Analyse overgang
sturen op CO2
Impact of greenhouse gas emissions
reduction-based targets on the
investment landscape for renewable
transport fuels in the Netherlands
Final report

Contract details
Rijksdienst voor Ondernemend Nederland (RVO)
GAVE210009

Presented by
Trinomics B.V.
Westersingel 32A
3014 GS, Rotterdam
the Netherlands

Main author(s)
Marine Gorner (Marine.Gorner@trinomics.eu)
Tycho Smit (Tycho.Smit@trinomics.eu)
Onne Hoogland (Onne.Hoogland@trinomics.eu)

Date
22/02/2022

Disclaimer
The views expressed in this report are purely those of the writers and may not in any circumstances be
regarded as stating an official position of RVO.

Rotterdam, 22/02/2022
Client: Rijksdienst voor Ondernemend Nederland (RVO)
GAVE210009
Analyse overgang sturen op CO2 : Impact of greenhouse gas emissions
reduction-based targets on the investment landscape for renewable transport
fuels in the Netherlands

Marine Gorner, Trinomics
Tycho Smit, Trinomics
Onne Hoogland, Trinomics

TEC1289NL

TEC1289NL

Analyse overgang sturen op CO2

TABLE OF CONTENT
1

RED II and its revision proposal (RED III) in the EU and the Netherlands ............... 7
1.1

Current European legislation: the EU RED II ................................................. 7

1.2

The EU RED II revision proposal (RED III) ..................................................... 7

1.2.1

EU policy context for sustainable transport fuels .................................................... 7

1.2.2

Main characteristics and key differences with RED II ................................................ 8

1.3

2

1.3.1

The Jaarverplichting policy ............................................................................. 9

1.3.2

The Dutch Climate Agreement ........................................................................ 11

1.3.3

E10 obligation ........................................................................................... 11

1.3.4

Decarbonisation of the aviation sector .............................................................. 12

Alternative fuel use in Dutch transport......................................................13
2.1

Historical evolution (2011-2020) ............................................................. 13

2.1.1

Liquid biofuels dominate renewable energy use under the Jaarverplichting .................. 13

2.1.2

The mix of renewable energy carriers in transport is diversifying ............................... 13

2.1.3

Biofuel use in the maritime sector ................................................................... 14

2.2

3

Dutch policies for renewable energy in transport and links to the RED ............... 9

Transport fuel projections to 2030 .......................................................... 15

2.2.1

EU trends ................................................................................................ 15

2.2.2

Projected evolution of renewable energy in transport in The Netherlands .................... 15

GHG emissions accounting under the RED III and impacts................................17
3.1

GHG emissions savings of renewable fuels and energy sources ....................... 17

3.1.1

Biofuels and biogas ..................................................................................... 18

3.1.2

Electricity ................................................................................................ 19

3.1.3

RFNBOs ................................................................................................... 21

3.2

Calculated impact of the RED III accounting mechanism for renewable fuels in the

Netherlands in a 2020 timeframe ............................................................................. 21
3.3

Calculated impact of the RED III accounting mechanism for renewable fuels in the

Netherlands in a 2030 timeframe ............................................................................. 23

4

3.3.1

Impact of electric vehicles ............................................................................ 23

3.3.2

Impact of a cap on the use of used cooking oil and animals fats as feedstocks ............... 24

Dutch landscape for renewable fuel production ...........................................25
4.1

Liquid biofuel production in the Netherlands ....................................................... 25

4.1.2

Green gas production for transport .................................................................. 26

4.2

5

Domestic production ............................................................................ 25

4.1.1

Imports and exports ............................................................................. 26

Discussion and conclusions .....................................................................29
5.1

TEC1289NL

Transport electrification ....................................................................... 30

Analyse overgang sturen op CO2

5.2

UCO-based fuels .................................................................................. 30

5.3

Other renewable fuels and energy vectors ................................................ 31

5.3.1

Conventional biofuels .................................................................................. 31

5.3.2

Advanced biofuels ...................................................................................... 32

5.3.3

RFNBOs ................................................................................................... 32

5.4

Prospects in the maritime and aviation sectors .......................................... 32

