Recycled carbon fuels (RCF)

What qualifies, and what does not

• Non-recyclable waste. The waste has to be genuinely unsuitable for material recycling. Material that could have been mechanically recycled does not become an RCF feedstock because someone chose not to recycle it.
• Unavoidable industrial waste gases. Gases produced inevitably and unintentionally as a by-product of an industrial process, for example steel mill off-gases. Deliberately produced gas does not qualify.
• Non-renewable origin. This is what separates RCF from biofuels. Biogenic carbon routes go to Annex IX; fossil-origin carbon in waste goes to RCF.
• Typically thermochemical. Pyrolysis and gasification are the usual conversion routes, which is why this category matters so much to anyone in plastic pyrolysis oil.
• The fossil half of tyre pyrolysis oil. Synthetic rubber is fossil carbon, so the non-biogenic fraction of TPO falls here while the biogenic fraction is treated as an advanced biofuel. That makes tyre-derived oil the clearest example of one cargo using two frameworks at once. See tyre pyrolysis oil.

The threshold and the accounting

Delegated Regulation (EU) 2023/1185 sets both the methodology and the bar: an RCF must deliver at least a 70 % greenhouse gas saving against the fossil comparator. In practice that translates to total life-cycle emissions of no more than roughly 28.2 g CO2e per MJ, the same reference point applied to renewable fuels of non-biological origin.

Because an RCF is not renewable, it does not count towards renewable energy targets in the way a biofuel does. Member states may allow RCFs to count towards a greenhouse gas intensity reduction target, and national treatment varies significantly. This is the single most important thing to establish before contracting: name the destination member state and confirm in writing how it treats RCF, for the delivery years in question.

Certification runs through the voluntary schemes, with REDcert and ISCC both operating RCF and RFNBO scope. As with everything else in this chain, check that the certificate scope actually covers the product and the activity.

Why this matters commercially

For a plastic pyrolysis operator there are two entirely different business models sitting on the same reactor, and the choice is usually made too late.

• The petrochemical route. The oil goes to a steam cracker under ISCC PLUS mass balance and becomes certified circular polymer. The value is in the recycled-content claim a brand owner needs. Annex IX and RCF are both irrelevant here, because nothing is being burned.
• The fuel route. The oil becomes a transport fuel, and then RCF rules decide whether it counts for anything. Meet the 70 % threshold and get national recognition, and it has value; miss either, and it is simply a hydrocarbon competing on energy content.
• These two routes reward different things. The petrochemical route rewards low chlorine and a clean chain of custody. The fuel route rewards a defensible greenhouse gas calculation. A plant that has not decided which it is aiming at tends to be weak at both.

Frequently asked questions

What is a recycled carbon fuel?

A liquid or gaseous fuel produced from waste or exhaust gas of non-renewable origin, where the waste is no longer suitable for material recycling. Typical examples are fuels from non-recyclable plastic waste and from unavoidable industrial waste gases, usually made by pyrolysis or gasification.

Is a recycled carbon fuel a renewable fuel?

No, and this is the most common misunderstanding. RCFs are made from non-renewable carbon and sit outside Annex IX entirely. They are accounted for under their own rules, and member states may allow them to count towards a greenhouse gas intensity target rather than a renewable energy target. National treatment varies.

What greenhouse gas saving does an RCF have to achieve?

At least 70 % against the fossil comparator, under the methodology in Delegated Regulation (EU) 2023/1185. That corresponds to total life-cycle emissions of no more than about 28.2 g CO2e per MJ, the same reference point used for renewable fuels of non-biological origin.

Is plastic pyrolysis oil an RCF?

It can be, when it is used as a fuel and meets the RCF criteria and threshold. It is not an RCF when it goes to a steam cracker as circular feedstock, because it is not being used as a fuel at all. Those are two different business models on the same product and they reward different things.

Can RCF be certified?

Yes. The voluntary schemes operate RCF scope, with REDcert and ISCC both active in this area alongside RFNBO certification. Check that the certificate scope covers the specific product and activity, and that the greenhouse gas calculation will stand up to audit.

Do all member states recognise RCF?

No, and treatment differs considerably. Because RCFs are not renewable fuels, whether and how they count is a national decision. Establish the position for your destination market and delivery years in writing before contracting. This is the single biggest commercial risk in an RCF deal.

Who to ask about Recycled carbon fuels (RCF)

Ask us. Producing fuel from non-recyclable waste? The classification question decides the value. Ask before you contract. 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.

+31 6 115 83 448
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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.