The Union Database exists so that a litre of renewable fuel can be traced across the European Union without being counted twice. Under the Renewable Energy Directive, economic operators record consignments and transfers in it, so that a volume claimed in one member state cannot also be claimed in another. It does not replace your scheme certification: you still need ISCC, REDcert or another recognised scheme, and the database records what that certification supports. The rollout has been phased and the detail differs by member state and by fuel type, so the useful preparation is not to memorise a deadline but to make sure your own records can survive being matched against somebody else's, consistent quantities, consistent feedstock categories, and a defensible greenhouse gas figure at every transfer.
- 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 problem it is solving
The European waste-based market grew faster than the systems tracking it. Sustainability proof moved as documents between private parties, which worked well enough within one chain but made cross-border checking hard. If the same volume was declared to two authorities, nothing in the system necessarily caught it.
The Union Database is the answer to that: a single place where consignments and their transfers are recorded, so a claim in one member state is visible against a claim in another. Whatever you think of the administrative load, the intent is one most honest participants in this market share, because fraud in waste feedstock hurts the people doing it properly first.
It does not replace your certification
This is the most common misunderstanding, and it is worth being blunt about. The database records data; the scheme certifies the operator and the chain. You need both, and one does not substitute for the other.
In practice the database asks for information you should already hold if your certification is in order. Which is the useful way to think about preparation: if entering your data into a shared system worries you, the problem is usually upstream of the database.
What actually has to be right at every transfer
The detail of who registers what, and when, has been phased in and varies by member state and fuel type. Rather than restate a timetable that may have moved by the time you read this, here is the part that does not change: the data has to reconcile with somebody else's data.
That is a higher bar than it sounds. A rounding difference between the declaration and the bill of lading, a feedstock described one way at collection and another at the refinery gate, a greenhouse gas figure carried forward without the basis it was calculated on, all of these survive fine in a paper chain and fail in a matched one.
- Quantities that reconcile across the declaration, the bill of lading and the invoice.
- Feedstock category described consistently from collection to delivery, with the same words at each step.
- Greenhouse gas figures carried with the basis they were calculated on, not just the number.
- Counterparty identity matching between the declaration, the contract and the invoice, the same trap that stalls Nabisy entries.
- Certificate scope covering the activity being recorded, not just the product.
What to do before it reaches you
The most useful preparation is unglamorous and pays off regardless of what the database eventually requires of you specifically.
None of this is database-specific. It is what a well-run chain looks like, and the database simply makes the gaps visible.
- Ask your certification body what applies to your role, in your member state, for your product. That answer is specific and it changes; a website cannot give it to you, including this one.
- Reconcile your own documents first. Take three recent consignments and check that quantities, categories and parties match across every document. If they do not, that is your homework.
- Fix the vocabulary. Agree one description per feedstock and use it everywhere, including in contracts.
- Keep the calculation, not just the number. A greenhouse gas figure without its basis is not defensible when someone asks.
- Talk to your counterparties. Your data has to match theirs, so the conversation is worth having before the system has it.
Why we wrote this page
A buyer asked us, in writing: they had searched this site for information on the Union Database in the HVO chain, not found it, and emailed instead.
That is a fair complaint about a site that claims to explain this market, so the gap is closed. Where the answer depends on your member state, your role or your fuel type, this page points you at your certification body rather than guessing on your behalf, a confident wrong answer about a compliance obligation is worse than no answer at all.
Frequently asked questions
What is the Union Database?
It is the European system for recording biofuel consignments and their transfers, introduced under the Renewable Energy Directive so that a volume claimed in one member state cannot also be claimed in another. It records data about consignments that your scheme certification supports; it does not certify anything itself.
Does the Union Database replace ISCC or REDcert?
No. The scheme certifies the operator and the chain of custody; the database records the resulting consignment data so it can be matched across borders. You need both, and the database generally asks for information you should already hold if your certification is in order.
What do I have to do to prepare?
Ask your certification body what applies to your role, your member state and your product, because that answer is specific and it changes. Then do the part that helps regardless: reconcile quantities, categories and counterparty names across the declaration, bill of lading and invoice for a few recent consignments, and fix whatever does not line up. Data that survives being matched against someone else's is the whole game.
What are the requirements for UDB in an HVO supply chain?
The registration and reporting detail has been phased in and differs by member state and fuel type, so confirm your own position with your certification body rather than reading it off a page. What holds in every version is that each transfer has to reconcile: quantities consistent across documents, feedstock described the same way from collection to refinery gate, the greenhouse gas figure carried with its calculation basis, and the counterparty identity matching between declaration, contract and invoice.
Who has to register?
Economic operators in the chain, with the specifics depending on your role and member state. If you are a collector, processor, trader or fuel supplier, assume the question applies to you and get a definite answer from your certification body rather than assuming somebody downstream will handle it.
What is the most common problem people hit?
Data that does not reconcile. A rounding difference between the declaration and the bill of lading, a feedstock described one way at collection and another at delivery, or a greenhouse gas figure passed on without its basis. All of these survive fine in a paper chain and fail the moment two records are matched against each other.
How does it relate to national systems like Nabisy?
The Union Database changes how sustainability data moves across the EU, and its relationship with national systems has been evolving. Confirm the current position for your specific chain with your certification body. What has not changed is that the national authority still needs proof it can book, and that proof still starts with your certification and your documents.
Will this make fraud harder?
That is the intent, and cross-border matching does close a gap that document-based proof left open. It is not a complete answer on its own, data entered consistently can still describe something that never happened, which is why audit and physical verification still matter. But double counting across member states gets considerably harder, and that is worth something to everyone trading this material honestly.
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.
- Singapore, Brazil move to build green fuel shipping corridor
- Auramarine builds business on marine fuel flexibility
- Stargate Hydrogen Strengthens Nordic Expansion with Petri Sarnes, Former Siemens Power Sector Director of FinBaltic region
- Econetix Adds New Biochar And Bamboo Project To Its Portfolio
- Everllence launches G80 ethanol capable engine for shipping with Vale
- Airfix, CO2 Energie AG and South Pole begin commercial cross-EU BECCS project
- California recycled content bill passes legislature
- RINA Type Approval for PowerCell Marine System 225
- Engine for ‘world’s first’ ethanol-powered VLOC completes R&D test
- Suzun Marine Fuels: Crew welfare and bunker contracts
- GMI doubles hydrogen bulker programme
- The top 10 most-read nova and RCI reports of the last 12 months
- UNDP, HUL partner to scale up circular economy for plastics
- Tyromer Wins Colorado Mining Cleantech Challenge with Circular Solution for Mining Tyres
- Planning for a circular city
- Recycling bills clear House subcommittee
- Envalior, Secara MOU focuses on PCR use in automotive resins
- Planning for a circular city: An implementation guide to strategic urban planning policy for circularity
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 Union Database
Just ask. Working out what the Union Database means for your chain? Tell us where you sit in it and what your certification covers, and we will go through it with you. 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 Union Database
A direct line to the desk. We answer the same working day in almost all cases, and we will tell you plainly when a cargo is not something we can place.
Prefer email? bart@sustainablecommodities.eu · +31 6 115 83 448
Last reviewed 03 September 2026. Regulatory references are given for orientation and are not legal advice: verify against the current Official Journal text before contracting.