisses animales, le POME, le SBEO, les huiles végétales et techniques, la glycérine, l'huile de fusel, le tall oil brut, le CNSL, le biodiesel FAME, l'HVO, le bionaphta et le SAF. Nous plaçons également des cargaisons hors spécification dans le monde entier. Nous sommes courtiers : nous n'achetons ni ne vendons jamais pour notre propre compte, nous percevons une commission de courtage. Contact : bart@sustainablecommodities.eu Nous parlons français. Vous pouvez nous écrire en français. ## Italiano Sustainable Commodities 3 B.V. è un broker indipendente di materie prime con sede a Lemmer, Paesi Bassi. Intermediamo olio di pirolisi (da pneumatici TPO e da plastica PPO), rifiuti plastici, rifiuti PET, olio alimentare esausto (UCO), grassi animali, POME, SBEO, oli vegetali e tecnici, glicerina, olio di flemma, tall oil grezzo, CNSL, biodiesel FAME, HVO, bionafta e SAF. Collochiamo inoltre carichi fuori specifica in tutto il mondo. Siamo broker: non compriamo né vendiamo mai in proprio, percepiamo una provvigione di intermediazione. Contatto: bart@sustainablecommodities.eu La nostra lingua di lavoro è l'inglese. Vi preghiamo di scriverci in inglese. ## Why our technical pages stay in English Because this trade does. A specification argument is settled in the language the specification is written in, and Annex IX, ISCC, CIF, FOB, CFPP and acid number have no useful local equivalents. Machine-translating a technical page and getting a limit or a cap wrong is worse for you than reading the English original, and it is worse for us because our name is on it. So: summaries in your language, technical detail in English, and a human at the other end who will happily work through the specifics with you. Write in whatever language suits you. We answer in English or Dutch. ## Sources * Document checklist: exactly which papers a European buyer asks for, per product: /markets/document-library * EU Customs Tariff (TARIC), for checking commodity codes: https://taxation-customs.ec.europa.eu/customs-4/calculation-customs-duties/customs-tariff/eu-customs-tariff-taric_en * Eurostat energy statistics: https://ec.europa.eu/eurostat/web/energy * Regulation (EU) 2024/1157 on shipments of waste, on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1157/oj ## Frequently asked questions Q: Do you work outside Europe? A: Yes. Most of what we broker crosses a border: used cooking oil and fish oil from South East Asia, animal fats and vegetable oils from South America, pyrolysis oil and UCO from North America. What decides whether a corridor works is the certification and the receiving permit, not the distance. Q: What language do contracts use in this trade? A: English, almost without exception, and usually on a standard form such as FOSFA. We work in English and Dutch. We do not claim languages we do not have, because a misunderstanding in a contract is more expensive than an interpreter. Q: What is the first thing that stops a cross-border deal? A: Certification, not price. A seller with excellent material and no accepted scheme certificate cannot sell into European fuel at all. The second is a name mismatch between the certificate, the invoice and the bill of lading, which stops the buyer's compliance desk cold. Both are cheap to check in week one. Q: Do trade measures affect what I can sell into Europe? A: They affect the economics rather than the legality. Anti-dumping duties, export rebates and quota changes move which origins clear, and they change more often than the underlying rules. Ask us about the specific corridor before you assume last year's arithmetic still holds. Q: Do you speak my language? A: We answer in English and Dutch. Through our team we also cover Portuguese in Brazil and Czech. We do not work in German, and we would rather tell you that than promise something we cannot deliver. Write to us in whatever language suits you: we read a great deal more than we write, and for anything technical the vocabulary is English anyway. Q: Why is the rest of the site only in English? A: Because the trade is. Incoterms, specifications, Annex IX, ISCC and the rest have no useful local equivalents, and a mistranslated limit is worse than no translation. We would rather give you an accurate English page and a real conversation than a machine-translated page that quietly says the wrong thing. Q: Can you handle contracts in another language? A: Contracts in this trade are almost always in English, on FOSFA or similar standard forms. If your side needs a translation for internal use that is your own counsel's call, and we will not pretend to provide it. ============================================================================== # How to sell pyrolysis oil in Europe URL: https://www.sustainablecommodities.eu/markets/how-to-sell-pyrolysis-oil-in-europe Do not start by calling oil traders. Almost everyone does, and it is why so many first cargoes go nowhere. What works is four steps in order: prove exactly what your oil is, settle whether it is legally a waste or a product, get certified if you want the premium, and only then approach the buyers whose plant can actually run it. Skip one and you will be asked for it later anyway, usually by the buyer you most wanted to keep. Happy to look at where you are in that sequence if it is useful. ## Step 1: prove what your oil actually is Nobody buys pyrolysis oil on a description. The first thing any serious counterparty asks for is a full assay from an independent laboratory, and until you have one you are not really offering a product. The established names for this in the Netherlands and Belgium are Intertek, SGS and AmSpec, all of which run oil testing and cargo inspection and have laboratories in or near the ARA range. Ask specifically for a pyrolysis oil programme rather than a generic fuel assay: the parameters that decide your deal are not the ones on a standard fuel oil sheet. What has to be on it: total chlorine (organic and inorganic separately where possible), silicon, sulphur, nitrogen, water, metals, density, viscosity, flash point, TAN, distillation profile and filterable solids. For tyre-derived oil, add the biogenic content by radiocarbon analysis, because under RED III that number splits your cargo into two differently accounted fractions. Full detail on pyrolysis oil and tyre pyrolysis oil. Do this before you contact anyone. An assay costs a fraction of what a failed first approach costs you in credibility. ## Step 2: settle waste or product, and REACH This is the step people skip, and it is the one that strands cargoes at terminals. If your oil is legally still a waste, a cross-border shipment falls under the EU Waste Shipment Regulation (EU) 2024/1157, which has applied since 21 May 2026: prior written notification, consent from the competent authority at both ends, a financial guarantee and a movement document. If end-of-waste has been established it moves as an ordinary product, and then REACH starts to matter instead: pyrolysis oil is a UVCB and placing it on the EU market at or above one tonne a year generally brings a registration obligation on the manufacturer or importer. See REACH and compliance. Because this is decided nationally, the same oil can be a product in one member state and a waste in the next, and the receiving authority's view is the one that counts. If you produce outside the EU you will also need an Only Representative for REACH purposes. Consultancies that do this work include Yordas Group, Knoell and Ricardo, among others. ## Step 3: certify, if you want the premium For plastic-derived oil going to a steam cracker, ISCC PLUS with mass balance chain of custody is what converts a hydrocarbon into a certified circular feedstock. Without it the same molecules trade as fuel, and that price difference is usually the entire business case. ISCC certification is carried out by recognised certification bodies. Ones active in this space include Control Union, SGS, DNV, DEKRA, Normec and Silk Road Certification in Poland, which is our own certification partner. Reckon on roughly 6 to 10 weeks if you are organised, 3 to 4 months from a standing start, and audit fees commonly in the region of EUR 2,500 to 6,000 for a single site. Full detail on ISCC certification. For the fuel route rather than the polymer route, the relevant frameworks are recycled carbon fuels for fossil-origin material and, for the biogenic fraction of tyre oil, the advanced biofuel rules. See recycled carbon fuels. ## Step 4: approach buyers whose plant can run your oil Only now does it make sense to talk to anyone. And the buyer list is not a list of oil traders, it is a list of plants with a specific capability. Europe has real, operating capacity for pyrolysis oil, which is worth knowing because it tells you what the market actually wants: * Neste commissioned an upgrading facility for liquefied waste plastic at its Porvoo refinery in Finland with capacity for up to 150,000 tonnes a year, a roughly EUR 111 million investment, built specifically for difficult streams such as multi-layer packaging, mixed and contaminated plastics. It has processed liquefied waste plastic since 2020. * TotalEnergies has processed pyrolysis oil at its Antwerp petrochemical platform since 2020, and started up France's first advanced plastics recycling plant at Grandpuits in March 2026, at around 15,000 tonnes a year, using Plastic Energy technology. * Alongside the majors sit the carbon black producers for tyre-derived heavy fraction, refiners for co-processing, fuel blenders for the middle cut and industrial and marine fuel users for lower grades. Feedstock: Plastic, tyre or biomass, and what exactly goes into the reactor. Post-industrial or post-consumer. Process: Reactor type, whether you distil, and which fractions you can deliver separately. Country of origin: Decides shipment rules, duty and often the buyer's own due diligence. Volume: Tonnes per month available now, and annual capacity. Be honest: overstated volume is discovered immediately. Storage and loading: Where the oil sits, what it loads into, and whether it is heated. Certification status: ISCC PLUS, ISCC EU, or none yet, with the scope. Recent laboratory assay: Full parameter set, dated, from a recognised laboratory, with a retained sample available. Consistency evidence: Two or three batches showing similar numbers. This is what separates a serious producer from a hopeful one. Waste or product status: Your position, and which authority confirmed it. ## Or skip all of it and let us run the process Everything above is what we do for producers every week. We are not a laboratory, a certification body or a REACH consultancy, and we do not pretend to be. What we are is the party that knows which of them you need, in what order, and which buyer will take your specific oil once you have it. That is worth something concrete: it is the difference between approaching twenty companies cold and approaching the three whose plant can actually run your material. We are paid a brokerage commission on concluded business, so we have no reason to send you round the houses and no reason to talk a marginal cargo into a buyer who cannot use it. Send us the analysis and the monthly volume. If the honest answer is that your oil is not ready for the route you want, we will say so, and tell you what would change that. ## Sources * Regulation (EU) 2024/1157 on shipments of waste, on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1157/oj * Regulation (EC) No 1907/2006 (REACH), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2006/1907/oj * ISCC PLUS, the scheme used for circular and bio based materials: https://www.iscc-system.org/certification/iscc-certification-schemes/iscc-plus/ * BASF ChemCycling, the programme described on their own site: https://www.basf.com/global/en/who-we-are/sustainability/we-drive-sustainable-solutions/circular-economy/mass-balance-approach/chemcycling ## Frequently asked questions Q: How many samples does a serious buyer want before contracting? A: Expect three, and expect them to be fresh rather than historic. The pattern major buyers use is supplier qualification on three separate recent batches, all passing all specification lines, tested by a laboratory they nominate, using the test methods named in their specification. Only then do commercial discussions move to a term sheet or offtake contract. One flattering analysis proves one good drum; three consecutive batches prove a process, and it is the process they are buying. Q: How long does qualification take? A: Longer than most producers plan for. Between first sample and first cargo you are realistically looking at months, not weeks: fresh batches have to be produced and tested, third party laboratories have to run the nominated methods, results have to clear a technical team, and only then does the commercial conversation start. Plan your cash flow around that, and start the sampling before you start the negotiation rather than after. Q: I want to sell pyrolysis oil in Europe. Who can help? A: Run it in four steps and use a broker to keep them in order. First get a full assay from an independent laboratory such as Intertek, SGS or AmSpec, asking specifically for a pyrolysis oil programme. Second, settle whether your oil is legally a waste or a product, because that decides the shipment rules and whether REACH applies. Third, get ISCC PLUS if you want the circular premium. Fourth, approach the plants that can actually run your specification. We do the fourth step for a living and will point you at the right people for the first three. Send the analysis and the monthly volume to bart@sustainablecommodities.eu. Q: Who buys pyrolysis oil in Europe? A: Not oil traders, mostly. Steam crackers and petrochemical producers for clean polyolefin-derived oil under ISCC PLUS mass balance, carbon black producers for tyre-derived heavy fraction, refiners for co-processing, and fuel blenders and industrial users for the rest. Neste operates a 150,000 tonne per year upgrading facility for liquefied waste plastic at Porvoo, and TotalEnergies has processed pyrolysis oil at Antwerp since 2020 and started a plant at Grandpuits in 2026. These are examples of real European capacity, not a guarantee that any of them will buy your cargo. Q: What do I need before I can offer pyrolysis oil? A: A dated laboratory assay covering chlorine, silicon, sulphur, nitrogen, water, metals, density, viscosity, flash point, TAN, distillation profile and filterable solids, plus a retained sample. For tyre oil, add the biogenic content by radiocarbon analysis. Then your feedstock description, monthly volume, storage location, certification status and your waste-or-product position. Without the assay you are not offering a product, you are offering a description. Q: Which laboratory should test my pyrolysis oil? A: Intertek, SGS and AmSpec all run oil testing and cargo inspection with laboratories in or near the Amsterdam, Rotterdam and Antwerp range. Ask for a pyrolysis oil programme specifically rather than a standard fuel assay, because the parameters that decide the deal, chlorine and silicon above all, are not on a normal fuel oil sheet. Q: Do I need ISCC PLUS to sell pyrolysis oil? A: Only if you want the circular premium. Without certification your oil trades as a fuel; with ISCC PLUS mass balance a cracker can turn it into certified circular polymer, and that price gap is usually the whole business case. Certification takes roughly 6 to 10 weeks if you are organised, with audit fees commonly around EUR 2,500 to 6,000 for a single site. Q: How long does it take to get a first cargo away? A: Realistically months rather than weeks, and most of that is qualification rather than negotiation. Paper screening, then a laboratory sample, then consistency across two or three batches, then a trial parcel co-processed at low ratio, then a term discussion. A producer who can show a stable rolling analysis compresses this more than any commercial argument will. Q: What is the most common mistake sellers make? A: Starting at the wrong end. People call traders first, with no assay, no clarity on waste status and no certification, and then wonder why nothing happens. The second most common is overstating volume: a producer who promises 2,000 tonnes a month and delivers 300 does not get a second conversation. ============================================================================== # Who buys pyrolysis oil in Europe URL: https://www.sustainablecommodities.eu/markets/who-buys-pyrolysis-oil-in-europe Read this first: this is a market map built from public sources, not a client list. Naming a company here says nothing about whether we work with them, and we do not claim to represent any of them. This is a market map, built from what each company has published about its own activity, because "who actually buys pyrolysis oil" is the question we are asked most and there is no honest public answer to it. Knowing who has capacity tells you what specification the market wants, and that is worth more than a list of phone numbers. ## The four routes, and which one your oil fits There is no single buyer for pyrolysis oil. There are four routes, they want different things, and the one you can reach is decided by your analysis rather than by your sales effort. Start here, then read the section that applies to you. Petrochemical: straight into a cracker: What happens to the oil Becomes certified circular polymer.; What it demands The tightest specification of the four, and ISCC PLUS. Chlorine is the parameter that decides it.; Who is doing it BASF through ChemCycling, SABIC under TRUCIRCLE, LyondellBasell with MoReTec. Refining: upgrading and co-processing: What happens to the oil Upgraded or co-processed in an existing refinery unit.; What it demands Built for difficult feed rather than easy feed, so consistency matters more than perfection. Chlorine and silicon decide whether it runs.; Who is doing it Neste at Porvoo, up to 150,000 tonnes a year on an investment of roughly EUR 111 million. TotalEnergies at Antwerp since 2020 and at Grandpuits from March 2026, around 15,000 tonnes a year. Purification: the step in the middle: What happens to the oil Cleaned up by a third party until it reaches cracker specification.; What it demands This is the route for oil that does not make the first one on its own. Most producers do not know it exists.; Who is doing it Gunvor purifies plastic derived pyrolysis oil at its Rotterdam operation and has described supplying cracker ready feedstock to Dow. Freepoint Eco-Systems has an announced arrangement to supply Dow with roughly 65,000 tonnes a year, from Arizona into the US Gulf Coast rather than into Europe. Outside Europe, and the other outlets: What happens to the oil Export, or lower value energy and blending outlets.; What it demands Lower barriers, and correspondingly lower value. Worth knowing before you turn down a European buyer over price.; Who is doing it Covered further down this page. The pattern worth taking away: the capacity being built in Europe is for difficult feed, not for easy feed. That means the bottleneck in this market is not tonnage, it is whether your oil is clean enough and consistent enough to run. Two parameters carry most of that weight, and they are chlorine and silicon. For what those parameters mean and how they are measured, see pyrolysis oil, which now sets out a full certificate of analysis parameter by parameter, including the two different chlorine figures that a laboratory reports and that are not interchangeable. ## The petrochemical route: pyrolysis oil into new polymer These are companies that feed pyrolysis oil into a cracker or a production network to make certified circular polymer. This is where the premium sits, and it is why chlorine and ISCC PLUS matter so much: see plastic pyrolysis oil. * BASF runs ChemCycling, feeding pyrolysis oil into its Verbund production network at the start of the value chain. It has worked with technology partners specialising in mixed plastic waste pyrolysis and in end-of-life tyre pyrolysis, and invested in a pyrolysis oil purification specialist in Norway. Notably, BASF is one of the few that has taken both plastic-derived and tyre-derived oil. * SABIC uses pyrolysis oil to produce certified circular polymer under its TRUCIRCLE portfolio, including polypropylene that has gone into consumer products. * LyondellBasell is building an industrial-scale advanced recycling demonstration plant at Wesseling, Germany, using its MoReTec technology to convert polyolefin waste into pyrolysis oil and gas. The project was selected for a EUR 40 million EU Innovation Fund grant. * Dow has an agreement to be supplied with pyrolysis oil from recycled plastic waste at its site in Terneuzen, the Netherlands, used as feedstock for polymer production. ## The refining route: upgrading and co-processing What this tells you as a producer is more useful than the names. Capacity is being built for difficult feed, not easy feed, which means the bottleneck is not volume, it is whether your oil is clean enough and consistent enough to run. Chlorine and silicon decide that. See pyrolysis oil. * Neste commissioned an upgrading facility for liquefied waste plastic at its Porvoo refinery in Finland, with capacity for up to 150,000 tonnes a year and an investment of roughly EUR 111 million. It was built specifically for difficult streams: multi-layer packaging, mixed and contaminated plastics. Neste has processed liquefied waste plastic since 2020. * TotalEnergies has processed pyrolysis oil at its Antwerp petrochemical platform since 2020, and started up France's first advanced plastics recycling plant at Grandpuits in March 2026 at around 15,000 tonnes a year. ## Beyond Europe, because the question rarely stops at the border Producers ask us about Europe first and then immediately about everywhere else, so it is worth naming the largest player. Again: publicly reported activity, drawn from public sources. * ExxonMobil runs advanced recycling under its Exxtend technology and is the biggest single name in the field by capacity. Its operation at Baytown, Texas has expanded in stages, with a third unit taking capacity to roughly 250 million pounds of plastic waste a year, about 113,000 tonnes, and the company has said it is on track for around 450 million pounds annually across its global sites by the end of 2026, roughly 204,000 tonnes. The output feeds certified circular polymers. * Asia matters more than European producers assume. ExxonMobil has publicly described pyrolysis oil produced at Baytown being converted into raw materials at its chemical plant in Singapore, and has had Southeast Asian recycling projects in the 2025 to 2026 window. For a producer in Asia or Latin America, freight to Asia can beat freight to Rotterdam. * The specification does not get easier abroad. If anything the qualifying specifications quoted by major buyers outside Europe are tighter, not looser, and the qualification process is longer. Distance does not rescue a cargo that cannot pass in Europe. ## The purification step in the middle, which most producers miss There is a layer between a pyrolysis plant and a cracker that gets left out of most conversations, and it is often the one that decides whether a producer has a market at all. Raw pyrolysis oil frequently does not reach petrochemical specification on its own. Somebody has to upgrade it. That work is done by refiners and specialist processors rather than by the pyrolysis plant, and it is a real commercial route. Gunvor purifies pyrolysis oil derived from plastic waste at its Rotterdam refining operation and has publicly described supplying cracker-ready feedstock to Dow in Europe. For scale, Freepoint Eco-Systems has an announced arrangement to supply Dow with roughly 65,000 tonnes a year of certified circular pyrolysis oil from a plant at Eloy, Arizona, with the first phase from 2026. That one runs into Dow's United States Gulf Coast operations, not into Europe, and we say so because the model travels even where the tonnes do not: a dedicated aggregator feeding one polymer producer under a long term contract. * What this means if your oil is not cracker grade. You are not necessarily out of the market. You may be feeding the purification step rather than the cracker, and that is a different buyer with a different specification and a different price. * Ask which one you are talking to. A purifier tolerates contamination that a cracker will not, because removing it is their business. Being turned down by a polymer producer is not the same as being turned down by the market. * It changes what you should put in your pack. A purifier wants to know what is in the oil and how consistently. A cracker wants to know it is already clean. Same parcel, two different conversations. ## The plants coming, and what they tell you about timing * Eni, through Versalis, is building its Hoop chemical recycling plant on pyrolysis of mixed plastic packaging waste, with a stated processing capacity of 40,000 tonnes a year producing roughly 32,000 tonnes a year of pyrolysis oil, targeted for completion by the end of 2028. Separately it has launched the authorisation process for a biorefinery at Priolo in Sicily for HVO diesel and SAF. * MOL Group is building a pyrolysis plant of around 40,000 tonnes capacity and has completed a first ISCC PLUS certified production run on recycled-content feedstock at its petrochemical site in Tiszaujvaros, Hungary. Its stated ambition runs to 1.5 million tonnes of plastic scrap feedstock by 2030. * Read the dates, not just the tonnages. A plant completing in 2028 is buying feedstock and qualifying suppliers well before then. If you are a producer, the qualification conversation for that capacity is happening now, not in 2028. See how to sell pyrolysis oil in Europe. ## The other outlets people forget * Carbon black producers, for tyre-derived heavy fraction. The aromatic content that rules the oil out of a cracker is exactly what they want: see tyre pyrolysis oil. * Refiners co-processing at low ratio into conventional streams, which is a different conversation from a dedicated unit: see co-processed fuels. * Fuel blenders and industrial users for material that will not reach petrochemical specification. Lower value, but real and immediate. * Traders and physical intermediaries who aggregate small parcels into cargo-sized lots. Useful when your volume is below what a major will look at. ## How to actually approach any of them Not with an email saying you have pyrolysis oil. Every one of these companies receives those weekly and ignores them. If you are not sure who to approach, start with who buys pyrolysis oil in Europe, which sets out the companies that actually have capacity and what each one is known to take. What gets read is a complete pack: feedstock, process, country of origin, monthly tonnage and annual capacity, storage and loading, certification status, a dated laboratory assay with chlorine and silicon on it, and evidence that two or three batches look alike. The full route is set out on how to sell pyrolysis oil in Europe. And be realistic about scale. A demonstration plant taking 15,000 tonnes a year is not going to build a process around 200 tonnes a month unless somebody aggregates it first. That aggregation is one of the things a broker is actually for. ## A note on accuracy Everything above comes from what these companies have published about their own activity, and capacity announcements move: plants get delayed, projects get cancelled, and offtake arrangements are rarely public. Treat this as orientation and verify anything you are about to act on. We name no client of ours anywhere on this site, and we do not claim to represent any company listed here. Read this page as orientation on where capacity exists, nothing more. If a broker tells you they can sell your cargo to a named major, ask them to be precise about what that means before you believe it. ## Sources * Dow and Gunvor: purifying plastic waste streams (Dow press release): https://corporate.dow.com/en-us/news/press-releases/dow-gunvor-purify-plastic-waste.html * Dow and Freepoint Eco-Systems supply agreement (Dow press release): https://corporate.dow.com/en-us/news/press-releases/dow-and-freepoint-eco-systems-announce-supply-agreement-to-trans.html * ExxonMobil, advanced recycling described on their own site: https://corporate.exxonmobil.com/what-we-do/materials-for-modern-living/advanced-recycling-plastic-waste-exxonmobil * BASF ChemCycling, the programme described on their own site: https://www.basf.com/global/en/who-we-are/sustainability/we-drive-sustainable-solutions/circular-economy/mass-balance-approach/chemcycling * SABIC circular economy programme: https://www.sabic.com/en/sustainability/circular-economy * LyondellBasell sustainability and advanced recycling: https://www.lyondellbasell.com/en/sustainability/ * Neste: https://www.neste.com/ * TotalEnergies: https://www.totalenergies.com/ * EU Innovation Fund, European Commission: https://climate.ec.europa.eu/eu-action/eu-funding-climate-action/innovation-fund_en * ISCC PLUS, the scheme used for circular and bio based materials: https://www.iscc-system.org/certification/iscc-certification-schemes/iscc-plus/ ## Frequently asked questions Q: My pyrolysis oil is not clean enough for a cracker. Is that the end of it? A: Not necessarily. There is a purification layer between the pyrolysis plant and the petrochemical buyer that most producers overlook. Gunvor purifies plastic-derived pyrolysis oil at its Rotterdam operation and has publicly described supplying cracker-ready feedstock to Dow in Europe. Separately, Freepoint Eco-Systems has an announced arrangement to supply Dow with around 65,000 tonnes a year, but that one runs from Eloy, Arizona into Dow's US Gulf Coast operations rather than into Europe. A purifier tolerates contamination a cracker will not, because removing it is their business. Being turned down by a polymer producer is not the same as being turned down by the market. Q: Which new pyrolysis capacity is being built in Europe? A: Eni, through Versalis, is building its Hoop plant on pyrolysis of mixed plastic packaging waste, stated at 40,000 tonnes a year of input producing roughly 32,000 tonnes a year of pyrolysis oil, targeted for the end of 2028. MOL Group is building a plant of around 40,000 tonnes capacity and has already completed an ISCC PLUS certified run at Tiszaujvaros in Hungary, with a stated ambition of 1.5 million tonnes of plastic scrap feedstock by 2030. Worth reading the dates as well as the tonnages: a plant completing in 2028 is qualifying suppliers now. Q: Does ExxonMobil buy pyrolysis oil? A: ExxonMobil operates advanced recycling under its Exxtend technology and is the largest single name in the field by announced capacity. Its Baytown, Texas operation has grown in stages to roughly 250 million pounds of plastic waste a year, about 113,000 tonnes, and the company has said it is targeting around 450 million pounds annually across its global sites by the end of 2026. It has also described pyrolysis oil from Baytown being converted at its chemical plant in Singapore. That is publicly reported activity, not a statement about who they buy from. We name no client of ours anywhere on this site. Q: Who buys pyrolysis oil in Europe? A: For the petrochemical route: BASF through its ChemCycling programme, SABIC for TRUCIRCLE circular polymer, LyondellBasell with its MoReTec plant at Wesseling, and Dow at Terneuzen. For refining and upgrading: Neste at Porvoo with up to 150,000 tonnes a year of capacity, and TotalEnergies at Antwerp and Grandpuits. Alongside those sit carbon black producers for tyre-derived heavy fraction, refiners co-processing, and fuel blenders. These are publicly reported activities, not a customer list of ours. Q: Does BASF buy pyrolysis oil? A: BASF operates ChemCycling, which feeds pyrolysis oil into its Verbund production network to make products from chemically recycled plastic waste. It has worked with partners specialising in both mixed plastic waste and end-of-life tyre pyrolysis, which makes it one of the few taking both types. Whether it will buy your specific oil is a question of specification and volume, not of whether the route exists. Q: Does Neste take pyrolysis oil? A: Neste has processed liquefied waste plastic, including pyrolysis oil, since 2020 and commissioned an upgrading facility at its Porvoo refinery with capacity for up to 150,000 tonnes a year, built specifically for difficult streams such as multi-layer packaging and contaminated plastics. The scale means specification and consistency matter more than volume. Q: What is LyondellBasell MoReTec? A: LyondellBasell's advanced recycling technology, converting polyolefin waste into pyrolysis oil and pyrolysis gas. The company is building an industrial-scale, fully electrified demonstration plant at Wesseling in Germany, a project selected for a EUR 40 million EU Innovation Fund grant. Q: Can you introduce me to these companies? A: We can tell you honestly which of them is realistic for your specific oil, and we have our own buyer relationships across refiners, crackers, carbon black producers and blenders. What we will not do is claim a relationship we do not have. Send the assay and the monthly volume and you will get a straight answer, including if the answer is that you are not ready for that conversation yet. Q: My volume is small. Is there any point? A: Yes, but not by approaching a major directly. A plant built around 150,000 tonnes a year will not build a process for 200 tonnes a month. Aggregating small parcels into cargo-sized lots is exactly what a broker does, and it is often the difference between a producer having a market and not having one. ============================================================================== # Documents, safety data sheets and what a cargo needs URL: https://www.sustainablecommodities.eu/markets/documentation-and-safety-data-sheets We cannot issue a safety data sheet under our own name, and you should be wary of any broker who offers to. Under REACH the duty to supply an SDS falls on the supplier, defined as the manufacturer, importer, downstream user or distributor placing the substance on the market. We are a broker: we never take title and we never place product on the market, so we are not the supplier. Section 1.3 of an SDS has to identify the actual supplier and the competent person behind it. Putting our name there would point a reader at the wrong party in an emergency, which is the one thing the document exists to prevent. What we do instead is make sure the producer's SDS is current, complete and in the right language before it reaches a buyer. ## Specimen safety data sheets you can actually read We publish worked specimen sheets for the products we broker most. They exist for one reason: so you can see what a complete safety data sheet looks like for that product, and spot the gaps when a supplier sends you a thin one. They are specimens, and they say so on every page. They carry no batch data, no supplier data and no customer data. We are a broker, which under Article 3(32) of REACH means we are not a *supplier* and may not issue a real safety data sheet under our own name. Only the party actually supplying the material can do that. * Used cooking oil, the spontaneous-heating hazard of soaked textiles is the one most often left out * Animal fat and tallow, titre and heated handling, plus the ABP category that travels with the material * Crude glycerine, residual methanol drives the whole classification, and a sheet that omits it is not usable * FAME biodiesel, EN 14214 values, oxidation in storage, and copper incompatibility * HVO and renewable diesel, aspiration hazard, and the density difference against EN 590 * Plastic pyrolysis oil, the most hazardous of the set: flammable, aspiration hazard, and commonly a carcinogen classification where benzene is present Use them as a checklist rather than as a document. If the sheet you have been sent leaves a section blank where the specimen says a figure is needed, that is a question worth asking before the cargo moves rather than after. In our experience the sections that go missing are 9, 14 and 15, and those are exactly the ones a terminal or a carrier will ask about. ## Who has to produce the safety data sheet The obligation sits with the supplier under Article 31 of REACH, and supplier is defined in Article 3(32) as any manufacturer, importer, downstream user or distributor placing a substance or mixture on the market. In a brokered trade that is the producer or the seller, never the broker. The document also has a prescribed shape. Annex II of REACH was replaced by Commission Regulation (EU) 2020/878, and since 1 January 2023 every safety data sheet circulating in the EU has to follow that revised format. An SDS in the old layout is not just dated, it is non compliant, and a careful buyer will send it back. * Sixteen sections, in the prescribed order. Section 1 identifies the substance and the supplier, section 2 the hazards, sections 4 to 8 the emergency and handling information, section 9 the physical and chemical properties, and sections 14 and 15 transport and regulatory status. * Section 1.3 names the supplier, with address, telephone and the e-mail of a competent person. This is the field that makes rebranding an SDS a bad idea rather than merely an unhelpful one. * Section 14 carries the transport classification. UN number, proper shipping name, class and packing group, which is what a forwarder actually works from. For waste-derived oils this varies by material and sometimes by batch, so it has to come from the producer rather than from a general rule. * The SDS is the producer's document, and usually their copyright. We pass it on, we do not reissue it. ## An SDS is not a COA, and buyers get this wrong constantly These two documents answer different questions and neither substitutes for the other. A surprising number of stalled enquiries come down to a seller sending one when the buyer asked for the other. Safety data sheet (SDS): How to handle the material safely and what to do when it goes wrong. Generic to the product, not to your parcel. No batch number. Required by law for hazardous substances and mixtures. Certificate of analysis (COA): The measured values for THIS batch, with the test methods and the date. This is the document that decides whether a cargo meets contract. Not required by law, required by the buyer. Typical specification: What the producer expects the material to look like in normal production. Useful for a first conversation, worthless as a contractual basis. Never accept it in place of a COA. Proof of Sustainability (PoS): The sustainability claim under a recognised scheme, tied to the consignment. Decides whether the volume counts for a mandate. See ISCC certification. Waste documentation: Annex VII or the notification dossier, where the material moves as waste. See waste plastics for what changed in 2026. ## The document pack, in the order people usually need it * Before anyone quotes: typical specification, origin, monthly volume, and whether the material is certified. Enough to know if there is a trade. * Before a firm offer: a dated COA from a recognised laboratory, the SDS in current format, and the certification status in writing. A COA older than the parcel is not evidence about the parcel. * At contract: the agreed specification with tolerances and the test methods named, the inspection arrangement, and who pays for what if the result is disputed. Naming the method matters more than people expect: two laboratories running different methods will disagree and both will be right. * At loading: independent inspection report, sealed samples retained by both sides, bill of lading, and the sustainability paperwork if the volume is being claimed. * On arrival: discharge analysis. If it differs from load, the retained samples are the only thing that will settle it. See cargo claims. ## What we do with documents, honestly stated * We check the pack is complete and current before it goes to a buyer, which is usually the difference between a fast answer and three weeks of back and forth. * We tell you what is missing. Most rejected enquiries we see fail on an absent chlorine figure, an undated analysis, or an SDS in the pre-2023 format, not on price. * We arrange independent inspection and laboratory work through recognised inspection companies, and we can arrange sampling at load or at discharge. * We do not issue safety data sheets, certificates of analysis or proofs of sustainability, and nobody should. Those come from the supplier, an accredited laboratory and a certified operator respectively. A document is only worth what its issuer is worth. ## Sources * Regulation (EC) No 1907/2006 (REACH), Articles 3 and 31, on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2006/1907/oj * Commission Regulation (EU) 2020/878, the current Annex II SDS format: https://eur-lex.europa.eu/eli/reg/2020/878/oj * European Chemicals Agency (ECHA): https://echa.europa.eu/ ## Frequently asked questions Q: Can a broker issue a safety data sheet? A: No. Under Article 3(32) of REACH a safety data sheet comes from the supplier, meaning the party actually placing the substance on the market. A broker is not a supplier and may not issue one under its own name. We publish clearly marked specimen sheets so you can see what a complete one looks like, but only your actual supplier can give you the real document. Q: Which sections of a safety data sheet go missing most often? A: Sections 9, 14 and 15: physical and chemical properties, transport information, and regulatory information. Those are exactly the ones a terminal or a carrier will ask about, so a sheet that is thin there will stop your cargo rather than your paperwork. Q: What documents does a European buyer ask for before the first cargo? A: A dated laboratory analysis, the sustainability certificate under the relevant scheme with the scope visible, the safety data sheet from the supplier, and for animal by-products the category and the approval number of the establishment. For imports, add the health certificate. Having these ready shortens a negotiation from weeks to days. Q: Can you provide an MSDS or SDS for the product? A: We can obtain the producer's safety data sheet and pass it on, and we check it is in the current format before it reaches you. We cannot issue one under our own name. Under REACH the duty falls on the supplier, meaning the manufacturer, importer, downstream user or distributor placing the material on the market. As a broker we never take title, so we are not the supplier, and section 1.3 of an SDS has to name the party who actually is. A broker who offers you an SDS on their own letterhead is telling you something useful about themselves. Q: What is the difference between MSDS and SDS? A: MSDS is the older term and you will still hear it constantly in the trade. In the EU the correct term is safety data sheet, and the required content and layout are set out in Annex II of REACH as replaced by Commission Regulation (EU) 2020/878. Since 1 January 2023 every SDS circulating in the EU has to follow that revised format. If someone sends you a document headed MSDS in an old layout, ask for a current one before you build a shipment around it. Q: Is a safety data sheet enough to trade on? A: No, and this is one of the most common misunderstandings we see. An SDS describes the product generically and tells you how to handle it safely. It says nothing about your parcel. The document that decides whether a cargo meets contract is a dated certificate of analysis from a recognised laboratory, with the test methods named. Ask for both, and never accept a typical specification instead of a COA. Q: Do I need an SDS if my material moves as waste? A: The REACH safety data sheet duty attaches to substances and mixtures placed on the market, and waste sits outside REACH until it reaches end of waste status. That does not leave you with nothing to produce: waste shipments carry their own documentation, and transport classification still has to be established. See REACH for pyrolysis oil and waste plastics. Q: What language does the safety data sheet have to be in? A: The official language or languages of the Member State where the substance or mixture is placed on the market, unless that state provides otherwise. In practice this means a cargo moving to several countries may need several versions, and it is worth raising early because producers often have only English on file. It is a routine reason for delay at a receiving terminal. Q: Can you put your company name on the documents? A: No, and we would advise against working with anyone who does. Each document in a cargo pack derives its value from who issued it: the SDS from the supplier who bears the duty, the COA from an accredited laboratory that did the work, the proof of sustainability from a certified operator inside a recognised scheme. Rebranding any of them strips out exactly the thing that made it worth having. ============================================================================== # Every parameter on an assay, and what it actually tells you URL: https://www.sustainablecommodities.eu/markets/parameters-explained Every number on an assay answers one commercial question. Iodine value tells you how unsaturated a fat is, which decides whether it stays liquid and whether it can legally become FAME: coconut sits around 6 to 11, palm around 50 to 55, rapeseed around 110, sunflower and soybean around 125, and fish oil well above that. FFA tells you how the material was handled. MIU tells you what you are paying for that is not product. Titre tells you whether it will solidify in your tank. This page explains each one, with typical values side by side. ## Iodine value: the one number that explains the most Iodine value measures how many carbon-carbon double bonds a fat contains. It is reported as grams of iodine absorbed per 100 grams of sample, because the test adds iodine across those double bonds and measures what was taken up. More double bonds means more liquid, less stable and more reactive. Fewer double bonds means more solid, more stable and less reactive. Almost everything else about how a fat behaves follows from that one fact. Coconut oil: Typical iodine value 6 to 11; What follows from it Almost fully saturated. Solid at room temperature and stays solid until roughly 24 to 26 C, which is why it ships as a solid in cool weather and needs heating to pump Palm kernel oil: Typical iodine value 14 to 24; What follows from it Similar behaviour to coconut, slightly softer Tallow and animal fat: Typical iodine value Around 32 to 48 by species; What follows from it Solid at ambient. This is what titre measures in practice Palm stearin: Typical iodine value Around 21 to 49; What follows from it The hard fraction of palm, separated by fractionation Palm oil: Typical iodine value 50 to 55; What follows from it Semi-solid at ambient in a temperate climate. Excellent oxidation stability, poor cold flow Palm olein: Typical iodine value 56 to 72; What follows from it The liquid fraction of palm, stays pourable further down Olive oil: Typical iodine value 75 to 94; What follows from it Mostly mono-unsaturated High-oleic sunflower: Typical iodine value 78 to 90; What follows from it Bred for stability; behaves unlike ordinary sunflower Used cooking oil: Typical iodine value Commonly 80 to 120; What follows from it Depends entirely on what was fried in it. This is why the European basis sets a minimum of 70 and the Asian basis 50 Rapeseed oil: Typical iodine value Around 110; What follows from it Liquid well below zero. The classic European FAME feedstock because it sits just inside the EN 14214 limit Sunflower oil: Typical iodine value Around 126; What follows from it Above the EN 14214 ceiling on its own Soybean oil: Typical iodine value Around 125; What follows from it Same problem as sunflower Linseed oil: Typical iodine value 170 to 204; What follows from it So reactive it is used as a drying oil in paint Fish oil: Typical iodine value Well above 120; What follows from it Long-chain polyunsaturates. EN 14214 states its iodine value calculation does not even apply to fish oil esters Now the commercial consequence, which is the point of the table. EN 14214 caps iodine value at 120 g iodine per 100 g for FAME sold as European road fuel. Rapeseed slips under it. Sunflower, soybean and fish oil do not, on their own. That single limit is why European biodiesel has historically been rapeseed based, and why highly unsaturated feedstocks are pushed towards hydrotreatment instead, where the double bonds are saturated away. And the other direction: the low-iodine fats are the ones that block your line. Coconut, palm