5.5

Domestic consumption and exports ......................................................... 33

TEC1289NL

Analyse overgang sturen op CO2

1 RED II and its revision proposal (RED III) in
the EU and the Netherlands
1.1 Current European legislation: the EU RED II
The Renewable Energy Directive (RED) is the European Commission’s (EC) “legal framweork for the
development of renewable energy across all sectors of the EU economy” (EC, 2021a), by setting
renewable energy use targets and conditions. The current version of the RED (abbreviated as RED II)
entered into force in 2018. It replaces the original Renewable Energy Directive from 2009.
A specific target of 14% renewable energy exists for the transport sector (road and rail), that fuel
suppliers need to meet in each Member State by 2030. The target is expressed in terms of energy
content, meaning that, of all the energy delivered to the road and rail transport sectors in 2030, 14% of
it must be energy that is considered renewable under the conditions of the Directive.
In addition to this overall target, the RED II establishes a number of conditions and accounting rules for
the renewable energy sources eligible under the framework. In particular, it includes:


Subtargets and caps, in addition to the 14% overall target, for specific fuels;



Sustainability conditions and criteria to be met in order to be eligible as a renewable fuel and
to be eligible to be accounted towards RED II targets;



Multipliers that allow certain renewable energy sources and fuels to contribute more than one
time their energy content towards the targets;



A classification of feedstocks for the production of biofuels and biogas in three main
categories: 1. food crops, 2. Annex IX.A feedstocks (for the production of biogas for transport
and advanced biofuels), 3. Annex IX.B feedstocks (for the production of biogas for transport
and biofuels from used cooking oil and animal fats) (see Table 1-1).

Table 1-1 Examples of biogas and biofuel feedstocks under the three main categories considered under the RED
Conventional (food crops)

Feedstocks under RED Annex IX,
Part A

Feedstocks under RED Annex IX,
Part B

Corn, sugarcane, sugarbeet,
wheat, rapeseed, palm, soy

Organic waste, straw, bagasse and other
non-food cellulosic and ligno-cellulosic
material, animal manure, sewage sludge

Used cooking oil, animal fats1

Sources: EC (2018), NEa (2021)

The set of conditions and rules for different renewable energy sources and fuel categories under the
RED II are summarized in Table 1-2.
Finally, the maritime and aviation sectors are out of the scope of the RED II for transport, although
fuels used in those sectors may opt-in to be counted towards the 14% target (EC, 2019).

1.2 The EU RED II revision proposal (RED III)
1.2.1 EU policy context for sustainable transport fuels
In view to deliver on the European Green Deal, which aims at “transform[ing] the EU into a modern,
resource-efficient and competitive economy” (EC, 2022), the European Commission presented in
summer 2021 a Fit-for-55 package of policy proposals to reduce greenhouse gas (GHG) emissions by at

1

Classified as categories 1 and 2 in accordance with Regulation (EC) No 1069/2009. In this report, the wording
“animal fats” will always refer to these categories.

7

Analyse overgang sturen op CO2

least 55% by 2030, from 1990 levels (EC, 2021b). The RED II revision proposal (hereafter abbreviated as
RED III) was issued in this framework, along with other policy proposals relevant to the transport sector
and that, if adopted, will have an impact on the roll-out of more efficient, lower-carbon transport fuels
in the period leading to 2030 and beyond. Such other relevant proposals, that will impact the future of
transport fuels in various transport sectors, are summarized below:
-

The inclusion of transport in the EU Emissions Trading Scheme;

-

Stronger CO2 emission standards for cars and vans and the conversion of the Alternative Fuel
Infrastructure Directive (AFID) into a Regulation (AFIR), which will accelerate the penetration of
alternative powertrains (e.g. battery and fuel cell electric vehicles) and thus of alternative
transport fuels (typically electricity and hydrogen) on the market;

-

The aviation and maritime sectors are specifically tackled via the new ReFuelEU Aviation and
FuelEUMaritime proposals respectively:
o

ReFuelEU Aviation requires the blending of Sustainable Aviation Fuels (SAF) in aircrafts at
EU airports: aircrafts should be fueled with a minimum volume of 5%2 of SAFs by 2030, and
63%3 by 20504 (EC, 2021c);

o

FuelEU Maritime introduces GHG emissions reduction targets for energy use on-board of
ships calling at European ports: -6% by 2030 and -75% by 20505. It also requires zeroemission energy supply while at berth (EC, 2021d).

