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.
- 1Mandates and targets set the floor
- 2Installed capacity sets the ceiling
- 3Trade measures redirect the flow
- 4Feedstock availability decides what is actually run
- 5The gap between those four is the opportunity
An outlook is a set of assumptions with dates on it, not a forecast we stand behind. We will tell you which assumption a view rests on, so you can judge it yourself rather than take a number on trust.
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 happens to feedstock prices in 2030?
Scarcer, pricier and more documented, the mandate curve rising against finite waste, the direction written in law. The 2030 barrel is being bid for today.
Can technology change the feedstock equation?
Efficiency and collection technology widen supply at the margins, the mandate's arithmetic outrunning the gains by design, technology chasing law. Innovation is enrolled, not exempt.
What is the SAF pull on household waste oils?
Aviation's mandate reaching into every kitchen's grease, the same litre feeding jets as trucks, the queue lengthening at the fryer. Your chip pan has a boarding pass now.
Do feedstock shortages mean buyer competition?
Fierce and formal, plants competing through premiums and term structures, the seller's market by legislation. Competition so regulated it has a compliance officer.
Is there a feedstock investment thesis?
Collection infrastructure, aggregation capacity and certified origin chains, the picks and shovels of the mandate gold rush. Sell the certainty, buy the logistics.
Where will extra waste oil come from?
Collection expansion in new regions, better aggregation in old ones, and the steady march of documentation turning informal oil into tradable tonnes. Supply grows where paperwork learns to walk.
Will chemical recycling eat feedstock from fuels?
They compete for polyolefins while fuels want the fats, the real contest being for attention and capital, and both markets are rising on the same policy tide. Plastics to chemistry, dinner to fuel, no overlap yet.
What happens to feedstock demand if mandates were cancelled?
It would halve to technical demand overnight, the compliance premium being the engine, which is why we read politics as closely as analyses. The market's floor is written in law.
Is over-supply of feedstock possible?
Locally and seasonally yes, structurally no, mandates growing faster than collection worldwide, the deficit by design. Sell the truth, it happens to be bullish.
Will SAF demand eat all the waste oil?
It will keep trying: aviation obligations grow faster than waste oil supply, so SAF plants bid the same litres away from biodiesel and HVO. There is no scenario where certified waste oil goes unsold, only scenarios where it goes to a different buyer at a better price.
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.
- The Digest’s 2026 Multi-Slide Guide to Pipeline Access for Biofuels
- Scientists urged to crack green hydrogen cost barrier
- Neste and United Airlines extend SAF agreement
- WELTEC BIOPOWER begins construction of 60GW Spanish biomethane plant
- U.S. ethanol exports set new records
- FedEx expanding SAF procurement across five US airports in 2027
- Pertamina seeks ethanol import excise exemption
- Senate advances bill to allow year-round E15
- The Digest’s 2026 Multi-Slide Guide to Regional SAF Distribution
- Research and innovation projects supporting the Circular Economy Act Focus area : extended producer responsibility
- Ecodesign for Sustainable Products Regulation: Stakeholder consultation on the methods for defining classes of performance and labels
- Research and innovation projects supporting the Circular Economy Act, Focus area : circular public procurement
- Ecodesign for Sustainable Products Regulation: Stakeholder consultation on the method for identifying and tracking substances of concern in products
- Birla Carbon to present ‘next-generation carbon solutions’ at Global Polymer Summit 2026
- ‘World’s first hydrogen-fuelled engine for large commercial vessels’ completes land-based testing
- Moeve breaks ground on renewable hydrogen project
- Yokogawa wins order from KHI for hydrogen-fuelled vessels
- Azane and Yara ink ammonia supply agreement
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: 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 Demand outlook and origin rules
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Last reviewed 21 September 2026. Regulatory references are given for orientation and are not legal advice: verify against the current Official Journal text before contracting.