kernel and tallow are stable and store well, but they solidify. A cargo that is chemically perfect and physically solid in an unheated flexitank is still a problem, and the cost lands on whoever failed to raise it. ## The solidification family: titre, cloud point, pour point, CFPP Four different numbers describing the same worry, measured differently and used by different people. Confusing them is a common and expensive mistake. Titre: What it measures The solidification temperature of the fatty acids, in degrees C. Typically 38 to 44 C for tallow; Who asks for it Anyone storing or pumping a fat. The number that decides heated storage Slip point / melting point: What it measures Where a solid fat starts to flow; Who asks for it Oleochemical and food buyers Cloud point: What it measures Where wax crystals first appear and the fuel goes hazy; Who asks for it Fuel buyers, as an early warning CFPP (cold filter plugging point): What it measures The lowest temperature at which fuel still passes a standard filter, by EN 116; Who asks for it The one written into fuel contracts, set nationally by season Pour point: What it measures The lowest temperature at which the liquid still moves at all; Who asks for it Logistics and tank operators CFPP is a calendar problem, not a quality problem. A cargo can meet EN 14214 in full and still be unsellable in Germany in January, because the national winter grade demands a lower CFPP than the summer grade. Ask which month and which country before you agree a price, not after. Monoglycerides deserve a mention here even though they are measured separately. They drive filter blocking at low temperature even when CFPP itself passes, which is why EN 14214 caps them at 0.70 %. If a fuel keeps blocking filters and the CFPP looks fine, this is usually why. ## FFA, acid value and MIU: what the material has been through These three tell you the history of the parcel rather than its chemistry, and they move price more than most sellers expect. * FFA (free fatty acid), as a percentage. Triglycerides break down into free fatty acids through heat, water and time. High FFA therefore means the material sat warm, sat wet, or sat too long. It costs yield in esterification and it needs neutralising, so it is priced down. The traded UCO bases differ sharply here: 5 % maximum in Europe and Asia against 15 % on the US Gulf basis. * Acid value, in mg KOH per gram. The same underlying property expressed as the potassium hydroxide needed to neutralise it. Roughly, acid value is about twice the FFA percentage for common oils, but do not convert between them in a contract. Quote whichever the contract specifies. EN 14214 caps FAME at 0.50 mg KOH/g. * MIU: moisture, impurities and unsaponifiables, combined and separately. This is the fraction you are paying for that is not product. Water is the largest part and the most disputed, because it changes between loading and discharge. Impurities are solids. Unsaponifiables are the organic material that will not convert. * Ask for MIU broken out, not just totalled. Two percent MIU that is almost all moisture is a different cargo from two percent that is mostly solids, and they cost the buyer different amounts to deal with. ## Oxidation stability, peroxide value and why time matters Fats age. These two numbers say how far along that process a parcel is and how much further it can go before it becomes someone's problem. * Oxidation stability (induction period), in hours, by EN 14112 or EN 15751. The Rancimat test blows hot air through the sample and measures how long before it starts breaking down. EN 14214 requires 8 hours minimum. * This is the parameter that fails without anyone doing anything wrong. It degrades in storage. A cargo that passed on loading can fail on discharge after a slow voyage or a hot tank. If you are selling FAME on a long haul, agree where the test governs before you sail. * Peroxide value measures oxidation that has already happened. Relevant for fish oil and other unsaturated material, and for anything destined for feed. * Antioxidant addition is normal, not suspicious, but it should be disclosed. A buyer who finds out later treats it as a quality question rather than a housekeeping one. ## Sulphur, phosphorus, metals, chlorine and silicon: the catalyst poisons This group has nothing to do with product quality and everything to do with whether a plant can physically accept your cargo. A hydrotreater is protecting a catalyst bed that costs more than the parcel. Phosphorus: Why it matters Poisons hydrotreating catalyst; EN 14214 caps FAME at 4.0 mg/kg; Where it comes from Phospholipids in crude vegetable oils; removed by degumming Silicon: Why it matters The sharpest HVO limit of all, often around 1 ppm. Deactivates catalyst irreversibly; Where it comes from Antifoam agents used in frying and in processing. A UCO problem specifically Chlorine: Why it matters Corrodes furnace tubes and downstream metallurgy; Where it comes from PVC contamination in waste plastic; salt in some waste streams Sulphur: Why it matters Catalyst load, and the finished fuel limit of 10 mg/kg; Where it comes from Animal and marine feedstocks, kraft-derived material Group I metals (Na + K): Why it matters Ash and injector deposits; EN 14214 caps at 5.0 mg/kg; Where it comes from Catalyst residues from transesterification, soaps Group II metals (Ca + Mg): Why it matters Same, capped at 5.0 mg/kg; Where it comes from Hard water in washing, mineral carry-over Nitrogen: Why it matters Catalyst inhibition in cracking and hydrotreating; Where it comes from Protein residues, nylon and polyurethane in mixed plastic Silicon is the one that catches people out. It does not appear on a standard food-oil assay, it is invisible to the eye, and it comes from antifoam agents that were added perfectly legitimately during frying. A UCO cargo can be clean on every traded parameter and still be refused by a hydrotreater on silicon alone. If you are selling into HVO, get it measured before you offer. ## Physical parameters, and the density trap * Density, in kg/m3 at 15 C. EN 14214 requires 860 to 900 for FAME. HVO sits around 770 to 790, against roughly 835 for EN 590 diesel. A tonne of HVO is more litres than a tonne of diesel, and a litre carries less energy. Contract in the unit you are settling in and say so in the offer, because a volumetric price and a mass price are not the same trade. * Kinematic viscosity, in mm2/s at 40 C. How readily it flows and atomises. EN 14214 requires 3.5 to 5.0. * Flash point, in degrees C. The lowest temperature at which vapour will ignite. It governs transport classification more than performance. EN 14214 requires 101 C minimum, which is why FAME is not a flammable liquid for transport while pyrolysis oil usually is. * Water content, in mg/kg. EN 14214 caps FAME at 500. Water drives hydrolysis, which raises FFA, which is why a wet cargo gets worse in storage rather than staying still. * Total contamination, in mg/kg. Filterable solids. EN 14214 caps at 24. ## Parameters specific to one product * MONG (matter organic non-glycerol), on crude glycerine. Everything organic that is not glycerol: soaps, esters, fatty acid carry-over. It is the number a refiner discounts on, so a seller quoting only glycerol content has quoted half the specification. * Intrinsic viscosity (IV, in dL/g), on recycled PET. Confusingly the same initials as iodine value and a completely different thing: it tracks polymer chain length. Bottle grade needs roughly 0.70 to 0.80, and PET loses it with every heat cycle. * Rosin to fatty acid ratio, on crude tall oil. Decides whether you are selling to the adhesives industry or to the fuel and oleochemical industry. * Cetane number, on diesel fuels. Ignition quality. EN 15940 class A requires 70 minimum against 51 for class B and for EN 590. * Ester content, on FAME. EN 14214 requires 96.5 % minimum, measured by EN 14103. It is the headline purity number. ## How to read an assay you have just been sent A practical order of reading, which is roughly how we do it. * First, is it the right product at all? Iodine value and FFA together tell you that within seconds. * Second, can it move? Titre or CFPP against the season and the tank. * Third, can the buyer's plant take it? Sulphur, phosphorus, silicon, metals. * Fourth, what am I paying for that is not product? MIU, broken out. * Fifth, will it survive the journey? Oxidation stability and how long the material has already been sitting. * Last, the paperwork. Which is usually where the delay actually is. If a parameter you need is missing, that is information too. A seller who cannot produce a silicon figure for UCO going to a hydrotreater is not necessarily hiding anything, but they are not yet ready to sell into that outlet, and it is better to find that out in week one. ## Sources * EN 14214 biodiesel standard, full parameter table: https://dieselnet.com/tech/fuel_biodiesel_std.php * FOSFA oils and fats glossary: https://www.fosfa.org/wp-content/uploads/2022/03/Glossary-Oils-and-Fats.pdf * Iodine value: overview and comparative data: https://www.sciencedirect.com/topics/agricultural-and-biological-sciences/iodine-value ## Frequently asked questions Q: What is iodine value and what does it tell you? A: Iodine value measures how many carbon-carbon double bonds a fat contains, reported as grams of iodine absorbed per 100 grams. More double bonds means the fat is more liquid, less stable and more reactive; fewer means more solid and more stable. Coconut oil sits around 6 to 11, palm around 50 to 55, rapeseed around 110, sunflower and soybean around 125. Almost everything else about how a fat behaves follows from that number. Q: What is the iodine value of palm oil? A: Typically 50 to 55, with measured values commonly reported around 51 to 54. That is low enough to make palm semi-solid at ambient temperature in a temperate climate and to give it good oxidation stability, and high enough that it is not as hard as coconut or palm kernel oil. Palm stearin, the hard fraction, sits lower and palm olein, the liquid fraction, higher. Q: Why is coconut oil solid at room temperature? A: Because its iodine value is very low, around 6 to 11, meaning almost all its fatty acids are saturated with no double bonds to disrupt the crystal packing. Saturated chains stack neatly and stay solid, and coconut oil generally remains solid up to roughly 24 to 26 C. That is excellent for shelf life and awkward for logistics: it needs heated storage and heated lines to pump in cool weather. Q: Why can sunflower or soybean oil not simply be made into European biodiesel? A: EN 14214 caps iodine value at 120 g iodine per 100 g. Sunflower and soybean both sit around 125, so on their own they exceed it. Rapeseed at around 110 slips underneath, which is the practical reason European FAME has historically been rapeseed based. Highly unsaturated feedstocks are usually pushed towards hydrotreatment instead, where the double bonds are saturated away. Q: What is the difference between FFA and acid value? A: They measure the same underlying thing in different units. FFA is a percentage of free fatty acid by mass; acid value is the milligrams of potassium hydroxide needed to neutralise one gram of sample. As a rough guide acid value is about twice the FFA percentage for common oils, but never convert between them inside a contract. Quote whichever unit the contract specifies. Q: What does MIU stand for and why is it broken out? A: Moisture, impurities and unsaponifiables. It is the fraction of a cargo that is not product. It is worth asking for the three figures separately rather than as a total, because two percent that is almost all water is a very different cargo from two percent that is mostly solids, and they cost a buyer different amounts to deal with. Q: What is titre and why does it matter more than people think? A: Titre is the solidification temperature of the fatty acids in a fat, in degrees Celsius, typically 38 to 44 C for tallow depending on species mix. It decides whether you need heated storage and heated lines. A high-titre fat that solidifies in an unheated tank or a cold flexitank turns a routine delivery into an expensive salvage operation, and the cost lands on whoever did not raise it. Q: What is CFPP and how is it different from cloud point? A: Cloud point is where wax crystals first become visible and the fuel goes hazy. CFPP, the cold filter plugging point measured by EN 116, is the lowest temperature at which the fuel still passes a standard filter. CFPP is the one written into fuel contracts and set nationally by season, which makes cold flow a calendar problem rather than a quality problem: a cargo can meet EN 14214 in full and still be unsellable in the wrong month. Q: Why does silicon matter in used cooking oil? A: Because it deactivates hydrotreating catalyst, and the limit is very tight, often around 1 ppm. It comes from antifoam agents added perfectly legitimately during frying, so it is invisible, it does not appear on a standard food-oil assay, and a cargo can be clean on every traded parameter and still be refused on silicon alone. If you are selling into HVO, get it measured before you offer. Q: What is oxidation stability and why does it fail in transit? A: It is the induction period measured by the Rancimat test under EN 14112 or EN 15751, expressed in hours; EN 14214 requires at least 8. It measures how long the material resists breaking down. Unlike most parameters it degrades in storage, so a cargo that passed on loading can fail on discharge after a slow voyage or a hot tank, without anyone having done anything wrong. Agree where the governing test is taken before you sail. Q: What is MONG in glycerine? A: Matter organic non-glycerol: everything organic in a crude glycerine parcel that is not glycerol, including soaps, residual esters and free fatty acid carry-over. It is the number a refiner prices the discount on, because it is what fouls their process. A seller who quotes only the glycerol content has quoted half the specification. Q: Two different things are called IV. Which is which? A: In oils and fats, IV means iodine value, a measure of unsaturation in grams of iodine per 100 grams. In recycled PET, IV means intrinsic viscosity, a measure of polymer chain length in decilitres per gram. They are unrelated. If you trade both, write the unit out, because the initials alone have caused real confusion in real negotiations. ============================================================================== # Test methods, standards and how a cargo is actually measured URL: https://www.sustainablecommodities.eu/markets/test-methods-and-analysis The single most expensive mistake in this trade is agreeing a number without agreeing the method. Chlorine measured by combustion ion chromatography and chlorine measured by a field kit are not the same measurement, and a cargo can pass one and fail the other without anything changing in the tank. Name the method, name the laboratory, and agree in advance who pays for the umpire analysis. Everything below is orientation on which method is normally named for which parameter; the contract governs. ## The product standards people actually reference EN 14214: Fatty acid methyl esters (FAME) for use in diesel engines, at 100 percent or as a blend component with EN 590. The reference standard for biodiesel quality in Europe. EN 15940: Paraffinic diesel from synthesis or hydrotreatment, which is the standard HVO is sold against. Permits up to 7.0 percent by volume FAME. Do not confuse HVO under this standard with FAME under EN 14214: they are chemically different products. ASTM D7566: Aviation turbine fuel containing synthesised hydrocarbons, the SAF specification. Structured as annexes per production pathway, including Fischer Tropsch SPK, HEFA SPK, synthesised iso paraffins, SPK with aromatics, alcohol to jet and catalytic hydrothermolysis. Blend limits are set per pathway and reach 50 percent for several of them. ASTM D1655: Conventional aviation turbine fuel. A SAF blend that has been correctly produced and certified under D7566 is redesignated as meeting D1655 once blended, which is why you will see both quoted on the same parcel. ASTM D7544: Pyrolysis liquid biofuel from BIOMASS, for industrial burners. Covers gross heat of combustion, water, pyrolysis solids, kinematic viscosity, density, sulphur, ash, pH, flash point and pour point. Note carefully: this is a biomass bio oil standard and it does NOT describe plastic or tyre derived pyrolysis oil, though it is frequently misquoted for both. ASTM D8577: Standard Guide for Waste Plastic Process Oil Analyses, approved in 2025. The first dedicated framework for characterising plastic derived pyrolysis oil, covering composition, physical properties and contaminants. If you are producing PPO, this is the document your laboratory should be working from. That last pair is worth dwelling on. Until recently there was no standard written for plastic derived oil, so the market improvised with crude oil and biomass methods that were never designed for it. ASTM D8577 closes that gap, and quoting it marks you out as a producer who has done the work. See plastic pyrolysis oil. ## Parameter by parameter, and why each one costs money Chlorine, organic: ASTM D4929 for organic chloride in crude oil, by sodium biphenyl reduction, microcoulometry or XRF. ASTM D7359 determines total fluorine, chlorine and sulphur by combustion ion chromatography. Field kits such as ASTM D5384 exist and are useful for screening, not for settlement. This is the number that decides whether pyrolysis oil reaches a cracker at all. Sulphur: UV fluorescence for low levels, X-ray fluorescence for higher ranges. The method has to suit the expected concentration: a method chosen for the wrong range produces a confident wrong answer. Water: Karl Fischer titration, which measures water specifically. Distillation methods measure water plus anything else that comes over, so the two disagree on wet or volatile material and the difference is not noise. Acid value / FFA: Titration. For fats and oils the acid value routes are well established; for FAME the ester specific method applies. Free fatty acid content and acid value express the same underlying property in different units, which is a routine source of confusion in offers. Density: Hydrometer or oscillating U tube, at a stated reference temperature. The temperature is part of the number: quoting density without it is quoting nothing. Kinematic viscosity: Capillary viscometer at a stated temperature, normally 40 degrees Celsius for fuels. Decides pumpability and whether a receiving terminal can handle the parcel at ambient. Flash point: Closed cup, normally Pensky Martens. Drives transport classification and storage requirements, so a wrong flash point is a safety problem before it is a commercial one. Ash and carbon residue: Ash by ignition; carbon residue by micro method or Conradson. Both indicate what will be left behind in a burner or a reactor. Metals and silicon: ICP-OES. Silicon is the parameter most often missing from a pyrolysis oil COA and one of the most likely to end a conversation with a refiner, because it poisons catalyst. Pour point, cloud point, CFPP: Three different cold flow properties measured three different ways, and they are not interchangeable. See additives and blending for what actually moves each one. Oxidation stability: Accelerated ageing, commonly the Rancimat approach for FAME. Predicts how a parcel behaves after weeks in a tank rather than on the day it was made. ## What makes a COA usable, and what makes it worthless * A date, and a parcel it belongs to. An analysis with no batch reference is a marketing document. If it predates the material it claims to describe, somebody is hoping you will not check. * The method next to every value. A number without a method cannot be reproduced and therefore cannot be defended. * A laboratory the counterparty will accept. Agree this before loading, not after a dispute. Recognised inspection companies exist precisely so that neither side has to trust the other's laboratory. * The parameters that matter for the destination, not just the easy ones. For pyrolysis oil that means chlorine and silicon, which is exactly where thin COAs go quiet. * Consistency across batches. One good analysis proves one good drum. Buyers building a process around your material want two or three that look alike, which is a different and harder claim. ## When load and discharge disagree It happens on perfectly honest cargoes. Material settles, water separates, a sample is drawn from a different level, or the two laboratories ran different methods. The question is never who is lying, it is whose number the contract makes binding. Retained sealed samples from load, taken jointly and held by both sides, are the only thing that reliably settles this. Agree the umpire laboratory in the contract while everyone is still friendly, because agreeing one afterwards is close to impossible. The practical route through a dispute is set out on cargo claims, and if the parcel is already off specification, off-spec and distressed cargoes covers where it can still go. ## Sources * ASTM International, standards catalogue: https://www.astm.org/ * ISCC System, for the certification side of the document pack: https://www.iscc-system.org/ ## Frequently asked questions Q: How is chlorine measured in pyrolysis oil? A: Several ways, and they do not agree. ASTM D4929 covers organic chloride determination by sodium biphenyl reduction, microcoulometry or X-ray fluorescence. ASTM D7359 determines total fluorine, chlorine and sulphur together by combustion ion chromatography. Field kits exist for screening. Because the results differ, the method has to be named in the contract, and total chlorine and organic chloride are different quantities: agreeing one number while each side means a different measurement is how disputes start. Q: Is there an ASTM standard for plastic pyrolysis oil? A: Yes, and it is recent. ASTM D8577, Standard Guide for Waste Plastic Process Oil Analyses, was approved in 2025 and is the first dedicated framework for characterising plastic derived oil, covering composition, physical properties and contaminants. Before it, the market borrowed crude oil and biomass methods that were never written for this material. Do not use ASTM D7544 for plastic oil: that is a biomass pyrolysis liquid specification for industrial burners. Q: What standard does HVO have to meet? A: EN 15940, the European standard for paraffinic diesel from synthesis or hydrotreatment, which also covers XTL fuels. It permits up to 7.0 percent by volume FAME. HVO is not FAME and is not covered by EN 14214, and quoting the wrong standard in an offer signals inexperience faster than almost anything else. Q: Which ASTM standard covers SAF? A: ASTM D7566, for aviation turbine fuel containing synthesised hydrocarbons. It is organised as annexes by production pathway, including Fischer Tropsch SPK, HEFA SPK, synthesised iso paraffins, SPK with aromatics, alcohol to jet and catalytic hydrothermolysis, each with its own blend limit, reaching 50 percent for several. Once correctly blended, the resulting fuel is treated as meeting ASTM D1655, the conventional jet specification, which is why both numbers appear on one parcel. Q: Why do two laboratories give different results on the same cargo? A: Usually because they ran different methods, sampled from different points, or tested at different times while the material settled. None of that requires anyone to be dishonest. It is why sealed samples retained by both sides at load, an agreed test method, and a named umpire laboratory belong in the contract rather than in the argument afterwards. Q: What does a good certificate of analysis look like? A: It names the parcel and the date, lists the method beside every value, comes from a laboratory the buyer will accept, and covers the parameters that matter for the destination rather than only the flattering ones. For pyrolysis oil that means chlorine and silicon are present rather than absent. A COA without methods is a number you cannot defend. Q: Do you carry out the testing yourselves? A: No, and no broker should. Analysis has to come from an accredited laboratory that both sides accept, otherwise it settles nothing. What we do is arrange inspection and sampling through recognised inspection companies, make sure the right parameters are on the list before anyone loads, and tell you when a COA in front of you is not going to survive contact with a buyer. ============================================================================== # Safety data sheet template: the 16 sections, blank URL: https://www.sustainablecommodities.eu/markets/safety-data-sheet-template This page is a blank structure, not a filled in safety data sheet, and not one for any product. A real SDS can only be issued by the supplier: the manufacturer, importer, downstream user or distributor who places the material on the market. We are a broker and never take title, so we are not that party and neither is any other broker. What we can do is show you the shape the document has to have, so you can see at a glance whether the one in your inbox is complete. The format below follows Annex II of REACH as replaced by Commission Regulation (EU) 2020/878, mandatory for every safety data sheet circulating in the EU since 1 January 2023. ## The 16 sections, in the order they must appear The order is prescribed. A document that renumbers or merges sections is not a compliant safety data sheet, however good the content is. 1. Identification of the substance/mixture and of the company/undertaking: 1.1 Product identifier. 1.2 Relevant identified uses and uses advised against. 1.3 Details of the supplier of the safety data sheet. 1.4 Emergency telephone number. See the warning below about 1.3. 2. Hazards identification: Classification, label elements, and any hazards not covered by classification. For waste-derived oils this is where variability between batches starts to matter. 3. Composition/information on ingredients: 3.1 Substances or 3.2 Mixtures, whichever applies. Pyrolysis oil is typically a UVCB, which changes how this section reads and is worth getting right: see REACH for pyrolysis oil. 4. First aid measures: By route of exposure, plus delayed effects. 5. Firefighting measures: Suitable and unsuitable extinguishing media, special hazards from the material, and advice for firefighters. 6. Accidental release measures: Personal precautions, environmental precautions, containment and clean up. 7. Handling and storage: Where inerting, nitrogen blanketing and temperature limits belong for materials that oxidise. See pyrolysis oil on why that matters commercially as well as for safety. 8. Exposure controls/personal protection: Occupational exposure limits and the controls that go with them. 9. Physical and chemical properties: The section buyers read first for commercial purposes, though it is NOT a substitute for a batch certificate of analysis. 10. Stability and reactivity: Reactivity, chemical stability, conditions and materials to avoid, hazardous decomposition products. Peroxide formation belongs here. 11. Toxicological information: By hazard class, with the data source. 12. Ecological information: Toxicity, persistence, mobility, PBT and vPvB. 13. Disposal considerations: Waste treatment methods. Note this is disposal guidance and does not settle the material's waste status: see waste plastics. 14. Transport information: UN number, proper shipping name, class, packing group, environmental hazards. This is what a forwarder actually works from, and it has to come from the producer rather than a general rule. 15. Regulatory information: Safety, health and environmental regulations specific to the substance or mixture, and whether a chemical safety assessment has been done. 16. Other information: Revision date, abbreviations, references, and what changed since the previous version. An SDS with no revision date is a warning sign. ## The sixteen sections, and which ones actually stop a cargo Regulation (EU) 2020/878 fixes both the headings and their order. A sheet with different structure is not compliant however complete the content is. But in practice only a handful of sections decide whether your cargo moves. 1. Identification: What belongs there Product, use, supplier, emergency telephone; Weight Basic 2. Hazards identification: What belongs there CLP classification, labelling, other hazards; Weight Decides handling 3. Composition: What belongs there Substances, concentrations, CAS and EC numbers; Weight Often thin, often queried 4-8. First aid, fire, spillage, handling, exposure: What belongs there Practical response and controls, plus exposure limits and PPE; Weight Routine 9. Physical and chemical properties: What belongs there Appearance, flash point, density, viscosity, solubility; Weight A terminal will ask. Blank here stops loading 10-13. Stability, toxicology, ecology, disposal: What belongs there Reactivity, health and environmental data, waste routes; Weight Routine 14. Transport information: What belongs there UN number, class, packing group, marine pollutant status; Weight A carrier will not move without it 15. Regulatory information: What belongs there REACH, national rules, other applicable legislation; Weight Where compliance desks look first 16. Other information: What belongs there Revision date, abbreviations, sources; Weight Check the date Sections 9, 14 and 15 are where sheets go thin, and they are exactly the three a terminal, a carrier and a compliance desk each look at. If a supplier sends you a sheet with those sparse, that is worth a question before the cargo moves rather than after. One more: check the revision date in section 16. A sheet written before Regulation (EU) 2020/878 applied uses the old structure, and a buyer who spots that will ask for a current one. ## Section 1.3, and the mistake we see most Section 1.3 names the supplier of the safety data sheet, with address, telephone number and the e-mail of a competent person. It is the field that tells a reader who is legally behind the document and who to reach in an emergency. The mistake is putting an intermediary there. A trader, agent or broker who puts their own details in 1.3 has not customised the document, they have misidentified the responsible party. If something goes wrong on a terminal at two in the morning, the person reading section 1.3 needs the party who knows what is actually in the tank. * Ask your producer for their sheet rather than making one. It is their obligation and their document. * Check the format is current. A sheet in the pre-2023 layout is not merely dated, it is non compliant. * Check the language. It has to be in the official language of the member state where the material is placed on the market, and a cargo going to several countries may need several versions. * Never accept an SDS in place of a certificate of analysis. They answer different questions: see documents and safety data sheets. ## Using this as a checklist The quickest use of the table above is as a completeness check on a sheet somebody has just sent you. Four things account for most of the rejections we see at receiving terminals: a missing or stale revision date in section 16, an incomplete section 14 so the forwarder cannot classify the load, an intermediary sitting in 1.3, and the old pre-2023 layout. If yours fails on any of those, it is usually a five minute fix at the producer rather than a problem with the cargo. It is worth catching before the buyer does. ## Sources * Commission Regulation (EU) 2020/878, the current Annex II format: https://eur-lex.europa.eu/eli/reg/2020/878/oj * Regulation (EC) No 1907/2006 (REACH), Articles 3 and 31: https://eur-lex.europa.eu/eli/reg/2006/1907/oj * European Chemicals Agency (ECHA): https://echa.europa.eu/ ## Frequently asked questions Q: What regulation sets out the 16 sections? A: Regulation (EU) 2020/878, which amended Annex II to REACH and applies to safety data sheets in the EU. It fixes both the sixteen headings and their order, so a sheet that uses a different structure is not compliant regardless of how complete the content is. Q: Can I use your specimen as my own safety data sheet? A: No, and please do not. Our specimens carry no batch data and no supplier data by design, and they say on every page that they are examples. Use them as a checklist against the sheet your supplier gives you: if a section is blank where the specimen says a figure is needed, that is a question worth asking before the cargo moves. Q: Who has to provide the safety data sheet in a brokered trade? A: The supplier, meaning the party placing the substance on the market. In a brokered trade that is the seller, not the broker and not the buyer. If a seller cannot produce one, that is a signal about how ready they are to sell into Europe. Q: Can I download a blank SDS template? A: The structure is set out in full on this page, section by section, following Annex II of REACH as replaced by Commission Regulation (EU) 2020/878. You can work straight from it. What we deliberately do not publish is a filled in safety data sheet for a product, because a real SDS has to be issued by the supplier who places the material on the market, and section 1.3 has to name that party. Q: Who has to write the safety data sheet, me or my broker? A: The supplier, meaning whoever places the substance or mixture on the market. That is the producer, importer, downstream user or distributor, never the broker. If you are the producer, it is yours to issue. If you bought the material, ask whoever sold it to you. A broker offering to issue one on their own letterhead is telling you something useful about themselves. Q: Is an MSDS the same as an SDS? A: MSDS is the older term and it is still used constantly in the trade. In the EU the correct term is safety data sheet, and its required content and layout come from Annex II of REACH as replaced by Regulation (EU) 2020/878, mandatory since 1 January 2023. If someone sends you a document headed MSDS in an old layout, ask for a current one before you plan a shipment around it. Q: How do I know if a safety data sheet is out of date? A: Look at section 16 first: it should carry a revision date and say what changed. Then check the layout matches the 16 section structure on this page, since sheets written before 2023 often do not. Then check section 14 is complete enough for a forwarder to classify the load. Those three checks catch most of it. Q: Do I need an SDS if my material is a waste? A: The REACH duty attaches to substances and mixtures placed on the market, and waste sits outside REACH until it reaches end of waste status. That does not leave you with nothing to produce: waste shipments carry their own documentation and the transport classification still has to be established. See REACH for pyrolysis oil. ============================================================================== # Document library: where to get every form you actually need URL: https://www.sustainablecommodities.eu/markets/document-library We link to the official source rather than hosting copies, and you should be suspicious of sites that do the opposite. Scheme documents are updated, sometimes several times a year, and a downloaded copy sitting on a third party website goes stale silently. Someone then files last year's form and finds out at audit. On top of that these are the schemes' own copyrighted documents, and several of the mandatory templates sit in a members' area precisely because they are controlled. So: links to the current version, plus our own explanation of which document does what, which is the part that is genuinely hard to find. ## Start here: the Commission's own list Before you pick a scheme, check it is currently recognised. The European Commission maintains the authoritative list of voluntary schemes recognised for demonstrating compliance under the Renewable Energy Directive, and recognition is granted for a period and then renewed. A certificate under a scheme whose recognition has lapsed is a problem you do not want to discover at the receiving end. * European Commission, voluntary schemes is the master list and the only source that settles an argument about whether a scheme counts. ## The checklist: exactly what you need, per product The question we are asked more than any other, and the one this page exists to answer. The full list of documents in this trade is long; the list for your specific cargo is short. Here is what a European buyer will actually ask for. Used cooking oil: Always required Dated analysis (FFA, MIU, IV, sulphur) · scheme certificate with the scope visible · Proof of Sustainability per consignment · SDS from the supplier; Additionally, and often forgotten Self declaration at the point of origin, signed where the waste arose. Going to a hydrotreater? Add silicon and phosphorus Animal fats and tallow: Always required Analysis (FFA, MIU, titre) · ABP category (1, 2 or 3) · approval number of the rendering establishment · scheme certificate · PoS; Additionally, and often forgotten Commercial document under Regulation (EU) No 142/2011. For import: health certificate and the border control post Fish oil and marine fats: Always required Analysis with iodine value · ABP category and establishment approval · health certificate for import; Additionally, and often forgotten Annex IX status confirmed in writing by the certifier. Fish oil is not named as its own entry, so do not assume Vegetable oils: Always required Analysis (FFA, MIU, peroxide, colour) · scheme certificate · PoS; Additionally, and often forgotten EUDR evidence for palm and soy: geolocation of the plots and the due diligence statement FAME and HVO: Always required Certificate of analysis against EN 14214 or EN 15940 · PoS with the greenhouse gas figure · SDS; Additionally, and often forgotten The CFPP grade for the destination country and season. A compliant cargo can still be unsellable in the wrong month Plastic waste and pyrolysis oil: Always required Analysis including chlorine and silicon · waste classification · receiving installation's permit · SDS; Additionally, and often forgotten For movement: notification under Regulation (EU) 2024/1157 where it applies. For a circular claim: ISCC PLUS, not ISCC EU Crude glycerine: Always required Analysis with glycerol content, MONG, ash, salt and methanol · SDS; Additionally, and often forgotten Methanol above roughly 0.5 % changes the transport classification. Settle it before the truck is booked Three things fail more often than everything else combined. The scheme certificate does not cover the activity actually being performed, most often storage. The self declaration at the point of origin is missing, which cannot be fixed retrospectively because it has to be signed where the waste arose. And the entity name differs between the certificate, the invoice and the bill of lading, which stops a compliance desk cold no matter how good the material is. Send us the pack before you send it to a buyer. We will tell you what is missing in a day rather than letting you find out over three weeks and one lost enquiry. It costs you nothing and it is the single most useful thing we do for a first-time exporter. ## The schemes, and where their documents live Each of these publishes its own system documents, procedures and templates. Where a template is mandatory it usually sits in the members' or client area, which is a good sign rather than an obstacle: controlled documents should be controlled. ISCC: The scheme most feedstock and pyrolysis oil trades run under, with ISCC EU for the Renewable Energy Directive and ISCC PLUS for circular and bio-based materials. System documents, procedures and templates: ISCC documents. Scheme overview: iscc-system.org. REDcert: Widely used in Germany and across the EU, with REDcert EU for the Directive and REDcert2 for the chemical industry. redcert.org. 2BSvs: French origin, common on agricultural feedstocks and widely accepted across the EU. 2bsvs.org. KZR INiG: Polish scheme, frequently seen on central and eastern European volumes. kzr.inig.eu. SURE: Focused on solid and gaseous biomass for heat and power. sure-system.org. Bonsucro: Sugarcane and its derivatives, including ethanol. bonsucro.com. CertifHy: Hydrogen and derivatives, relevant if you are moving toward RFNBOs. certifhy.eu. Others: RSB, Better Biomass, RTRS, Red Tractor, SQC, TASCC and UFAS also appear. Check the Commission list above for current status before relying on any of them. ## Which document does what This is the part people actually get stuck on. The names sound interchangeable and are not. Proof of Sustainability (PoS): Issued per consignment by a certified operator, carrying the sustainability characteristics down the chain. This is the document that decides whether a volume counts for a mandate. Not a certificate, not a declaration: it travels with the goods. Sustainability Declaration: The declaration accompanying a delivery within a scheme, confirming the material meets the scheme's requirements. Terminology varies between schemes, which is exactly why people mix it up with a PoS. Self declaration (point of origin): Signed by the party where a waste or residue arises, confirming what the material is and that it is genuinely a waste or residue. The foundation of an Annex IX claim, and the document most often missing from a thin file. Scheme certificate: Proves the OPERATOR is certified, with a scope and a validity period. It says nothing about any particular cargo. Always check the scope covers both the product and the activity: see ISCC certification. Certificate of analysis: The measured values for one batch. Nothing to do with sustainability; everything to do with whether the cargo meets contract. See test methods. Safety data sheet: Hazard and handling information, issued by the supplier. Structure and a section by section checklist: SDS template. Waste shipment paperwork: Annex VII, or a full notification dossier where consent is required. Changed materially in 2026: see waste plastics. ## The legislation itself, in one place * Directive (EU) 2018/2001, RED II and Directive (EU) 2023/2413, RED III, including Annex IX. * Regulation (EU) 2024/1157 on shipments of waste. * Regulation (EU) 2025/40, packaging and packaging waste. * Regulation (EC) No 1907/2006, REACH and Regulation (EU) 2020/878 for the safety data sheet format. * Regulation (EC) No 1069/2009 on animal by-products, which governs category 1, 2 and 3 material. * Directive 2008/98/EC, the Waste Framework Directive, for waste status and end of waste. * Regulation (EU) 2023/1115, deforestation free products. Always read the consolidated text on the date that matters to you. Legislation is amended, and a provision quoted from a blog post is worth nothing in an audit. ## What we can actually do with all this * Tell you which documents your specific trade needs, which is a shorter list than this page suggests and depends on product, origin and destination. * Check a file before it goes to a buyer. Most rejected enquiries fail on a missing self declaration, an out of scope certificate or an undated analysis, not on price. * Introduce you to a certification body and stay involved through the audit rather than handing you over: see ISCC certification. * Read a certificate properly. Scope, validity and the exact product listed. We have turned down volumes on scope alone, and that is cheaper than finding out later. ## The Proof of Sustainability, and what it has to demonstrate This is the document people ask about most and understand least. A Proof of Sustainability travels with the consignment, not with the company. It is issued by a certified operator for a specific delivery, and it is what allows the volume downstream to be counted against a mandate. Without it your material is chemically identical and commercially worth a great deal less. * It is per consignment. A scheme certificate proves the operator is certified. A Proof of Sustainability proves this delivery qualifies. Sending a certificate when a buyer asked for a PoS is one of the most common delays we see. * It carries the greenhouse gas figure. Plants commissioned from 2021 onward have to demonstrate at least a 65 percent greenhouse gas saving. The figure can be built from default values where they exist for that feedstock, or from actual calculated values, and which route you use has to be consistent and auditable. * It rests on the chain of custody behind it. Records have to run from the point of origin through to the point of delivery, and a certified operator is audited annually by an independent body. The PoS is the visible end of that chain; the audit is what makes it worth anything. * The exact form belongs to the scheme. Each scheme publishes its own template and updates it, which is why we link to ISCC documents rather than hosting a copy that would quietly go out of date. The practical failure we see most often is not a missing PoS but an inconsistent one: a greenhouse gas figure that does not match the declared feedstock route, a consignment volume that does not tie back to the delivery documents, or a certificate whose scope does not actually cover the product being sold. Any of those turns up at the buyer's audit rather than at yours, which is the expensive moment to find out. ## Sources * SPECIMEN SDS: Used cooking oil (worked example, 16 sections per Regulation (EU) 2020/878): /documents/sds-used-cooking-oil * SPECIMEN SDS: Animal fat and tallow (worked example, 16 sections per Regulation (EU) 2020/878): /documents/sds-animal-fat * SPECIMEN SDS: Crude glycerine (worked example, 16 sections per Regulation (EU) 2020/878): /documents/sds-crude-glycerine * SPECIMEN SDS: FAME biodiesel (worked example, 16 sections per Regulation (EU) 2020/878): /documents/sds-fame-biodiesel * SPECIMEN SDS: HVO renewable diesel (worked example, 16 sections per Regulation (EU) 2020/878): /documents/sds-hvo-renewable-diesel * SPECIMEN SDS: Plastic pyrolysis oil (worked example, 16 sections per Regulation (EU) 2020/878): /documents/sds-pyrolysis-oil * European Commission, recognised voluntary schemes: https://energy.ec.europa.eu/topics/renewable-energy/bioenergy/voluntary-schemes_en * ISCC documents and templates: https://www.iscc-system.org/certification/iscc-documents/ * REDcert: https://www.redcert.org/en/ * 2BSvs: https://www.2bsvs.org/ * KZR INiG: https://kzr.inig.eu/en/ * SURE: https://sure-system.org/en/ * Bonsucro: https://www.bonsucro.com/ * CertifHy: https://certifhy.eu/ ## Frequently asked questions Q: What exactly is a Proof of Sustainability? A: A document issued by a certified operator for a specific consignment, confirming that this delivery meets the sustainability requirements of a recognised scheme. It travels with the goods rather than with the company, and it is what allows the volume to be counted against a mandate downstream. It is not the same as the scheme certificate, which proves only that the operator is certified. Q: What greenhouse gas saving does a biofuel have to show? A: For plants commissioned from 2021 onward, at least 65 percent. The figure can be built from default values where they exist for that feedstock, or from actual calculated values specific to your raw material and process. Whichever route you use has to be applied consistently and has to survive the annual audit. Q: Where do I get the actual PoS template? A: From the scheme itself. Each one publishes and updates its own form, so a copy hosted anywhere else goes out of date without anyone noticing. ISCC's documents are at iscc-system.org, with the mandatory templates in the client area. What we can do is check the one you have filled in before a buyer sees it. Q: Where can I download an ISCC sustainability declaration template? A: From ISCC itself, at ISCC documents. Mandatory templates sit in the client area, which is deliberate: controlled documents should be controlled, and a copy hosted elsewhere goes stale without anyone noticing. We link to the current version rather than hosting our own copy for exactly that reason. Q: What is the difference between a Proof of Sustainability and a certificate? A: A certificate proves the OPERATOR is certified, with a scope and a validity period, and says nothing about any particular cargo. A Proof of Sustainability is issued per consignment and carries the sustainability characteristics with the goods. You need both, and confusing them is one of the most common reasons a file gets sent back. Q: Which certification schemes are recognised in the EU? A: The European Commission maintains the authoritative list, and recognition runs for a period and is then renewed, so check it rather than assuming. The ones you are most likely to meet in