-

The revision of the taxation of energy products (Energy Taxation Directive) in line with EU energy
and climate policies.

These policies will also influence the competitiveness landscape for transport fuels, either by
supporting alternative vehicle powertrains in different transport modes or by supporting the delivery
and use of a variety of alternative, low-carbon transport fuels. As a result, the effect of the RED II
revision proposal on various transport fuels should also be considered in the wider context of other EU
policies relevant to energy in the transport sector.
1.2.2 Main characteristics and key differences with RED II
In 2021, as part of the European Green Deal and the Fit-for-55 package, a revision proposal of the
Renewable Energy Directive was presented by the EC in July 2021. It is expected to be adopted by the
end of 2022 (EC, 2021).
For transport, one of the major changes introduced by this revision is the formulation of the 2030
target, which, from being expressed in terms of energy content in the RED II - 14% renewable energy by
2030 – is expressed in terms of greenhouse gas emissions (GHG) intensity reduction in its revision : -13%
GHG intensity of transport fuels by 20306. Other major changes in the revised RED framework is the
application of the new target to all transport modes, 7 and the end of multipliers.8 Changes in a number
of caps and subtargets are also being proposed (EC News, 2021).

2

0.7 % of which synthetic aviation fuels
28 % of which synthetic aviation fuels
4
ReFuelEU Aviation also includes intermediate targets for the years 2025, 2035, 2040 and 2045.
5
FuelEU Maritime also includes intermediate targets for the years 2025, 2035, 2040 and 2045.
6
The EC calculated that this new target should be equivalent to an energy-based target of 28% under the RED II
framework (EC News, 2021).
7
vs. road and rail only in RED II – see 1.1
8
except for advanced biofuels and Renewable Fuels of non-Biological Origin (RFNBOs) in the aviation and maritime
sectors.
3

8

Analyse overgang sturen op CO2

Table 1-2 presents the major characteristics of RED II and its revision proposal for various renewable
transport fuels and energy sources.
Table 1-2 Comparative table of the main characteristics of the RED II and its revision proposal for transport
RED II
Overall transport target

14% renewable energy by 2030

Scope

Road and rail transport9

Fuel

Feedstock

FAME/
Ethanol/
HVO/Biogas

Conventional
(food crops)
Advanced
biofuels (IX.A)
UCO and animal
fats (IX.B)

10

RED II revision proposal (RED III)
13% GHG intensity reduction by 2030
(compared to a liquid fossil fuel
baseline GHG intensity)
Entire transport sector

Mandate/Cap

Multiplier

Mandate/Cap11

Multiplier

7% cap

-

7% cap

-

1.75% mandate

x2

2.2% mandate

-

1.7% cap

x2

1.7% cap

-

Renewable electricity

x4

RFNBOs

-

Maritime and aviation

2.6% mandate

x1.212

fuels

x1.213

Sources: EC (2019), EC News (2021), ICCT (2021)
Note: In the RED II and its revision proposal, Recycled Carbon Fuels (RCFs) may also contribute towards the targets.

In both the RED II and RED III, renewable fuels need to meet certain GHG emissions reduction thresholds
in order to be eligible to count towards the targets. These sustainability criteria remain largely
unchanged in the revised version.
Finally, under the RED III, GHG emission intensity reductions are to be calculated against benchmark
values. There are two counterfactual values to be considered:
1.

94 gCO2eq/MJ, representative of the GHG emissions intensity of liquid and gaseous fossil fuels,
against which the GHG emissions savings of all liquid and gaseous biofuels is to be calculated;

2.

183 gCO2eq/MJ, representative of the GHG emissions intensity of fossil-derived electricity,
against which the GHG emissions savings of renewable electricity are to be calculated (ICCT
(2021)).

