Recycled carbon fuels are liquid or gaseous fuels made from waste or exhaust gas of non-renewable origin, where the waste is no longer suitable for material recycling. In practice that means non-recyclable plastic waste and unavoidable industrial waste gases, usually converted by pyrolysis or gasification. The critical point, and the one that catches people out: an RCF is not a renewable fuel. It sits outside Annex IX entirely and is accounted for under its own rules, with a 70 % greenhouse gas saving threshold set by Delegated Regulation (EU) 2023/1185.
- 1Non-biogenic waste stream
- 2Converted into a fuel
- 3Greenhouse gas saving calculated on its own methodology
- 4Counted separately from biofuels
- 5Placed with a buyer whose mandate allows it
Recycled carbon fuels come from fossil-origin waste, so they sit outside Annex IX and are counted under their own rules. A buyer set up for biofuel mandates cannot always use them, and that eligibility question decides the deal long before the specification does.
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.
Why a recycled carbon fuel is not a biofuel, and what that costs
This is the distinction that catches people out. A fuel made from non-recyclable plastic waste is not a biofuel and is not in Annex IX. It is a recycled carbon fuel, governed by its own rules, and it does not automatically count towards the same targets. Assuming otherwise has underwritten more than one business plan that did not survive contact with a fuel supplier's compliance desk.
| Waste-based biofuel | Recycled carbon fuel | Fossil | |
|---|---|---|---|
| Carbon origin | Biogenic waste or residue | Non-renewable waste, typically non-recyclable plastic | Crude |
| Listed in Annex IX | Yes, Part A or Part B | No | No |
| GHG saving threshold | Per RED, by plant commissioning date | 70 % against a 94 gCO2e/MJ fossil comparator | Not applicable |
| Counts towards the renewable target | Yes | Member state discretion; not automatic | No |
| Typical products | HVO, FAME, biomethane, SAF | Pyrolysis-derived naphtha and fuels | Refinery slate |
The 70 % threshold is the gate. A recycled carbon fuel has to demonstrate at least a 70 % greenhouse gas saving against a fossil comparator of 94 gCO2e/MJ, and the methodology for that is set out in Commission Delegated Regulation (EU) 2023/1185. That calculation is a project-level exercise, not a product property, so two plants running the same feedstock can land on different sides of it.
There is a second route that avoids the question entirely: sell the pyrolysis oil as a chemical feedstock rather than as a fuel. A steam cracker taking it towards new polymer is working under mass balance and recycled content rules instead, which is a different conversation with different economics. See plastic 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 a lot. This is the first 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.
Four categories that people mix up, and the 70 percent trap
Almost every argument we hear about recycled carbon fuels comes from someone using the word for something that is not one. The categories are legally distinct, they are accounted for differently, and a volume in the wrong box is worth a different amount of money.
| Biofuel | From biomass. Counts towards renewable targets, and if the feedstock sits in Annex IX Part A it can be double counted where a member state allows it. See Annex IX feedstocks. |
|---|---|
| Recycled carbon fuel (RCF) | From non renewable waste streams that are not suitable for material recovery, or from unavoidable industrial process and exhaust gases. Defined in Article 2(35) of RED. NOT renewable, so it does not count towards a renewable target. A member state MAY allow it against a greenhouse gas intensity target, and national treatment varies. |
| RFNBO | Renewable fuel of non biological origin: hydrogen and its derivatives made with renewable electricity. Renewable, but under its own strict additionality and correlation rules. |
| Low carbon fuel | Low carbon hydrogen and synthetic fuels derived from it, governed separately under the gas market rules rather than under RED. Delegated Regulation (EU) 2025/2359 sets the methodology here and expressly EXCLUDES recycled carbon fuels, because those stay under RED. |
Here is the trap. A 70 percent greenhouse gas saving threshold appears in more than one of these regimes, so people assume the regimes are interchangeable. They are not. For RCF the threshold comes from Delegated Regulation (EU) 2023/1185 and is measured against a fossil comparator of 94 grams CO2 equivalent per megajoule, which puts the ceiling at roughly 28.2 grams per megajoule for the finished fuel. Meeting 70 percent under one regime tells you nothing about your position under another, and the certification scope on your certificate has to match the category you are actually selling into.
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
Do recycled carbon fuels double count under RED III?
No. Recycled carbon fuels count once towards the transport target: they sit outside Annex IX, so there is no double counting and no advanced biofuel multiplier, wherever you are in the EU. The nuance is the same cargo can carry both frameworks: the fossil fraction of tyre pyrolysis oil counts as an RCF while the biogenic fraction of the very same oil can be an advanced biofuel under Annex IX Part A. Which is why the biogenic share, measured by carbon-14, is part of the product rather than a nice extra.
What is the difference between a recycled carbon fuel and a biofuel?
Feedstock origin, and it changes how the volume counts. A biofuel comes from biomass and counts towards renewable targets. A recycled carbon fuel comes from non renewable waste streams not suitable for material recovery, or from unavoidable industrial process gases, and is defined in Article 2(35) of RED. An RCF is not renewable, so it cannot count towards a renewable target. A member state may allow it against a greenhouse gas intensity target instead, and that decision is national.
Does the 70 percent threshold for recycled carbon fuels mean the same as the 70 percent for low carbon fuels?
No, and this catches people out. For recycled carbon fuels the threshold comes from Delegated Regulation (EU) 2023/1185, measured against a fossil comparator of 94 grams CO2 equivalent per megajoule. The separate methodology for low carbon fuels, in Delegated Regulation (EU) 2025/2359, expressly excludes recycled carbon fuels: those stay under RED. Same number, different regime, different certification scope. Check that your certificate covers the category you are actually selling into.
Is pyrolysis oil from plastic a recycled carbon fuel?
It can be, if it goes to fuel and the waste stream genuinely was not suitable for material recovery. That last condition is the one that gets skipped. If the material could have been recycled, the RCF route is not automatically open, and the same oil sent to a cracker for new polymer is a different proposition commercially and legally. See plastic pyrolysis oil.
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.
Market news
The most recent headlines touching this market, followed by wider news from across the feedstock and renewable fuel sector. 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 Recycled carbon fuels (RCF)
Just ask. Producing fuel from non-recyclable waste? The classification question decides the value. Ask before you contract. 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
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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.