feedstocks and renewable fuels are ISCC, REDcert, 2BSvs, KZR INiG, SURE and Bonsucro, with CertifHy relevant for hydrogen and derivatives. Q: Do you host copies of these documents? A: No, and that is a considered decision rather than laziness. Scheme documents are updated regularly, and a copy on a third party site goes stale silently until someone files an outdated form and discovers it at audit. They are also the schemes' own copyrighted documents. Linking to the issuing body means you always get the current version. Q: What is a self declaration for a point of origin? A: A signed statement from the party where a waste or residue arises, confirming what the material is and that it genuinely is a waste or residue rather than something produced deliberately. It underpins an Annex IX claim and is the document most often missing when a file looks thin. See Annex IX feedstocks. Q: Can you help us get certified? A: We introduce you to a certification body, help you prepare, and stay involved through the audit rather than handing you over at the door. What we cannot do is issue certificates or declarations ourselves, and neither can any broker: those come from certified operators and accredited bodies, which is what makes them worth having. See ISCC certification. ============================================================================== # Delivered the cargo and not been paid? Start here URL: https://www.sustainablecommodities.eu/markets/trade-dispute-mediation You delivered, and the money stopped. Usually the buyer says the quality is off, or a document is wrong, or they simply go quiet. Meanwhile demurrage runs, the cargo sits, and both sides start talking to lawyers who are paid by the hour to disagree. On what we do: we are brought in by sellers AND by buyers to get a stalled trade moving again, including trades we never brokered. We are not lawyers and this is not arbitration. We are commercial people who know what the cargo is actually worth, what the paperwork should say, and what each side can realistically accept. On the clock, which is the part most people miss: you may already be running against a deadline. ## What we are, and what we are not Worth putting at the top rather than in small print at the bottom, because it decides whether we are the right call at all. * We are brokers, not lawyers. Nothing here is legal advice, and none of it is a substitute for your own solicitor or your own contract. * We are not arbitrators. We do not sit on FOSFA, GAFTA or GROFOR tribunals and we issue no binding decision. We are a member of GROFOR; that is a trade membership, not a qualification in its rules. * We do not interpret your contract for you. Where we mention deadlines or procedures on this page, they are general indications of how these regimes commonly work. Rules are revised, editions differ, and your contract may say something else entirely. Read your own contract and take professional advice on it. * We are not an inspection company. We can bring one in, and we will recommend it early, but the analysis and the report are theirs. * Where a case needs a lawyer, we say so. Insolvency, suspected fraud, or an amount large enough that the legal cost is worth it: that is a lawyer's job, and telling you that quickly is more use than a slow attempt at something else. What we do bring is narrower and more practical: we know what the material is actually worth in its current condition, we can find the buyer who will take it that way, and we have no position in the cargo, so we are not arguing for an outcome. In a lot of stuck shipments that is the missing piece, and it is not something a law firm is set up to provide. ## The deadline nobody mentions until it has passed Standard commodity contracts carry time limits for starting a formal claim, and they are much shorter than people expect. Under FOSFA terms, an arbitrator must be appointed within 90 days of completion of discharge for quality and condition claims, and within 120 days of completion of the delivery period for monetary and other disputes. Miss it and you can lose the right to bring the claim at all, regardless of how obviously right you are. We have seen sellers spend three months being patient and reasonable, and discover that patience cost them their remedy. * Check your contract first, today. GAFTA and FOSFA terms govern the large majority of grain and vegetable oil trade, and most other physical contracts borrow their structure. Find the clause and diary the date. * Mediating does not stop the clock. Talking is the right first move, but it is not a substitute for protecting your position. Do both. * A protective appointment is not an act of war. Appointing an arbitrator to preserve the deadline while you keep negotiating is normal practice, and any experienced counterparty will read it that way. ## Why these stall, and it is rarely the reason given The stated reason is usually quality. The real reason is usually something else, and knowing which changes what you should do next. The market moved: The buyer agreed a price, the market fell, and the cargo is now worth less than the contract. A marginal specification deviation becomes the reason to renegotiate. This is the most common one and nobody says it out loud. The analysis genuinely disagrees: Load and discharge results differ, often for honest reasons: settling, water separation, a different sampling point or a different test method. See test methods. A document is wrong: A discrepancy in the bill of lading or the certificate pack puts the buyer in a strong position: they can demand a discount to waive it or reject outright. The bill of lading is a receipt, a contract of carriage AND a document of title, which is why a small error has such weight. The buyer cannot pay: Credit has dried up, or their own onward sale collapsed. Quality becomes the polite way to say so. This one needs a completely different approach and the sooner you know, the better. Someone is holding documents hostage: A seller withholding the original bill of lading over a payment dispute usually cannot then recover the storage charges the delay caused. Both sides lose while the container sits. Meanwhile the cargo is deteriorating and demurrage accrues daily. In physical trade the standoff itself is expensive, which is exactly the pressure a mediator uses to get a deal. ## What we actually do * Establish the facts both sides can agree on. Usually far more than either expects. We work from the contract, the load and discharge analyses, the sampling records and the documents rather than from what anyone is feeling. * Get an independent measurement where the numbers are the issue. We instruct recognised inspection companies and laboratories, on terms both sides accept in advance, so the result binds rather than starts a new argument. Retained sealed samples from load are usually the key. * Value the parcel honestly. This is where a broker beats a lawyer. We know what off-specification material is genuinely worth and where else it can go, so a discount can be argued from a real number rather than from leverage. See off-spec and distressed cargoes. * Find the landing zone and put it in writing. A price adjustment, a replacement parcel, a split of the demurrage, a resale to a third buyer at a shared loss. Almost every one of these ends in a commercial number rather than a legal ruling. * Tell you when we are the wrong answer. If the counterparty is insolvent, if there is fraud, or if the amounts justify formal proceedings, you need a lawyer and you need one now. We will say so on the first call. ## Why an intermediary works when direct talks have failed By the time payment has stopped, the two sides have usually written each other several e-mails they cannot take back. Positions harden, and every further message is read as a threat. That is a communication problem more than a commercial one. A neutral party changes the mechanics. Each side can say what they would really accept without conceding it publicly. We can carry a number between them and test it without either party losing face for having floated it. And because we are paid to conclude rather than to be right, our incentive points at a settlement instead of at a verdict. * We take no position and no title. We are a broker: we never own the cargo, so we have nothing riding on which way it goes. * Both sides can appoint us. We work for sellers, for buyers, and occasionally for both jointly where they want one process rather than two. * It is confidential. Nothing said in the process goes further, which is the whole reason people can be honest in it. * It is fast and it is cheap next to the alternative. Formal proceedings run in months and cost real money, and note that under GAFTA terms you normally cannot recover your legal costs even when you win, while FOSFA allows it. Either way, a commercial settlement in two weeks usually beats a ruling in eight months. ## Which rules your contract actually sits under Before anyone argues about the cargo, find out which regime governs it. It decides the deadline, the procedure and whether you can recover your costs, and those differ enough to change what you should do. FOSFA: Oils, seeds and fats. Two tier, with a Board of Appeal. Arbitrator within 90 days of completion of discharge for quality and condition, 120 days from the end of the delivery period for monetary claims. The winning party can recover reasonable legal and consultancy costs. GAFTA: Grain and feed. Also two tier, with five arbitrators at appeal. Offers a mediation service alongside arbitration, and Rules No. 126 give an expedited lower cost route. Legal costs are normally NOT recoverable, so winning does not automatically pay for itself. GROFOR: The German association for oils, fats and oil raw materials, founded in 1916. Publishes its own standard trading conditions and runs an arbitration tribunal staffed by merchants as well as lawyers, under German law. We are a GROFOR member, listed in its public member directory. That is a membership, not a qualification in its rules. Note what all three have in common: they are built by traders for traders, and they keep lawyers out of the room where they can. That tells you something about how these disputes are meant to be settled, and it is the same instinct behind bringing in a broker rather than a firm. ## Beyond our own markets We work in waste-based feedstocks, renewable fuels and recycled polymers, and that is where our technical judgement is strongest: we can tell you what a chlorine number or an FFA result actually means for value. The mechanics of a stalled cargo, though, are the same in any physical commodity: a specification argument, a document problem, a market that moved, and demurrage running while nobody moves. Where the dispute is commercial rather than technical, we can help outside our own products too. If your situation needs specialist technical knowledge we do not have, we will say so rather than learn on your cargo. ## Sources * GROFOR member directory (Sustainable Commodities is listed under S): https://grofor.de/mitglieder/ * GROFOR, the German oils and fats traders association: https://www.grofor.de/ * GAFTA, arbitration and mediation rules: https://www.gafta.com/ * FOSFA International: https://www.fosfa.org/ ## Frequently asked questions Q: Are you a member of a trade association? A: Yes. We are a member of GROFOR, the German association of wholesale traders in oils, fats and oil raw materials, founded in 1916 with around 150 member companies across Europe. GROFOR publishes its own standard trading conditions and runs an arbitration tribunal staffed by merchants as well as lawyers, and it sits inside the European umbrella body COCERAL with close ties to FOSFA, NOFOTA, FEDIOL and ECOGRAS. You can check the membership yourself in the GROFOR member directory. To be clear about what that does and does not mean: it says we trade in this sector under its conventions. It does not make us qualified in GROFOR, FOSFA or GAFTA rules, and we do not hold ourselves out as arbitrators or as legal advisers. Q: I delivered the cargo and the buyer will not pay. What do I do first? A: Two things today, in this order. Find the dispute clause in your contract and diary the deadline: under FOSFA terms an arbitrator must be appointed within 90 days of completion of discharge for quality and condition claims, and within 120 days of completion of the delivery period for monetary claims. Miss that and you can lose the right to claim at all. Then secure your evidence: the retained sealed samples from load, the sampling records, the full document pack and every message. After that, talk. Negotiating does not stop the clock, so do both. Q: Can you help if you were not the broker on the trade? A: Yes, and that is a large part of this work. We are brought in by sellers and by buyers on trades we had nothing to do with, precisely because we have no history with either side and no position in the cargo. Being unconnected to the original deal is an advantage here rather than an obstacle. Q: Is this arbitration or legal advice? A: Neither, and it matters that you understand the difference. We are not lawyers and we do not issue binding rulings. We are commercial people who know what the cargo is worth, what the paperwork should say and what each side can realistically accept, and we use that to find a settlement both can sign. If your situation needs a lawyer or a formal arbitration we will tell you on the first call, and sometimes we do. Q: The buyer says the quality is off. Are they just trying to get a discount? A: Sometimes, and sometimes the analysis genuinely disagrees for honest reasons: the material settled, water separated, the sample came from a different point, or the two laboratories ran different methods. You cannot tell which from the argument itself. What tells you is the retained sealed samples from load, tested by a laboratory both sides accepted in advance. That is usually the first thing we arrange, and it very often ends the dispute on its own. Q: How much does mediation cost compared with arbitration? A: Far less, and the bigger saving is time. Formal proceedings run for months while demurrage accrues and the cargo deteriorates. Note also that under GAFTA terms you normally cannot recover your legal costs even if you win, while FOSFA does allow recovery, so read your contract before assuming a win pays for itself. A commercial settlement reached in two weeks usually beats a ruling in eight months even when the ruling would have gone your way. Q: Do you only mediate in biofuels and feedstocks? A: Our technical judgement is strongest there: we can tell you what a chlorine figure or an FFA result means for the value of a parcel. But the mechanics of a stalled cargo are the same across physical commodities, and where the dispute is commercial rather than technical we can help outside our own products. If it needs specialist knowledge we do not have, we will say so rather than learn on your cargo. Q: Will this stay confidential? A: Yes, and that is the point of using an intermediary. Nothing said in the process goes anywhere else, which is what lets each side say what they would actually accept without conceding it on the record. We are a broker: discretion on both sides of a trade is how we have always worked. ============================================================================== # Industries we supply, and what each one screens on URL: https://www.sustainablecommodities.eu/markets/industries-we-serve We broker waste-based feedstocks and renewable fuels in both directions. Alongside the collectors and producers who place volume with us stand the industries that take it: steam crackers, refineries, carbon black producers, marine fuel suppliers, aviation, oleochemical plants, feed producers, resin and coatings manufacturers and packaging companies. What is a defect on one side of the trade is a specification on the other: a high sulphur reading rules an oil out of a steam cracker and changes nothing for a fuel blender, and an acid oil priced on total fatty acid is an Annex IX question for a biodiesel plant and a cost question for an oleochemical buyer. This page is written from the buying side. Tell us what your plant runs on and we will tell you honestly which of our suppliers can hold that specification, at what certification, and what a realistic qualification timeline looks like. ## The industries, at a glance Ten industries take the bulk of what we place. The table is deliberately blunt: if the screening question in your industry does not appear here, ask us what replaces it, because it exists. Steam crackers and polymer producers: Materials we place with them Plastic pyrolysis oil (PPO), bionaphtha; What the deal screens on Chlorine in ppm, ISCC PLUS mass balance, stability of the specification over batches Refineries: Materials we place with them Biofeedstock for co-processing, TPO for upgrading; What the deal screens on Waste or product status, mass balance accounting, metals and water Carbon black producers: Materials we place with them Tyre pyrolysis oil (TPO); What the deal screens on Aromaticity, sulphur, ash and consistency of supply Marine fuel suppliers: Materials we place with them TPO and heavy fractions as blending components; What the deal screens on ISO 8217 fit, sulphur cap compliance, flash point Aviation and SAF suppliers: Materials we place with them SAF (HEFA-SPK), and UCO, tallow and fish oil as SAF feedstock; What the deal screens on ASTM D7566 pathway, ISCC scope, carbon intensity Oleochemical, personal care and pharma downstream: Materials we place with them Refined glycerine, TOFA, vegetable and technical oils; What the deal screens on Purity, MONG, colour, and the audit trail behind the grade Animal feed producers: Materials we place with them Category 3 tallow, feed glycerine, distillers corn oil; What the deal screens on ABP category, approval numbers, Free Fatty Acid and stability Resins, coatings and friction materials: Materials we place with them CNSL and distilled cardanol, tall oil pitch; What the deal screens on Cardanol content, acid number, rosin share Packaging and brand owners: Materials we place with them Food grade rPET, certified recyclate under mass balance; What the deal screens on IV, PVC in ppm, food contact approval, PPWR claim rules Recyclers and pyrolysis plant operators: Materials we place with them Waste plastics as feedstock, outlets for their own oils; What the deal screens on Bale and regrind quality, PVC content, logistics economics ## Steam crackers and polymer producers The highest-value home for plastic pyrolysis oil is a steam cracker taking it as circular feedstock under ISCC PLUS mass balance, and this is the most demanding qualification on the list. Chlorine is the gate: crackers work to single digit ppm and untreated mixed plastic oil tests in the hundreds. What a cracker buyer wants beyond the number is repeatability, because a cracker cannot re-tune its furnace for every parcel. * Plastic pyrolysis oil (PPO) into crackers and polymer producers, qualification through a pilot parcel and successive sampling rounds. How the qualification runs. * Bionaphtha for bio-based polymers or gasoline blending, where the certificate decides which market the molecule is worth more in. Bionaphtha brokerage. ## Refineries Refineries take our materials through two doors. Co-processing runs bio feedstock alongside crude under mass balance, with the fuel product covered by the ASTM D1655 Annex A1 limit for co-processed components. The other door is upgrading: tyre-derived and other pyrolysis oils bought as streams to run through existing units, where metals, water and solids decide whether the economics survive the pretreatment. * Co-processed naphtha and kerosene from refineries that run our feedstock, and the mass balance behind the claim. Co-processing. * Tyre pyrolysis oil bought for refinery upgrading. TPO brokerage. ## Carbon black producers Furnace black plants run on feedstock that is part fuel, part chemistry, and aromatic heavy oils sit close to what a tyre-derived oil offers. TPO is not a like for like replacement for standard carbon black feedstock: sulphur, ash and batch consistency have to be managed, which is why qualification starts with a burn trial rather than a price conversation. * Tyre pyrolysis oil into carbon black production and industrial heat. What TPO screens on. ## Marine fuel suppliers and bunker blenders Heavy pyrolysis fractions work as blending components, and bio-based streams are entering the pool as the sulphur cap and FuelEU squeeze conventional bottoms. Two limits run the conversation: the ISO 8217 grade the end vessel actually needs, and flash point, which is where pyrolysis-derived components most often fail. We do not present an off-spec cargo as on-spec; where a stream only fits as a component under a buyer's own quality management, we say exactly that. * TPO and heavy fractions as marine blending components, placed with suppliers who test before they blend. * Off-spec and distressed parcels that still hold value in fuel outlets, placed fast while demurrage runs. Off-spec cargoes. ## Aviation and SAF suppliers On the buying side this splits in two: finished sustainable aviation fuel under ASTM D7566 for fuel suppliers and airlines working to ReFuelEU, and the feedstocks that HEFA producers need to make it, which is where most of our volume sits. Feedstock carbon intensity is becoming as decisive as price, because it passes straight through the CORSIA and ReFuelEU accounting. * SAF, neat and blended, HEFA-SPK under ASTM D7566 Annex A2. SAF brokerage. * UCO, animal fats and fish oil as SAF producer feedstock, with the traceability chain that survives an audit. UCO and animal fats. ## Oleochemical, personal care and pharmaceutical downstream For these buyers the certificate matters less than the purity figure and the audit trail behind it. Refined glycerine for downstream use is specified on purity and the impurities that survive refining, and a technical grade that clears a fuel specification comfortably can still fail a personal care brief. Crude tall oil and TOFA compete with biofuel demand for the same barrel, so timing and origin decide what is available. * Crude and refined glycerine, where purity and MONG set the outlet. Glycerine brokerage. * Crude tall oil, TOFA and tall oil pitch. Crude tall oil. * Vegetable and technical oils outside the food chain. Vegetable and technical oils. ## Animal feed producers Category 3 material is the rule here, with the ABP framework deciding what may go where and establishment approvals deciding who may handle it. Feed buyers screen on category paperwork first and quality second, which is the reverse of the fuel trade and catches new suppliers out. * Category 3 tallow, feed glycerine and distillers corn oil, with the approval numbers in order before the cargo moves. Animal fats and tallow. ## Resins, coatings and friction materials A quiet corner of the portfolio that has nothing to do with fuel. Technical CNSL and distilled cardanol go into resins, friction linings and surface coatings, and tall oil pitch finds outlet in the same industrial chemistry. These buyers screen on cardanol content and acid number, not on sustainability certificates, and the supply routes run through Vietnam, India and West Africa. * CNSL and distilled cardanol. CNSL brokerage. * Tall oil pitch and TOFA into industrial chemistry. Crude tall oil. ## Packaging, FMCG and brand owners Recycled content obligations under the Packaging and Packaging Waste Regulation turn rPET and certified recyclate into procurement questions with deadlines attached: 30 % recycled content in contact sensitive PET packaging and in single use beverage bottles from 2030. Food grade rPET is specified on intrinsic viscosity and PVC in ppm, and the claim behind it, food contact approval or mass balance, needs to be in the paperwork before the contract, not after. * Bottle bales, hot washed flake and food grade rPET. Waste PET and rPET. * Post industrial and post consumer polyolefins into recyclate streams. Waste plastics. ## Recyclers and pyrolysis plant operators Operators run in both directions with us: they buy feedstock, and they need dependable outlets for the oils and fractions their plants produce. For the buying side, feedstock quality is the whole business case: PVC content in a plastics stream is the chlorine problem moving downstream, and bale quality decides yield before the plant is even involved. * Waste plastics as pyrolysis and recycler feedstock, screened on PVC and quality class. Waste plastics. * Term outlets for pyrolysis oils, the commercial half of a new plant's business plan. How to sell pyrolysis oil in Europe. ## How buying through a broker actually works We are paid a brokerage commission on concluded business, agreed in advance and carried by a named side, so for most buyers the introduction costs nothing beyond the commercial terms. On feedstocks and fuels we never take title, which means the supply contract runs directly between you and the producer and we are never your supplier of record. What we bring is the qualification work: counterparties that already clear your KYC rather than starting it, sampling rounds that catch problems before a cargo, and documentation that reaches your plant complete. ## Sources * ISCC PLUS, the scheme behind circular and mass balance claims: https://www.iscc-system.org/certification/iscc-certification-schemes/iscc-plus/ * Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2025/40/oj * Directive (EU) 2023/2413 (RED III), on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * Regulation (EU) 2024/1157 on shipments of waste, on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1157/oj ## Frequently asked questions Q: We are a buyer, not a seller. Can we approach you? A: Yes, and roughly half of the desk works for exactly that side. We source supply for refiners, crackers, blenders, carbon black plants and end users, and we qualify the seller before an introduction rather than after it. Q: What do you need from us before you start sourcing? A: The specification your plant actually runs to, not a wish list: parameters with their limits, monthly volume, delivery basis and location, the certification scheme your own accounting requires, and how a trial would run at your site. With that we can tell you within a working day whether the panel holds it. Q: Do you quote prices on this website? A: No. Market levels are discussed with counterparties directly and are not published. Two quotes for the same product are often not comparable anyway, because certification, basis and payment terms hide in the number. We do not publish price assessments. Q: How does qualification of a new supplier run? A: Documents first, then the laboratory, then the plant. A certificate with the right scope, a dated analysis from a recognised laboratory, retained samples, and a pilot parcel into your own tanks or a trusted terminal. Two or three consistent batches is when term volume becomes realistic. Q: We need monthly term supply, not a spot cargo. Can you hold that? A: Term is the larger part of the business, and it is where a broker earns the commission: supplier qualification, sampling rounds and certification take weeks to months, and we would rather tell you that timeline honestly than promise a start date a producer cannot keep. Tell us the volume profile and we will tell you what is realistic to commit. Q: Can you supply under ISCC EU or ISCC PLUS mass balance? A: Yes, within the limits of what the counterparties' certificates actually cover. The scope of the certificate and the certified product group decide what claim you can make downstream, so we check both before an introduction rather than discovering the gap at your audit. See ISCC certification. Q: Our procurement policy requires three comparable quotes. Do you run tenders? A: We are not a tender platform. We bring the counterparty that fits your specification and your lane, and where more than one realistic counterparty exists we say so. If your purchasing policy formally requires a multi quote process, tell us at the start: we would rather decline cleanly than fill in a form that was never going to conclude. Q: We are a waste management company. Is this relevant to us? A: Yes, twice over. Your fractions are raw material for someone on this page, and if you run your own pyrolysis or recycling line, the feedstock and the offtake are the two halves of your business plan. Both directions run through the same desk. Q: Our incoming cargo was rejected at discharge. Can you help? A: That is a speciality of the desk. The commercial placement of a rejected or off-spec parcel runs alongside your insurer, surveyor and average adjuster, and speed matters more than price discovery once demurrage is running. We are not an insurance intermediary and give no insurance advice. See off-spec and distressed cargoes. Q: Which buyers do you not serve? A: Retail and household quantities, because below freight economics nobody wins. And on feedstocks and fuels we are never the seller of record: the contract runs between you and the producer, so if your process needs a principal counterparty, additives and blending components are the one line where we act as principal. ============================================================================== # CN and HS codes for feedstocks and renewable fuels URL: https://www.sustainablecommodities.eu/markets/cn-codes-customs Customs classification is one of the quiet deal killers in this trade. The same product can move under several CN headings depending on how it was made, what it is used for and whether the receiving country treats it as a waste or a product, and a reclassification after arrival moves duty, import VAT and energy taxation all at once. We see the same headings come back across our markets, so we have collected them here, product by product, together with the questions that decide between them. Treat the table as orientation: the only binding answers come from your customs authority, ideally in writing through a Binding Tariff Information. ## Commonly used headings, product by product These are the headings we most often see on the documents crossing our desk. Confirm the individual line and suffix with your customs agent against the current Combined Nomenclature, because lines are amended every year. Used cooking oil (UCO): Commonly used CN heading 3823 80 99 vs 1518 00 99; What decides between the options National practice differs widely: many member states treat unprocessed UCO as industrial fatty substance, refined UCO as a processed fat under 1518 Animal fats and tallow (category 3): Commonly used CN heading 1502; What decides between the options Technical or feed use keeps tallow in 1502; category 1 and 2 material moves under the fatty substance and waste headings instead FAME biodiesel (UCOME, RME, TME, SME): Commonly used CN heading 3824 99 92; What decides between the options Mixtures in which petroleum oils make up 70 % or more by weight fall under 2710 19 instead, which is the rule B30 style blendstocks trip over; neat FAME stays in 3824 99 92 HVO and renewable diesel: Commonly used CN heading 2710 19 series; What decides between the options The same family as the fossil gas oil it substitutes; blending composition and sulphur content pick the exact line SAF and aviation kerosene: Commonly used CN heading 2710 19 21 and nearby lines; What decides between the options Blended fuel meeting the jet fuel spec moves under the aviation kerosene line; neat synthetic fractions before blending sit on adjacent lines Bionaphtha: Commonly used CN heading 2710 12 or 2901; What decides between the options A genuinely live classification question: hydrocarbon naphtha sits under 2710 12, renewable origin naphtha is regularly argued under the hydrocarbon lines of 2901, and practice differs between member states. Worth a BTI before a term flow Pyrolysis oil (TPO and PPO): Commonly used CN heading 2707, 2710, 2713 or 3824; What decides between the options Origin and intended use decide: aromatic tyre oils, plastic-derived oils and waste-status oils each land differently, and one UK advance ruling placed heavy plastic-derived oil under 2710 19 71 Glycerine: Commonly used CN heading 1520 00 00 vs 2905 45 00; What decides between the options Purity: crude glycerine below roughly 95 % glycerol stays under 1520, refined glycerol at or above it moves to the pure glycerol line Crude tall oil, TOFA and pitch: Commonly used CN heading 3803 00; What decides between the options Tall oil stays in 3803 through considerable refining; that is unusual and worth knowing before a buyer assumes otherwise Waste plastics (bales, regrind): Commonly used CN heading 3915 series; What decides between the options The polymer decides the suffix; once processed into pellets the cargo leaves 3915 and enters the polymer line, PET for example under 3907 61 Vegetable and technical oils: Commonly used CN heading 1510 to 1518; What decides between the options The parent oil decides the line; chemically modified and technical grades usually land under 1518 ## Why one product carries several headings The Combined Nomenclature was written for products, not for waste streams climbing the value chain, so the border question is almost never "what is it" but "what has been done to it and what will it be used for". Three switches do most of the work in our markets. * Waste or product. The same liquid can be a waste under the shipment rules and a product for customs purposes, or the reverse, and neither answer implies the other. The waste status follows the Waste Shipment Regulation and the member state's end-of-waste practice; the tariff follows the CN text. Settle both separately. * Processing level. Crude versus refined decides UCO's two realistic headings and glycerine's two, and processing into pellets moves waste plastics out of 3915 entirely. * Intended use. Blending into mineral fuel pulls a product into the 2710 family even when the chemistry says otherwise, which is precisely the trap with pyrolysis oil destined for refinery upgrading. ## The Binding Tariff Information, and when it is worth one A Binding Tariff Information (BTI) is a written classification issued by one member state's customs authority that binds all EU customs authorities for three years. It costs a modest fee, takes weeks to months, and is applied for through the European BTI e-service. For a one-off parcel it is rarely worth the wait; for a term supply line that will cross the same border monthly, it is the cheapest insurance in the file, because a reclassification after arrival touches duty, import VAT and often excise or energy taxation in one stroke. Two practical notes from experience. The BTI binds the classification, not the product: change the process or the specification materially and the ruling stops applying. And a ruling obtained in one member state is valid across the EU, but it is still issued under national practice, so argue the file carefully before submitting. ## Sources * TARIC database, the European Commission tariff database: https://ec.europa.eu/taxation_customs/dds2/taric/taric_consultation.jsp * European BTI e-service, for binding tariff information applications: https://ec.europa.eu/taxation_customs/dds2/ebti/ebti_consultation.jsp * Regulation (EU) 2024/1157 on shipments of waste, on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1157/oj ## Frequently asked questions Q: We ship the same product every month. Do we need a new BTI each time? A: No, that is the point of one: a Binding Tariff Information is valid for three years across all EU customs authorities, so one ruling covers the whole term flow. What ends the validity is a material change in the product or the process that produced it, so if you change feedstock, process or specification, have the ruling checked before relying on it. Q: Why does the same product move under different CN codes? A: Because classification follows processing level, intended use and waste or product status, not the trade name. Refined UCO is a processed fat, unprocessed UCO is in many member states an industrial fatty substance, and the two carry different headings and different treatment at the border. Q: Which CN code applies to used cooking oil? A: In practice two: 3823 80 99 as an industrial fatty substance and 1518 00 99 as a processed fat or oil. Member states lean differently and practice shifts, so the working answer is: ask the destination authority or cover the flow with a BTI before fixing a term contract. Q: Which heading does biodiesel move under? A: Neat FAME, whatever the feedstock, is commonly classified under 3824 99 92. Blends that contain mineral oil fall under the 2710 19 family instead, which surprises people moving B30 and similar blendstocks. Q: Is there a dedicated CN code for pyrolysis oil? A: No. Depending on origin, aromatic content and intended use, cargoes have moved under 2707, 2710, 2713 and 3824, and one UK advance tariff ruling placed heavy plastic-derived pyrolysis oil under 2710 19 71. Agree the classification with your customs agent in advance; reclassification after arrival moves duty, excise and energy taxation together. Q: Does an ISCC certificate change the customs classification? A: No. Certification says something about sustainability characteristics and chain of custody, not about the tariff. A certified and a non-certified tonne of the same product carry the same heading, and the certificate value lives in the market claim instead. Q: What is a Binding Tariff Information and is it worth one? A: A written, EU-wide binding classification from a customs authority, valid three years. Worth it for any term flow that crosses the same border repeatedly; rarely worth it for a one-off parcel. Apply through the European BTI e-service and argue the file carefully, because the ruling binds the classified product, not your trade name. Q: Who decides if customs and the importer disagree? A: The receiving member state's customs authority decides at the border, which is why national practice matters so much in the UCO headings. A BTI takes that discretion away; a phone opinion does not. The TARIC database shows the current lines and measures but settles nothing. Q: Can you help us get the paperwork right before a first shipment? A: That is part of the brokerage. We check the document pack before it reaches a buyer, including the customs side, and we would rather flag a heading question in week one than lose the margin in a reclassification at discharge. See documentation and safety data sheets. ============================================================================== # The Proof of Sustainability, and what has to be on it URL: https://www.sustainablecommodities.eu/markets/proof-of-sustainability A Proof of Sustainability, called a Sustainability Declaration in the ISCC documents, is the per-consignment document that travels with certified material. The certificate proves the company is in the system; the PoS proves this batch is. It has to reflect the product group actually delivered, carry the GHG figure for the fuel, and place the material in the right Annex IX category, because that category decides whether the buyer can count it at all. ## A certificate is not a Proof of Sustainability This is the single most common confusion we see, and it costs people weeks. A supplier sends a scan of their ISCC EU certificate and considers the certification question answered. It is not. The certificate says that an audit took place and that the company holds a scope for certain materials until a certain date. It says nothing about the parcel in front of you. The Proof of Sustainability is issued per delivery. It is what the buyer's compliance desk books against, what an auditor asks for two years later, and what a national authority looks at. Before we take an offer to a buyer we read both, plus the specification and the CoA, and we check that they describe the same material. * The certificate names the certificate holder, the scope, the materials and the validity period. Check it in the public ISCC register rather than against a PDF you were sent, and check that the scope actually covers the material you are being offered. * The Proof of Sustainability is per consignment. It must at minimum reflect the product group of the material physically delivered, and the GHG value of the final fuel has to be stated on it. * They have to agree. A certificate covering used cooking oil and a declaration describing acid oil is not a paperwork detail; it is a different chain, and the buyer cannot book it. ## Every field on the form, and what goes wrong in each one People search for an ISCC PoS template constantly, and what they usually need is not a file to fill in but a list of what the form asks. The blank form is published by ISCC itself and your certification body will give you the current version; what follows is what each field is for, and where we see declarations get rejected. We do not publish a filled in Proof of Sustainability, for the same reason we do not publish a filled in safety data sheet: the document has to be issued by the certified party making the claim, and half the fields below identify that party. A filled in specimen circulating with a real certificate number on it is a problem, not a service. Unique number of the PoS: What it has to say A number that identifies this declaration and nothing else.; Where it goes wrong Reused across consignments. Each delivery gets its own. Date of issuance: What it has to say When the declaration was issued.; Where it goes wrong Issued after the material moved, which invites the question of what the buyer was booking in the meantime. Supplier: name, address, certificate number: What it has to say The certified party making the claim, with its EU-ISCC-Cert number.; Where it goes wrong A trading entity named as supplier while the certificate sits with a different legal entity in the group. Recipient: name and address: What it has to say Who the material is being declared to.; Where it goes wrong Left as the agent or the broker. It has to be the party taking the material into their mass balance. Address of dispatch or shipping point: What it has to say Where the sustainable material physically leaves from.; Where it goes wrong Set to "same as supplier" when the material actually ships from a third party terminal. Date of dispatch: What it has to say When the material moved.; Where it goes wrong Missing, which makes the consignment impossible to place in a period. Type of product: What it has to say The product group as delivered, for example HVO or FAME.; Where it goes wrong The product group of what was sold rather than what physically moved. Type of raw material: What it has to say The feedstock, for example used cooking oil.; Where it goes wrong Vague wording such as "waste oil" that does not map onto an Annex IX entry. Country of origin of the raw material: What it has to say Where the feedstock was collected or grown.; Where it goes wrong The country of the last trader rather than of collection. Quantity, in metric tons or cubic metres: What it has to say The quantity being declared, with the unit ticked.; Where it goes wrong Unit not ticked. Tonnes and cubic metres are not the same number. Energy content in MJ: What it has to say The energy behind the quantity.; Where it goes wrong Left blank. The buyer needs it because quota accounting runs on energy, not on weight. EU RED compliant, and ISCC compliant: What it has to say Two separate claims, ticked separately.; Where it goes wrong Treated as one. They mean different things: see the footnotes on the form itself. Waste or residue under the RED: What it has to say Whether the raw material meets the definition.; Where it goes wrong Ticked yes without the collection chain behind it being certified. GHG emission information: What it has to say Either the total default value, or the calculated figure broken out.; Where it goes wrong A single number with no breakdown, on a chain where no default value applies. GHG emission saving, as a percentage: What it has to say Calculated against the fossil comparator for the intended use.; Where it goes wrong A saving quoted against the wrong comparator: see the next section. Chain of custody option: What it has to say Voluntary field, but buyers read it.; Where it goes wrong Left blank when the buyer specifically needs mass balance stated. The form is valid without a signature. By issuing it, the issuing party guarantees that everything on it is correct and that the material has not already been used to meet a national quota obligation. That last clause is the one that makes double counting a declaration offence rather than an administrative slip. ## How the GHG saving is actually calculated The percentage on a declaration is not an opinion and it is not negotiable. It comes out of a formula set in the Directive, measured against a fixed fossil comparator that depends on what the fuel is used for. The emissions total is built up term by term: * E = Eec + El + Ep + Etd + Eu, minus Esca, minus Eccs, minus Eccr, in grams of CO2 equivalent per megajoule. * Eec is extraction or cultivation of the raw material. For genuine waste and residues this is zero, which is the single largest reason waste based material carries a high saving. * El is annualised emissions from carbon stock change due to land use change, spread over 20 years. * Ep is processing. On a waste based chain this is usually the biggest term on the sheet. * Etd is transport and distribution, including downstream distribution up to and including the filling station. * Eu is emissions from the fuel in use. For bioliquids and biomass fuels the non-CO2 gases, N2O and CH4, have to be included here. * Esca, Eccs and Eccr are subtracted: soil carbon accumulation through improved agricultural management, carbon capture and geological storage, and carbon capture and replacement. The saving is then (EF minus EB) divided by EF, where EB is the total for your fuel and EF is the fossil comparator. Which comparator applies depends entirely on the end use, and that is where a saving gets quoted wrongly. ## Which fossil comparator applies, and why it changes the percentage EF is not one number. It is set per end use, and the same cargo therefore has more than one correct saving figure. Biofuels for transport: 94 gCO2eq/MJ Bioliquids used for electricity: 183 gCO2eq/MJ Biomass fuels used for electricity: 183 gCO2eq/MJ Biomass fuels used for electricity, outermost regions: 212 gCO2eq/MJ Bioliquids for useful heat, or heating and cooling: 80 gCO2eq/MJ Biomass fuels for useful heat, or heating and cooling: 80 gCO2eq/MJ Biomass fuels for useful heat, where direct physical substitution of coal can be demonstrated: 124 gCO2eq/MJ Two practical consequences. First, the same cargo has more than one correct saving figure, because the comparator differs by end use, and a declaration will normally carry several. A buyer reading the transport line when the material is going to heat is comparing the wrong pair of numbers. Second, a saving above the threshold is not the same as a saving that will be accepted: the calculation has to hold up against the chain behind it, and the certification body is entitled to ask for the workings. For what the thresholds are and how they interact with the Annex IX categories, see RED III quotas and caps and Annex IX feedstocks. ## Part A or Part B decides whether your buyer can book it Annex IX of the Renewable Energy Directive splits eligible waste and residue feedstocks into Part A and Part B. That letter is not a label; it changes what the fuel is worth to the party that has to meet a target, because the two parts sit under different sub-targets and caps in the member states. We have seen offers stall entirely on this. Two products from the same yard, two different chains, and the declaration carried the wrong letter. The buyer's system simply would not accept it. If you are not certain which part your material falls under, settle that before anyone quotes a price, not after. ## Mass balance, and when your own company needs a certificate Certified material moves under mass balance: the certified volume in and the certified volume out have to reconcile over a defined period, per site. That is the mechanism, and it is also the thing an audit tests hardest. The consequence that catches traders out is about their own position in the chain. If production sits outside the EU and the commercial entity sits inside it, that European entity has to be in the chain of custody itself. Either it holds its own certificate as a trader, or it works through a counterpart that is certified. There is no third option where the material is certified but the seller is not part of