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.
- 1You send the facts
- 2We test the market
- 3We introduce
- 4You contract directly
- 5We stay reachable
We never take title, so the contract is always between you and the counterparty.
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.
| From | SAF share | Of which e-fuel (RFNBO) |
|---|---|---|
| 2025 | 2 % | , |
| 2030 | 6 % | 1.2 % |
| 2035 | 20 % | 5 % |
| 2040 | 34 % | Rising |
| 2045 | 42 % | Rising |
| 2050 | 70 % | 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.
| From | Destination | What applies |
|---|---|---|
| 21 May 2026 | OECD countries | Non-hazardous plastic waste moves to the notification procedure: prior written consent, no more green-list simplicity |
| 21 November 2026 | Non-OECD countries | Export of non-hazardous plastic waste is banned. Covers Basel B3011 and A3210 |
| 21 May 2029 | Non-OECD countries | 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.
| Product | Demand direction | Why |
|---|---|---|
| UCO and category 1 and 2 animal fat | Structurally tight | 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 | Tight, but capped by the feed market | Aquafeed pays for the same barrel and pays for the unsaturation a fuel producer removes |
| Cat 3 animal fat | Steady rather than tight | Not in Annex IX, so it does not ride the mandate. Priced on its own merits |
| Plastic pyrolysis oil | Rising, and the 2026 date is the trigger | PPWR pulls demand for recycled content while the export ban pushes feedstock back into Europe |
| rPET, bottle grade | Rising sharply into 2030 | 30 % recycled content becomes an obligation, and only post-consumer counts |
| Crude glycerine | Follows biodiesel output, not mandates | It is a co-product: volume appears whether or not anyone wants it |
| Crude tall oil | Contested | Chemical industry and fuel producers want the same limited barrel, and the policy argument is live |
| Vegetable oils into fuel | Capped, not growing | 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.
Frequently asked questions
What is the SAF mandate in Europe and when does it step up?
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.
When does the EU ban plastic waste exports?
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.
Does the export ban stop me importing feedstock into Europe?
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.
Which countries can supply used cooking oil to Europe?
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.
Is demand for waste feedstock actually guaranteed, or is that marketing?
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.
Why does the e-fuel sub-mandate matter to me if I sell used cooking oil?
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.
What happens to low-grade plastic after November 2026?
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.
Do you publish price forecasts?
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.
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.
- Indonesia’s palm oil export growth slows ahead of B50 biodiesel rollout
- Sorghum producers urge US Senate to preserve year-round E15
- Peninsula and Evos plan biofuel hub at Algeciras
- PureCycle increases revenue in Q3
- PowerCell clinches SEK 21 million order for integrated Fuel-to-Power system
- MFA looking to address maritime liens in bunker contracts to support the understanding of rights, risks, and remedies for stakeholders
- BASF’s engineering plastics plants in Shanghai and Zhanjiang certified ISCC PLUS
- BASF: ISCC Plus-Zertifizierung von zwei Produktionsstandorten für technische Kunststoffe in China
- IPG launches new PCR Air Pillow Film
- New IMarEST analysis evaluates IMO NZF amendment options ahead of ISWG-GHG 22
- Results of new MESD study ‘demonstrate the qualified readiness of existing large harbour craft in Singapore for B100 adoption’
- Envision to explore green hydrogen design for Sasol’s Sasolburg facility
- INEOS and Recuro sign memorandum of understanding to construct advanced recycling facility in Norway
- Scaling circular investment: From barriers to opportunity
- Circular Packaging Challenge 2026: international open call for startups advancing packaging circularity
- RI.CIRCO.LO.: helping Lombardy's SMEs develop circular initiatives in priority sectors
- Axens launches a new ERA for French SAF
- Public procurement: the hidden EU bioeconomy driver
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 Demand outlook and origin rules
Just ask. Sizing a position or a plant? Tell us the product and the destination country. 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: we are a broker, so we never take title and we do not trade our own book. We are paid a commission on business that concludes, which is why you will also 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
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Sustainable Commodities 3 B.V., Lemmer, the Netherlands
Last reviewed 10 August 2026. Regulatory references are given for orientation and are not legal advice: verify against the current Official Journal text before contracting.