Annex IX of the EU Renewable Energy Directive is the list that decides what a waste-based feedstock is worth. Part A covers advanced feedstocks and counts towards the advanced sub-target. Part B covers used cooking oil and category 1 and 2 animal fats, and is capped at 1.7 % of transport energy per member state. Below are both lists in full. The commercial point is not the list itself: it is that the same physical cargo can sit in different places depending on how it is classified and which member state it lands in.
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.
Frequently asked questions
What is the difference between Annex IX Part A and Part B?
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.
Is crude glycerine an Annex IX feedstock?
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.
Which part is POME in?
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.
Is category 3 animal fat in Annex IX?
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.
Does Annex IX material still count double?
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.
Is tyre pyrolysis oil in Annex IX?
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.
Where is the official list?
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.
Who to ask about Annex IX Part A and Part B
Ask us. Not sure which part your feedstock falls under, or which letter to write in the contract? Ask us before you price it. We answer the same working day, in English or Dutch, and there is no charge and no obligation for a market read or a second opinion on a specification.
You get Bart van den Brug directly, not a call centre and not a form that goes nowhere. We are an independent broker: we never take title, we do not trade our own book, and we are paid a commission only on business that actually concludes. That is why we will also tell you when the answer is no.
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Sustainable Commodities 3 B.V., Lemmer, the Netherlands
Last reviewed 09 August 2026 by Bart van den Brug, Sustainable Commodities 3 B.V. (KvK 99665042), Lemmer, the Netherlands. Regulatory references are given for orientation and are not legal advice; verify against the current Official Journal text before contracting.