1.3 Dutch policies for renewable energy in transport and links to the RED
1.3.1 The Jaarverplichting policy
Principle and scope
In the Netherlands, the EU renewable energy obligations for the transport sector have been transposed
into the “Jaarverplichting transportbrandstoffen” (Jaarverplichting). This instrument is one of the key
policies in place to ensure the achievement of RED targets for transport. Under the Jaarverplichting,
suppliers of liquid transport fuels are obliged to submit a number of renewable energy units (HBEs) for
each unit of gasoline and diesel they sell on the domestic market. Renewable electricity in rail
9

fuels used in the maritime and aviation sectors may opt-in to be counted towards the 14% target (EC, 2019).
Expressed in energy terms. Exemptions may apply under certain conditions.
11
Expressed in energy terms. Exemptions may apply under certain conditions.
12
Applicable to non food-based renewable fuels.
13
Applicable to advanced biofuels and Renewable Fuels of non-Biological Origin (RFNBOs) only.
10

9

Analyse overgang sturen op CO2

transport, which is relatively important in the Netherlands, cannot generate HBEs. It however does
count for the achievement of the RED transport target. Finally, renewable energy supplied to the
aviation and maritime sectors can opt-in to contribute to the RED II target. The respective scopes of
RED II for transport and Jaarverplichting, i.e. the sectors which cumulative energy supplied needs to
meet the targets, are presented in Table 1-3.
Table 1-3 Sectoral scopes of the RED II for transport and of the Dutch Jaarverplichting policy
Scope Jaarverplichting

Scope RED II transport target

All gasoline and diesel and their biobased alternatives

Road and rail transport

supplied to the domestic market14

Generation and submission of HBEs
Even though HBEs only need to be submitted for gasoline and diesel fuels supplied onto the domestic
market, HBEs can be generated for all renewable fuels delivered to the transport sector, regardless of
where they are used (with the exception of electricity used for rail transport). In 2021, there were
three types of HBEs: HBEs for conventional biofuels from food or energy crops;15 HBEs for advanced
fuels;16 and HBEs for other types of renewable transport energy.17
Fuel suppliers that supply fuel to the sectors that fall under the scope of the Jaarverplichting need to
submit an amount of HBEs that is equal to the target share set for that year: if a fuel supplier supplies
100 GJ of such liquid fuels and the obligation share is 16.4% (obligation for 2020), the supplier needs to
submit an equivalent of 16.4 GJ in HBEs. The supplier can do so by delivering renewable fuels (biofuels,
renewable electricity, RFNBOs) for which HBEs are issued or the supplier can buy HBEs from renewable
fuel producers. The HBE market is independent from the market for the actual fuels and HBEs can be
traded between different transport subsectors. Therefore, for a same subsector, differences between
the amount of HBEs submitted and its physical consumption of renewable energy are possible. When
this difference becomes too large, the achievement of some targets for which the reporting is based on
the physical quantities of renewable energy consumed in certain sectors, such as under the RED, can
pose an issue.
When it comes to the multipliers used in the Jaarverplichting, the x2 multipliers for non-conventional
biofuels have been taken over directly from the RED. When it comes to the accounting of electricity in
the HBE system, only renewable electricity can receive HBEs. Until 2017, renewable electricity would
benefit from a multiplier of x2.5, in line with RED I. Since 2018, this evolved to a x5 multiplier. These
multipliers are meant to account in particular for the energy efficiency of electric vs. internal
combustion engine vehicles. From 2022 onwards the multiplier is changed again, to x4 – in line with RED
II.

14

Except a fraction of gasoline and diesel that may be supplied to stationary applications, these fuels are supplied to
the transport sector. From 2022 onwards, inland shipping is excluded from the scope.
15
“Type C” HBEs
16
“Type G” HBEs, including liquid or gaseous biofuels produced with feedstocks listed under Annex IX.A of the RED.
17
“Type O” HBEs, including renewable electricity used in road transport, biofuels produced from feedstocks listed in
Annex IX.B of the RED, biofuels produced from feedstocks not listed in Annex IX.B of the RED which are also not from
food or energy crops, and renewable fuels from non-biological origin (RFNBOs) (e.g. hydrogen and other e-fuels).
From 2022, Annex IX.B biofuels are included under a new HBE category (“HBE IX.B”).