the chain. ## The Union Database Every transaction of renewable fuel placed on the EU market is logged in the Union Database, and the entry links back to the Proof of Sustainability. In practice this means the document is no longer a piece of paper between two parties: it is the thing the entry is built on. Declarations that were tolerated when they were vague are now a problem for the party that has to make the entry. ## National schemes alongside ISCC ISCC is the scheme most of this trade runs on, but it is not the only one, and some markets ask for their own. Italy's national scheme comes up regularly in our conversations, and it is a fair question whether it can be held alongside ISCC. Poland asks about waste codes before anything else. Whether a second scheme is worth the audit depends entirely on where the volume is going, which is a commercial question rather than a certification one, and it is worth answering before you commit to the audit. ## Where we come in We are a broker, not a certification body and not a consultancy, and we do not issue or verify documents. What we do is read them before they reach a buyer, and say plainly when something will not clear. When the answer is that certification work is genuinely needed, we can put you in touch with ISCC consultants and auditors we have worked with, and with laboratories for the analysis that usually comes with it. That introduction is not a service we sell; it exists because a supplier who cannot produce a clean PoS is a supplier we cannot place. ## Sources * ISCC EU 203, Traceability and Chain of Custody: https://www.iscc-system.org/wp-content/uploads/2024/01/ISCC_EU_203_Traceability_and_Chain-of-Custody_v4.1_January2024-1.pdf * ISCC list of materials eligible for ISCC EU certification: https://www.iscc-system.org/wp-content/uploads/2026/02/ISCC_EU_material_list_260206.pdf * Directive (EU) 2023/2413 (RED III), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * ISCC public certificate register: https://www.iscc-system.org/certificates/all-certificates/ ## Frequently asked questions Q: What exactly is a Proof of Sustainability? A: It is the per-consignment document that travels with certified material, called a Sustainability Declaration in the ISCC documentation. It must reflect the product group of the material physically delivered and state the GHG value of the final fuel. The market says PoS; the scheme documents say Sustainability Declaration; they are the same thing. Q: What is the difference between a Proof of Sustainability and a certificate? A: The certificate is about the company: it was audited, it holds a scope for certain materials, and it is valid until a date. The PoS is about the consignment: this batch, this volume, this feedstock, this GHG figure. A buyer needs both, and rejects far more often on the PoS than on the certificate. Q: What has to be on an ISCC EU delivery note? A: At minimum it has to reflect the product group of what was physically delivered, and the GHG value of the final fuel has to be stated. The full requirements are set out in ISCC EU 203, Traceability and Chain of Custody, which is public. If a buyer has queried a declaration you hold, send it to us and we will read it against what they have to book. Q: Does the GHG figure have to be on the document? A: Yes. The GHG value of the final fuel must be stated in the proof of sustainability. If a supplier offers certified material without a GHG figure, that is not a formality they forgot; the buyer cannot complete their side without it. Q: What is the biogenic percentage, and where does it come from? A: For co-processed and mixed streams the question is what share of the output counts as renewable, and it follows from the mass balance rather than from a measurement on the finished product. It is set out per consignment. Ask for it in writing at offer stage, because it changes the value of the parcel and is not something you can establish afterwards. Q: What are the voluntary add-ons on a declaration? A: ISCC offers optional add-ons that a certificate holder can be audited against and that are then reflected in the documentation. Buyers with their own reporting commitments sometimes require one. Whether a given add-on is on the declaration is a question to settle before contracting, not at loading. Q: Do I need to be certified to buy, or only to sell? A: If you take title to certified material and pass it on as certified, you are in the chain of custody and you need to be certified, or work through a counterpart that is. This catches out European trading entities buying from a certified producer outside the EU: the production being certified does not put the trader in the chain. Q: Can Annex IX Part A material be sold as Part B, or the other way round? A: No. The letter follows the feedstock, and the declaration has to carry the right one. They are two different products with two different chains, and if the letter is wrong the buyer's system will not accept it. Settle the category before you quote. Q: What does the Union Database change for me? A: Every transaction of renewable fuel placed on the EU market is logged there and the entry links back to the PoS. The practical effect is that the declaration has to stand on its own, because someone downstream has to make an entry from it. Q: Can I hold a national scheme alongside ISCC? A: It comes up most often for the Italian national scheme, and the answer depends on where your volume is going. The question worth asking first is commercial rather than technical: does the buyer you want actually require it? A second audit is real money, and it is worth knowing whether it opens a market before you commit. Q: My supplier's certificate is recent. Is that a problem? A: Not in itself. Plenty of legitimate producers certified recently, particularly in pyrolysis oil where the material only became eligible relatively lately. What matters is that the certificate is valid in the public register today, that the scope covers the material offered, and that the declarations are consistent with it. Q: Can you help us get certified? A: We do not certify anyone and we are not a consultancy. When certification work is genuinely needed we can introduce you to ISCC consultants and auditors we have worked with, and to laboratories for the analysis that goes with it. We do that because material we cannot document is material we cannot place. ============================================================================== # Certified and non certified material, and what sits between them URL: https://www.sustainablecommodities.eu/markets/certified-and-non-certified Certified and non certified material are not the same product at two prices; they are two products with different buyers. Certification exists because fuel suppliers have obligations they can only meet with documented material, so the difference reflects what a buyer can do with it rather than any quality difference. Non certified material is not worthless: it has its own outlets, and for some of them the certification would add nothing. ## The difference is about what the buyer can count, not about quality Two parcels of used cooking oil can be chemically indistinguishable and still trade far apart. That is not a quality judgement. A fuel supplier with an obligation under the Renewable Energy Directive can only meet it with material that carries documentation back through the chain. Without that, the litre does not count towards anything, whatever it burns like. So the question to ask about an offer is not whether the oil is good. It is which buyer can use it, and what that buyer is able to do with it once it arrives. ## What moves the difference The gap is not a fixed number and does not move for one reason. These are the factors we see behind it in practice, and they are worth checking one by one before you compare two offers: * Which Annex IX category the material falls in. Part A and Part B sit under different sub-targets and caps, so the same certification can be worth materially different amounts depending on the letter. * Which member state the volume lands in. National implementation of the targets differs, and so does what a supplier there is short of. * Which scheme. ISCC EU is what most of this trade runs on, but some markets ask for a national scheme, and holding the wrong one is close to holding none for that buyer. * Whether the chain is complete. A certified producer does not make a certified chain. If a link in the middle is not in the system, the material arrives as non certified regardless of where it started. * Where the material is in its own cycle. Feedstocks that only became eligible recently behave differently from ones that have traded for a decade. ## Non certified material has its own market It is worth saying plainly, because sellers sometimes assume the opposite: material without certification is not stranded. Oleochemical, technical and industrial outlets buy on specification and do not need a sustainability chain, and for a buyer outside the fuel obligation the certification adds cost without adding use. We place both. What we will not do is take an uncertified parcel to a buyer whose whole reason for buying is the obligation, because that wastes everyone's week. ## How to compare two offers that are not on the same basis Most of the confusion we are asked to sort out comes from comparing offers that are not comparable. Before you put two numbers side by side, make sure you have the same five things for both: * The scheme, in full, and whether the seller is themselves in the chain. * The Annex IX category, and evidence for it rather than an assertion. * The GHG figure, because it is part of what the buyer books. * The incoterm and load port, since the basis moves the number more than people expect. * A recent certificate of analysis, so that you know the two parcels are the same material before you argue about the difference. ## Why we do not quote a number here We are asked for the current difference regularly and we do not publish one. Price levels are discussed with counterparties directly, against the actual feedstock, origin, volume and destination, because a figure quoted without those is not information, it is noise. Argus and the other assessment services exist for published levels, and buyers who need a reference use them. What we will do, on a specific parcel, is tell you which of the two routes is realistic and what would have to change for the other one to open. ## Sources * Directive (EU) 2023/2413 (RED III), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * ISCC list of materials eligible for ISCC EU certification: https://www.iscc-system.org/wp-content/uploads/2026/02/ISCC_EU_material_list_260206.pdf ## Frequently asked questions Q: What is the price difference between certified and non certified material? A: There is no single figure, and we do not publish price assessments. The difference depends on the Annex IX category, the destination member state, the scheme, and whether the chain is complete end to end. On a specific parcel, with feedstock, origin and volume, we can tell you which route is realistic. Q: Is non certified material harder to sell? A: Not harder, different. Oleochemical, technical and industrial buyers purchase on specification and do not need a sustainability chain. What does not work is offering uncertified material to a buyer whose reason for buying is a fuel obligation. Q: Will it be certified or non certified? A: This is the first question to settle on any enquiry, and it is worth asking it before specification. The answer decides which buyers exist for the parcel, and everything downstream follows from it. Q: My producer is certified, so my cargo is certified. Is that right? A: Only if every link between them and the buyer is in the chain of custody. A certified producer selling through an entity that is not certified delivers uncertified material. This is the most expensive misunderstanding in this trade. Q: Does certification improve the quality of the oil? A: No. It documents origin and sustainability, not specification. A certified parcel can still fail on chlorine or free fatty acid, and an uncertified one can be clean. The certificate of analysis answers the quality question; the declaration answers a different one. Q: Is it worth getting certified for the volume I have? A: That is an arithmetic question, not a principle: audit and scheme costs against the volume you can actually place, and whether the buyers you want require it at all. If you want to work through it we can tell you what the buyers in your market ask for, and introduce you to consultants and auditors if the answer is yes. ============================================================================== # Sampling, laboratories and the certificate of analysis URL: https://www.sustainablecommodities.eu/markets/sampling-and-laboratories A certificate of analysis is only worth what the sampling behind it is worth. The sample has to be representative of a well mixed batch that nothing is added to afterwards, the laboratory has to be able to run every method in the scope in house, and the methods themselves have to be the ones the buyer screens on. Get those three right and one analysis can cover a whole shore tank batch, which is also how the cost per tonne comes down. ## The sample decides everything after it A sample drawn from a well mixed shore tank, where the batch is closed and no further material is added after the sample is taken, can be treated as representative of that batch. That is the condition, and it is worth stating in writing rather than assuming, because it is what allows one certificate of analysis to cover everything loaded out of that tank. The practical consequence is money. If four isotanks are filled from one shore tank batch, they can move on the same CoA. Producers running six small tanks of thirty cubic metres each cannot spread the cost of an external batch analysis over enough volume, and it shows up in their offer. This is a real constraint on small producers, and it is often the reason a first parcel prices badly. ## The laboratory has to be able to run the whole scope The certificate needs to come from a laboratory that can perform every test in the agreed scope, with the applicable method modifications, in house. A laboratory that subcontracts half the parameters produces a report that takes longer, costs more and is harder to defend when a result is questioned. Ask for written confirmation that the full scope runs in house before the first sample is sent. We do this routinely for parcels we are placing, and it has saved more than one qualification round. ## Methods matter as much as numbers A parameter without its method is not a specification. The same property reported by two different methods can produce numbers that are not comparable and a discussion that goes nowhere. Three that come up constantly in pyrolysis oil: * Halogens. It helps a great deal if chlorine is run as total halogens by ASTM D7359, with chlorine and bromine reported separately. A single combined figure hides which of the two you are dealing with, and they are not the same problem. * Metals. Usually ASTM D5185, frequently with a modification for this matrix. If a specification sheet gives a modification note, check that the note and the parameter table name the same method; we have found them disagreeing. * Distillation cuts. Some parameters, total oxygenates and benzene among them, call for an ASTM D1160 distillation followed by analysis on a specific cut. That is two operations, and a laboratory quoting only the second has not quoted the job. ## Qualification, then routine The scope at qualification and the scope per batch are usually not the same, and this is worth agreeing before anyone starts spending money. The questions to settle with the buyer are simple and rarely asked early enough: * Do they expect a certificate of analysis on every batch covering the full parameter list, or a reduced routine set per batch with the full list at qualification and then at intervals? * Is one analysis per shore tank acceptable, or do they want it per production batch? * What batch size is workable as a starting point while a producer builds up? * Who pays for what, and at whose cost the assessment tests are run. ## Timing is part of the specification Analysis takes days. Production, sampling, testing and loading all have to be synchronised around one batch, and a producer who has not planned for that discovers it at the worst moment. When we set up a first movement we work the timing backwards from the loading window, not forwards from production. ## Where we come in We can put you in touch with laboratories and inspection companies for the analysis itself, including in the origin country, and we regularly obtain quotations on a producer's behalf so that the method list goes out complete rather than in pieces. Where a specification is covered by an NDA we pass on the test methods and modification notes only, without categories or specification values, so a laboratory can quote without seeing anything it should not. We are a broker. We do not run tests, we do not issue certificates, and we do not stand behind a laboratory's result. What we do is make sure the right questions are asked before money is spent, and read the report against what the buyer will actually do with it. ## Sources * ASTM D7359, total halogens by combustion ion chromatography: https://www.astm.org/d7359-18.html * ASTM D5185, metals by ICP atomic emission spectrometry: https://www.astm.org/d5185-18.html * ASTM D1160, distillation of petroleum products at reduced pressure: https://www.astm.org/d1160-18.html ## Frequently asked questions Q: What makes a sample representative? A: It has to come from a well mixed shore tank that is then batched, with no further material added to the batch after the sample is drawn. Under that condition the analysis can be treated as covering the whole batch, including every isotank loaded out of it. State the condition in writing; do not assume it. Q: Can one certificate of analysis cover several isotanks? A: Yes, if they are all loaded from the same closed shore tank batch that the sample represents. That is also how the cost of testing comes down per tonne, which matters a great deal to smaller producers. Q: Which laboratory should we use? A: One that can run every method in the agreed scope in house, including the modifications. Ask for written confirmation of that before the first sample is sent. We can introduce you to laboratories and inspection companies, including in the origin country, and we often obtain the quotation on the producer's behalf. Q: How should chlorine be reported? A: It helps considerably if it is run as total halogens by ASTM D7359, with chlorine and bromine reported separately. A single combined halogen figure leaves the buyer unable to tell which of the two they are dealing with, and they are different problems with different consequences downstream. Q: Do we need a full analysis on every batch? A: That is a question for the buyer and it should be settled at qualification. Some ask for the full parameter list on every batch; others accept a reduced routine set per batch with the full list at qualification and then at intervals. The answer changes the cost per tonne significantly. Q: How long does the analysis take, and does that matter? A: Days rather than hours, and yes. Production, sampling, testing and loading have to be synchronised around a single batch. Work the timing backwards from the loading window; producers who plan forwards from production tend to discover the problem when a vessel is waiting. Q: Our specification is under an NDA. Can a laboratory still quote? A: Yes. A laboratory needs the test methods and any modification notes to price the work. It does not need the categories or the specification values. We pass on the methods only, so a quotation can be obtained without disclosing anything covered by the agreement. Q: Who pays for the analysis? A: It varies, and it should be agreed before samples move. Assessment tests run to establish whether a laboratory can do the work are commonly at the seller's cost. For the trade itself, inspection at the load port is frequently split, but that is a term to negotiate rather than a rule. Q: The specification sheet contradicts itself on a method. What now? A: Ask, before anyone spends money. We have found parameter tables and modification notes naming different methods for the same property. It is almost always a typographical error rather than a disagreement, but a laboratory quoting against the wrong one produces a report the buyer will not accept. ============================================================================== # Who buys used cooking oil in Europe URL: https://www.sustainablecommodities.eu/markets/who-buys-used-cooking-oil-in-europe Used cooking oil in Europe goes to four kinds of buyer: HVO and renewable diesel refiners, SAF producers running the HEFA route, biodiesel plants making FAME, and integrated collectors who both gather and process. A fourth, smaller outlet is oleochemical and technical use, which does not need a sustainability chain at all. Neste, the largest single buyer, states that waste and residues are around 90% of its global raw material input and that used cooking oil is one of its top three waste categories. ## The renewable diesel refiners Read this first: this is a market map built from public sources, not a client list. Naming a company here says nothing about whether we work with them, and we do not claim to represent any of them. It exists because "who actually buys this" is the question we are asked most often, and there is no honest public answer to it anywhere. The largest buyers of UCO in Europe are the companies hydrotreating it into renewable diesel. Neste operates renewable refineries in Porvoo, Rotterdam and Singapore alongside a joint operation in California, and publishes that waste and residues account for roughly 90% of its total renewable raw material input globally, with used cooking oil among its top three waste categories. Eni produces biofuel in Italy from what it describes as primarily waste and residues. Preem in Sweden, Repsol in Spain and TotalEnergies in France all run or are expanding renewable capacity. What they screen on is consistency more than headline quality. A refiner sizing a pretreatment unit needs to know what arrives every month, not what the best parcel looked like. Free fatty acid, moisture and impurities, polyethylene content and the metals that poison a catalyst are the numbers that decide whether a cargo is workable. ## The SAF route, which is the same chemistry with a different buyer Aviation fuel made from UCO uses the HEFA pathway, and in Europe the overwhelming majority of SAF is produced that way. EU mandates under ReFuelEU have been in force since 2025, and European HEFA capacity is being added through the 2026 to 2027 window to meet them. For a seller this matters in one specific way: SAF buyers are competing for the same molecules as the renewable diesel refiners, from a feedstock pool that does not grow as quickly as the mandates do. Several analysts have written about a HEFA ceiling for exactly this reason. It is the clearest structural argument for why a reliable, documented UCO supply is worth having a relationship over rather than selling spot to whoever calls. ## The biodiesel producers FAME plants take UCO to produce UCOME, and they remain the deepest outlet by number of buyers even as the hydrotreating capacity grows. Greenergy describes itself as a leading European manufacturer of biodiesel from waste and states that it sources used cooking oil globally. Argent Energy in the UK runs an integrated model, collecting UCO and producing biodiesel from it. Münzer Bioindustrie in Austria is another long-established name in this part of the market. Biodiesel buyers are generally more tolerant of variable quality than a hydrotreater, because esterification handles free fatty acid differently. That tolerance is worth understanding: a parcel that a refiner turns down on FFA can be perfectly placeable with a FAME producer. ## The integrated collectors, who are buyers and competitors at once A group of companies both collect UCO from kitchens and process it, which makes them a buyer for volume they cannot gather themselves and a competitor for the volume they can. Olleco in the UK is the largest, and market reporting puts its processed volume in the region of 1.9 million tonnes in 2023; it now operates a joint venture with Bunge serving food service and food manufacturing customers across Europe. Saria's group companies gather and process across several countries. For a collector in an origin country these are often the most realistic first counterparty, because they understand aggregated supply and are less likely to demand a full refinery specification on a first parcel. ## The outlet people forget: oleochemical and technical Not every buyer needs a sustainability chain. Oleochemical and technical users buy on specification, and for them certification adds cost without adding use. This is the route for material that cannot be certified, or where the chain has a gap that cannot be closed retrospectively. It is worth knowing this exists before you conclude that an uncertified parcel is stranded. It is not; it is simply in a different market. ## How to approach any of them The mistake we see most often is a first email that leads with volume and price and nothing else. Every buyer in every one of these groups will ask the same questions, so answer them first: * Certification, in full. Which scheme, whether you are in the chain of custody yourself, and whether the declaration will carry the right Annex IX category. See Proof of Sustainability. * A recent analysis, with the methods named. Free fatty acid, moisture and impurities, and the sampling basis behind them. * Volume per month, and for how long. A refiner is sizing a relationship, not buying a parcel. One cargo with no follow-up is a different conversation. * Origin and the route it takes. Buyers care where it comes from, and increasingly they have to. * How long you can hold a quote. This one is almost never volunteered and it decides whether the buyer can act on it at all. ## A note on accuracy Everything above is drawn from what companies have published about their own operations, from trade association material and from price reporting agencies. Capacity gets delayed, projects get cancelled and feedstock slates change with the spread, so treat this as a map of the landscape rather than a live position. Where a name appears, it is because that company has said publicly what it does, not because we have any relationship with them. If something here is out of date or wrong, tell us and we will correct it. We would rather be corrected than repeat something that costs someone a week. ## Sources * Neste, renewable raw materials in its portfolio: https://www.neste.com/products-and-innovation/raw-materials/renewable-raw-materials * Neste, production sites: https://www.neste.com/about-neste/how-we-operate/production * Eni, biofuel production in Italy: https://www.eni.com/en-IT/actions/energy-transition-technologies/biofuels.html * Greenergy, biofuels from waste: https://www.greenergy.com/biofuels * Olleco Bunge, the joint venture: https://ollecobunge.com/ * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj ## Frequently asked questions Q: Who is the biggest buyer of used cooking oil in Europe? A: By volume, the renewable diesel refiners, with Neste the largest single buyer. It publishes that waste and residues are around 90% of its global raw material input and that used cooking oil is one of its top three waste categories, refining at Porvoo, Rotterdam and Singapore. That said, the biggest buyer is rarely the right first call for a new supplier. Q: Can I sell UCO directly to a refinery? A: Sometimes, but a refiner buying a first parcel from an unknown counterparty is unusual. They are sizing a supply relationship and will want consistency, documentation and a qualification process. Integrated collectors and biodiesel producers are generally a more realistic first counterparty, and several of them supply the refiners in turn. Q: What specification do UCO buyers screen on? A: Free fatty acid, moisture and impurities first, then polyethylene content and catalyst-poisoning metals for anyone hydrotreating. A FAME producer tolerates higher FFA than a hydrotreater does, which is why the same parcel can be rejected by one and accepted by the other. Q: Do I need ISCC to sell UCO in Europe? A: To sell into the fuel obligation, yes, and the whole chain has to be certified, not only the producer. Without it you are selling into the oleochemical and technical market instead, which is real but pays for something else. See certified and non certified. Q: Why do SAF producers and diesel refiners compete for the same oil? A: Because they use the same chemistry. Almost all SAF made in Europe today comes through the HEFA route, which takes the same lipid feedstocks as renewable diesel. Mandates under ReFuelEU raise demand faster than the collected volume grows, which is what the analysts calling it a HEFA ceiling are pointing at. Q: Is UCO from outside Europe accepted? A: Yes, and a large share of European supply is imported. What matters is that the certification chain holds across the border and that the documentation supports the Annex IX category being claimed. Scrutiny on imported UCO has increased, so expect questions about origin and be able to answer them. Q: What volume do I need before a buyer takes me seriously? A: Less than people assume for a collector, more than people assume for a one-off. What matters is monthly consistency rather than a single large parcel. A steady few hundred tonnes a month with clean paperwork is a better conversation than one opportunistic cargo. ============================================================================== # Who buys POME oil in Europe URL: https://www.sustainablecommodities.eu/markets/who-buys-pome-in-europe POME oil goes to the same European hydrotreaters and biodiesel producers that buy used cooking oil, and it competes for the same processing slots. What makes it a different trade is the classification: POME oil sits on the Annex IX Part A list, which is where its value comes from, and that is exactly why the documentation behind it is scrutinised more heavily than for almost any other feedstock. ## The buyers are the refiners, and the route is the same as UCO Read this first: this is a market map built from public sources, not a client list. Naming a company here says nothing about whether we work with them, and we do not claim to represent any of them. It exists because "who actually buys this" is the question we are asked most often, and there is no honest public answer to it anywhere. POME oil is hydrotreated into renewable diesel and jet, which means the buyer list overlaps almost entirely with used cooking oil. Neste states that wastes and residues from vegetable oil processing are among its top three waste and residue categories, alongside used cooking oil and animal fat waste. Eni's Italian biofuel production runs primarily on waste and residues. The renewable capacity in Spain, Sweden and France takes lipid feedstocks of this type. The practical consequence is that POME is not competing with palm oil for a buyer; it is competing with UCO and animal fat for a pretreatment slot. That is the frame to hold when you think about where your parcel sits. ## Annex IX Part A is where the value is, and where the scrutiny is POME oil is included on the Annex IX Part A feedstock list, and that letter is the whole commercial argument. Part A material sits under a different sub-target than Part B, which is why a buyer can pay differently for it. It is also why nothing gets looked at harder. Import volumes of POME-based biofuel into the EU have been discussed at Energy Council level, and the regulatory position has been described by price reporting agencies as a source of uncertainty in the trade. If you are offering POME oil, expect the certification and traceability to be examined line by line, and treat that as normal rather than as distrust of you specifically. ## POME oil, SBEO and SSAO are not the same thing Three products travel under names that get used loosely, and mixing them up in an offer is the fastest way to lose credibility with a buyer who knows the difference. The distinction is set out in full on our POME page, but in short: POME oil is recovered from mill effluent, spent bleaching earth oil is recovered from the clay used in refining, and soapstock acid oil comes from the splitting of soapstock. They have different chains, different classifications and different buyers. ## There is now a published price reference Fastmarkets launched a crude palm oil mill effluent assessment on a CIF Amsterdam-Rotterdam-Antwerp basis in 2026. That matters for a seller in a practical way: buyers increasingly quote against a published reference rather than negotiating a flat number, and an offer that ignores the reference reads as uninformed. We do not publish price assessments ourselves and we do not quote levels on this site. ## What a European buyer will ask you * Which mills, and whether the chain from mill to vessel is certified end to end. A certified aggregator buying from uncertified mills does not produce certified material. * The classification, with evidence rather than assertion. * A recent analysis, with sampling basis and methods named. * Monthly volume and duration. POME buyers are sizing a slot, not a cargo. * Whether you can hold a quote, and for how long, against a moving reference. ## A note on accuracy Everything above is drawn from what companies have published about their own operations, from trade association material and from price reporting agencies. Capacity gets delayed, projects get cancelled and feedstock slates change with the spread, so treat this as a map of the landscape rather than a live position. Where a name appears, it is because that company has said publicly what it does, not because we have any relationship with them. If something here is out of date or wrong, tell us and we will correct it. We would rather be corrected than repeat something that costs someone a week. ## Sources * Neste, renewable raw materials in its portfolio: https://www.neste.com/products-and-innovation/raw-materials/renewable-raw-materials * ISCC list of materials eligible for ISCC EU certification: https://www.iscc-system.org/wp-content/uploads/2026/02/ISCC_EU_material_list_260206.pdf * Directive (EU) 2023/2413 (RED III), Annex IX, on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * Fastmarkets, crude palm oil mill effluent CIF ARA assessment: https://www.fastmarkets.com/insights/fastmarkets-launches-crude-palm-oil-mill-effluent-cif-amsterdam-rotterdam-antwerp-tonne-on-thursday-april-30/ ## Frequently asked questions Q: Who buys POME oil in Europe? A: The same hydrotreaters and biodiesel producers that buy used cooking oil. Neste lists wastes and residues from vegetable oil processing among its top three waste categories; Eni's Italian biofuel production runs primarily on waste and residues; renewable capacity in Spain, Sweden and France takes the same lipid feedstocks. Q: Is POME oil Annex IX Part A? A: Yes, POME oil is included on the Part A list, and that classification is where its value comes from. It is also the reason the documentation gets examined more closely than for most other feedstocks. Q: Why is POME scrutinised more than other feedstocks? A: Because the volume of POME-based biofuel imported into the EU grew quickly and has been discussed at Energy Council level, and because Part A status makes it worth misdeclaring. Expect the certification chain to be checked thoroughly. If your chain is clean this is an advantage, not a problem. Q: What is the difference between POME oil, SBEO and SSAO? A: Different origins in the palm chain: POME oil from mill effluent, spent bleaching earth oil from the clay used in refining, and soapstock acid oil from splitting soapstock. Different classifications and different buyers. Our POME page sets the three out in full. Q: Is there a price reference for POME? A: Fastmarkets launched a crude POME assessment on a CIF ARA basis in 2026. We do not publish price assessments and do not quote levels here; buyers who need a reference subscribe to one. Q: Can I sell POME oil without certification? A: Into the fuel obligation, no. Without a complete certified chain the material is not usable for the purpose that gives it its value, and the Part A argument disappears entirely. ============================================================================== # Who buys animal fat and tallow in Europe URL: https://www.sustainablecommodities.eu/markets/who-buys-animal-fat-in-europe Animal fat in Europe is bought by biodiesel and HVO producers, by SAF plants on the HEFA route, by oleochemical manufacturers, and by the feed and pet food industry. Which of them can buy from you is decided first by the category. Category 1 and 2 go to fuel and technical uses only; category 3 is the contested one, because all four industries can use it and they are actively bidding against each other. ## Category decides the buyer list before anything else Read this first: this is a market map built from public sources, not a client list. Naming a company here says nothing about whether we work with them, and we do not claim to represent any of them. It exists because "who actually buys this" is the question we are asked most often, and there is no honest public answer to it anywhere. The animal by-product categories are not a quality grading, and treating them as one is the most common error we see. They determine what the material may lawfully be used for, and therefore who is allowed to buy it. Category 1 is not banned from the market; it is restricted to specific outlets, and there is a real trade in it. Category 3 is the one every industry wants. Our animal fats and tallow page sets out what each category looks like in practice. This page is about who is at the other end. ## The renderers, who are the source and often the seller Rendering is a concentrated industry in Europe and is represented by EFPRA, the European Fat Processors and Renderers Association. The larger groups process across several countries: Saria's companies describe supplying rendered fats into fuel applications, and Leo Group in the UK publishes that its tallow is produced from category 3 material. For a slaughterhouse or a smaller processor, the renderer is usually the first counterparty rather than the end buyer. For a trader, the renderers are the supply side of the market. ## Fuel: biodiesel, HVO and increasingly SAF Animal fat is a long-established biodiesel feedstock and the volume going that way has grown substantially over the past decade. Neste names animal fat waste as one of its top three waste and residue categories globally, alongside used cooking oil and residues from vegetable oil processing. Aviation has now entered the same queue. Almost all SAF produced in Europe today comes through the HEFA route, which takes exactly these lipids, and the trade press has written about category 3 fat being pulled between fuelling aircraft and feeding animals. That competition is the single most important commercial fact about this product right now. ## Oleochemicals, which pay for something else entirely Oleochemical manufacturers convert fats into fatty acids, glycerine, soaps and derivatives. KLK OLEO runs four companies and seven production sites in Europe; IOI Oleo is headquartered in Hamburg with production at Witten and Wittenberge. These buyers screen on specification and colour rather than on sustainability chain, and for them certification adds cost without adding use. This is the outlet to remember when a parcel cannot be certified. It is not a fallback of last resort; for some material it is the better market. ## Feed and pet food, and the fraud problem that follows Category 3 fat is a feed and pet food raw material, and that industry has been vocal about losing volume to fuel. Where two industries bid for the same material at different prices, misdeclaration follows: APAG, the European oleochemical industry association, has published on the distortion and the fraud risk around blending of category 3 fats. For an honest seller this is worth knowing because it explains the questions you will get. A buyer asking hard questions about category and traceability is not doubting you personally; they are managing a known risk in their own supply chain. ## What every one of them will ask * Category, with the paperwork behind it. This is the first question and there is no answering around it. * Free fatty acid, and the trend of it rather than one number. * Certification, if the material is going into fuel: which scheme, and whether the chain holds. * Monthly tonnage and consistency. Rendering output is steady, which is an advantage worth stating explicitly. * Storage and handling, since these are solid or semi-solid at ambient temperature and the logistics are part of the price. ## A note on accuracy Everything above is drawn from what companies have published about their own operations, from trade association material and from price reporting agencies. Capacity gets delayed, projects get cancelled and feedstock slates change with the spread, so treat this as a map of the landscape rather than a live position. Where a name appears, it is because that company has said publicly what it does, not because we have any relationship with them. If something here is out of date or wrong, tell us and we will correct it. We would rather be corrected than repeat something that costs someone a week. ## Sources * EFPRA, the European Fat Processors and Renderers Association: https://efpra.eu/ * EFPRA on rendered fat: https://efpra.eu/rendered-products/rendered-fat/ * APAG on fraud risk in blending of category 3 animal fats: https://www.apag.org/wp-content/uploads/2023/05/Animal_Fats_cat_3__Fraud_Risk_December_2022.pdf * Neste, renewable raw materials in its portfolio: https://www.neste.com/products-and-innovation/raw-materials/renewable-raw-materials * Regulation (EC) No 1069/2009 on animal by-products, on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2009/1069/oj ## Frequently asked questions Q: Who buys animal fat in Europe? A: Four industries: biodiesel and HVO producers, SAF plants on the HEFA route, oleochemical manufacturers, and feed and pet food. Which of them can buy from you depends on the category of the material, not on its quality. Q: Why is category 3 fat so contested? A: Because all four outlets can legally use it, and they value it differently. Fuel demand has grown sharply while feed and pet food need the same material, and the trade press has covered the resulting tension directly. That competition is the main commercial fact about this product today. Q: Can category 1 fat be sold at all? A: Yes. Category 1 is restricted rather than banned, and there is an established trade into fuel and technical outlets. What it cannot do is enter the feed chain. Our animal fats page sets out what each category may be used for. Q: Do I need ISCC to sell tallow? A: For fuel outlets, yes, and the whole chain has to be in the system. For oleochemical and technical buyers, no; they screen on specification and colour. That is a genuine commercial choice rather than a fallback. Q: What does an oleochemical buyer look at that a fuel buyer does not? A: Colour, titre and the fatty acid profile, because those decide what can be made from it. A fuel buyer cares far more about free fatty acid, moisture and impurities and about the sustainability chain. Q: Why do buyers ask so many questions about category and origin? A: Because misdeclaration is a known risk in this market. APAG has published on distortion and fraud risk in the blending of category 3 fats. A buyer with a robust process asks everyone the same questions. ============================================================================== # Who buys acid oils and soapstock in Europe URL: https://www.sustainablecommodities.eu/markets/who-buys-acid-oils-in-europe Acid oils and soapstock go to two markets in Europe. Biodiesel and HVO producers buy them as an advanced feedstock where the classification supports it; oleochemical manufacturers buy them as a raw material for fatty acids and derivatives. Neste names residues from vegetable oil processing among its top three waste and residue categories. The classification question decides which market you are in, and it is worth settling before anyone quotes. ## The fuel market, where classification carries the value Read this first: this is a market map built from public sources, not a client list. Naming a company here says nothing about whether we work with them, and we do not claim to represent any of them. It exists because "who actually buys this" is the question we are asked most often, and there is no honest public answer to it anywhere. Acid oils from vegetable oil refining are used as a biodiesel and hydrotreating feedstock across Europe. Neste states that wastes and residues from vegetable oils processing are among its top three waste and residue categories globally, alongside used cooking oil and animal fat waste. The European FAME producers take acid oils routinely. What decides the value here is not the appearance of the material but where it sits under Annex IX, and the answer depends on the origin oil and the process it came from. That is a question to settle with evidence before you go to market, because two parcels that look identical can be worth very different amounts on the strength of their paperwork alone. ## The oleochemical market, which buys on chemistry Oleochemical manufacturers split acid oils into fatty acids and derivatives. KLK OLEO operates four companies and seven production sites in Europe; IOI Oleo is headquartered in Hamburg with production at Witten and Wittenberge. These buyers look at total fatty matter, the fatty acid profile, colour and impurities. They do not need a sustainability chain, which makes this the natural home for material that cannot be certified or whose classification is contested. Total fatty matter in particular is the number a soap or fatty acid buyer works from, and it is worth having on your offer from the start. ## There is a published reference for soapstock acid oil Fastmarkets launched a soapstock acid oil assessment for the Amsterdam trading hub in 2025. As with POME, this changes how offers read: a seller quoting into a market that has a reference is expected to know it exists. We do not publish price assessments and we do not quote levels here. ## Esterification, and what it changes Acid oils are frequently esterified before sale, which changes the free fatty acid profile and therefore the buyer. Our esterified acid oils page covers what that process does to the product and what it does not fix. The short version for this page: esterification can open the fuel market for material that would otherwise be oleochemical, but it does not resolve a classification problem. ## What both markets will ask * The origin oil. Soy, rape, sunflower, palm: the answer changes the classification and the fatty acid profile at once. * Free fatty acid and total fatty matter, with methods named. * The classification, with evidence. This is the single biggest source of stalled acid oil offers we see. * Certification, if you are aiming at the fuel market. * Consistency. Refinery by-product streams are steady by nature, which is worth saying out loud because it is an advantage. ## A note on accuracy Everything above is drawn from what companies have published about their own operations, from trade association material and from price reporting agencies. Capacity gets delayed, projects get cancelled and feedstock slates change with the spread, so treat this as a map of the landscape rather than a live position. Where a name appears, it is because that company has said publicly what it does, not because we have any relationship with them. If something here is out of date or wrong, tell us and we will correct it. We would rather be corrected than repeat something that costs someone a week. ## Sources * Neste, renewable raw materials in its portfolio: https://www.neste.com/products-and-innovation/raw-materials/renewable-raw-materials * KLK OLEO Europe, production sites: https://klkoleo.eu/ * IOI Oleo, Hamburg, Witten and Wittenberge: https://www.ioioleo.de/en/ * Fastmarkets, soapstock acid oil price launch: https://www.fastmarkets.com/insights/soap-stock-acid-oil-price-launch-frequently-asked-questions/ * Directive (EU) 2023/2413 (RED III), Annex IX, on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj ## Frequently asked questions Q: Who buys acid oils in Europe? A: Two groups. Biodiesel and HVO producers buy them as feedstock where the classification supports it, and oleochemical manufacturers buy them as raw material for fatty acids and derivatives. Neste lists residues from vegetable oil processing among its top three waste and residue categories. Q: What decides whether acid oil is worth more as fuel or as oleochemical feedstock? A: The classification, and after that the free fatty acid and total fatty matter. The fuel market pays for what the material can be counted as; the oleochemical market pays for what can be made from it. They are not comparable on a single number. Q: What is total fatty matter and why does it matter? A: It is the share of the material that is actually fatty matter rather than water, impurities or unsaponifiables, and it is the number a soap or fatty acid buyer works from. Have it on the offer; without it an oleochemical buyer cannot price the parcel. Q: Is soapstock acid oil Annex IX Part A? A: Soapstock from vegetable oil refining is treated as an advanced feedstock, but the position depends on the origin oil and the process, and it has to be evidenced rather than asserted. Settle it before you quote; it is the most common reason an acid oil offer stalls. Q: Does esterification make acid oil more valuable? A: It can open the fuel market for material that would otherwise be oleochemical, by changing the free fatty acid profile. It does not fix a classification problem and it does not fix contamination. Our esterified acid oils page covers what it does and does not change. Q: Is there a price reference for acid oil? A: Fastmarkets launched a soapstock acid oil assessment for Amsterdam in 2025. We do not publish price assessments ourselves and do not quote levels on this site. ============================================================================== # Selling into ARA: Amsterdam, Rotterdam and Antwerp URL: https://www.sustainablecommodities.eu/markets/ara-amsterdam-rotterdam-antwerp ARA stands for Amsterdam, Rotterdam and Antwerp, the three-port corridor that functions as the pricing and physical hub for liquid fuels and waste-based feedstocks in northwest Europe. Most European offers are quoted CIF ARA. The three ports are one price basis but not one market: Rotterdam is the deepwater and refining centre, Amsterdam is heavily weighted towards blending and storage, and Antwerp sits next to the chemical and oleochemical cluster. National implementation of EU rules differs across the Dutch-Belgian border, which can make the same cargo worth different amounts depending on where it discharges. ## One basis, three different ports Read this first: this is a market map built from public sources, not a client list. Naming a company here says nothing about whether we work with them, and we do not claim to represent any of them. CIF ARA is a pricing convention before it is a destination. When a buyer quotes it, they are pricing delivery into the range, and the actual discharge port is decided later against tank availability, draft and what happens to the cargo next. For a seller that is convenient, but it hides real differences. * Rotterdam is the deepwater port and the refining centre of the range. Parcel tankers and larger vessels discharge here, and it is where material destined for hydrotreating generally lands. It is also the bunkering centre. * Amsterdam is weighted towards storage and blending rather than refining, with a large independent tank cluster running to roughly five million cubic metres of bulk liquid capacity. Biodiesel blending and component storage sit here. * Antwerp sits next to one of the largest chemical clusters in Europe, which makes it the natural discharge point for material heading into oleochemicals, fatty acids and petrochemical feedstock rather than fuel. ## The border matters more than people expect Amsterdam and Rotterdam are in the Netherlands; Antwerp is in Belgium. EU directives are implemented nationally, and the implementations do not move in step. Argus reported in 2025 on a regulatory mismatch between EU-wide FuelEU Maritime rules and national implementation of RED III, and described it as set to disrupt ARA biofuel trade. The practical effect for a seller is uncomfortable but useful to know: the same certified cargo can be worth a different amount depending on which side of that border it discharges, because the buyer's own obligation is defined nationally. If a buyer insists on a specific discharge port rather than leaving the range open, that is usually why, and it is a reasonable request rather than an awkward one. ## Independent storage is what makes the hub work The reason ARA became the hub is tank capacity in independent hands. A trader can take title to a parcel, hold it, blend it and sell it onward without owning a refinery, which is what allows a market rather than a set of bilateral refinery supply deals. For a producer this is the practical route into Europe. You do not need a refiner to take your first parcel; you need a buyer with tank access. That is a much shorter list of conditions, and it is why a first cargo into ARA is often placed with a trader rather than an end user. Our storage and logistics page covers how tank access is arranged. ## What discharging in ARA demands of your paperwork The documentation bar in this range is high, and it is the most common reason a first cargo from a new origin runs into trouble. What a buyer here expects as a matter of course: * A Proof of Sustainability per consignment with the GHG figure on it, and a certified chain that holds across the border. See Proof of Sustainability. * A certificate of analysis from a laboratory that can run the full scope, with the sampling basis stated. See sampling and laboratories. * Independent inspection at load port, commonly split between the parties. * A customs classification that survives contact with the authorities. See CN codes and customs. * Waste shipment paperwork where the material is classified as waste, which is a separate regime from the sustainability one and catches people out. ## Where the volume comes from ARA is an import hub. Used cooking oil arrives from Asia and from across Europe, POME oil from Malaysia and Indonesia, tallow from within Europe and from the Americas, pyrolysis oil from wherever the plants are. The buyers are the refiners, blenders and traders described on our who buys UCO and who buys POME pages. If you are exporting into this range for the first time, the honest summary is that the commercial part is rarely what stops a deal. The paperwork is. ## A note on accuracy This page is built from regulation as published, from trade association and port material, and from reporting by the price agencies. Mandates get amended, terminals change hands and national implementation moves at its own pace, so treat this as orientation rather than a live position, and verify against the current text before contracting. If something here is out of date or wrong, tell us and we will correct it. ## Sources * Argus, regulatory clash set to disrupt ARA biofuel trade: https://www.argusmedia.com/en/news-and-insights/latest-market-news/2718365-regulatory-clash-set-to-disrupt-ara-biofuel-trade * Directive (EU) 2023/2413 (RED III), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * Regulation (EU) 2024/1157 on shipments of waste, on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1157/oj * Port of Rotterdam: https://www.portofrotterdam.com/en * Port of Antwerp-Bruges: https://www.portofantwerpbruges.com/en ## Frequently asked questions Q: What does CIF ARA mean? A: Cost, insurance and freight delivered into the Amsterdam-Rotterdam-Antwerp range. It is a pricing convention rather than a named destination; the discharge port is usually settled later against tank availability and what happens to the cargo next. Q: Which of the three ports should my cargo go to? A: It depends on what happens after discharge. Material for hydrotreating generally lands in Rotterdam, blending components and storage plays lean towards Amsterdam, and anything heading into the chemical or oleochemical cluster suits Antwerp. Tell us the product and the buyer type and we can say which is realistic. Q: Why does a buyer sometimes insist on one specific port? A: Usually because their own obligation is defined nationally. EU directives are implemented per member state and the implementations do not move in step, so the same cargo can be worth different amounts in a Dutch port than in a Belgian one. It is a reasonable request, not an awkward one. Q: Do I need a European entity to sell into ARA? A: Not necessarily to sell, but if the material is certified and you are passing it on as certified, you have to be in the chain of custody yourself or work through a counterpart who is. That catches out a lot of first-time exporters. Q: Can I store material in ARA before I have a buyer? A: Yes, and traders do it routinely; independent tank capacity is exactly what makes the hub function. For a producer without a European entity it is more complicated, and generally the first parcel is sold to someone who already has tank access rather than stored speculatively. Q: Is Rotterdam always the cheapest place to discharge? A: No, and freight is rarely the deciding number. Tank availability, the buyer's own position and the national rules on their side move the economics more than the difference in freight between the three ports. ============================================================================== # eSAF: the synthetic aviation fuel sub-mandate URL: https://www.sustainablecommodities.eu/markets/esaf-and-synthetic-aviation-fuel eSAF is synthetic aviation fuel made from renewable hydrogen and captured carbon, and under EU rules it counts as a renewable fuel of non-biological origin. ReFuelEU aviation sets a separate sub-mandate for it: 1.2% of aviation fuel supplied at EU airports from 2030, rising to 35% by 2050, alongside the general SAF share of 2% from 2025 and 70% by 2050. That separate quota is the whole reason the product exists commercially, because eSAF cannot compete with HEFA on cost and is not meant to. ## The sub-mandate is the market Read this first: this is a market map built from public sources, not a client list. Naming a company here says nothing about whether we work with them, and we do not claim to represent any of them. ReFuelEU aviation requires fuel suppliers to blend a rising share of SAF into conventional jet fuel at EU airports: 2% from 2025 rising to 70% by 2050. Within that, there is a separate obligation for synthetic aviation fuel: 1.2% from 2030, rising to 35% by 2050. The European Commission publishes both trajectories. That second number is the entire commercial case for eSAF. A synthetic litre cannot compete on cost with a HEFA litre made from used cooking oil, and it is not supposed to; it satisfies an obligation that a HEFA litre cannot satisfy. Anyone modelling eSAF against the HEFA price is modelling the wrong thing. The regulation covers more than 95% of air transport departing from EU airports and replaces national SAF mandates, which is what gives a developer one rulebook rather than twenty-seven. ## What counts as eSAF, in the regulation's own terms ReFuelEU defines SAF in Article 3(7) and it is broader than most people assume. It covers synthetic aviation fuels from renewable hydrogen and captured carbon, advanced biofuels from Annex IX Part A feedstocks, biofuels from oils and fats in Part B, and recycled carbon aviation fuels. Only the first of those satisfies the synthetic sub-mandate. Fuel suppliers may also comply using renewable hydrogen for aviation, and synthetic low-carbon aviation fuels and low-carbon hydrogen from non-fossil sources meeting a 70% lifecycle emissions saving. The distinction between these routes is not academic: it decides which obligation your product can actually be sold against. ## What an offtaker will ask a project, and in what order The questions that come up in every serious eSAF conversation are about whether the fuel will qualify, not about whether it will burn. In rough order of how early they arrive: * The power basis. Whether the electricity meets the RFNBO criteria, how many full load hours the project assumes, and what happens in the hours it does not run. This is the single largest determinant of both compliance and cost. * The carbon source. Where the CO2 comes from, whether it is biogenic, industrial or captured from air, and how long that source remains eligible under the rules as they stand. * The technology route and who stands behind it. Electrolyser supply and the fuel synthesis step, and whether those are contracted or intended. * Certification. Which scheme, and at what stage a pre-certification study is scheduled. This is the question that separates a project from a slide. * Timing and the delivery window, against a sub-mandate that starts in 2030 and steps up from there. * Whether the price is a number or a mechanism. For a first-of-a-kind plant with a start date years out, a fixed figure is rarely credible; buyers expect an indexed structure and a shorter first term. ## Why the volume is not there yet Most eSAF capacity being discussed today is pre-final-investment-decision. That is not a criticism of the sector, it is the stage it is at, and it shapes how the trade works: the conversations that matter now are offtake conversations for volume that will exist later, which is closer to project finance than to a cargo trade. For an airline or a fuel supplier facing the 2030 sub-mandate this creates a genuine problem: the obligation arrives on a fixed date and the supply arrives when it arrives. That mismatch is what makes early offtake commitments valuable to both sides and is worth understanding before you enter one. ## Where a broker is useful and where we are not We are not project developers, we do not build plants, and we do not give investment advice. What we do is put projects in front of people who could credibly take the volume, and tell a developer plainly which parts of their package will not survive a counterparty's first read. The most common thing we send back is that the power basis and the carbon source are described in ambitions rather than in contracts. That is worth fixing before an approach, not during one. Where certification work is needed we can introduce ISCC consultants and auditors we have worked with. ## A note on accuracy This page is built from regulation as published, from trade association and port material, and from reporting by the price agencies. Mandates get amended, terminals change hands and national implementation moves at its own pace, so treat this as orientation rather than a live position, and verify against the current text before contracting. If something here is out of date or wrong, tell us and we will correct it. ## Sources * European Commission, ReFuelEU aviation: https://transport.ec.europa.eu/transport-modes/air/environment/refueleu-aviation_en * Regulation (EU) 2023/2405 (ReFuelEU Aviation) on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2023/2405/oj * Directive (EU) 2023/2413 (RED III), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj ## Frequently asked questions Q: What is eSAF? A: Synthetic aviation fuel made from renewable hydrogen and captured carbon, counted as a renewable fuel of non-biological origin under EU rules. It is a drop-in jet fuel, chemically distinct from HEFA SAF made from fats and oils, and it satisfies a different obligation. Q: What is the eSAF mandate in 2030? A: ReFuelEU aviation sets a synthetic aviation fuel share of 1.2% of fuel supplied at EU airports from 2030, rising to 35% by 2050. That sits inside the wider SAF obligation of 2% from 2025 rising to 70% by 2050. The European Commission publishes both. Q: Why is eSAF so much more expensive than HEFA SAF? A: Because it is made from renewable electricity, hydrogen and captured carbon rather than from a waste fat, and because the plants are first-of-a-kind. It is not competing with HEFA on price: it satisfies a separate sub-mandate that HEFA cannot satisfy. Comparing the two on cost per litre misses the point of both. Q: Does HEFA SAF count towards the synthetic sub-mandate? A: No. HEFA SAF counts towards the general SAF share but not towards the synthetic sub-quota, which is specifically for fuels from renewable hydrogen and captured carbon. That separation is what creates the eSAF market. Q: What makes power RFNBO compliant? A: The criteria cover the origin of the electricity and its relationship in time and place to the hydrogen production. It is the first thing a serious counterparty will test, and a project describing its power basis loosely will not get past a first read. Verify against the delegated acts as they currently stand rather than against a summary. Q: Can I sell eSAF before the plant is built? A: Offtake agreements for volume that does not yet exist are how this market currently works, because the mandate arrives on a fixed date and capacity does not. Expect a buyer to want a pricing mechanism rather than a fixed number, a shorter first term, and conditions tied to how the regulation lands. Q: Do you broker eSAF? A: We introduce projects to counterparties who could credibly take the volume, and we tell developers which parts of their package will not survive scrutiny. We are not project developers and we give no investment advice. ============================================================================== # Marine biofuel: B30, B100 and FuelEU Maritime URL: https://www.sustainablecommodities.eu/markets/marine-biofuel-and-fueleu-maritime Marine biofuel is conventional bunker fuel blended with a biogenic component, most commonly FAME, and sold as a blend such as B30, or as a pure biogenic fuel such as B100 FAME or B100 HVO. Demand is driven by FuelEU Maritime and by the cost of emissions under the EU ETS rather than by price advantage. Because member states implement the underlying directives at their own pace, the same blend can have a different compliance value depending on which port it is bunkered in. ## What the blends actually are Read this first: this is a market map built from public sources, not a client list. Naming a company here says nothing about whether we work with them, and we do not claim to represent any of them. The naming is straightforward once you see it. The number is the percentage of biogenic component in the blend, and the base fuel is whatever it is blended into. * B30 is thirty per cent biogenic component, most commonly FAME, blended into a conventional base such as VLSFO or marine gasoil. It is the most widely bunkered blend. * B100 FAME is the pure biogenic fuel, with no fossil base at all. * B100 HVO is hydrotreated rather than esterified, which gives different cold flow behaviour and storage stability. It costs more and behaves better. * Residue-based B100 exists as well, made from the heavier end of the biogenic slate, and behaves differently again in a tank. ## The demand comes from regulation, not from price Nobody bunkers biofuel because it is cheap. FuelEU Maritime sets a declining limit on the greenhouse gas intensity of energy used on board, and the EU ETS puts a cost on emissions from voyages in scope. Together they make a more expensive fuel the cheaper option overall, and as both tighten the gap moves further in that direction. That is worth stating plainly because it explains the buying behaviour. A shipowner is not shopping for a fuel; they are managing a compliance position across a fleet and a year. The conversation is about what the fuel counts as, not what it costs per tonne. ## Why the bunker port is a commercial decision EU directives are implemented nationally and the implementations do not move in step. Argus reported in 2025 on a mismatch between EU-wide FuelEU Maritime rules and national implementation of RED III, describing it as set to disrupt ARA biofuel trade. For a shipowner this is not an abstraction: it means the same blend bunkered in two ports in the same range can produce a different compliance outcome. For a supplier of blend components it means the demand is not evenly spread across the range. Our ARA page covers how the three ports differ. ## What this means if you are selling feedstock Marine is a genuine outlet for FAME and for the feedstocks behind it, and it has grown quickly. It also has its own documentation expectations, because the buyer has to prove the emissions saving rather than simply consume the fuel. The practical requirement is the same as for road fuel and no lighter: a certified chain and a Proof of Sustainability per delivery with the GHG figure on it. A blend supplier who cannot document the biogenic component cannot serve this market at all, however good the fuel is. ## The handling questions that come up * Cold flow and storage stability, which is where FAME and HVO differ most and where a blend that sat too long causes trouble. * Compatibility with the previous cargo in the tank, since biogenic components behave differently against residues than fossil fuel does. * Water and microbial growth, a real issue in FAME blends held over time. * The documentation trail, which for this buyer is part of the product rather than an administrative afterthought. ## A note on accuracy This page is built from regulation as published, from trade association and port material, and from reporting by the price agencies. Mandates get amended, terminals change hands and national implementation moves at its own pace, so treat this as orientation rather than a live position, and verify against the current text before contracting. If something here is out of date or wrong, tell us and we will correct it. ## Sources * Regulation (EU) 2023/1805 (FuelEU Maritime) on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2023/1805/oj * European Commission, reducing emissions from the shipping sector: https://climate.ec.europa.eu/eu-action/transport/reducing-emissions-shipping-sector_en * Argus, regulatory clash set to disrupt ARA biofuel trade: https://www.argusmedia.com/en/news-and-insights/latest-market-news/2718365-regulatory-clash-set-to-disrupt-ara-biofuel-trade * Directive (EU) 2023/2413 (RED III), consolidated text on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj ## Frequently asked questions Q: What does B30 mean? A: Thirty per cent biogenic component, usually FAME, blended into a conventional base such as VLSFO or marine gasoil. The number is simply the percentage of the biogenic part. Q: What is the difference between B100 FAME and B100 HVO? A: Both are pure biogenic fuels with no fossil base, but FAME is esterified and HVO is hydrotreated. HVO has better cold flow behaviour and storage stability and costs more. Which is appropriate depends on the vessel, the route and how long the fuel will sit. Q: Why would a shipowner pay more for biofuel? A: Because FuelEU Maritime limits the greenhouse gas intensity of energy used on board and the EU ETS puts a price on emissions in scope. The fuel is more expensive per tonne and cheaper overall once compliance is counted. It is a compliance purchase, not a fuel purchase. Q: Does it matter which port I bunker in? A: It can matter a great deal. National implementation of the underlying directives differs between member states, so the same blend can produce a different compliance outcome depending on where it is bunkered. Argus reported on exactly this mismatch in the ARA range in 2025. Q: Do marine biofuels need the same certification as road fuel? A: Yes, and for the same reason: the buyer has to prove the emissions saving. A certified chain and a Proof of Sustainability per delivery with the GHG figure are required. A supplier who cannot document the biogenic component cannot serve this market. Q: Can I sell FAME into bunkering without a marine background? A: The product is the same; the buyer and the documentation expectations are different. If you already produce or place FAME, marine is a real second outlet. Tell us the specification and the volume and we will tell you whether it fits. ============================================================================== # What a biofuel and feedstock broker actually does URL: https://www.sustainablecommodities.eu/markets/biofuel-and-feedstock-brokerage A broker introduces two parties and structures the trade between them; a trader buys and sells for its own account. We are a broker. We never take title to a cargo, never take a price position, and never trade against the parties we work for. The fee is agreed per tonne before any introduction is made, one side pays it, and no deal means no fee. What a broker is worth in this market is the matching itself, waste-based feedstock has no exchange, so buyers and sellers do not find each other by looking, plus keeping counterparties apart until both sides want to meet, and getting the documentation right, because in this trade the paperwork carries as much value as the cargo. ## A broker is not a trader, and the difference decides who carries what This is the first thing to establish in any conversation, because the two roles look identical from the outside and behave completely differently when something goes wrong. A trader buys the cargo, owns it, and sells it on. It carries the price risk between those two moments, and it earns the spread. Its interest in the price is the opposite of yours: every euro it does not pay you, it keeps. A broker never owns the cargo. It brings a buyer and a seller into a contract with each other and is paid a fee for doing so. Title, payment and risk run directly between the two principals. That is why a broker can be straight with both sides about what a parcel is worth: it is not on the other side of your trade. Neither role is better. A trader is the right counterparty when you want to sell today at a firm price and be done. A broker is the right one when the match itself is the hard part, which in waste-based feedstock it usually is. * Trader: owns the cargo, carries price risk, earns the spread, and is your counterparty. * Broker: never owns the cargo, carries no price risk, earns a fee, and is not your counterparty. * Agent: acts for one named principal under a mandate, and its duty runs to that principal only. * Platform: lists offers and lets you find each other; nobody checks who is real. ## Why this market has brokers at all Waste-based feedstock has no exchange. There is no screen where used cooking oil from a collector in one country meets a hydrotreater in another. Crude palm oil has futures; UCO, POME, acid oils, tall oil and pyrolysis oil do not. Everything is bilateral, negotiated, and largely invisible. That has four practical consequences, and each one is a reason this role exists. None of that is glamorous. It is, however, most of the work. * Discovery. A refiner does not publish what it is short of, and a collector does not publish what it has spare. Both are findable only through people who talk to both sides every week. * Anonymity. A seller does not want its buyer to become its supplier's customer, and a buyer does not want its competitors to know what it is short of. Until both sides agree to meet, neither name should travel. * Documentation. In this trade the paperwork carries the value. An Annex IX letter, a certificate scope that covers both the product and the activity, and a sustainability declaration that matches the consignment. A parcel with the wrong letter on it is a different product commercially, whatever is in the tank. * Qualification. A refiner does not accept a new supplier on the strength of an email. There is an onboarding process with certification checks, trial cargoes and credit review, and knowing what it will ask before it asks saves months. ## Who pays, and how the fee works Brokerage is paid per tonne, by one side, agreed in writing before any introduction is made. If no contract is concluded, nothing is owed. That is the whole model, and any version of it that is more complicated deserves a question. Which side pays depends on who has the harder problem. Usually it is the side that came looking. It should be stated openly at the start, because a broker who is vague about who pays him is telling you something. What a fee does not buy is an obligation to accept the introduction. You are free to decline a counterparty for any reason, and a broker who treats a refusal as a breach is not brokering. * Agreed per tonne, in writing, before the introduction. * One side pays. Ask which, and expect a straight answer. * No conclusion, no fee. Nothing is payable on an introduction that goes nowhere. * No advance. A broker asking for money up front, for any reason, is the single clearest warning sign in this market. ## How a trade actually runs, step by step The sequence below is what a real transaction looks like. It matters because most stalled deals are stalled at a specific step, and naming the step is usually enough to unblock it. Two of these steps are where trades most often die. The first is the specification: a seller who cannot produce a recent analysis is not ready to sell, however firm the offer sounds. The second is the certification chain, where a certificate that does not cover the activity, or a declaration that does not match the consignment, stops a cargo that is otherwise perfect. * Enquiry. What the material is, how much, where it sits, and what certification it carries. * Specification. A recent analysis from a laboratory the buyer will accept. Not a typed sheet; an actual certificate of analysis. * Indication. A price range against a published reference where one exists, with the basis stated: FOB, CIF, DAP, and which port. * Counterparty. The broker approaches the other side without naming you, and only names both once both agree. * Firm offer. Price, quantity, tolerance, delivery window, payment terms, inspection, and the contract rules the trade sits under. * Contract. Signed by the two principals with each other. The broker is not a party to it. * Nomination and loading. Vessel or truck nominated, independent surveyor appointed, samples drawn and retained. * Documents. Bill of lading, invoice, packing list, certificate of analysis, sustainability declaration, and whatever else the payment terms name. Have the list agreed before loading, not after. * Payment. Against documents, on the terms in the contract. ## How to tell a real broker from an LOI carousel This market has a persistent problem with people who present themselves as brokers and are neither brokers nor connected to any cargo. The pattern is recognisable and it costs sellers real time, so it is worth writing down plainly. The tell is almost always the same: a great deal of process before any verifiable fact. Real trades start with a specification and a location. Fake ones start with a document chain. Ask the four questions below. A working broker answers all four without hesitating. * Does the price arrive before the specification? Nobody can price a parcel they have not seen an analysis of. A firm number offered against a product name alone is not a real number. * Is there a chain of LOI, ICPO, FCO, soft probe and NCNDA before anything concrete? In real trade these documents are rare, and a long sequence of them substitutes paperwork for a cargo. * Can they name a step they have personally handled? Not a company name, which proves nothing, but a port, a surveyor, a laboratory, a certification body. * Is money requested up front? Registration, escrow, allocation, tank reservation, the reason varies and the answer is always no. * Four questions to ask any broker: Who pays your fee? Have you spoken to this counterparty yourself? What happens to my name before I agree to be introduced? And what would make you tell me this trade will not work? ## What a broker does not do Being clear about the edges of the role saves everybody time, and a broker who claims all of the below is worth less trust, not more. What sits inside the role is narrower and more useful: finding the right counterparty, keeping both sides apart until they want to meet, getting the document set complete before it becomes urgent, reading the certification chain properly, and staying in the trade when something goes wrong. * Not financing. A broker does not fund the cargo, open the letter of credit or carry the receivable. * Not inspection. Sampling and analysis belong to an independent surveyor and an accredited laboratory. A broker arranges it; it does not certify it. * Not certification. Scheme certificates come from a certification body after an audit. Nobody can sell you one. * Not a guarantee of performance. The contract is between the two principals and their obligations run to each other. * Not a market report. Where a published assessment exists it should be named as the reference; where none exists, that should be said rather than papered over with a confident number. ## A note on how we work We broker. We do not buy for our own account and we do not take positions, which means we have no interest in where the price lands beyond the trade concluding on terms both sides will repeat. Names do not travel until both sides agree to be introduced. That is not a courtesy, it is the condition on which anyone tells a broker anything useful, and it applies in both directions. If a trade will not work we say so early, including when saying so costs us the fee. A specification that no European buyer will accept, a certification chain with a gap in it, or a volume too small to move economically, these are better said in week one than in month three. ## Sources * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * ISCC EU system documents: https://www.iscc-system.org/certification/iscc-documents/ * FOSFA, contracts and trade rules: https://www.fosfa.org/ * GAFTA, contracts and arbitration rules: https://www.gafta.com/ ## Frequently asked questions Q: What is the difference between a broker and a trader? A: A trader buys the cargo, owns it and sells it on, carrying the price risk in between and earning the spread. It is your counterparty, and its interest in the price runs opposite to yours. A broker never owns the cargo: it brings a buyer and a seller into a contract with each other and is paid a fee for doing so, with title, payment and risk running directly between the two principals. Ask which one you are talking to before you discuss price. Q: Who pays the brokerage fee? A: One side, agreed per tonne in writing before any introduction is made, and usually the side that came looking. If no contract is concluded, nothing is payable. A broker who is vague about which side pays, or who wants money before anything has been concluded, is telling you something worth listening to. Q: Why does waste-based feedstock need brokers when other commodities do not? A: Because there is no exchange. Crude palm oil has futures; used cooking oil, POME, acid oils, tall oil and pyrolysis oil do not. Every trade is bilateral and negotiated, refiners do not publish what they are short of, and collectors do not publish what they have spare. On top of that the value sits partly in the documentation, so matching the material is only half the work. Q: Do you take ownership of the cargo? A: No. We never take title and never take a price position. The contract is signed by the buyer and the seller with each other, and we are not a party to it. That is what allows us to be straight with both sides about what a parcel is worth. Q: How do I tell a real broker from a fake one? A: Real trades start with a specification and a location; fake ones start with a document chain. Be careful with a firm price offered before anyone has seen an analysis, with a long sequence of LOI, ICPO, FCO and NCNDA before any verifiable fact, and with anyone unable to name a port, surveyor or laboratory they have actually dealt with. Any request for money up front, under any label, is the clearest signal of all. Q: Will my name be given to the other side? A: Not until you agree to it. A broker approaches the counterparty with the specification, the volume and the location, not with your identity, and both names are exchanged only once both sides want to be introduced. This runs in both directions and it is the condition on which anyone tells a broker anything useful. Q: What information should I send with a first enquiry? A: What the material is, the monthly or one-off volume, where it sits, what certification it carries, and a recent certificate of analysis from a laboratory a buyer will accept. Those five things are enough to say honestly whether there is a trade. Without the analysis, any price discussion is guesswork. Q: Can a broker guarantee that the buyer will pay? A: No, and anyone saying otherwise is misdescribing the role. Payment obligations run between the two principals under their contract. What a broker can do is make sure the payment terms and the document list are agreed before loading rather than after, which is where most payment disputes actually originate. Q: Do you work on exclusivity? A: No. You are free to talk to other brokers and to approach buyers directly. What is agreed is the fee on a trade we introduce, not a claim on your material. A broker who treats your right to decline a counterparty as a breach is not brokering. Q: What if the cargo goes wrong after it is sold? A: We stay in it. Quality disputes, demurrage and rejected parcels usually come down to whose sample governs and what the contract rules say, and both sides tend to talk past each other once lawyers appear. An intermediary who knows the trade and is not a party to it can often unblock a cargo faster than escalation would. ============================================================================== # REDcert-EU, REDcert-DE and how they sit next to ISCC URL: https://www.sustainablecommodities.eu/markets/redcert-certification REDcert and ISCC are both voluntary schemes recognised by the European Commission under the Renewable Energy Directive, so in principle a compliant consignment is compliant under either. In practice the buyer decides. Many European refiners are set up for ISCC EU, some accept REDcert-EU without question, and a few will only take one. That is a commercial position, not a legal one, and it is the single most useful thing to establish before you talk about price. Three names get mixed up: REDcert-EU is the European scheme for RED compliance, REDcert-DE serves the German national requirements, and REDcert² covers material in the chemical and material chain rather than fuel. A certificate under one of them says nothing about the others. ## Three schemes with one name, and they are not the same thing This trips people up constantly, including people who hold the certificate. Read the scheme name on your own certificate before quoting it in an offer. The practical test is simple: what does the buyer have to book, and under which regime? If they are meeting a European renewable energy obligation, they need EU scheme material. If they are making a bio-based polymer, they are in a different world entirely. * REDcert-EU, the European scheme for compliance with the Renewable Energy Directive. This is the one that competes directly with ISCC EU. * REDcert-DE, built around the German national requirements. Relevant if the material is going into the German quota system. * REDcert², for the chemical and material chain, closer in purpose to ISCC PLUS than to ISCC EU. Not a fuel compliance certificate. * A certificate names one of these. Holding REDcert² does not make you REDcert-EU certified, and an offer that says only "REDcert certified" is incomplete. ## Will my buyer accept REDcert instead of ISCC? This is the question we are actually asked, in exactly these words, and the honest answer is: ask them, before anything else in the negotiation. Both schemes are recognised by the Commission, so there is no legal barrier. What there is instead is an operational one. A refiner has its systems, its auditors and its internal procedures built around the scheme it uses, and adding a second scheme to its incoming flows is a decision somebody has to make. Some have made it; some have not. What this means for a seller is uncomfortable but worth knowing: your certificate narrows your buyer list. Not to zero, and often not by much, but it narrows it. When you are choosing which scheme to certify under, ask who you expect to sell to rather than which audit looks easier. * Establish acceptance first. Before the specification, before the price. * Get it in writing. "We generally accept REDcert" from a trader is not the same as the compliance desk confirming it for this product. * Check the product, not just the scheme. A buyer may take REDcert-EU for one feedstock and not for another, because its own downstream obligations differ. * Expect the question in reverse too. Buyers ask us whether a parcel comes with ISCC or REDcert before they ask what is in it. ## What happens when material crosses between schemes Material certified under one scheme does not automatically carry into another, and this is where consignments get stuck. Both schemes have rules for recognising each other's material, and both make that recognition conditional. The conditions are the part people skip. Whether the receiving party's own certification covers the incoming material, whether the sustainability declaration carries everything the receiving scheme needs, and whether the chain of custody method matches. Get any of those wrong and the volume is still physically fine but no longer bookable. Practical consequence: if you know a parcel will cross schemes, raise it with both certification bodies before loading, not after the declaration has been issued. Re-issuing a declaration after the fact is difficult and sometimes impossible. ## What a REDcert certificate actually tells you The same reading applies as with any scheme certificate, and the same mistakes get made. A certificate is not a yes-or-no; it is a scope. The most common failure we see is a certificate that is perfectly valid and simply does not cover what the offer says it covers. That is not fraud; it is usually a company that grew into a new product and did not extend its audit. * Which scheme, exactly, in the words on the certificate. * Which products are in scope. A trading scope and a processing scope are different things. * Which activities. Collecting, trading, storing and processing are separate; holding one does not imply the others. * Validity dates, and whether a renewal audit has happened. * The registration number, so it can be checked in the scheme's own public database rather than taken on trust. ## Where REDcert shows up in our own trade REDcert comes up constantly in the waste oils and animal fats we are asked about, and the pattern is consistent: a seller in central or eastern Europe holds REDcert, a buyer in the Netherlands or Spain runs on ISCC, and the conversation stops until somebody checks. It is worth an email at the start of a discussion rather than a problem at the end of one. We ask it as a standard question on any new enquiry, alongside the product, the volume and the analysis. ## Sources * REDcert, scheme documents and certificate database: https://www.redcert.org/en/ * European Commission, voluntary schemes recognised under RED: https://energy.ec.europa.eu/topics/renewable-energy/bioenergy/voluntary-schemes_en * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * ISCC EU system documents: https://www.iscc-system.org/certification/iscc-documents/ ## Frequently asked questions Q: Is REDcert the same as ISCC? A: No, but they do the same job. Both are voluntary schemes recognised by the European Commission for demonstrating compliance with the Renewable Energy Directive, so material certified under either can in principle be used against the same obligations. They are separate organisations with separate audits, separate certificates and separate databases, and a buyer set up for one does not automatically accept the other. Q: Will a European refiner accept REDcert-EU material? A: Many will and some will not, and it is a commercial decision rather than a legal one. The buyer's systems, auditors and internal procedures are built around whichever scheme it uses, and taking in a second one is a choice somebody has to make. Establish acceptance in writing before you discuss price, and check it for the specific product rather than in general. Q: What is the difference between REDcert-EU, REDcert-DE and REDcert2? A: REDcert-EU is the European scheme for Renewable Energy Directive compliance and is the direct counterpart to ISCC EU. REDcert-DE is built around German national requirements and matters if the material goes into the German quota system. REDcert² covers the chemical and material chain rather than fuel, closer in purpose to ISCC PLUS. A certificate names one of them, and holding one says nothing about the others. Q: Can material move from REDcert to ISCC or the other way round? A: There are rules for it in both schemes and they are conditional. What matters is whether the receiving party's certification covers the incoming material, whether the sustainability declaration carries everything the receiving scheme needs, and whether the chain of custody method matches. Raise a crossing with both certification bodies before loading; re-issuing a declaration afterwards is difficult and sometimes impossible. Q: Which scheme should I certify under? A: Ask who you expect to sell to, not which audit looks easier. Your certificate narrows your buyer list, and the direction it narrows in depends entirely on your market. If most of your likely buyers run ISCC EU, certifying under REDcert alone puts a question in front of every conversation. Q: Do I need REDcert for the German market? A: Not necessarily REDcert, but you do need something the German system recognises, and the proof has to end up in Nabisy for anyone claiming against the German greenhouse gas quota. See our page on Nabisy and the German market for how that part works in practice. Q: How do I check whether a REDcert certificate is real? A: Take the registration number from the certificate and look it up in the scheme's own public database rather than relying on the PDF you were sent. Then read the scope: which products, which activities, and which dates. A valid certificate that does not cover the product in the offer is the most common problem, and it is usually an oversight rather than fraud. Q: Does a REDcert certificate mean the material is Annex IX? A: No. Those are two different questions. The certificate says the operator is audited under a recognised scheme; the Annex IX category is a property of the material and has to be evidenced through the chain and stated on the sustainability declaration. Plenty of certified material is not Annex IX at all. ============================================================================== # Nabisy, biomass codes and selling into Germany URL: https://www.sustainablecommodities.eu/markets/nabisy-and-the-german-market Nabisy is the German database for sustainability proof, run by the BLE. Anyone claiming biofuel against the German greenhouse gas quota needs the proof to exist in Nabisy, which means somebody in the chain must be registered and must issue the Nachweis there. For a supplier outside Germany this usually means your German counterparty does the entering, but they can only do it if what you send them is complete. Three things get asked for over and over: the biomass code for the product, an example of an earlier Nachweis so the buyer can see the format, and confirmation of who the seller of record is. If you can answer those three, the German route is usually straightforward. If you cannot, it stops there regardless of how good the material is. ## What Nabisy is, and who has to touch it Nabisy is the web database the German authority uses to register sustainability proof for biofuels. It sits alongside the voluntary scheme certification rather than replacing it: you still need ISCC, REDcert or another recognised scheme, and Nabisy is where the resulting proof is recorded for German purposes. For most non-German suppliers the practical position is that you do not operate in Nabisy yourself. Your German buyer or their trader does. What you supply is the underlying documentation that makes their entry possible and correct, which is why the questions come to you rather than to them. ## The biomass code is the question you will be asked first Every feedstock has a code in the German system, and a German counterparty will ask which one applies to your product before much else happens. In our own correspondence this exact question, what biomass code is being used for this product, comes back again and again, over