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
How does ERE interact with FuelEU for Dutch bunkers?
Shipping fuel in Dutch ports sits where national and maritime regimes meet, the obligations layering rather than conflicting, both reading the same litres. Rotterdam's ships file double homework.
Can foreign material earn ERE value?
Imported certified material earns within the Dutch chain's rules, the origin papers converting to Dutch compliance units. Foreign oil learns Dutch arithmetic.
What is an emission factor in ERE terms?
The lifecycle carbon number per energy unit, the factor deciding how hard each tonne works toward the obligation. The factor is the fuel's tax fingerprint.
How liquid is ERE compliance trading?
The Dutch market's depth makes its instruments among Europe's most tradable, liquidity being the point of the hub. Compliance trades like a commodity because it is one.
Do ERE prices lead Europe?
The Dutch market's transparency makes it a reference others watch, the price discovery radiating outward. Rotterdam thinks out loud.
What is a HBE in the Dutch system?
Hernieuwbare Brandstof Eenheid, the renewable fuel unit the Dutch obligation trades in, the currency the old system minted and the new ERE regime inherits in evolved form. Dutch compliance has its own money, and we speak it.
How does ERE treat waste oils versus crops?
Waste and residue chains carry the higher compliance value as everywhere, the Dutch intensity arithmetic rewarding the same carbon logic the EU mandates. The Netherlands prices good chemistry.
What changed for importers under the ERE?
The bookkeeping moved deeper into the digital chain and theGHG figures became sharper currency, import files now built to Dutch tolerances from the first document. The Dutch market reads decimals.
Is the Dutch market open to new sellers?
Very, depth of buyers meeting strictness of files, exactly the market where a complete newcomer with complete documents beats an established name with loose ones. The Netherlands rewards preparation.
Who has to comply with the ERE?
The Dutch fuel suppliers who bring fuels to the Dutch market, the parties with the obligation to reduce greenhouse gas intensity. Producers and traders do not carry the obligation, they supply the tonnes and the documentation that let the obligated parties comply.
What is the penalty for missing ERE compliance?
Standard amounts per unit of shortfall, set in the Dutch implementation, paid by the obligated party that misses its reduction line. That penalty is the floor under the price of compliance tonnes, which is why it is a number the market knows by heart.
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.
- Introducing Green Value Chain Connect: From WCEF learnings to value chain action
- Ashland unveils vegetable oil-based crop protection dispersant
- Polybion’s cultivated cellulose debuts on the runway
- Maersk successfully bunkers vessel with US corn-based ethanol
- California Bioenergy acquires Sevana Bioenergy’s interest in South Dakota Biogas LLC
- Nord Gas Solutions wins tech contract for Polish biogas liquefaction plant
- Island Oil rebrands as Island Energies
- ContiTech to Use BolderBlack for Conveyor Belt Production in the Americas
- Plastics Recycling: TotalEnergies Becomes the Sole Owner of the Grandpuits Advanced Plastics Recycling Plant
- Stargate Hydrogen secures 21 million Euros from the EU Innovation Fund to further scale up its operations
- I’m green™ bio-based Helps Deterra® Win Multiple Industry Awards for Pharmaceutical Packaging
- „I’m green™ bio-based” verhilft Deterra® zu mehreren Branchenauszeichnungen für pharmazeutische Verpackungen
- World’s Largest Green Methanol Project Achieves ISCC EU Certification
- Bundesumweltministerium startet Innovationsplattform “Circular AI Hub”, Künstliche Intelligenz soll Unternehmen der Kreislaufwirtschaft helfen
- Brazil sorghum output surges as China exports and ethanol demand grow
- Hong Kong opens first hydrogen fuel testing lab
- NAW appeals Oregon EPR ruling
- Industry stakeholders urge EU to retain RED III binding RFNBO targets post-2030
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 29 September 2026. Regulatory references are given for orientation and are not legal advice: verify against the current Official Journal text before contracting.