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.
- 1Material and its origin
- 2Which letter of Part A or B applies
- 3Certification under an approved scheme
- 4Mass balance through the chain
- 5Double counting where the member state allows it
The letter is decided by what the material IS and where it came from, not by what anyone would like it to be. Double counting is set per member state.
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.
| Point | Feedstock |
|---|---|
| (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.
| Point | Feedstock |
|---|---|
| (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.
| Product | Usual position | What decides it |
|---|---|---|
| Used cooking oil | Part B (a) | Straightforward. Collection documentation is the real work |
| Animal fat cat 1 and cat 2 | Part B (b) | The ABP category and the establishment approval |
| Animal fat cat 3 | Not in Annex IX | Food-chain origin. A different market, priced differently |
| POME | Part A (g) | Must be effluent, not diverted crude palm oil |
| Empty palm fruit bunches | Part A (g) | Same entry as POME |
| Crude glycerine | Part A (i) | Crude, not refined |
| Tall oil pitch | Part A (h) | Pitch specifically, not crude tall oil |
| Tall oil | Within Part A (o) | As a forestry residue, inside the composite entry |
| SSAO (soapstock acid oil) | Requires assessment | 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) | Requires assessment | Same logic and the same uncertainty as SSAO |
| PFAD and POME-FAD | Requires assessment | Treatment differs by member state and has changed over time |
| Fish oil from processing residues | Requires assessment | Not named as its own entry |
| Pyrolysis oil from waste plastic | Not in Annex IX at all | 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.
| Requirement | Figure and article |
|---|---|
| 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.
Frequently asked questions
Someone asked me for "annex 9" and "euro 1" documents. What do they mean?
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.
How do I prove which part my material falls under?
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.
Is a waste code the same thing as an Annex IX classification?
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.
Does double counting still apply in the Netherlands and Germany?
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.
Is Annex 9A the same as Annex IX Part 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.
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.
Market news
Recent headlines from across the feedstock and renewable fuel sector. Nothing specific to this market has come through the wires lately, so this is the wider view. The links go to the publisher; we do not host or edit their reporting, and a headline here is not our endorsement of it. Scroll for more.
- Kimchi waste could become viable feedstock for bioplastics
- Braskem biobased polymer helps Deterra drug disposal pouch earn packaging awards
- Eni and PETRONAS to explore high-performance bio-gasoline
- Linglong signs $2 billion Egypt investment MoU
- BTMA to represent European national associations at Tyres Europe board meetings
- Osaka Gas claims STS LNG bunkering first in Osaka Bay
- ISWG-GHG 22: Non-profits react
- USTC brings Copenhagen-based offices together in new hub
- ORLEN instigates new Baltic regional energy initiative
- TotalEnergies Lubmarine launches lubricant for 4-stroke medium speed marine engines
- IMO carbon price heads for December showdown
- LyondellBasell: Pyrolysis Reactors Installed for MoReTec Plant in Wesseling
- Sustainable aviation fuel pioneer completes successful trials
- Louis Dreyfus Company to generate biogas from citrus waste
- Nature by Design: A decade of IUCN, Monaco collaboration driving circular solutions for biodiversity
- European Digital Sustainability Skills Conference
- UCL reacts to IMO ISWG-GHG: ‘Steady progress on the Net Zero Framework’ made but ‘high uncertainty’ remains
- ISWG-GHG 22: ‘Genuine willingness’ for further NZF progress, observes Chair
18 headlines, updated automatically. Last refreshed .
Sources and further reading
Primary sources for the rules and figures on this page, so you can check them yourself. Legislation is amended: always read the consolidated text on the date that matters to you.
Who to ask about Annex IX Part A and Part B
Just ask. Not sure which part your feedstock falls under, or which letter to write in the contract? Ask us before you price it. You get Bart van den Brug on the other end, same working day, in English or Dutch, and across the team also in French, Portuguese, Polish, Czech and Russian.
On how we work: on the feedstocks and fuels on this site we are a broker. We never take title, we do not trade our own book, and we are paid a commission on business that concludes. Additives are the one exception: those we also buy and sell for our own account, and we say in which capacity we are acting before you commit to anything. Either way you will hear it from us when the answer is no, or when your parcel is not ready for the conversation you want to have. A market read or a second opinion on a specification costs nothing and commits you to nothing.
Happy to look at whatever you have, even if it is half an analysis and a question.
+31 6 115 83 448
bart@sustainablecommodities.eu
Sustainable Commodities 3 B.V., Lemmer, the Netherlands
Ask about Annex IX Part A and Part B
Specification, volume, location and certification are enough to start.
Or e-mail us directly: bart@sustainablecommodities.eu
Last reviewed 08 September 2026. Regulatory references are given for orientation and are not legal advice: verify against the current Official Journal text before contracting.