years. It matters because the code is not decoration. It ties the physical material to a category, and the category carries the value: what it can be counted as, at what weighting, against which obligation. A code that does not match the material is the same problem as an Annex IX letter that does not match, and it surfaces at the same late moment. If you do not know which code applies, say so and ask your certification body rather than guessing from the product name. Guessing here is how a consignment ends up re-declared. ## How a proof of sustainability becomes a Nabisy entry The sustainability declaration your scheme produces is not itself a Nabisy Nachweis. The German entry is generated in Nabisy on the basis of it, by a registered party, and it carries its own identifiers. Buyers frequently ask a new supplier to share an example from an earlier shipment, not because they doubt you, but because they want to see whether the format and the fields will work on their side before they commit to a cargo. It is a reasonable request and worth being ready for. What makes the entry work or fail is boring and specific: the seller of record has to match the party on the declaration, the quantities have to reconcile, the feedstock category has to be consistent, and the greenhouse gas figure has to be present and defensible. * Your scheme certificate, in scope for the product and the activity. * The sustainability declaration for the consignment, complete and consistent with the physical documents. * The biomass code, agreed rather than assumed. * The greenhouse gas saving figure, with the basis it was calculated on. * Who the seller of record is, matching the declaration and the invoice. ## Why Germany asks more questions than other markets Germany meets its transport obligation through a greenhouse gas quota rather than a volume quota. That means the value of a parcel to a German buyer depends on how much emission saving it delivers, not simply on how many tonnes it is. The consequence for a seller is that the greenhouse gas figure stops being a line on a form and becomes part of the price conversation. A well-documented saving is worth money in Germany in a way it is not everywhere, and a figure you cannot substantiate costs you more there than elsewhere. It also explains why German counterparties are more insistent about paperwork than some other markets. They are not being difficult; their own claim depends on it. ## What we do with this We are asked about Nabisy from both directions: suppliers who have been sent a question they cannot answer, and German buyers checking whether a new supplier will be able to deliver documentation that works. What helps most is getting the three questions answered before a cargo is nominated rather than while it is on the water. It is a short conversation early and a long one late. ## Sources * BLE, Nabisy, sustainable biomass systems database: https://www.ble.de/EN/Topics/Climate-Energy/Sustainable-Biomass-Production/sustainable-biomass-production_node.html * Nabisy web application: https://nabisy.ble.de/ * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj ## Frequently asked questions Q: What is Nabisy? A: It is the German web database for sustainability proof for biofuels, operated by the BLE. It does not replace scheme certification: you still need ISCC, REDcert or another recognised scheme, and Nabisy is where the resulting proof is registered for German purposes. Anyone claiming against the German greenhouse gas quota needs the proof to exist there. Q: What is a Nabisy biomass code? A: It is the code that ties your physical material to a feedstock category in the German system. A German counterparty will usually ask which code applies to your product early in the conversation. The code carries value, because the category decides what the material can be counted as and against which obligation, so a code that does not match the material causes the same kind of problem as a wrong Annex IX letter. Q: Do I need to register in Nabisy myself if I am not in Germany? A: Usually not. In most chains the German buyer or their trader is the registered party and does the entering. What you supply is the underlying documentation that makes their entry possible and correct, which is why the questions land with you even though the database is theirs. Q: A buyer asked for an example of a previous Nabisy proof. Is that normal? A: Yes, and it is worth being ready for it. Buyers ask new suppliers to share an earlier example so they can check whether the format and fields will work on their side before committing to a cargo. It is a practical check rather than a sign of distrust. Remove commercially sensitive detail before sharing, but do share the structure. Q: Is a sustainability declaration the same as a Nabisy Nachweis? A: No. The declaration is produced under your voluntary scheme and travels with the consignment. The Nabisy entry is generated in the German database on the basis of it, by a registered party, and carries its own identifiers. One is the input to the other. Q: Why does Germany care so much about the greenhouse gas figure? A: Because the German transport obligation is a greenhouse gas quota rather than a volume quota. The value of a parcel there depends on how much emission saving it delivers, not just on the tonnage. That makes a well-documented saving worth real money in Germany, and an unsubstantiated one more expensive than elsewhere. Q: What does a German buyer need from me before they can book the volume? A: In practice: a scheme certificate in scope for the product and the activity, a complete sustainability declaration consistent with the physical documents, the agreed biomass code, the greenhouse gas saving with the basis it was calculated on, and confirmation of who the seller of record is. If the seller on the declaration does not match the seller on the invoice, the entry stalls. Q: Does Nabisy disappear now that the Union Database exists? A: The Union Database changes how sustainability data moves across the EU, and the relationship between it and national systems has been evolving. Treat the current position as something to confirm with your certification body for your specific chain rather than something to read off a website, including this one. What has not changed is that a German buyer needs proof it can actually book. ============================================================================== # ERE and the Dutch fuel transition obligation URL: https://www.sustainablecommodities.eu/markets/ere-and-the-dutch-market On 1 January 2026 the Netherlands moved from an energy based obligation to a greenhouse gas based one. The annual obligation (jaarverplichting) became the fuel transition obligation (brandstoftransitieverplichting), and the tradeable unit changed from the HBE, which counted renewable energy delivered, to the ERE, where one unit represents one kilogram of avoided CO2. The Nederlandse Emissieautoriteit supervises it through the Register Energie Vervoer. For anyone selling feedstock into this market the practical consequence is direct: the GHG figure on your proof of sustainability now translates into units, and two cargoes with the same specification and different GHG values are no longer worth the same here. ## What changed on 1 January 2026 The change is easy to underestimate because a lot of the machinery looks the same: the same regulator, the same register, the same certificates. What moved is the thing the system counts. The obligation: Until 2025 Jaarverplichting energie voor vervoer, an annual obligation on the share of renewable energy.; From 2026 Brandstoftransitieverplichting, the fuel transition obligation. The unit: Until 2025 HBE, hernieuwbare brandstofeenheid. Counted energy delivered.; From 2026 ERE, an emission reduction unit. One unit is one kilogram of avoided CO2. What decides the count: Until 2025 How much renewable energy you delivered.; From 2026 How much CO2 the fuel actually avoids, which follows from the GHG value on the declaration. Which sectors: Until 2025 Mainly road transport, with exemptions elsewhere.; From 2026 Several transport sectors, and each has to decarbonise in its own right. Maritime and inland shipping are now fully inside the system. Sub-targets: Until 2025 A sub-target for advanced fuels.; From 2026 Limits and sub-targets per sector, plus a new RFNBO sub-target. Opting in: Until 2025 Possible for some deliveries.; From 2026 The opt in is gone. Registration: Until 2025 Registering deliveries created units.; From 2026 Registration and verification of fuel deliveries became mandatory. Multipliers: Until 2025 Applied to certain deliveries.; From 2026 Changed. Check the current factors before you model anything. The register itself is the Register Energie Vervoer, held by the Nederlandse Emissieautoriteit. Obligated parties settle by holding enough units in their account by the annual deadline, and they can either register their own deliveries or buy units from someone else. That second route is why the unit has a price at all. ## Why this changes what your cargo is worth This is the part that matters commercially, and it is the reason we wrote this page. Under the old unit, the GHG value on your proof of sustainability was a compliance detail. It had to be there, it had to clear the threshold, and beyond that the system counted the energy you delivered. Two cargoes of the same feedstock with different GHG values produced much the same result. Under the new unit it is the number the whole thing runs on. A unit is a kilogram of avoided CO2, so a lower GHG value on the same tonnage means more units. Your declaration stopped being paperwork and became part of the price. Three practical consequences for a seller: * Get the GHG figure calculated properly, not defaulted. Where a real calculation beats the default value for your chain, that difference now converts into units. Our Proof of Sustainability page sets out the formula and the fossil comparators. * Expect the calculation to be examined. A GHG figure that cannot be supported by the chain behind it was always a problem; now it is a commercially interesting problem, which means it gets looked at harder. * Know which threshold applies to your plant. Installations that came into operation after 1 January 2021 have to deliver at least 65 percent lower greenhouse gas emissions than the fossil comparator. Without the documentation to show it, a delivery does not count towards the obligation at all. ## Who is now inside the system that was not before The widening is the second big change and it caught people out. Suppliers to maritime and inland shipping were often exempt and are now obligated, which for many of them means dealing with the Nederlandse Emissieautoriteit for the first time. For a feedstock seller this cuts both ways. It adds demand, because a group of buyers that previously had no obligation now has one. It also adds scrutiny, because those buyers are new to the documentation and will ask questions that a road fuel supplier stopped asking years ago. Budget time for that rather than being surprised by it. ## What a Dutch buyer will ask you for The list is not longer than elsewhere in Europe, but the emphasis moved. The GHG value, and how it was arrived at: It converts into units. This is the item that moved from the back of the file to the front. A valid proof of sustainability under a recognised scheme: Without it the delivery does not count. Unchanged, and still the thing most often incomplete. The Annex IX category, Part A or Part B: It decides which sub-target the material can serve and whether the cap applies. The date the producing installation came into operation: It decides which GHG threshold applies to you. Which sector the material is destined for: Road, rail, inland shipping and maritime each carry their own obligation now. Traceability of the collection chain: Unchanged in principle, and examined more closely as the value of the unit rises. For the certification side of that list, see ISCC certification and Annex IX feedstocks. For how the Dutch position compares with the German one, our Nabisy and the German market page covers the greenhouse gas quota and the proof registry there, which is a different system solving a similar problem. ## What we do with this We broker feedstock and renewable fuel into Dutch buyers, and we sit close enough to this market to tell you plainly whether an offer will clear here or whether it belongs somewhere else. We are based in the Netherlands, which is the reason we can, and it is not a claim we make about every market we work in. What we do not do is publish unit prices or advise on trading them. The Nederlandse Emissieautoriteit publishes the rules and the register, obligated parties trade the units, and we work on the physical side. If you want to know where a specific parcel is likely to clear, send the specification, the origin, the volume and the GHG value, and you get a read rather than a number. ## Sources * Nederlandse Emissieautoriteit, the main changes under RED III: https://www.emissieautoriteit.nl/regelgeving/hernieuwbare-energie-voor-vervoer-eres/ontwikkelingen/belangrijkste-red3-veranderingen * Dutch Emissions Authority, Renewable Energy for Transport (English): https://www.emissionsauthority.nl/topics/renewable-energy-for-transport/general---renewable-energy-for-transport * RVO, hernieuwbare energie voor vervoer: https://www.rvo.nl/onderwerpen/bio-energie/hernieuwbare-energie-vervoer * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj ## Frequently asked questions Q: What is an ERE? A: An emission reduction unit, the tradeable unit in the Dutch fuel transition obligation since 1 January 2026. One unit represents one kilogram of avoided CO2. It replaced the HBE, which counted renewable energy delivered rather than emissions avoided. Q: What happened to the HBE? A: It was replaced by the ERE on 1 January 2026, as part of the Dutch implementation of RED III. The Nederlandse Emissieautoriteit sets out the change and the other differences, including sub-targets per sector, the end of the opt in, and changed multipliers. Q: Does this change what my UCO is worth in the Netherlands? A: It changes what decides the value. The unit now counts avoided CO2, so the GHG figure on your proof of sustainability translates into units in a way it did not before. Same tonnage, same specification, lower GHG value: more units. Q: Do shipping fuel suppliers now have an obligation? A: Maritime and inland shipping are fully inside the system from 2026, where suppliers to those sectors often had an exemption before. Q: What GHG threshold applies to my plant? A: Installations that came into operation after 1 January 2021 have to show at least 65 percent lower greenhouse gas emissions than the fossil comparator. Which comparator applies depends on the end use; the figures are on our Proof of Sustainability page. Q: Do you publish the ERE price? A: No. We do not publish price assessments of any kind. Units are traded by obligated parties and there are established venues for that. We work on the physical side and can tell you where a specific parcel is likely to clear. Q: Can you introduce us to Dutch buyers? A: That is what we do. Send the specification, the origin, the monthly volume and the certification, and we will tell you plainly whether it clears here. ============================================================================== # The Union Database, and what it asks of your supply chain URL: https://www.sustainablecommodities.eu/markets/union-database-udb The Union Database exists so that a litre of renewable fuel can be traced across the European Union without being counted twice. Under the Renewable Energy Directive, economic operators record consignments and transfers in it, so that a volume claimed in one member state cannot also be claimed in another. It does not replace your scheme certification: you still need ISCC, REDcert or another recognised scheme, and the database records what that certification supports. The rollout has been phased and the detail differs by member state and by fuel type, so the useful preparation is not to memorise a deadline but to make sure your own records can survive being matched against somebody else's, consistent quantities, consistent feedstock categories, and a defensible greenhouse gas figure at every transfer. ## What problem it is solving The European waste-based market grew faster than the systems tracking it. Sustainability proof moved as documents between private parties, which worked well enough within one chain but made cross-border checking hard. If the same volume was declared to two authorities, nothing in the system necessarily caught it. The Union Database is the answer to that: a single place where consignments and their transfers are recorded, so a claim in one member state is visible against a claim in another. Whatever you think of the administrative load, the intent is one most honest participants in this market share, because fraud in waste feedstock hurts the people doing it properly first. ## It does not replace your certification This is the most common misunderstanding, and it is worth being blunt about. The database records data; the scheme certifies the operator and the chain. You need both, and one does not substitute for the other. In practice the database asks for information you should already hold if your certification is in order. Which is the useful way to think about preparation: if entering your data into a shared system worries you, the problem is usually upstream of the database. ## What actually has to be right at every transfer The detail of who registers what, and when, has been phased in and varies by member state and fuel type. Rather than restate a timetable that may have moved by the time you read this, here is the part that does not change: the data has to reconcile with somebody else's data. That is a higher bar than it sounds. A rounding difference between the declaration and the bill of lading, a feedstock described one way at collection and another at the refinery gate, a greenhouse gas figure carried forward without the basis it was calculated on, all of these survive fine in a paper chain and fail in a matched one. * Quantities that reconcile across the declaration, the bill of lading and the invoice. * Feedstock category described consistently from collection to delivery, with the same words at each step. * Greenhouse gas figures carried with the basis they were calculated on, not just the number. * Counterparty identity matching between the declaration, the contract and the invoice, the same trap that stalls Nabisy entries. * Certificate scope covering the activity being recorded, not just the product. ## What to do before it reaches you The most useful preparation is unglamorous and pays off regardless of what the database eventually requires of you specifically. None of this is database-specific. It is what a well-run chain looks like, and the database simply makes the gaps visible. * Ask your certification body what applies to your role, in your member state, for your product. That answer is specific and it changes; a website cannot give it to you, including this one. * Reconcile your own documents first. Take three recent consignments and check that quantities, categories and parties match across every document. If they do not, that is your homework. * Fix the vocabulary. Agree one description per feedstock and use it everywhere, including in contracts. * Keep the calculation, not just the number. A greenhouse gas figure without its basis is not defensible when someone asks. * Talk to your counterparties. Your data has to match theirs, so the conversation is worth having before the system has it. ## Why we wrote this page A buyer asked us, in writing: they had searched this site for information on the Union Database in the HVO chain, not found it, and emailed instead. That is a fair complaint about a site that claims to explain this market, so the gap is closed. Where the answer depends on your member state, your role or your fuel type, this page points you at your certification body rather than guessing on your behalf, a confident wrong answer about a compliance obligation is worse than no answer at all. ## Sources * European Commission, Union Database for Biofuels: https://energy.ec.europa.eu/topics/renewable-energy/bioenergy/biofuels/union-database-liquid-and-gaseous-renewable-and-recycled-carbon-fuels_en * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * ISCC EU system documents: https://www.iscc-system.org/certification/iscc-documents/ ## Frequently asked questions Q: What is the Union Database? A: It is the European system for recording biofuel consignments and their transfers, introduced under the Renewable Energy Directive so that a volume claimed in one member state cannot also be claimed in another. It records data about consignments that your scheme certification supports; it does not certify anything itself. Q: Does the Union Database replace ISCC or REDcert? A: No. The scheme certifies the operator and the chain of custody; the database records the resulting consignment data so it can be matched across borders. You need both, and the database generally asks for information you should already hold if your certification is in order. Q: What do I have to do to prepare? A: Ask your certification body what applies to your role, your member state and your product, because that answer is specific and it changes. Then do the part that helps regardless: reconcile quantities, categories and counterparty names across the declaration, bill of lading and invoice for a few recent consignments, and fix whatever does not line up. Data that survives being matched against someone else's is the whole game. Q: What are the requirements for UDB in an HVO supply chain? A: The registration and reporting detail has been phased in and differs by member state and fuel type, so confirm your own position with your certification body rather than reading it off a page. What holds in every version is that each transfer has to reconcile: quantities consistent across documents, feedstock described the same way from collection to refinery gate, the greenhouse gas figure carried with its calculation basis, and the counterparty identity matching between declaration, contract and invoice. Q: Who has to register? A: Economic operators in the chain, with the specifics depending on your role and member state. If you are a collector, processor, trader or fuel supplier, assume the question applies to you and get a definite answer from your certification body rather than assuming somebody downstream will handle it. Q: What is the most common problem people hit? A: Data that does not reconcile. A rounding difference between the declaration and the bill of lading, a feedstock described one way at collection and another at delivery, or a greenhouse gas figure passed on without its basis. All of these survive fine in a paper chain and fail the moment two records are matched against each other. Q: How does it relate to national systems like Nabisy? A: The Union Database changes how sustainability data moves across the EU, and its relationship with national systems has been evolving. Confirm the current position for your specific chain with your certification body. What has not changed is that the national authority still needs proof it can book, and that proof still starts with your certification and your documents. Q: Will this make fraud harder? A: That is the intent, and cross-border matching does close a gap that document-based proof left open. It is not a complete answer on its own, data entered consistently can still describe something that never happened, which is why audit and physical verification still matter. But double counting across member states gets considerably harder, and that is worth something to everyone trading this material honestly. ============================================================================== # EXW, FOB, CIF or DAP: what each price actually includes URL: https://www.sustainablecommodities.eu/markets/delivery-terms-cif-fob-dap A price means nothing without the basis it sits on. EXW is the material at the seller's gate and nothing else. FOB adds getting it to the load port and on board, and the risk passes there. CIF adds sea freight and insurance to a named discharge port, but not discharge, duty or delivery inland. DAP goes further: the seller carries it to a named place, usually the buyer's tank or refinery gate, with import clearance still on the buyer. In waste-based feedstock, CIF ARA is the working reference for Europe because that is where the demand and the published assessments sit; an origin like FOB Brazil or EXW at a mill is what a seller usually starts from. The gap between those two numbers is freight, insurance and the cost of getting to the ship, and it is where most misunderstandings live. The official definitions are the ICC's Incoterms® rules; what follows is what they mean in practice for these cargoes. ## The four you will actually be quoted There are eleven Incoterms® rules. In waste oils, fats and renewable fuels you will meet four of them most of the time, and the difference between them is simply how far down the chain the seller's price reaches. The practical reading: each step adds cost and moves the point where things become your problem. Two offers are only comparable once they are on the same step. * EXW, the material where it stands, at the mill, the collector's yard or the tank. Loading, transport, export formalities and everything after are the buyer's. The cheapest headline number and the least included. * FOB, the seller delivers on board at a named load port and clears it for export. Risk passes when it is on board. Freight and insurance from there are the buyer's. * CIF, FOB plus sea freight and marine insurance to a named discharge port. Note the trap below: risk still passes at loading, not on arrival. * DAP, the seller delivers to a named place, often a tank or a refinery gate, ready for unloading. Import clearance and duty stay with the buyer unless the contract says otherwise. ## Getting from EXW to FOB to CIF: what you add This is the question we are asked most, in almost these words: what do I add to make this an FOB number, or a CIF one. There is no fixed percentage, the figures move with route, parcel size and packing, but the list of what you are adding does not change. The two that surprise people are packing and the load port charges. A parcel that moves in flexitanks or ISO tanks carries a completely different cost structure from a bulk vessel, and terminal handling at the load port is often quoted separately when it was assumed to be included. Ask for the basis and the port in the same sentence as the price. "1,070 FOB" is not a price until you know which port. * EXW to FOB: inland transport to the port, loading, export clearance and documents, terminal handling at load, and any tank or storage cost in between. * FOB to CFR: the sea freight for that route and parcel size. * CFR to CIF: marine cargo insurance, normally to 110 per cent of invoice value. * CIF to DAP: discharge, onward transport to the named place, and any storage while it waits. Duty and import formalities stay with the buyer. * Not automatically in any of them: inspection and survey, demurrage, quality claims, and financing cost. ## The CIF trap: risk passes at loading, not on arrival Under CIF the seller pays the freight and the insurance, so it is natural to assume the seller carries the cargo until it arrives. It does not work that way. Risk passes when the goods are on board at the load port, the same as FOB. What CIF adds is that the seller has paid for the carriage and taken out insurance for the buyer's benefit. The practical consequence: if something happens to the cargo at sea, it is the buyer who claims on that insurance, and the buyer who still owes the price. That is why the insurance clause and the certificate matter, and why "CIF, so it is your problem until it lands" is a sentence that has cost people money. Read that alongside where quality is determined. A contract can pass risk at loading and still determine quality at discharge, or the other way round. Those are separate clauses and both need to be right, see our page on cargo claims. ## Laytime and demurrage, and who ends up paying Demurrage is what the buyer or the seller owes when loading or discharging takes longer than the contract allows. Laytime is the allowance itself. In practice this is the cost that appears out of nowhere on a trade that otherwise went fine. It behaves differently by cargo type. On a bulk vessel the laytime and rate are negotiated and written into the contract, and the clock is governed by the notice of readiness. On containers and ISO tanks the equivalent is detention and demurrage at the terminal, which accrues quietly per day per unit and is invoiced later, the question in our own inbox was about exactly that: how long the boxes had been standing. What to fix before loading: how much time is allowed, from when the clock starts, what stops it, and the rate. If a contract is silent on those, somebody is going to be surprised. ## Who pays the surveyor, and why it is worth settling early An independent surveyor draws and seals the samples, checks quantity and issues the report both sides rely on. The cost is small next to a cargo and it is the cheapest insurance in the trade, so the argument about who pays it is rarely about the money. Common practice is that the party appointing the surveyor pays, often split, and that the load port survey and the discharge survey are separate appointments. What matters more than the split is that both sides accept the surveyor before the cargo moves, and that retained samples are kept and sealed. A dispute where each side has its own laboratory result and no agreed retained sample is a dispute without a referee. ## Where payment terms fit in The delivery term says who does what; the payment term says when money moves against which documents. They are separate and they need to line up. Cash against documents is the common one: the buyer pays when the document set arrives complete. A letter of credit adds a bank's undertaking and, with it, a list of documents that has to match to the letter. In this trade that list almost always includes a sustainability declaration alongside the bill of lading, invoice, packing list and certificate of analysis. Agree the document list before loading, not after. More payment disputes start with a document that nobody named in advance than with a party unwilling to pay, see proof of sustainability for what belongs in that set. ## A note on the source The Incoterms® rules are published by the International Chamber of Commerce and their exact wording is the authority. This page is a practical reading for these cargoes, not a substitute for that text or for legal advice on your contract. Where a contract references a rule, it should say which edition. If your counterparty writes only "CIF" with no year and no named port, that is worth one email to fix before it becomes worth a lawyer. ## Sources * International Chamber of Commerce, Incoterms® rules: https://iccwbo.org/business-solutions/incoterms-rules/ * FOSFA, contracts and trade rules: https://www.fosfa.org/ * GAFTA, contracts and arbitration rules: https://www.gafta.com/ ## Frequently asked questions Q: What is the difference between FOB and CIF? A: FOB means the seller delivers on board at a named load port and clears the goods for export; freight and insurance onward are the buyer's. CIF is the same delivery point with the seller additionally paying sea freight and marine insurance to a named discharge port. The catch is that risk passes at loading under both: CIF does not mean the seller carries the cargo until it arrives. Q: What do I add to an EXW price to make it FOB? A: Inland transport to the port, loading, export clearance and documents, terminal handling at the load port, and any storage in between. There is no fixed percentage: it moves with the route, the parcel size and whether the cargo goes bulk, in ISO tanks or in flexitanks, and those three have very different cost structures. Q: What does CIF include, and what does it not? A: It includes the material, getting it on board, export clearance, sea freight to the named port and marine insurance, normally at 110 per cent of invoice value. It does not include discharge, import duty, customs clearance, onward transport, storage on arrival, or demurrage. Those are the buyer's unless the contract says otherwise. Q: Why is CIF ARA the price everyone quotes? A: Because Amsterdam, Rotterdam and Antwerp is where European demand and tank infrastructure concentrate, and where the published price assessments are set. It gives two parties in different countries one reference they both recognise. A seller usually starts from an origin basis instead, and the gap between the two numbers is freight, insurance and the cost of reaching the ship. Q: Who pays demurrage? A: Whoever exceeded the time the contract allowed, at the rate the contract names. On a bulk vessel that is governed by laytime and the notice of readiness; on containers and ISO tanks it shows up as terminal detention and demurrage, accruing per unit per day and invoiced afterwards. Fix the allowance, the start of the clock, what stops it and the rate before loading, because a contract that is silent on those will surprise somebody. Q: Who appoints and pays the surveyor? A: Usually the party appointing pays, frequently split between the two, with the load port and discharge surveys as separate appointments. What matters more than the split is that both sides accept the surveyor before the cargo moves and that sealed retained samples are kept. A dispute where each side has its own laboratory result and no agreed retained sample has no referee. Q: Can I quote a price as CIF if I was given it as FOB? A: Not without adding the freight and insurance for that specific route and parcel, and not without naming the discharge port. Passing an FOB number on as CIF is one of the commonest ways a trade unravels three emails later. If you are unsure what the carriage costs on that route, ask before you quote rather than after. Q: Does the delivery term decide where quality is determined? A: No, and treating them as one thing causes real disputes. The delivery term decides where risk and cost pass. Where quality is determined, at load, at discharge, or on a retained sample, is a separate contractual clause. A contract can pass risk at loading and still determine quality at discharge, and both need to be written down. Q: What documents does a letter of credit usually call for? A: For these cargoes typically the bill of lading, commercial invoice, packing list, certificate of analysis and the sustainability declaration, plus whatever else the credit names. The whole point is that the documents must match the credit exactly, so the list has to be agreed before loading. Most payment disputes start with a document nobody named in advance. Q: Which Incoterms edition applies to my contract? A: Whichever one the contract names, which is why it should name one. If your counterparty writes only "CIF" with no year and no named port, that is worth settling in one email now rather than in a dispute later. The authoritative text is published by the International Chamber of Commerce. ============================================================================== # KYC: what a buyer checks before your first cargo moves URL: https://www.sustainablecommodities.eu/markets/kyc-and-counterparty-checks Before a refiner or trading house will contract with a new counterparty, it runs you through onboarding, and until that clears, nothing moves. In practice it is a document pack: company registration and ownership, VAT and tax identifiers, bank details confirmed by the bank rather than by email, identification of the people who own and sign for the company, a sanctions and adverse-media screen, and for this trade the certification and licences that cover what you are selling. Expect it to take weeks rather than days at a large buyer, and expect it to run alongside the commercial conversation instead of after it. The single most useful thing you can do is have the pack assembled before anyone asks: the delays we see are almost never refusals, they are a missing document and a person on holiday. Once you are through at one major, say so, being cleared elsewhere is a real reference and counterparties treat it as one. ## What is actually in the pack The list varies by buyer, and a large refiner asks more than a regional biodiesel producer. What follows covers most of what gets requested, and having it in one folder turns a three-week exchange into a single email. Two of these catch people out. Bank details are almost never accepted on an emailed letterhead any more, because that is exactly what invoice fraud looks like; expect a bank-issued confirmation or a verification call. And ownership goes further than the company register: the question is who ultimately owns and controls the company, which for a holding structure means walking up the chain. * Company registration: an extract from the commercial register, recent rather than filed away from three years ago. * Ownership and control: shareholders, and the ultimate beneficial owners behind any holding company. * Identification of directors and authorised signatories, and evidence of who may sign what. * Tax and VAT identifiers, valid and matching the entity that will invoice. * Bank details, confirmed through the bank rather than by email. * Sanctions and adverse-media screening, run by the buyer on the company and the people behind it. * Certification in scope for the product and activity, ISCC, REDcert or another recognised scheme, with the annex that names the products. * Licences and permits where the material is a waste stream: collection, transport and, for cross-border movements, the notification paperwork. * Insurance and, for larger volumes, financials, recent accounts or a credit reference. ## Why it stalls, and it is rarely a refusal When onboarding drags, the cause is nearly always mechanical rather than a judgement about you. The three we see most: The pattern behind all three is the same: nobody owns the process on the supplier side. One named person who keeps the folder current and answers within a day makes more difference than anything else. * A mismatch between entities. The company on the offer is not the company on the certificate, or not the one that will invoice. Every such difference has to be explained, and each explanation costs a round trip. * A document that has expired. A certificate renewed but not sent, a register extract from two years ago, a signatory who has left. * Nobody chasing it. The buyer's compliance desk is not going to hunt you down. A form sitting half-completed in somebody's inbox is the most common reason a first cargo slips a month, and it shows up in our own correspondence in exactly those words. ## Start it in parallel, not afterwards The instinct is to agree the trade first and do the paperwork once there is something to paper. In this market that costs you the cargo, because the window on a parcel is shorter than the onboarding. Ask early and directly: *what does your onboarding need from us, and how long does it normally take?* A buyer will tell you, and the answer lets you run the two tracks side by side. It also signals that you have done this before, which is itself part of what they are assessing. Where a first parcel is time-critical, some buyers will accept a lighter check for an initial trade and complete the full file afterwards. That is their call, not yours, but it is worth asking rather than assuming. ## Being cleared somewhere is worth saying Onboarding is not transferable, every buyer runs its own, but it is a reference. A supplier who has passed the checks at a European major has demonstrably survived a serious file review, and counterparties read it that way. So say it, plainly and without naming anything you are not free to name: which kind of counterparties have onboarded you, and roughly when. It shortens the conversation and it is the sort of thing a smaller supplier undersells. We have seen it written exactly like that in a first email, and it worked. ## What the buyer is actually assessing It helps to understand what the file is for. A compliance desk is answering three questions, and everything on the list serves one of them. Notice what is not on that list: whether they like your price. Onboarding runs on a different track from the commercial conversation and is decided by different people, which is why pushing your trader contact rarely speeds it up. * Are you who you say you are, and is the entity that signs the same one that ships and invoices? * Is it lawful to trade with you, under sanctions rules and the buyer's own policy, including the people behind the company? * Can you deliver what you claim, with certification that actually covers the product and the activity, that last part is where scope problems surface, see what your ISCC certificate covers. ## Where we sit in it We are not a compliance service and we do not vet anyone on a buyer's behalf. What we do is know what each type of counterparty asks for, so the question does not arrive as a surprise, and keep both sides moving while the file is with the compliance desk. Practically: we tell you what to have ready before an introduction, we flag the entity and scope mismatches that stall files before they are sent, and when onboarding goes quiet we ask. That is unglamorous and it is where a fair number of first cargoes are saved. ## Sources * European Commission, EU sanctions map: https://www.sanctionsmap.eu/ * Wolfsberg Group, correspondent banking and due diligence principles: https://db.wolfsberg-group.com/ * ISCC EU system documents: https://www.iscc-system.org/certification/iscc-documents/ ## Frequently asked questions Q: What documents do I need for KYC as a supplier? A: Typically a recent commercial register extract, ownership down to the ultimate beneficial owners, identification of directors and authorised signatories, valid tax and VAT identifiers matching the invoicing entity, bank details confirmed through the bank, and your certification with the annex that names the products. For waste streams add collection and transport permits, and for cross-border movements the notification paperwork. Larger volumes often bring a request for recent accounts or a credit reference. Q: How long does onboarding take at a large buyer? A: Weeks rather than days, and longer if anything has to be chased. The review itself is not slow; the round trips are. Every mismatch between the entity on the offer, the certificate and the invoice costs another exchange, and a half-completed form sitting in somebody's inbox costs the most of all. Q: Can I start trading while KYC is still running? A: That is the buyer's decision, not yours. Some will accept a lighter check for a first parcel and complete the full file afterwards; others will not move at all. It is worth asking rather than assuming, and worth asking early, because the window on a parcel is usually shorter than the onboarding. Q: Why does the buyer want to know who owns my company? A: Because sanctions rules and their own policy apply to the people behind a company, not only to its name. A company register shows the immediate shareholder; the question is who ultimately owns and controls it, which for a holding structure means walking up the chain until you reach people. Q: Does being KYC cleared at one buyer help with another? A: It does not transfer, every counterparty runs its own, but it is a real reference. Passing a serious file review at a European major says something, and counterparties read it that way. Say so in a first email; smaller suppliers consistently undersell this. Q: Why is my bank letter not accepted? A: Because an emailed letterhead with account details is exactly what invoice fraud looks like, and buyers have been burned. Expect a confirmation issued by the bank itself or a verification call to a number the buyer looks up independently. It is not a comment on you. Q: The company on my certificate is not the company that invoices. Is that a problem? A: Yes, and it is the single most common reason a file stalls. It is usually explainable, a group structure, a trading entity alongside a production entity, but it has to be explained, in writing, with the relationship documented. Raise it yourself before the compliance desk finds it. Q: Can you get us through a buyer's onboarding? A: No, and nobody outside that buyer can. Their compliance desk decides and it decides independently of the commercial conversation. What we do is tell you what they will ask before they ask it, flag the entity and scope mismatches that stall files, and keep the process moving when it goes quiet. Q: What if I am a small company with large volume? A: Say so, with the volume and the counterparties that have already onboarded you. Size is not the test; the file is. Plenty of small companies move serious tonnage and clear onboarding at majors, and a compliance desk is looking at whether your documents hold together, not at your headcount. Q: Does certification replace KYC? A: No. They answer different questions. Certification says the material and the chain meet a scheme's requirements; onboarding says the buyer knows who you are and may lawfully trade with you. You need both, and a certificate whose scope does not cover the product will fail the second check even though it passed the first. ============================================================================== # EUDR and waste-based feedstocks: what is in scope, and what is not URL: https://www.sustainablecommodities.eu/markets/eudr-deforestation-regulation The EU Deforestation Regulation (EUDR) applies from 30 December 2026 for large and medium operators, and from 30 June 2027 for micro and small ones. It covers cattle, cocoa, coffee, oil palm, rubber, soya and wood, and a long list of derived products. For our markets the practical question is palm: palm oil and products made directly from it, such as PFAD, are in scope, while genuine waste and residue streams such as used cooking oil are not. The cut-off date is 31 December 2020: material from land deforested after that date cannot enter the EU at all, whatever the paperwork says. If you trade palm-derived feedstocks, you need the geolocation of the plots and a due diligence statement in the chain; if you trade UCO or tallow, you mainly need to be able to show the material is what it claims to be. ## The dates, and why they moved twice The regulation was adopted in 2023 and was originally meant to apply from the end of 2024. It has been postponed twice: first to 30 December 2025, then by a second delay to the dates that now stand. The reason both times was readiness, of the EU's own systems and of operator chains. The dates as they stand now: * 30 December 2026 -- the EUDR applies to large and medium operators and traders. * 30 June 2027 -- application for micro and small operators. * 31 December 2020 -- the deforestation cut-off date. Land deforested after this date produces material that is not deforestation-free, no matter who certified it. * In May 2026 the Commission published a simplification package easing parts of the compliance burden. The core obligations, geolocation and due diligence, are unchanged. ## What is actually in scope for feedstock traders The EUDR attaches to commodities and to derived products listed by CN code in its annex. For the oils and fats market that creates a line that matters commercially, because two feedstocks that look similar in a tank are treated completely differently. Palm oil, palm kernel oil: In scope. Needs plot-level geolocation and a due diligence statement. PFAD and palm-derived acid oils: In scope: produced directly from the regulated commodity. This is the one that surprises people, because the material itself is a processing residue. Soapstock and acid oils from other regulated oils (soy): In scope where produced from a regulated commodity. Used cooking oil (UCO): Out of scope. Waste and used products are excluded from the regulation's product scope. Animal fats and tallow (categories 1, 2, 3): Out of scope. Not derived from a regulated commodity. POME: Out of scope as palm oil mill effluent, a waste stream. The classification paperwork still needs to be watertight, because 'derived from palm' is exactly what a customs officer sees at first glance. ## What in-scope actually requires In-scope material needs three things, and all three have to come from the supply side, which is why