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.
- 1Origin of the material
- 2Chain of custody
- 3Mass balance bookkeeping
- 4Scheme certificate
- 5Claim on the invoice
A claim is only as good as the weakest box to its left.
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.
| Until 2025 | From 2026 | |
|---|---|---|
| The obligation | Jaarverplichting energie voor vervoer, an annual obligation on the share of renewable energy. | Brandstoftransitieverplichting, the fuel transition obligation. |
| The unit | HBE, hernieuwbare brandstofeenheid. Counted energy delivered. | ERE, an emission reduction unit. One unit is one kilogram of avoided CO2. |
| What decides the count | How much renewable energy you delivered. | How much CO2 the fuel actually avoids, which follows from the GHG value on the declaration. |
| Which sectors | Mainly road transport, with exemptions elsewhere. | Several transport sectors, and each has to decarbonise in its own right. Maritime and inland shipping are now fully inside the system. |
| Sub-targets | A sub-target for advanced fuels. | Limits and sub-targets per sector, plus a new RFNBO sub-target. |
| Opting in | Possible for some deliveries. | The opt in is gone. |
| Registration | Registering deliveries created units. | Registration and verification of fuel deliveries became mandatory. |
| Multipliers | Applied to certain deliveries. | 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.
| What | Why it matters here |
|---|---|
| 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.
Frequently asked questions
What is an ERE?
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.
What happened to the HBE?
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.
Does this change what my UCO is worth in the Netherlands?
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.
Do shipping fuel suppliers now have an obligation?
Maritime and inland shipping are fully inside the system from 2026, where suppliers to those sectors often had an exemption before.
What GHG threshold applies to my plant?
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.
Do you publish the ERE price?
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.
Can you introduce us to Dutch buyers?
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.
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 ERE & the Dutch market
Just ask. Offering into the Netherlands? Send the specification, the origin, the monthly volume and the GHG value on your proof of sustainability. That last one now does more work here than it used to. 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 ERE & the Dutch market
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.