buyers push them down the chain early. Geolocation: latitude and longitude of every plot the material came from, plus the date or time range of production. Aggregated claims do not satisfy this for plots over four hectares. A due diligence statement: filed in the EU's TRACES system, referenced down the chain. Whoever places the product on the EU market carries the obligation, and reference numbers follow the cargo. Country classification: the Commission grades source countries by risk (low, standard, high), which sets how deep the diligence has to go. Simplified checks only exist for low-risk origins. The enforcement side has teeth: penalties can run to at least 4% of total annual EU turnover for the worst violations, plus confiscation. That is why buyers treat EUDR paperwork as a condition of the deal, not an afterthought. ## The trap: material that straddles the line The commercial risk in our markets is not usually the clearly in-scope palm cargo. It is the stream whose paperwork describes it as a residue while its chemistry says otherwise, or the UCO collector whose intake is not documented well enough to rebut a palm assumption. The May 2026 Commission clarifications confirm the principle: only products produced directly from the regulated commodity fall in scope, which helps genuine waste streams, but the burden of showing that sits with the chain. Practically: if you sell acid oils, soapstock or PFAD, get the origin and CN story straight before the cargo is nominated, because retrofitting geolocation after a deal is agreed is close to impossible. If you sell UCO or tallow into the same buyers, expect them to ask anyway, and have the intake documentation ready. ## Sources * European Commission, Regulation on Deforestation-free products (official page, application dates): https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en * Regulation (EU) 2025/2650 (second EUDR postponement) on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2025/2650/oj * Regulation (EU) 2023/2746 (the EUDR itself) on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2023/2746/oj ## Frequently asked questions Q: Does the EUDR apply to used cooking oil? A: No. Waste and used products sit outside the regulation's product scope, so UCO does not need geolocation or a due diligence statement. The practical catch is that buyers and customs see a vegetable-type oil and may ask; documented intake (when it became waste, from what sources) answers that without drama. Q: Is PFAD in scope of the EUDR? A: Yes. PFAD is produced directly from palm oil, which is a regulated commodity, and it is listed among the derived products. Being a processing residue does not take it out of scope. PFAD deals need plot geolocation and a due diligence statement from 30 December 2026. Q: We are a small company. Do we get the 2027 date? A: Company size is measured by the EU's standard definitions (staff headcount, turnover, balance sheet), not by cargo size. A small trader placing in-scope product on the EU market gets 30 June 2027, but the material still has to be deforestation-free against the 2020 cut-off, so the supply-side data cannot wait. Q: What happens if the paperwork is missing at the border? A: In-scope product without a valid due diligence statement reference cannot be placed on the market, and the consequences scale from confiscation to fines of at least 4% of EU turnover for serious breaches. In practice the cargo sits, demurrage runs, and the deal turns into a claims file. Q: Does ISCC certification cover EUDR? A: No, they are separate regimes. An ISCC document says something about sustainability claims and chain of custody; the EUDR due diligence statement is a legal filing with geolocation behind it. Some of the same field data feeds both, which is why buyers like collecting it once, properly. ============================================================================== # Who buys crude tall oil in Europe URL: https://www.sustainablecommodities.eu/markets/who-buys-crude-tall-oil-in-europe European crude tall oil is bought by a short list of players: fractional distillers who split it into tall oil fatty acids (TOFA), distilled tall oil (DTO), rosin and pitch; tall-diesel plants that turn it into renewable fuel; and rosin-chemistry producers who consume the derivatives. The distilling capacity sits concentrated in Finland and Sweden, close to the Nordic kraft mills that produce the crude. That concentration is the practical fact of this market: a handful of real buyers, long relationships, and price talk built around the fatty-acid/rosin split rather than a single benchmark. If you sell CTO, you are not looking for a market, you are looking for the right two or three names for your specific crude -- and that is what we do all day. ## The buyers, by type Crude tall oil is not an end product. Everything about who buys it follows from what it is split into, because the economics of a distiller live in the yield of each fraction. Fractional distillers: Forchem in Rauma (Finland) and the Nordic distillation base generally: they buy crude and sell TOFA, DTO, rosin and pitch onward. The fatty-acid to rosin ratio of your crude decides what they pay. Tall-diesel and fuel outlets: SunPine in Pitea (Sweden) distills CTO into a renewable diesel component and rosin. Fuel outlets value the renewable, waste-based origin under certification. Rosin and chemistry producers: Kraton and derivative consumers such as adhesive, tyre and ink chemistry: they buy the distilled fractions rather than crude, but they set the pull that keeps distillers buying. Oleochemical and paper-chemistry buyers: Kemira and similar: tall oil derivatives into sizing agents and chemicals. Steady, spec-driven demand. Traders and brokers: The Nordic crude market also moves through traders, including US-origin crude imported into Finland and Sweden when local supply is short. ## What a CTO buyer screens on A distiller buys yield, so the first numbers are about the split, not the price. Acid number is the headline quality figure: it tracks the fatty and rosin acid content together, and low-acid crudes are worth less because more of the barrel is unsaponifiables and pitch. The fatty acid to rosin ratio decides which fractions pay. TOFA-led crudes and rosin-led crudes go to different buyers, and blending two crudes to hit a buyer's sweet spot is normal practice. Water and solids from the soap-skimming process matter: they steal paid-for tonnage and freeze in Scandinavian winters. Availability pattern matters more than in most feedstocks: mills produce CTO as a by-product of pulp, so a steady monthly volume from one origin is worth a premium over spot dribs. ## Where the crude comes from, and why that shapes the buyers CTO is a by-product of the kraft pulping process: tall oil soap is skimmed from black liquor and acidulated into crude. That ties supply to the pulp cycle, not to demand. The big sellers are the Nordic pulp producers -- Metsa, UPM, Stora Enso, Soedra -- who either run their own derivative capacity or sell the crude. The consequence for a seller outside the Nordics is that the buying side is thin and relationship-driven. When Finnish and Swedish distillers are long, imported crude (US-origin arrives in meaningful volumes in strong years) is the first thing they do not need. When they are short, the same cargo is suddenly interesting. Knowing which state the market is in, this month, is most of the job. ## Sources * Forchem, tall oil refining in Rauma, Finland: https://www.forchem.com/ * SunPine, tall oil diesel in Pitea, Sweden: https://www.sunpine.se/ * Directive (EU) 2023/2413 (RED III), Annex IX on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * Our crude tall oil product page: specification and routing: https://www.sustainablecommodities.eu/markets/crude-tall-oil ## Frequently asked questions Q: Can a pulp mill outside Scandinavia sell crude tall oil into Europe? A: Yes, but the realistic buyers are the same handful of distillers and fuel outlets, and they will screen the crude on acid number and split before anything else. Volume pattern matters: a steady monthly flow from one mill is placeable, a one-off tank often is not, and we will say which one you have. Q: Is crude tall oil priced off a public benchmark? A: Not cleanly. Price references for tall products are published by price reporting agencies such as Argus, but crude deals are negotiated on the split, the acid number and freight. If someone quotes you a flat number for CTO without asking those, they are guessing. Q: Does crude tall oil count as a waste-based feedstock? A: It is listed in Annex IX Part B of the Renewable Energy Directive, so its fuel outlets sit under the Part B cap -- that matters to tall-diesel buyers, and it is worth knowing before you assume a renewable premium. Q: What is the difference between crude and distilled tall oil? A: Crude is the acidulated soap straight from the mill. Distilled tall oil and the fractions (TOFA, rosin, pitch) are what distillers make from it. Selling crude means selling to distillers; selling fractions means selling to chemistry -- a different buyer list entirely. ============================================================================== # RED III quotas and caps: what changes for waste oils and fats URL: https://www.sustainablecommodities.eu/markets/red-iii-quotas-and-caps RED III, the EU Renewable Energy Directive, keeps waste oils and animal fats in a capped box. Feedstocks in Annex IX Part B -- used cooking oil, categories 1 and 2 animal fats -- count toward a member state's renewable transport target, but only up to 1.7% of transport energy per country, with the option for a member state to ask the Commission to raise its cap. At the same time the directive raises the overall transport target to 29% renewable energy by 2030 (or a 14.5% greenhouse-gas-intensity reduction) and sets a combined sub-target of 5.5% for advanced biofuels and RFNBOs, including a binding 1% RFNBO share. The practical effect for a seller: demand for Part B material stays strong but is structurally capped, while the growth premium sits with Part A feedstocks -- and with the national implementation choices that each member state is making right now. ## The architecture, in one view The directive works like nested buckets. Material counts toward the overall transport target unless it is capped or excluded; some feedstocks count double; and separate sub-targets must be met with specific material. Where your feedstock sits in that structure decides who wants it and how hard. Annex IX Part A (advanced): Counts toward the 5.5% combined advanced/RFNBO sub-target. Includes feedstocks such as algae, biomass fractions, and specific waste streams. Annex IX Part B (UCO, cat 1/2 fats): Counts toward the overall target but capped at 1.7% of transport energy per member state; a member state can request a higher cap from the Commission. Used cooking oil: Part B. Double counting applies where the member state has kept that option. The cap is the structural limit on how much UCO-biodiesel can earn. Category 1 and 2 animal fats: Part B, same cap. Category 3 fat is not in Part B and is treated differently. Food and feed crop biofuels: Frozen at 2020 levels plus a margin, capped at 7% or the 2020 share, whichever is lower per member state. RFNBOs (renewable fuels of non-biological origin): 1% binding by 2030 within the 5.5% combined sub-target. ## Why the cap matters even when it is not binding The 1.7% cap is not new in RED III -- it carried over from the previous directive -- but it now sits under a higher overall target, which changes what it does. With transport pushed toward 29% renewable by 2030, everything outside the caps has to grow faster, and the capped box becomes the marginal one. For sellers of UCO and category 1 and 2 fats this cuts two ways. Demand stays: the material still counts, still earns double in several countries, and biodiesel and HVO plants are built to run on it. But headroom above the cap earns a member state nothing, so buyers in a capped country cannot pay mandate-driven premiums for marginal Part B volume. The industry association for waste-based biofuels, EWABA, has publicly asked the Commission to revisit the cap level -- which tells you where the pressure sits. National implementation is where the real differences show up. Member states transpose the directive into their own quota systems, and several add sub-caps or country-specific rules for UCO and fats. The annual USDA GAIN overviews of EU member state biofuel mandates track those differences, and they change often enough that a current read is part of any serious feedstock conversation. ## What we tell sellers in practice If you collect or aggregate UCO, render fats, or trade acid oils, the quota system decides which buyers are hungry this quarter and which are long. Know which box your material is in. The Part A / Part B question is worth real money, and stream classifications are exactly where paperwork and reality drift apart. See our Annex IX feedstock page for the lists. Watch double counting country by country. The same cargo earns materially different value depending on where it is blended, because member states use the double-counting option differently. Sell the certificate with the cargo. Proof of sustainability is what converts a physical cargo into quota value; without it the buyer is buying feedstock, not compliance. Expect Part A premiums. The growth in the sub-targets has to come from Part A and RFNBOs, which is why advanced feedstock commands the premium it does. ## Sources * Directive (EU) 2023/2413 (RED III) on EUR-Lex: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * European Commission, RED III transposition deadline (21 May 2025): https://energy.ec.europa.eu/news/renewables-directive-sectoral-targets-reach-transposition-deadline-2025-05-21_en * EWABA position on the Annex IX Part B cap: https://biofuels-news.com/news/aligning-the-annex-ixb-cap-with-europes-climate-ambition/ * USDA FAS GAIN reports, EU biofuel mandates by member state: https://apps.fas.usda.gov/ ## Frequently asked questions Q: Does RED III ban used cooking oil as a feedstock? A: No. UCO remains eligible and counts toward renewable transport targets; it is capped, not banned. The 1.7% cap limits how much of a member state's target Part B feedstocks can cover, which affects the premium buyers can pay for marginal volume, not the legality of the trade. Q: What is double counting? A: A mechanism from the directive that lets certain waste-based fuels count twice toward the targets. Member states apply it differently, so the same certified cargo can be worth more blended in one country than in its neighbour. Q: Has RED III been implemented everywhere? A: The transposition deadline was 21 May 2025, and the Commission noted member states were required to have the transport provisions in national law by then; in practice implementation is uneven and the national systems are still moving. For a seller, that means the map of which buyer values what changes quarter by quarter. Q: Which feedstocks are in Annex IX Part B? A: The short list for our markets: used cooking oil, category 1 and 2 animal fats, and a few others including tall oil pitches and corn husks. The full lists and the practical differences are on our Annex IX feedstock page. ============================================================================== # Who buys waste PET and rPET in Europe URL: https://www.sustainablecommodities.eu/markets/who-buys-waste-pet-and-rpet-in-europe European waste PET is bought by three groups: integrated bottle-to-bottle recyclers who turn hot-washed flake into food-grade rPET pellets for their own preform production; independent recyclers and traders moving flake and pellets to converters; and polyester fibre producers who take washed flake as feedstock. The anchor buyers are names like ALPLA, whose PET Recycling Team runs food-grade capacity across Europe including a 54,000 tonne-per-year plant in Poland, and Plastipak, which is building flake-to-food-grade rPET capacity in Spain. What they pay for is not "PET" but a specification: colour, PVC and glue residues, moisture, and IV (intrinsic viscosity). A washed, single-colour flake with low PVC is a different business from a mixed bale -- and since the recycled-content rules tightened, it is the former that is in shortage. ## The buyers, by type Bottle-grade demand is where the regulation bites hardest, so the integrated players set the tone of the market. Integrated bottle-to-bottle recyclers: ALPLA and its PET Recycling Team -- food-grade rPET plants in Austria, Germany, Poland (54,000 t/yr after expansion) and Romania -- consume flake and pellets for their own preform and bottle production. Flake-to-pellet recyclers: Plastipak, with its Spanish investment converting PET flake into food-grade rPET pellets for preforms and containers. These plants are the natural home for consistent hot-washed flake. Independent recyclers and flake traders: Specialist traders (for example Dutch PET Recycling, Vanden Recycling) bridge collectors and converters, and keep flake moving when specifications sit between grades. Polyester fibre producers: Washed flake into staple fibre and filament. Food-contact rules do not apply here, so colour and purity still price the cargo but decontamination does not. Brand and converter packaging buyers: Bottlers and brand groups buying rPET pellets and food-grade flake against their recycled-content obligations. ## What a PET buyer screens on PET is a specification market: the same physical material spans a wide price range depending on a handful of numbers. Colour split is the first question: clear and light-blue bottle flake commands the food-grade premium; mixed colour goes to fibre at a discount. PVC content is the classic deal-killer in PET: parts per million of PVC char in the extruder and ruin clarity, so buyers screen bales and flake hard on it. Wash state separates a bale seller from a flake seller: hot-washed flake with low glue and label residue is what food-grade plants want; cold-washed or unwashed material sells into a different, cheaper list. IV (intrinsic viscosity) decides whether flake can go bottle-to-bottle or drops a grade; IV loss through recycling cycles is the physical limit of the loop. Food-contact status is binary: either the process and the material carry a valid decontamination and compliance position under Regulation (EU) No 10/2011, or the cargo is fibre feed, whatever the buyer calls it. ## Why demand is structural now Two EU rules anchor PET demand. The single-use plastics directive set recycled-content floors for PET bottles (25% by 2025, 30% by 2030), and the packaging regulation (PPWR) applies from 12 August 2026 with recycled-content targets that reach further into contact-sensitive packaging. Brand buyers therefore need certified post-consumer volume on multi-year horizons. The squeeze in the middle is input cost: bale prices rise with collection competition while brand buyers push for rPET at virgin-adjacent prices, and recyclers sit between the two. For a seller with consistent, well-sorted material, that squeeze is opportunity: the shortage is not in PET, it is in PET that meets spec on the first attempt. ## Sources * ALPLA, recycling division and PET Recycling Team capacity: https://www.alpla.com/en/capabilities/recycling * Plastipak, recycling investment in Spain (food-grade rPET): https://www.plastipak.com/recycling-is-top-of-the-agenda-for-plastipak-as-major-investment-announced-in-spain/ * Regulation (EU) No 10/2011 on plastic materials in contact with food: https://eur-lex.europa.eu/eli/reg/2011/10/oj * European Commission, packaging waste and the PPWR: https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en ## Frequently asked questions Q: Do buyers take mixed bales or only sorted? A: Sorted pays. A single-polymer, colour-split bale stream enters the food-grade conversation; mixed bales sell to sorting plants and fibre outlets at a discount. The step between the two is where most of the value in waste PET is won or lost. Q: Is hot-washed flake always food grade? A: No. Hot washing is a process step; food contact is a compliance status under Regulation (EU) No 10/2011 that depends on the decontamination process and its validation. Flake can be beautifully washed and still be fibre-grade legally. Buyers price the two very differently. Q: Why did my flake get rejected on PVC? A: Because PVC is the one contaminant PET extrusion does not forgive: it chars, specks and ruins clarity at parts-per-million levels, and it cannot be blended away. Buyers test for it at intake, in the bale and in the flake, and a rejection there is usually final. Q: What is rPET worth right now? A: It moves with virgin PET, bale costs and demand, and regional price assessments now exist for rPET flake in several European markets (ICIS publishes them). The honest answer for your cargo depends on colour, wash state, IV and volume -- send those and we will tell you where you sit. ============================================================================== # Who buys crude and refined glycerine in Europe URL: https://www.sustainablecommodities.eu/markets/who-buys-glycerine-in-europe European crude glycerine is bought by glycerine refiners and oleochemical plants, biogas operators -- especially in Belgium and the Netherlands -- and animal feed compounders, with biodiesel producers who refine in-house (such as Argent Energy with its technical-grade refinery) increasingly on both sides of the trade. What decides which door is open is not the word "glycerine" but three numbers: glycerol content, methanol, and ash / MONG. Refiners generally want 80%+ glycerol with low methanol and salt; biogas plants tolerate a rougher crude but price it as a substrate; feed has its own purity rules. Europe takes roughly a third of world glycerine output, and after the price cycle of recent years buyers are selective: a well-specified crude sells, a vague one does not. ## The buyers, by type Glycerine comes onto the market as a by-product: every tonne of biodiesel or HVO made from fats and oils brings glycerine with it. The buying side is therefore a disposal-and-upgrading market, and the buyers sort cleanly by specification. Glycerine refiners and oleochemicals: Players such as Emery Oleochemicals and the wider oleochemical base upgrade 80%+ crude into refined grades for pharma, personal care and chemistry. Low methanol and low ash protect their equipment; that is what the premium pays for. Biodiesel producers with own refining: Argent Energy built Europe's largest technical-grade bio-based glycerine refinery on its own waste-based crude. Integrated players are both sellers of crude and buyers of it, depending on the plant. Biogas operators: Strong demand in Belgium and the Netherlands, where waste-based glycerine is a valued digester substrate. The roughest crudes still sell here, priced as energy. Animal feed compounders: Glycerine as an energy ingredient, subject to feed purity rules. Volume buyer of suitable crude, but documentation has to be right. Traders and brokers: The crude market moves largely through specialists who match producer specs to refiner slots; small producers rarely ship direct. ## The three numbers that decide your buyer Glycerol content is the headline: 80% crude is the refiner threshold, and below it the cargo drifts to biogas pricing. The gap between 75% and 82% material is real money per tonne. Methanol is carried over from biodiesel production and is the impurity refiners fear most for their columns; feed and biogas have their own limits. A crude with high methanol sells itself out of the best doors. Ash, salt and MONG (matter organic non-glycerol) decide how much of your tonnage is actually product. Soaps and catalyst residues from transesterification end up here; a washing step upstream moves the cargo a grade. Bring those three numbers and a buyer list becomes short and specific. Bring only 'I have glycerine' and the answers you get will be discounts. ## What the market looks like from the producing side Because glycerine is a by-product, its supply moves with biodiesel and HVO runs, not with glycerine demand -- and renewable diesel growth has added volume. Prices cycled down hard from their 2022 peak, and the market is selective: well-specified, consistent crude finds slots; inconsistent material hunts for a home. For a producer, the working answer is continuity. A steady monthly volume with a stable analysis goes to a refiner on terms; one-off tanks go to whoever has a hole in their schedule. That difference, repeated every month, is most of the value a broker adds on this molecule. ## Sources * Emery Oleochemicals, oleochemical manufacturer: https://www.emeryoleo.com/ * Argent Energy, technical-grade bio-based glycerine refinery: https://www.argentenergy.com/news/argent-energy-launches-technical-grade-bio-based-glycerine/ * Our glycerine product page: specification and outlets: https://www.sustainablecommodities.eu/markets/glycerine * Directive (EU) 2023/2413 (RED III), the demand side behind biodiesel glycerine: https://eur-lex.europa.eu/eli/dir/2023/2413/oj ## Frequently asked questions Q: Can I sell glycerine below 80% glycerol? A: Yes, but into a different list. Sub-80% crude realistically sells to biogas and some feed outlets at substrate pricing, not to refiners. If the volume justifies it, upstream changes in the transesterification and washing step can move the crude a grade -- worth knowing before you sell, not after. Q: Does waste-based glycerine earn a premium? A: Not automatically as a certificate the way a PoS-bearing feedstock does; glycerine itself is not the compliance product. But its origin matters to buyers: biogas operators in Belgium and the Netherlands specifically value waste-based glycerine, and that is where origin shows up in the price. Q: Why do refiners reject high-methanol crude? A: Methanol is volatile, flammable and poisons the refining step; it also has to be stripped and handled as emissions. A crude with high methanol is a handling problem before it is a product, so refiners screen it first and price it last. Q: Is refined glycerine worth producing myself? A: Only above serious volumes and with a stable crude: refining is capital and quality-systems heavy, and the integrated players have scale. Most producers we work with sell crude well and leave the refining margin to those built for it. ============================================================================== # Who buys waste plastics in Europe URL: https://www.sustainablecommodities.eu/markets/who-buys-waste-plastics-in-europe European waste plastics are bought by two camps that increasingly compete for the same tonnes: mechanical recyclers, who want sorted single-polymer fractions, and chemical-recycling plants, who want mixed polyolefin feed to turn into pyrolysis oil and back into plastics. Around them sit the big waste groups (Veolia, SUEZ, Paprec, Morssinkhof, Mueller-Guttenbrunn) with their own sorting and recycling capacity, and the chemical side -- Plastic Energy, Eni Versalis with its Hoop plants, ExxonMobil and INEOS -- building outlets for mixed plastic waste. The sorting step decides which camp your material belongs to: a clean PP or PE stream is mechanical-recycling business; a washed mixed polyolefin fraction is chemical-recycling feed; an unsorted dirty mix is, honestly, an energy-recovery conversation. Prices across those three outcomes differ more than most sellers expect. ## The buyers, by type The plastics market splits first on polymer and form, and the buyer lists barely overlap between the fractions. Mechanical recyclers and waste groups: Veolia, SUEZ, Paprec, Morssinkhof, Mueller-Guttenbrunn and the wider recycling base: they buy sorted single-polymer bales and regrind (PP, HDPE, LDPE, PS, PET is its own market) and sell recyclate to converters. Chemical recycling / pyrolysis plants: Plastic Energy, Eni Versalis (Hoop), ExxonMobil and INEOS O&P are building and running capacity that takes mixed polyolefin waste as feed and turns it into oil or circular monomers. Converters and brand buyers: Manufacturers running recyclate into products, and brand groups buying recycled polymer against recycled-content commitments. Exporters and traders: Movement to non-OECD countries is tightly restricted under the Basel plastic amendments and the EU waste shipment rules, so the export door is narrow and paperwork-heavy -- the buyers who matter are inside Europe. ## What each camp screens on Mechanical buyers screen on polymer purity and form. A single-polymer, single-form stream (film with film, rigids with rigids) holds its value; cross-contaminated mixed loads drop a grade or exit the list. Moisture, dirt and bale density all price into the discount. Chemical-recycling buyers screen on input chemistry. Mixed polyolefins are welcome; PVC and PET in the feed are the enemies (chlorine and oxygen in the reactor), so even the 'anything plastic' buyer has a specification. Everyone screens on halogens. Chlorine from PVC and flame retardants is the common deal-killer across both camps -- it corrodes extruders and poisons pyrolysis catalysts alike. Volume and continuity decide terms everywhere: a steady sorted flow from one source gets contracts; one-off mixed loads get spot discounts. ## Where the market is tightening Two things changed the demand side recently. Recycled-content rules (the packaging regulation applies from 12 August 2026) pull sorted recyclate into packaging, raising the price of good fractions. And chemical-recycling plants coming online in Germany, the Netherlands and France now compete for mixed plastic waste that used to be cheap -- market watchers including ICIS describe the competition for mixed feedstock as intensifying. For a seller that means the worst material is still worth little, but the middle improved: washed mixed polyolefin that used to beg for a home now has plants built around it. The sorting investment question (do I sort finer, or wash and sell mixed?) is genuinely live, and the answer moves with local plant capacity. ## Sources * Veolia, plastics recycling: https://www.veolia.com/en/solutions/plastics-recycling-ecological-emergency * Regulation (EU) 2024/1157 on shipments of waste (export rules): https://eur-lex.europa.eu/eli/reg/2024/1157/oj * European Commission, packaging waste and the PPWR: https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en * Our waste plastics product page: https://www.sustainablecommodities.eu/markets/waste-plastics ## Frequently asked questions Q: Can I still export mixed plastic waste outside Europe? A: Only within narrow limits. The Basel Convention plastic amendments and the EU waste shipment regulation restrict plastic waste exports, especially mixed and contaminated loads to non-OECD countries. In practice the real buyer list for European material is European. Q: Why is PVC such a problem in every stream? A: Chlorine. It releases hydrochloric acid when heated, corrodes extrusion and pyrolysis equipment, and ruins recyclate quality at low levels. That is why both mechanical and chemical buyers screen for it first, and why PVC-free certification of a stream is worth money. Q: Is chemical recycling better paid than mechanical? A: Not inherently -- it is a different feedstock. Clean single-polymer fractions still earn the mechanical premium where recyclate demand is strong. Chemical recycling raised the floor for mixed material that mechanical could not use. Which side of that line your material sits on is a sorting question. Q: What should a first offer to a buyer contain? A: Polymer split, form (bale, film, regrind, flake), origin, estimated monthly volume, contamination level and photos. Offers missing the polymer split get answered with the lowest number the buyer can defend, because that is the risk they are pricing. ============================================================================== # Who buys biodiesel (FAME) in Europe URL: https://www.sustainablecommodities.eu/markets/who-buys-biodiesel-fame-in-europe European biodiesel is bought by obligated fuel suppliers -- the oil majors and wholesalers who must meet renewable-energy and GHG mandates -- plus the trading community around the ARA barge hub and industrial users outside road fuel. The mandate decides the grade: waste-based UCOME (from used cooking oil) and TME (from animal fats) count toward the targets buyers are legally bound to hit, with double counting where the member state allows it, while crop-based RME sits under the food-and-feed cap. Two practical walls shape every deal: the B7 limit in the diesel standard, which caps how much FAME the road pool can physically absorb, and the 7%-or-2020-share cap on conventional biofuels. Send feedstock, EN 14214 status and proof of sustainability with the offer -- without those, a buyer cannot even price the cargo. ## The buyers, by type FAME is a compliance-driven commodity: most tonnes are bought to be blended against an obligation, not because someone woke up wanting biodiesel. That defines who the buyers are. Obligated fuel suppliers and blenders: Oil majors and road-fuel wholesalers under RED III-based national mandates: they buy the grades and volumes their blending plans need, mostly UCOME and other waste-based FAME where double counting applies. Traders at ARA and inland: The Amsterdam-Rotterdam-Antwerp barge community and inland traders moving cargo between producers, terminals and blenders. Much physical volume changes hands more than once. Non-road fuel users: Mining, construction and shipping buyers running high-blend or neat biodiesel where logistics and engines allow, often closer to industrial fuel economics than to mandate premiums. Producers short of component: Biodiesel plants themselves buy feedstock-side, but also trade finished grade when a cargo misses their outlet -- the market is smaller and more connected than it looks. ## What a FAME buyer screens on Feedstock and Annex IX status first. The same molecule from used cooking oil or from rapeseed earns different quota value; the buyer asks what it is made from before what it assays at. Proof of sustainability, without which the cargo is feedstock, not compliance. Buyers want the certificate chain in order at the time of the offer. EN 14214 and grade specifics: ester content, iodine value, cold-flow (CFPP) for the destination market, acid number, phosphorus -- a full specification, not a summary. Blend wall fit: with road diesel capped around B7 in the standard, buyers plan volumes against that ceiling; high-blend and non-road outlets price differently. Logistics: barge-parcel size at ARA, truck loading at the plant, tank condition and compatibility. FAME picks up water and degrades; storage time is a real parameter. ## What the market is doing Demand is mandate-driven and shifting grade. As member states wind down multipliers and double counting in their national implementations, blenders have moved back toward counting real waste-based volumes -- UCOME stays the workhorse grade. The European Biodiesel Board's 2025-2026 statistics show EU FAME imports falling year on year while HVO imports rose, which tells you the imported competition is on the renewable diesel side, not the ester side. For a producer, the read is: the buyer list is stable and known, the grade question (which feedstock, which Annex IX box) is worth more than any negotiation tactic, and the documentation is not overhead -- it is the product. ## Sources * Directive (EU) 2023/2413 (RED III), the mandates behind demand: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * European Biodiesel Board, statistical report 2025-2026: https://ebb-eu.org/news/ebb-statistical-report-2025/ * USDA FAS GAIN, EU biofuels annual (obligated demand): https://apps.fas.usda.gov/ * Our biodiesel product page: grades and specification: https://www.sustainablecommodities.eu/markets/biodiesel-fame ## Frequently asked questions Q: Is UCOME worth more than RME? A: Usually yes, because UCO is an Annex IX Part B feedstock that counts toward the targets (double counting applies in several countries), while RME from rapeseed sits under the conventional-biofuel cap. The exact spread moves with mandate design per country -- which is a reason to sell through someone who reads that map daily. Q: Can I sell biodiesel without a proof of sustainability? A: You can sell the physical cargo, but not into the mandate market -- without the certificate chain it is priced as heating-value material at a discount. Getting the sustainability documentation in order before offering is the cheapest upgrade in this trade. Q: Why do buyers talk about a blend wall? A: Standard road diesel in Europe accommodates up to 7% FAME (B7), so beyond a point more ester cannot physically go into the road pool. That ceiling shapes volumes and premiums, and pushes growth toward waste-based grades, non-road outlets and drop-in renewable diesel. Q: What moves FAME prices? A: Feedstock costs (UCO and fat prices lead the ester), mineral diesel and gasoil for parity, mandate demand per country, and import flows. Price reporting agencies publish FAME assessments for the ARA market; your cargo prices off those references adjusted for grade, CFPP and documentation. ============================================================================== # Who buys HVO and renewable diesel in Europe URL: https://www.sustainablecommodities.eu/markets/who-buys-hvo-in-europe European HVO is bought by obligated fuel suppliers meeting greenhouse-gas quotas -- Germany's quota step-up to 12% in 2026 is the single biggest demand driver -- plus HVO100 fleet users, aviation fuel buyers under ReFuelEU and marine buyers under FuelEU Maritime. Market watchers expect EU renewable diesel demand to grow by roughly 2.5 million tonnes across 2026, and German consumption alone is estimated around 0.65 million tonnes next year. The flip side is feedstock: with waste and residue supply short by an estimated several million tonnes, a cargo's value is set less by its chemistry than by what it was made from and what paperwork proves it. Sell feedstock (UCO, tallow, acid oils) into that gap, or sell finished HVO with a certificate chain -- those are the two ways into this buyer list. ## The buyers, by obligation HVO is a compliance molecule with a premium retail face: most tonnes are blended against an obligation, and the rest is sold as neat HVO100 to fleets that want the emission claim on their own dashboard. Obligated fuel suppliers: Blending HVO into the diesel pool against national GHG quotas; Germany's step to 12% in 2026 pulls volume, and quota-driven buyers pay for certified waste-based material. HVO100 fleet users: Logistics, waste collection, construction and public transport running neat renewable diesel (EN 15940) in unchanged diesel engines -- uptake concentrated in Germany, the Nordics and France. Aviation fuel buyers: Under ReFuelEU, fuel suppliers at EU airports must blend SAF (2% now, rising to 6% by 2030); HEFA-type renewable jet draws on the same feedstock pool and the same producers. Marine buyers: FuelEU Maritime makes the GHG intensity of bunkered fuel a cost line; renewable diesel and bio-blends are one of the routes ships take. Producers short of feedstock: The large producers (Neste, TotalEnergies, OMV) and newer plants compete for waste-based feedstock -- the side of the market where collectors and renderers sell. ## What an HVO buyer screens on Feedstock and its proof. Waste-and-residue based HVO earns its quota value; crop-based sits under caps. The certificate chain (ISCC or recognised equivalent) is not optional. Cold flow and grade: CFPP for the destination market, EN 15940 parity for neat use, and cloud point discipline for winter specifications. Contaminants: phosphorus, metals and sulphur from feedstock carryover -- a refining problem that prices feedstock before it ever becomes fuel. Logistics and continuity: HVO moves as parcels and terminals; buyers on quota timelines value contracted continuity over spot drips. ## Where the market sits now Two facts define the present: demand steps up (the German quota and the wider EU growth estimates above), and Europe has moved from renewable-diesel deficit to surplus after import flows shifted. That combination squeezes producers on product price while the feedstock gap keeps waste-based supply short -- which is exactly where a collector, renderer or aggregator has leverage. The honest read for a feedstock seller: your UCO, tallow or acid oil is wanted by the same plants whose product margin is under pressure, so the negotiation is real -- but the structural shortage is on your side of the table, and documentation quality is the lever that moves your price. ## Sources * Biofuels News / UFOP: HVO demand and the German GHG quota: https://biofuels-news.com/news/hvo-demand-surges-as-tighter-ghg-quota-rules-reshape-germanys-diesel-pool/ * ResourceWise: Europe biofuels market growth phase (HVO demand 2026): https://www.resourcewise.com/blog/europes-biofuels-market-enters-a-new-growth-phase * Directive (EU) 2023/2413 (RED III), the mandate framework: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * Our HVO product page: grades and specification: https://www.sustainablecommodities.eu/markets/hvo ## Frequently asked questions Q: Is HVO the same as biodiesel? A: No. Biodiesel (FAME) is an ester blended up to about B7 in standard diesel; HVO is a paraffinic hydrocarbon made by hydrotreating fats and oils, specified under EN 15940, that can run neat in diesel engines. Different buyers, different specifications, different prices -- see our biodiesel page for that side. Q: Why does feedstock matter so much for HVO price? A: Because the quota and mandate value of the fuel depends on what it was made from: waste and residue feedstocks earn compliance value, crop-based does not (and is capped). With feedstock short by millions of tonnes, well-documented waste material is the scarce input -- that scarcity is the price. Q: Can small feedstock suppliers sell into HVO plants? A: Yes -- through aggregation. Plants buy continuity and certified volume, not one-off drums. That is the role we play: collect, document and consolidate smaller flows into a specifiable, certifiable monthly stream. Q: What is HEFA and what does it have to do with HVO? A: HEFA (hydroprocessed esters and fatty acids) is the aviation grade of the same hydrotreating process. ReFuelEU's rising SAF mandate pulls feedstock toward aviation, which tightens the pool for road HVO -- one more reason feedstock sellers are in a strong position. ============================================================================== # Who buys fusel oil in Europe URL: https://www.sustainablecommodities.eu/markets/who-buys-fusel-oil-in-europe European fusel oil is bought by flavour-and-fragrance processors who isolate the amyl alcohols, by chemical companies using it as a solvent and intermediate, and by blenders into industrial, agro and feed applications. The material is a by-product of ethanol and spirits fermentation -- mostly isoamyl alcohol with propanol, butanol, ethanol and water -- and its value tracks one thing: the GC breakdown. A cargo rich in isoamyl alcohol feeds the fragrance chain (where the value is); a watery, ethanol-heavy mix sells as cheap solvent feed at a discount. Freight is the second gate: fusel oil moves in modest parcels, so distance to the buyer eats margin faster than in bulk liquids. Send the analysis with the offer, because buyers price the composition, not the word "fusel". ## The buyers, by application Fusel oil is a mixed-alcohol stream, and each component has its own outlet. The buyer list follows that split. Flavour and fragrance processors: Isolate the amyl alcohols (isoamyl and related C5/C6 alcohols) that feed ester production for flavours and fragrances. The highest-value outlet, and the pickiest on composition. Chemical and intermediate users: Fusel alcohols as solvents and chemical intermediates in coatings, industrial processes and derivatives. Agro and specialty formulators: Components into soaps, crop-protection formulations and similar specialty applications, tolerant of a rougher mix. Animal feed and industrial outlets: Energy and processing uses where purity requirements are lower and pricing follows bulk-alcohol value. Traders and distributors: A specialist trader layer (for example Nedstar in the Netherlands) bridges producers and end users; small producers usually sell through it rather than around it. ## What a fusel oil buyer screens on The GC breakdown is the whole conversation: isoamyl alcohol content sets the ceiling on value; ethanol and water content dilute it; propanol and butanol shift the outlet. Acidity and colour signal oxidation and contamination -- fragrance-chain buyers are strict on both. Volume and continuity: producers make fusel oil in hundreds-of-litres-per-day increments; buyers want monthly consolidated parcels. Aggregation is the market's connective tissue. Freight and packaging: isotanks and IBCs on short distances beat drums on long ones; the buyer's location is part of the price. ## Where the material comes from Fusel oil is drawn off during ethanol and spirits distillation: the higher alcohols that would otherwise contaminate the spirit are separated as a by-product stream. Supply is therefore spread across every ethanol plant and distillery, in volumes too small for most of them to market seriously -- which is exactly why the trade runs through aggregation. For a producer, two honest questions decide the outcome: is the analysis good enough for the fragrance chain, and is the volume steady enough to matter? Both are answerable with one GC printout and a production figure -- bring those and the buyer list gets short and specific. ## Sources * ScienceDirect: fusel oil overview (C5/C6 alcohols, applications): https://www.sciencedirect.com/topics/engineering/fusel-oil * Nedstar: fusel oil as solvent and chemical intermediate: https://www.nedstar.com/products/non-food/fusel-oil * Advanced Biofuels USA: learning about fusel oils (market colour): https://advancedbiofuelsusa.info/opinion-learning-about-fusel-oils * Our fusel oil product page: https://www.sustainablecommodities.eu/markets/fusel-oil ## Frequently asked questions Q: What is fusel oil worth? A: It prices off composition: cargoes rich in isoamyl alcohol command the premium (the fragrance chain pays for that component), while watery, ethanol-heavy lots trade closer to bulk solvent value. Published references are scattered; a GC breakdown plus volume gets you a real number rather than a rumour. Q: Can a small distillery sell its fusel oil? A: Yes, through aggregation -- buyers take consolidated monthly parcels, not drums. Keep the stream consistent, keep a recent analysis on file, and accumulate to a shippable lot; that is the difference between selling and pouring it back into the process. Q: Is fusel oil a waste? A: It is a by-product with real value, and its classification depends on jurisdiction and paperwork. Where it is marketed as a product with a specification and a buyer, it is a product -- that status is part of what a broker establishes before the first offer. Q: Why do buyers keep asking for the GC? A: Because the components are the product: isoamyl alcohol is the valuable fraction, and ethanol/water content is the dilution. Two cargoes of the same tonnage can differ materially in value -- the chromatogram is the only honest price input. ============================================================================== # Who buys cashew nut shell liquid (CNSL) in Europe URL: https://www.sustainablecommodities.eu/markets/who-buys-cnsl-in-europe European CNSL is bought by friction-material producers (brake linings, clutch facings and friction dust -- the largest outlet for technical grade), by processors who convert it into cardanol for resins, coatings and surfactants, and by specialty polymer and laminate chemistry. Two grades run through the market: technical CNSL, extracted from the shell by decortication and priced for volume applications, and natural CNSL (cold-pressed), valued where composition matters for cardanol recovery. The market is growing steadily -- analysts put it in the 7-11% range per year -- and Europe is served through a trader-distributor layer (for example Equilex) plus direct contracts. What a buyer pays for is the composition: anacardic acid, cardol and cardanol content decide whether your cargo is friction feedstock or cardanol raw material. ## The buyers, by application CNSL is a renewable alkyl-phenol stream, and its buyers sort cleanly by what they do with the phenol. Friction material producers: Brake linings, clutch facings and friction dust: the volume outlet, mostly on technical-grade CNSL where cost efficiency rules. Cardanol processors: Convert CNSL into cardanol, the feedstock for resins, coatings, surfactants and specialty chemistry. Composition-sensitive, pays for natural grade with good cardanol potential. Resin, coating and laminate chemistry: Phenolic and renewable resins, friction binders, insulation laminates and surface coatings built on CNSL derivatives. Specialty and agro formulators: Insecticidal, fungicidal and anti-termite applications and plastics additives -- smaller but steady outlets. Traders and distributors: A European distributor layer (Equilex and similar) supplies manufacturers that do not buy direct from origin; origin exporters sell into both. ## What a CNSL buyer screens on Grade and extraction route: technical CNSL (solvent-decorticated) versus natural CNSL (hot/cold pressed) have different compositions and different buyers; the first question in every conversation. The component split: anacardic acid, cardol and cardanol contents decide cardanol yield and friction performance -- the analysis is the price. Impurities: shell particles, moisture and unsaturated side-chain polymerization affect processing; viscosity is part of the specification. Origin and continuity: CNSL comes from cashew-processing regions; European buyers value a steady, documented monthly flow over spot cargoes they have to re-assay. ## Where supply comes from CNSL is a genuine by-product: it sits in the honeycomb structure of the cashew shell, and it comes onto the market wherever cashews are processed -- West Africa, India, Vietnam and Brazil being the classic origins. Europe processes almost none of it at origin, so the trade is export-into-Europe by design. For an origin seller, the leverage points are grade discipline (separate technical from natural streams), a consistent component analysis, and shipment form (flexitank and drum logistics both common). The friction market buys volume and consistency; the cardanol market buys chemistry. Knowing which one your cargo is for, before you offer it, is the difference between a price and a discount. ## Sources * Mordor Intelligence: CNSL market (technical grade, friction share): https://www.mordorintelligence.com/industry-reports/cashew-nut-shell-liquid-market * Equilex Chemicals: CNSL as renewable alkyl phenol feedstock in Europe: https://www.equilex.com/products/renewable-feedstocks/cashew-nut-shell-liquid/ * Cargo Handbook: CNSL composition and handling: https://www.cargohandbook.com/Cashew_nutshell_liquid * Our CNSL product page: https://www.sustainablecommodities.eu/markets/cnsl ## Frequently asked questions Q: What is the difference between technical and natural CNSL? A: Extraction route and composition. Technical CNSL is recovered by solvent decortication of the shell -- cheaper, volume-grade, the friction market's feed. Natural CNSL is pressed, with a composition richer in the components cardanol processors want. Buyers ask which one you have before anything else. Q: Is CNSL the same as cashew nut oil? A: No. Cashew nut (kernel) oil is a food oil from the kernel; CNSL is the phenolic liquid from the shell -- chemically a completely different material with industrial, not food, applications. Q: Why do friction makers like CNSL? A: Because CNSL-based friction dust and resins hold performance under heat in brake linings and clutch facings at a cost position that works for volume production. That application is the demand anchor of the whole market. Q: Can small origin producers sell into Europe? A: Yes, through the same logic as every by-product trade: consolidate to a shippable monthly volume, keep grade streams separate, and carry a current component analysis. The European buyer layer (processors plus distributors) is reachable directly or through a broker -- the cargo still needs the paperwork either way. ============================================================================== # Who buys bionaphtha in Europe URL: https://www.sustainablecommodities.eu/markets/who-buys-bionaphtha-in-europe European bionaphtha is bought by two camps: petrochemical crackers that feed it in under ISCC PLUS mass balance to sell bio-attributed polymers, and gasoline blenders who value its paraffinic, sulphur-free octane. The names on the cracking side are the big European crackers -- INEOS (running tall-oil based bio-naphtha at certified German sites), BASF with its biomass-balanced products, Borealis, LyondellBasell, SABIC and TotalEnergies -- and the supply side counts Neste NExBTL, Topsoe HydroFlex output and every HVO plant with a naphtha co-product. The commercial heart of the market: the certificate, not the hydrocarbon, carries the value. Physically, bio-naphtha cracks like naphtha; commercially, open-spec material trades near fossil parity while certified renewable grades command multiples of it. Sell the molecule without the chain of custody and you leave most of the money on the table. ## The buyers, by camp Bio-naphtha is a drop-in: crackers and blenders need no capital change to take it, which is exactly why the product works. What they buy alongside the barrel is the right to claim it. Steam crackers under mass balance: INEOS, BASF, Borealis, LyondellBasell, SABIC, TotalEnergies and the wider European cracker base co-feed certified bio-naphtha and attribute it to outputs: bio-attributed ethylene and propylene into polymers that brand owners buy as lower-carbon packaging. Gasoline blenders: Bionaphtha's paraffinic, sulphur-free character gives it blending value in the gasoline pool, and its renewable origin counts toward fuel obligations where the rules allow. Chemical and specialty outlets: Solvent and specialty chemistry taking renewable carbon claims where a mass-balance story fits their product claims. Producers and traders: Neste (NExBTL renewable naphtha), Topsoe HydroFlex licensees and HVO plants with a naphtha cut sell direct or through the trading community around the ARA and Rhine-Scheldt corridor. ## The mechanic that sets the price ISCC PLUS mass balance is the market. Certified bio-feedstock is co-fed with fossil, and the certificate volume is attributed to chosen output streams. The buyer sells certified renewable polymer; the cracker needs the certificate flow continuous to keep those claims alive. The price gap is the certificate gap. Open-specification renewable naphtha trades close to fossil naphtha references; certified renewable grades have traded at multiples of that level, because the buyer is buying a claim, not a molecule. Specification still gates entry: distillation range, sulphur, olefins and colour decide whether the tank can take the cargo at all -- the premium conversation starts after the spec conversation is won. ## The two forces pulling the market On the demand side, brand owners keep pulling bio-attributed polymers through their packaging suppliers, and the European renewable naphtha market is projected to grow at roughly ten percent per year into the 2030s. On the supply side, every new HVO and renewable diesel plant brings a naphtha co-product with it. The countervailing force is structural: part of the European cracker base is ageing, and announced closures and mothballings shrink the physical buyer list over time. The reading for a seller: the next years favour certified, spec-clean material into the crackers that remain -- and punish undifferentiated cargo that has to compete with fossil naphtha on price alone. ## Sources * ISCC PLUS, the mass-balance scheme behind bio-attribution: https://www.iscc-system.org/certification/iscc-certification-schemes/iscc-plus/ * Neste: NExBTL renewable naphtha for bioplastics customers: https://neste.com/news/neste-oil-adds-n-ex-btl-renewable-naphtha-suitable-for-producing-bioplastics-to-its-corporate-customer-product-range * BASF: renewable feedstocks and biomass-balanced products: https://www.basf.com/global/en/who-we-are/sustainability/our-contributions-to-enabling-the-green-transformation/circular-economy/circular-feedstocks/mass-balance * Our bionaphtha product page: https://www.sustainablecommodities.eu/markets/bionaphtha ## Frequently asked questions Q: Can I sell bionaphtha without certification? A: You can sell the molecules -- at fossil-naphtha-linked pricing. The renewable premium exists because of the certified claim, so without the chain of custody most of the value is unavailable. Getting the certificate in place before selling is usually the highest-return step available to a producer with a naphtha cut. Q: Why do crackers buy bio-naphtha instead of just buying certificates? A: Effectively they are buying certificates -- attached to physical feedstock they can actually co-feed. The mass-balance system ties the claim to real input streams at certified sites, so the physical cargo and the certificate move together. That is the whole design. Q: Is bionaphtha the same as pyrolysis oil? A: No. Bionaphtha is a paraffinic light cut from renewable hydrotreating (HVO-type processes); plastic pyrolysis oil is a different, more contaminated circular feedstock with its own buyer list. Both end up in crackers, but on different specifications and different certificates. Q: What does a first offer to a cracker need? A: Certificate status and scheme, monthly volume, distillation range, sulphur, olefins, colour, and loading form. The commercial people cannot start until the sustainability people are satisfied -- bring both files at once and the deal moves at the speed of chemistry instead of paperwork. ============================================================================== # How to sell used cooking oil in Europe URL: https://www.sustainablecommodities.eu/markets/how-to-sell-used-cooking-oil-in-europe Selling used cooking oil in Europe comes down to five steps: secure the collection rights, get the waste status and paperwork right, aggregate to a shippable volume, certify the sustainability chain, and then sell -- by analysis, not by story. UCO is an Annex IX Part B feedstock under the Renewable Energy Directive, which is why biodiesel and HVO plants pay a premium for it: it counts toward their obligations, double counting applies in several countries. That same status is why the paperwork matters -- a cargo without documented waste origin and a proof of sustainability sells as feedstock at a discount, not as compliance material. The buyers exist and are hungry; what separates a good UCO business from a struggling one is almost never the oil -- it is the intake documentation, the consistency of the analysis and the volume pattern. ## Step 1 and 2: collection rights and waste status Collection rights. Restaurants, canteens, food plants and fryer services all produce UCO; whoever holds the collection agreement holds the tonnage. Agreements should specify container provision, pickup frequency and ownership of the oil -- and kitchens switch providers rarely, so early contracts compound. Waste status. UCO is waste the moment it is discarded, and cross-border movements of waste are regulated: within the EU the new waste shipment rules apply (green-listed movement for most UCO streams, but documentation and, since May 2026, digital procedures are mandatory -- see our waste shipment rules page). National waste transport permits apply on the road. Intake documentation is the asset: record when oil became waste, from what sources, in what containers. This is what an auditor and a buyer both ask for, and retrofitting it is close to impossible. ## Step 3 and 4: aggregation and certification Aggregate to a monthly shippable volume. Buyers take consolidated parcels -- barge lots, full flexitanks, tanker loads. A collector at a few tonnes per month sells through an aggregator; a collector at fifty sells direct. Set up settling tanks, dewatering and basic filtration: water and impurities are paid tonnage you are giving away. Get the analysis discipline. FFA (free fatty acids), water, impurities (MIU), sulphur and phosphorus are the numbers on which UCO prices. Test each consolidated lot and keep the results; a cargo with a current, consistent analysis sells itself. Certify the chain. ISCC EU (or a recognised scheme) covers the sustainability chain that makes your cargo compliance material rather than feedstock. Collectors usually start under an aggregator's certificate and certify independently as volumes grow -- see our ISCC page for how that works. ## Step 5: selling -- what actually sets the price The buyer list is short and known: biodiesel plants running UCOME, HVO and renewable diesel plants, and the trading community around them (our who buys UCO page maps it). What moves your number within that list: FFA and water are the classic discounts: high FFA limits which plants can process the cargo economically; water is simply weight you are not getting paid for. Certificate status decides whether the buyer can count the cargo; without it, expect feedstock pricing. Volume and continuity decide terms: contracted monthly flow earns premiums and pick-up logistics; spot dribs earn spot discounts. Location and logistics matter more than sellers expect: heated storage in winter, road distances, and port access all fold into the netback. Sell with the analysis attached and the paperwork ready, and the negotiation is about the market. Sell without them and it is about your discount. ## Sources * Directive (EU) 2023/2413 (RED III), Annex IX Part B and caps: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * Regulation (EU) 2024/1157 on shipments of waste: https://eur-lex.europa.eu/eli/reg/2024/1157/oj * ISCC EU system documents: https://www.iscc-system.org/certification/iscc-documents/ * Our who buys UCO page: the buyer map: https://www.sustainablecommodities.eu/markets/who-buys-used-cooking-oil-in-europe ## Frequently asked questions Q: Do I need a license to collect used cooking oil? A: Usually a waste transport or collection registration at national level, plus the agreements with the kitchens. It is lighter than hazardous waste regimes -- UCO is a green-listed waste in most contexts -- but it is a real requirement, and buyers will ask for your registrations as part of onboarding. Q: How much is my used cooking oil worth? A: It prices off FFA, water and impurities against UCO market references, adjusted for volume and logistics. Clean, dry, consistent material from a steady flow earns the top of the range; wet, high-FFA spot cargo earns the bottom. A current analysis plus monthly volume gets you a real number -- we give one same-day. Q: Can restaurants sell their own oil? A: A single kitchen's oil is a trickle, not a cargo -- the value is in aggregation. Kitchens are best served by a collector with containers and a route; the collection side is where local businesses are built, and the selling side is where scale matters. Q: Is UCO affected by the EUDR? A: No -- waste and used products sit outside the deforestation regulation's scope. The practical point is being able to show the material is genuine waste, because undocumented vegetable-type oil invites the palm question. Our EUDR page explains where that line runs. Q: What about selling outside the EU? A: Export adds the waste shipment regime on top: green-listed notifications for OECD movement, bans and strict controls for non-OECD destinations, and digital procedures since May 2026. It is workable for established flows and hostile to improvised ones -- most European UCO sells inside Europe for exactly that reason. ============================================================================== # EU waste shipment rules for feedstock trade: what applies since May 2026 URL: https://www.sustainablecommodities.eu/markets/eu-waste-shipment-rules Since 21 May 2026, cross-border waste movements in the EU run under the new Regulation (EU) 2024/1157: procedures go through the digital system DIWASS, exports of waste for disposal are banned outright, and exports for recovery outside the OECD face real scrutiny. For feedstock trade the regulation matters in three places. First, the waste-or-product question: if your stream is legally waste, the shipment regime applies in full; if it is a product with a specification and a buyer, it does not -- and that classification is a paperwork question before it is a chemistry one. Second, the green list: most clean, single-stream recyclables (including typical used cooking oil movements) move under green-listed procedures, which are lighter than full notification but still documented -- and since May 2026, digitally. Third, plastics: the Basel amendments and the new regulation together make mixed, contaminated plastic exports to non-OECD countries effectively impossible, which is why European mixed plastic now sells to European buyers. ## What changed and when The regulation entered into force in May 2024 and displaced the old shipment regulation in stages; the main body applies since 21 May 2026. If you last looked at waste shipment law before that date, three things moved: * Everything digital. Notifications and consent procedures run through DIWASS, the EU's digital waste shipment system; paper-based procedures belong to the past. * Disposal exports banned. Shipping waste for disposal across borders is prohibited except narrow exceptional cases -- recovery is the only generally exportable purpose. * Export controls tightened. Recovery exports outside the OECD face stricter conditions, with the plastic waste rules (Basel-aligned) the strictest of all for mixed and contaminated streams. ## Where your stream sits The practical map for feedstock people, in order of friction: Product: Not waste at law: specification, buyer, purpose. No shipment-regime notification -- but be prepared to defend the classification with paperwork. Green-listed waste (Annex III): Clean, single-stream recyclables: typical UCO, sorted metals, single-polymer plastics. Documented movement, lighter procedure, digital since May 2026. Notification waste (Annex IV): Mixed or contaminated streams: prior written notification and consent from every authority on the route, movement documents, financial guarantees. Banned or effectively banned: Waste for disposal (banned), mixed/contaminated plastics to non-OECD (effectively banned), exports to facilities that cannot demonstrate environmentally sound management. ## What this means in practice Know your entry. The waste-list entry your stream moves under decides the procedure. Sellers who let buyers guess the classification pay for it in discount and delay. Get digital-ready. Counterparties and authorities work through DIWASS now; brokers and logistics partners who cannot operate in that system cannot move notification waste for you. Document the waste-to-product line. The most valuable single question in this trade -- is my material still waste -- is answered by records: when it became waste, what was done to it, under what specification it now sells. Plan plastics realistically. European mixed plastic waste has a European buyer list; budget for that reality rather than an export fantasy. ## Sources * Regulation (EU) 2024/1157 on shipments of waste, on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1157/oj * European Commission, waste shipments overview: https://environment.ec.europa.eu/topics/waste-and-recycling/waste-shipments_en * Basel Convention plastic waste amendments: http://www.basel.int/Implementation/PlasticWaste/Amendments/Overview/tabid/8426.aspx ## Frequently asked questions Q: Does the regulation apply to used cooking oil? A: UCO is waste when discarded, and cross-border movements fall under the shipment regime -- typically the green-listed procedure for clean streams, with documentation and the digital route since May 2026. Within-country collection is national waste law instead. Q: My material is processed and has a buyer -- is it still waste? A: That is the by-product versus waste question, and it turns on classification and paperwork rather than chemistry: certainty about the waste status, a market, and lawful use. If it qualifies as a product, the shipment regime does not apply -- but expect counterparties and authorities to test the file. Q: What is DIWASS in one sentence? A: The EU's digital waste shipment system, mandatory for the procedures under the new rules since 21 May 2026 -- the place where notifications, consents and movement documents now live. Q: Can we still export waste plastics outside the EU? A: For mixed and contaminated plastic waste to non-OECD countries, effectively no: the Basel-aligned rules require near-clean, single-polymer streams for export and the rest must stay in the OECD. That is precisely why European chemical recyclers now compete for European mixed feedstock. ============================================================================== # How to sell animal fats and tallow in Europe URL: https://www.sustainablecommodities.eu/markets/how-to-sell-animal-fats-in-europe Selling animal fats in Europe starts with one question: which ABP category is it? Under the animal by-products regulation (EC) No 1069/2009, rendered fat is category 1, 2 or 3, and that single fact decides your buyer list. Category 1 and 2 fats (from specified risk material, fallen stock and similar) go to technical and fuel outlets -- biodiesel, HVO, oleochemistry -- and count double toward renewable obligations, which is why fuel plants pay for them. Category 3 fat (from material fit for human consumption at slaughter) has two competing markets: animal feed, its traditional home, and biofuel, its hungry new one -- a competition the feed industry is publicly unhappy about. After the category, the same three things decide everything as in every fat trade: the certificate chain, the analysis (FFA, MIU, sulphur), and volume continuity. Sell with all three in the file and category 1 fat outprices what most sellers expect; sell without them and even category 3 trades at a discount. ## Step 1: the category decides the market The category is not a detail -- it is the market. The animal by-products framework sorts material by risk, and every buyer's permit says which categories they may take. Category 1: Highest risk: specified risk material, TSE-suspect carcasses, catering waste. Sterilized and rendered; the fat goes to technical outlets -- biodiesel, HVO, oleochemicals -- never to feed. Category 2: Fallen stock and condemned material. Technical, fuel and some fertilizer applications after processing; not feed. Category 3: Fit for human consumption at the point of slaughter: trimmings, offal fat, former foodstuffs. The only category allowed into animal feed -- and also wanted by fuel, which is where the price tension lives. End point: Once rendered fat reaches a defined end point in an approved process (for example in biodiesel production), it leaves the ABP regime -- the trade continues under fuel and chemicals rules. ## Step 2 and 3: paperwork and analysis Commercial documents first. Rendered fat moves with category marking and traceability under the ABP rules; a buyer's first check is whether your paperwork matches your claim. Category mistakes are not pricing issues, they are compliance issues. The certificate chain. For fuel outlets, categories 1 and 2 are Annex IX Part B feedstocks with double counting in several countries -- but only with a proof of sustainability behind the cargo. Category 3 is not in Part B; it prices differently and its buyers differ too (see our RED III page). The analysis. FFA, moisture and impurities (MIU), sulphur and colour are the numbers in every tallow conversation. Sulphur matters doubly: impurities track protein residues, and fuel buyers watch them. Test every consolidated lot and keep the prints. Continuity. Renderers produce steadily; buyers of rendered fat buy steadily. Contracted monthly flow earns premium treatment -- spot tanks earn spot discounts. ## Step 4: choosing the buyer list For category 1 and 2, the buyers are biodiesel plants running TME, renewable diesel and HVO producers, and oleochemical users. Double counting makes the compliance maths work; the certificate makes it yours. Our who buys animal fat page maps this list in detail. For category 3, decide (or let the market decide) between feed compounders and pet food on one side and fuel on the other. The feed side values consistency and specification discipline over cycles; the fuel side's pull moves with mandates. Many renderers sell into both and let the relative prices do the sorting. One honest note for category 3 sellers: the feed industry is lobbying hard against fat flowing to fuel, because it raises their input costs. That is a sign of exactly one thing -- your material is wanted. Sell accordingly. ## Sources * Regulation (EC) No 1069/2009 (animal by-products), on EUR-Lex: https://eur-lex.europa.eu/eli/reg/2009/1069/oj * European Commission, animal by-products overview: https://food.ec.europa.eu/food-safety/animal-products_en * EFPRA: animal fats as a biofuel feedstock: https://efpra.eu/2025/10/15/animal-fats-are-a-sustainable-feedstock-for-biofuel/ * Our who buys animal fat page: the buyer map: https://www.sustainablecommodities.eu/markets/who-buys-animal-fat-in-europe ## Frequently asked questions Q: Which animal fat is worth more, category 1 or category 3? A: Not automatically either. Category 1 and 2 earn the fuel market's double-counted compliance value with a certificate; category 3 straddles feed and fuel and can command feed-grade pricing in its own market. The certificate and the analysis usually matter more than the category for the final number. Q: Can category 3 fat go into fuel? A: Yes -- category 3 is not restricted from technical or fuel uses; what changes is the compliance accounting, because category 3 is not an Annex IX Part B feedstock. Fuel buyers take it, but the quota value differs, and that shows in the price. Q: What documents does a fat cargo need? A: ABP category marking and traceability for the category claim, the rendering plant's approval references, a current analysis, and for fuel outlets the proof of sustainability chain. Cross-border movement adds the waste/ABP shipment paperwork -- see our waste shipment rules page. Q: Why did my tallow price drop? A: Usually one of three numbers moved: FFA (processing cost for the buyer), MIU (paid tonnage that is not fat), or sulphur. Sometimes the feed-versus-fuel balance shifted. Send the latest analysis and the volume pattern and we will tell you which one it was. ============================================================================== # How to sell POME oil into Europe URL: https://www.sustainablecommodities.eu/markets/how-to-sell-pome-in-europe Selling POME oil into Europe is a documentation exercise wrapped around a commodity: ISCC treats palm oil mill effluent as a processing residue, and everything a European buyer pays for flows from that classification being watertight. The chain runs mill (point of origin) to collecting point to trader to EU importer, and every link needs to be certified. That bar rose deliberately: the industry has seen misdeclared palm fractions sold as POME, and ISCC responded with tighter audits on palm-based waste streams -- which sounds like bad news for sellers but is the opposite for honest ones: every fraudulent stream that exits the market makes yours scarcer and your paperwork more valuable. Bring the mill's own documentation (not a trader's summary), a consistent analysis (FFA, moisture, impurities), and a volume pattern a buyer can plan on, and POME sells into European biodiesel and renewable diesel plants at residue-grade value. ## Step 1: start at the mill, not at the port POME oil is recovered from the effluent ponds of palm oil mills -- the wastewater from sterilising and pressing fresh fruit bunches. Because it is a processing residue, the point of origin is the mill, and European due diligence starts there: which mill, what effluent volumes, what recovery process, since when. The questions that decide credibility are quantitative: does the declared volume fit the mill's FFB throughput? A mill crushing a known tonnage of fruit produces a bounded amount of effluent and therefore of recoverable oil. Streams that exceed that bound get flagged -- correctly. The sibling streams trade on the same rails: SBEO (solvent-extracted) and SSAO (sludge/septic acid oil) each carry their own classification story, and mixing them muddies the file. Keep streams separate and documented from the source. ## Step 2: build the ISCC chain The certification chain has no gaps: mill or collecting point, storage and treatment, trader, EU importer -- each certified under ISCC EU, with the waste-and-residue classification carried in the documents at every step. ISCC publishes specific guidance for waste and residues from palm oil mills, and audits against it have tightened. Practical consequences for sellers: self-declarations from the point of origin get verified, mass balances get reconciled, and the distinction between residue and by-product decides whether the stream is eligible at all. Plan the chain before the cargo: retrofitting certification onto a shipment already afloat is how consignments become distressed (see our off-spec page). ## Step 3: the analysis and the commercial read FFA, moisture and impurities price the cargo: POME oil is a high-FFA stream by nature, and buyers design their pre-treatment around the number you declare -- surprises there are expensive. The EUDR question is settled but must be answerable: POME as waste falls outside the deforestation regulation (see our EUDR page), but importers will ask, because a palm-linked oil invites the question. The residue classification is the answer -- have it in the file. Buyers: European biodiesel plants and renewable diesel producers running high-FFA feedstock, mapped on our who buys POME page. Price references for palm waste streams exist through the price reporting agencies; the premium over uncertified material is the certificate, visible and bankable. ## Sources * ISCC: Understanding POME, context and controversy: https://iscc-system.org/understanding-pome-context-and-controversy/ * Argus: ISCC tightening POME audits: https://www.argusmedia.com/en/news-and-insights/latest-market-news/2268067-iscc-to-beef-up-pome-audits-in-2022 * ISCC guidance, waste and residues from palm oil mills: https://www.iscc-system.org/certification/iscc-documents/ * Our who buys POME page: the European buyer map: https://www.sustainablecommodities.eu/markets/who-buys-pome-in-europe ## Frequently asked questions Q: Can a trader certify POME without the mill? A: No -- the chain starts at the point of origin. A trader can hold the collecting-point or trader certificate, but the mill's documentation and the mass-balance story are the foundation the whole chain audits against. Files built on trader summaries alone fail exactly when scrutiny rises, which is now. Q: Why are POME audits stricter than before? A: Because the stream's value invited misdeclaration: other palm fractions sold as POME to capture residue-grade compliance value. ISCC tightened audit rules for palm-based waste streams in response. For sellers with genuine mill documentation, that is a competitive moat, not a burden. Q: What is the difference between POME, SBEO and SSAO? A: Recovery route and story. POME oil is recovered from mill effluent; SBEO is solvent-extracted from sludge; SSAO is acid oil from sludge/septic streams. All are palm-mill waste oils trading on the same rails into Europe, each with its own classification detail that the paperwork must state. Q: Is POME affected by the EU deforestation rules? A: As a waste stream, POME sits outside the EUDR's product scope. What the question really tests is whether your material is genuinely the residue it claims to be -- the same file that satisfies ISCC answers the customs question. ============================================================================== # How to sell acid oils and soapstock in Europe URL: https://www.sustainablecommodities.eu/markets/how-to-sell-acid-oils-in-europe Selling acid oils in Europe is a two-step commercial story: turn the soapstock into acid oil, and settle what the parent oil means for classification. Acid oil comes from acidulating soapstock -- the gum-and-soap by-product of vegetable oil refining split into free fatty acids and glycerides -- and it prices on total fatty acid content (TFA), with moisture, impurities and the unsaponifiable fraction as discount drivers. The strategic question is the parent oil: the origin material determines how the stream sits under the renewable energy rules, and with palm-linked streams, what the deforestation rules ask (our EUDR page covers that line). The buyer list is broad -- biodiesel and renewable diesel plants hungry for high-FFA feed, oleochemicals running fatty acid chemistry, and limited feed outlets -- and since price reporting agencies launched dedicated soapstock acid oil assessments, the stream trades as a named commodity rather than a refinery afterthought. ## Step 1: from soapstock to sellable acid oil Soapstock leaves the refinery as a watery, soapy sludge. Acidulation splits it: sulphuric or other acid breaks the soaps into free fatty acids, which separate as the acid oil phase. Done well, it concentrates value; done poorly, it ships water and salts at freight cost. The analysis that matters: TFA (total fatty acids), moisture, impurities, and unsaponifiables. Buyers quote on TFA and discount on the rest; a dry, clean acid oil at high TFA is a different product from a wet one at the same name. Esterified acid oil -- the FFA esterified into biodiesel-grade material -- is the upgraded route for refiners with volume; see our esterified acid oils page for that market. ## Step 2: the classification conversation The parent oil decides the paperwork story: Soybean, sunflower, rapeseed acid oils from European refining: waste-and-residue streams from vegetable oil processing -- the renewable-energy classification follows the stream and the member state's implementation, and the certificate is what converts that into premium. Palm-linked acid oils (PFAD, palm soapstock streams): in scope of the EUDR as products made directly from a regulated commodity -- geolocation and due diligence statements apply from the 2026 dates. This is the single biggest classification difference between acid oils that look identical in a tank. Whatever the parent: the ISCC chain (or equivalent) from refinery to buyer is what makes the cargo compliance material. Uncertified acid oil sells -- as feedstock, at feedstock prices. ## Step 3: the buyer list and the price Biodiesel and renewable diesel plants are the volume buyers: high-FFA acid oil suits pre-treatment and esterification routes, and where the classification qualifies, the compliance value follows the certificate. Our who buys acid oils page maps them. Oleochemicals buy acid oil as fatty-acid feed for soaps, esters and derivatives -- steady demand that balances the fuel side. Feed outlets take acid oil within purity limits -- a realistic third leg for suitable streams, not a dumping ground for unsuitable ones. On price: quote and compare on TFA-adjusted value, net of moisture and impurities, with freight and the certificate premium explicit. The classic mistake in this trade is comparing a wet cargo and a dry one on headline tonnage -- the market does not. ## Sources * Fastmarkets: soapstock acid oil price assessments (FAQ): https://www.fastmarkets.com/insights/soap-stock-acid-oil-price-launch-frequently-asked-questions/ * Haas et al., FAME from acid oil (acidulation chemistry): https://link.springer.com/article/10.1007/s11746-003-0658-4 * Regulation (EU) 2023/2413 (RED III), Annex IX and classification: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * Our who buys acid oils page: https://www.sustainablecommodities.eu/markets/who-buys-acid-oils-in-europe ## Frequently asked questions Q: What is acid oil worth? A: It prices on total fatty acid content against vegetable oil and fatty acid references, discounted for moisture, impurities and unsaponifiables -- and, where classification and certification allow it, carrying renewable compliance value. Dedicated price assessments for soapstock acid oil now exist, so ask for the TFA-adjusted comparison, not a flat number. Q: Should I esterify before selling? A: Depends on volume and outlet. Esterifying turns FFA into biodiesel-grade material and can lift the price into fuel parity -- but it needs process, certification and scale. Small refinery streams usually sell as acid oil; large ones justify the upgrade. We price both routes for sellers deciding. Q: Does the EUDR apply to my acid oil? A: If the parent oil is a regulated commodity -- palm above all -- then yes: products made directly from it are in scope, with geolocation and due diligence from the 2026 dates. Acid oils from other parents, and genuine waste streams, sit outside. This distinction is on our EUDR page in table form. Q: Can soapstock be sold as-is? A: Usually poorly. Raw soapstock is mostly water and soap; you are paying freight on the refinery's wastewater. Acidulating first concentrates the value into a cargo that prices on TFA. Where acidulation is not feasible, expect aggressive discounts -- the buyer is doing the chemistry you skipped. ============================================================================== # Every date that moves waste-based feedstock trade: the timeline URL: https://www.sustainablecommodities.eu/markets/feedstock-rules-timeline The twelve months around 2026 are the densest regulatory period this trade has ever had. Waste shipment procedures went digital and disposal exports were banned in May 2026. Packaging rules apply from 12 August 2026. The deforestation regulation lands on 30 December 2026 for large operators, June 2027 for small ones. And the renewable quota steps that reprice every cargo took effect from January. This page puts those dates in one table, in the order they hit, each linked to the page that explains what to do about it. Book it, revisit it: the table is maintained by a desk that trades under these rules daily, not scraped from a consultant's newsletter. ## The timeline Dates are application dates -- when the obligation starts biting -- not the dates the laws were published. Where a date has already passed, the row says what is now in force rather than what was coming. 21 May 2025 -- passed: RED III transposition deadline: member states had to write the directive into national law. Implementation remains uneven, which is why quota value differs by country. -> RED III quotas and caps 1 January 2025 -- in force: ReFuelEU Aviation blending begins: 2% SAF at EU airports in 2025, rising to 6% by 2030. Feedstock pull toward HEFA. -> SAF 1 January 2025 -- in force: FuelEU Maritime starts: GHG intensity of bunkered fuel becomes a cost line, pulling marine bio-demand. -> Marine biofuels and FuelEU 1 January 2026 -- in force: National quota steps: Germany's GHG quota rises to 12%, member-state sub-caps on UCO and fats apply per national law, and multiplier phase-outs move blenders back to real waste-based volumes. -> RED III quotas and caps 21 May 2026 -- in force: Waste shipment rules apply: all procedures digital through DIWASS, disposal exports banned, non-OECD recovery exports tightened. -> Waste shipment rules 12 August 2026 -- applies: Packaging regulation (PPWR) applies: recyclability requirements, PFAS ban in food packaging, reuse systems -- recycled-content demand anchors rPET and recyclate. -> Waste PET and rPET 30 December 2026 -- applies: EUDR applies to large and medium operators: geolocation and due diligence for palm and other in-scope commodities and their direct derivatives. -> EUDR 30 June 2027 -- applies: EUDR application date for micro and small operators. The deforestation cut-off (31 December 2020) applies regardless of company size. -> EUDR ## How to use this table Work backwards from the date. A cargo nominated one month before a rule applies is a cargo the buyer will screen under that rule already -- compliance teams do not switch on the day. Check the classification, not the product name. Most of these rules turn on what your stream legally is: waste or product, palm-derived or not, category 1, 2 or 3. That is a paperwork question you can settle quietly, long before a deadline makes it urgent. Ask us which rows touch you. Every row has a page behind it, and every page ends with a desk that answers. If a date on this table intersects a cargo you are holding, that conversation is cheaper than the demurrage. ## Sources * European Commission, EUDR application dates: https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en * European Commission, packaging waste (PPWR): https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en * Regulation (EU) 2024/1157 on shipments of waste: https://eur-lex.europa.eu/eli/reg/2024/1157/oj * Directive (EU) 2023/2413 (RED III): https://eur-lex.europa.eu/eli/dir/2023/2413/oj ## Frequently asked questions Q: Which of these dates matters most for UCO sellers? A: The January quota steps: they set how much waste-based material each country's mandate rewards and at what multiplier, which is the demand side of your price. The May shipment rules matter for cross-border flows, and the EUDR only asks you to prove what UCO already is -- waste. Q: I missed the May 2026 waste shipment changes. What do I do now? A: Nothing was grandfathered: since 21 May 2026 procedures run through DIWASS and disposal exports are banned. If you ship cross-border waste streams, your logistics and broker partners must be operating in that system today -- our waste shipment page has the map. Q: Does the PPWR date affect feedstock sellers or only packaging makers? A: Both. The regulation binds packaging on the EU market, but its recycled-content requirements are what make food-grade rPET and clean recyclate streams structurally short -- which is the demand behind your bale and flake prices. Q: Is this table maintained? A: Yes -- by a desk that trades under these rules daily, with each date checked against the official sources on its detail page. When a date moves, as EUDR's did twice, the table moves with it. ============================================================================== # The feedstock glossary: every term in this trade, commercially translated URL: https://www.sustainablecommodities.eu/markets/feedstock-glossary This glossary translates the terms that decide money in waste-based feedstock trade: what FFA does to a UCO price, what mass balance really claims, why Annex IX Part A versus Part B is worth knowing before you sell, and what a proof of sustainability actually proves. Definitions are written commercially, not legally: each says what the term means and what it does to your cargo. Where a deep page exists, the term links to it. If a word in your analysis or contract is not here, that is a gap worth reporting -- the desk answers. ## Parameters on your analysis The numbers a buyer reads before reading your name. FFA (free fatty acids): The share of the oil that is already split into free acids. High FFA raises pre-treatment cost for the buyer; it prices most feedstocks, including UCO and acid oils. TFA (total fatty acids): The fatty-acid value of an acid oil including what is bound in soaps. Acid oils quote on it -- see acid oils and soapstock. MIU (moisture, impurities, unsaponifiables): The three non-product fractions in one number: moisture (water), impurities (solids, gums, metals) and unsaponifiables (matter that cannot become soap). Everything in the tank that is not product: paid tonnage you are giving away, and the discount line on every fat and oil invoice. IV (intrinsic viscosity): For PET: the chain length that decides whether flake can go bottle-to-bottle. See waste PET and rPET. CFPP: Cold filter plugging point: how a fuel behaves in winter. Destination-market parameter for FAME and HVO. Chlorine / silicon: For pyrolysis oil, the gates: chlorine blocks cracker feed, silicon poisons catalysts. See pyrolysis oil. MONG: Matter organic non-glycerol: the non-product fraction of glycerine. Acid number: For crude tall oil: the headline quality figure a distiller prices first. ## Feedstocks and streams The materials, in the words the market uses. UCO: Used cooking oil: waste frying fat, the workhorse feedstock. Our UCO page and how to sell it. POME: Palm oil mill effluent, and the oil recovered from it: a processing residue with a certification story. See POME, SBEO and SSAO. Soapstock and acid oil: The soap by-product of refining, and the fatty acid oil made from it. See acid oils. PFAD: Palm fatty acid distillate: a palm derivative, which places it inside the EUDR unlike UCO. CTO and TOFA: Crude tall oil from kraft pulping, and its distilled fatty acid. See CTO. CNSL: Cashew nut shell liquid: a phenolic shell by-product feeding friction materials and cardanol. See CNSL. TPO and PPO: Tyre- and plastic-derived pyrolysis oil: same word, different chemistry, different buyers. rCB: Recovered carbon black from tyre pyrolysis. See rCB. Categories 1, 2, 3: The animal by-product classes that decide what rendered fat may become. See animal fats. ## Rules, certificates and counting The paperwork vocabulary -- where the premium lives. Annex IX, Part A and Part B: The RED lists: Part A feedstocks count toward advanced sub-targets; Part B (UCO, cat 1/2 fats) is capped at 1.7% per country. See the lists and the quotas. Double counting: Waste-based fuels counting twice toward targets where a member state allows it -- worth real money on the same molecules. PoS (proof of sustainability): The document that converts a physical cargo into compliance value. See proof of sustainability. Mass balance: The accounting rule that lets certified and fossil material share logistics while claims stay honest -- the mechanism behind bio-attributed products. ISCC EU / ISCC PLUS: The certification schemes: EU for fuels compliance, PLUS for circular and bio material. See ISCC. RFNBO: Renewable fuel of non-biological origin: hydrogen-based fuel with its own binding sub-target. RCF (recycled carbon fuel): Fuel from fossil-origin waste, counted under its own rules. See RCF. EUDR: The EU deforestation regulation: geolocation and due diligence for in-scope commodities from December 2026. See EUDR. UDB and Nabisy: The EU and German databases where certified volumes are recorded. See UDB and Nabisy. ## Trade and logistics The words around the cargo. B7: The FAME blend ceiling in standard road diesel -- the wall that shapes biodiesel volumes. See biodiesel. EN 14214 / EN 15940: The standards for FAME and for paraffinic renewable diesel (HVO100) respectively. UCOME, RME, TME: Biodiesel esters by feedstock: used-cooking-oil, rapeseed, tallow methyl ester. Demurrage: The clock that runs when a vessel waits. The reason compliance surprises are expensive -- see cargo claims. Isotank and flexitank: The parcel formats: ~20-25 t tank containers for liquids like pyrolysis oil; flexitanks in 20-ft containers for compatible streams. Surveyor: The independent party whose analysis at load and discharge decides who is right in a dispute. Green-listed / notification waste: The two movement regimes under the shipment rules: documented versus consent-based. ## Sources * Directive (EU) 2023/2413 (RED III), behind the counting terms: https://eur-lex.europa.eu/eli/dir/2023/2413/oj * ISCC system documents, behind the certification terms: https://www.iscc-system.org/certification/iscc-documents/ * Our parameters page: test methods behind the analysis terms: https://www.sustainablecommodities.eu/markets/parameters-explained * Our markets index: the deep pages behind every term: https://www.sustainablecommodities.eu/markets/ ## Frequently asked questions Q: Why do buyers discount on MIU? A: Because moisture, impurities and unsaponifiables are tonnage that is not product: the buyer pays freight on them, separates them, and disposes of them. A dry, clean cargo at a slightly lower headline price often nets more than a wet one. Q: Is double counting still available? A: It depends on the member state: national implementations decide whether waste-based fuels count twice, and several have been winding multipliers down. That is a question for the buyer's country, before it is a question for your cargo. Q: What is the difference between ISCC EU and ISCC PLUS? A: The scheme behind the claim: ISCC EU serves fuel compliance under the renewable energy rules; ISCC PLUS serves circular and bio-based claims in chemistry and plastics. Same audit rigour, different counting -- see the ISCC page. Q: Who checks that a glossary like this is right? A: The desk that trades under these terms daily, against the official sources linked on each deep page. Where a term has a legal definition, the linked page states it and cites the source; this glossary adds the commercial translation on top. ==============================================================================