10

Analyse overgang sturen op CO2

Jaarverplichting targets
The Jaarverplichting policy requires a renewable energy share of 28% by 2030 for the sectors falling
under its scope (Table 1-4). This is significantly more ambitious that the 2030 RED II target (14%), and is
expected to be comparable to the target of the revised RED II (see footnote 6). The difference between
the ambition level of the Jaarverplichting vs. the RED II may be explained by the fact that the
Jaarverplichting was not only designed to achieve EU-level targets but also national climate policy
targets, and to a lesser extent because of the difference in scope between the EU and the Dutch
policies discussed previously. Indeed, as the maritime sector is allowed to generate HBEs and is
particularly significant in the Netherlands, the target under the Jaarverplicthing needs to be higher
than the transport renewable energy target under the RED, to ensure sufficient renewable energy use
within the road transport sector as well. However, resctrictions over the generation of HBEs for biofuel
delivery to the maritime sector have been implemented by the Dutch government and, since 2021, the
maritime sector can only generate HBEs for the supply of advanced biofuels and RFNBOs.
Table 1-4 Targets of the EU RED and the Dutch Jaarverplichting policies
Policy target

Type of target

2020

2030

Jaarverplichting

Renewable energy share

16.4%

28%18

RED I

Renewable energy share

10%

N.A.

RED II

Renewable energy share

N.A.

14%

RED III

GHG emissions intensity reduction

N.A.

13%

1.3.2 The Dutch Climate Agreement
In the national Climate Agreement, multiple ambitions for emissions reductions in the transport sector
are outlined. It focuses strongly on the electrification of road transport through the stimulation of
electric vehicles (battery electric and plug-in hybrid electric vehicles) and the quick roll-out of charging
infrastructure. It has been agreed that on top of the increase in renewable electricity and hydrogen use
in road transport projected for 2030 by the National Climate and Energy Projections (KEV 2017), a
maximum of 27 PJ of additional renewable energy use (i.e. mostly biofuels) would be stimulated under
the Jaarverplichting. However, this means that if the use of electricity (and hydrogen) in road transport
grows faster than anticipated in the KEV 2017 projections, the additional amount of renewable liquid
fuels required would be lower. A separate target has been set for 5 PJ of renewable energy use in
domestic shipping, but a policy instrument to promote this still needs to be developed.

1.3.3 E10 obligation
In 2019, a blending obligation to blend at least 8.5% biofuels into gasoline by volume (V/V),19 has been
implemented. This policy measure therefore acts as a parallel driver, next to the targets from the RED
and the Climate Agreement, for the use of bioethanol in the Dutch road transport sector. The majority
of the bioethanol used in Dutch road transport is imported conventional bioethanol. In Spring 2021, the
Dutch parliament has adopted motion De Hoop,20 which requests the cabinet to include a phase out
trajectory for conventional biofuels in Dutch Energy for transport legislation (Besluit energie vervoer).
18

The 2030 target was revised from 27.1% (until 2021) to 28% (from 2022)
Staatsblad (2019) Besluit van 14 juni 2019 tot wijziging van het Activiteitenbesluit milieubeheer en het Besluit
brandstoffen luchtverontreiniging in verband met de invoering van E10-benzine en de informatieplicht van
leveranciers van brandstoffen.
20
Motie van het lid De Hoop over een afbouwpad voor biobrandstoffen uit voedsel- en voedergewassen opnemen in
het Besluit energie vervoer voor 2023 (2021).
19

11

Analyse overgang sturen op CO2

A study commissioned by the Ministry of Infrastructure and Water management21 concluded that the
concerns mentioned in the De Hoop motion in relation to direct and indirect land use change associated
with the use of sugar crops are relatively low. Nevertheless, future decisions of the parliament on
imposing further limitations on the use of food and fodder crops as biofuel feedstock could have
substantial implications on the evolution of renewable fuel use in the Dutch transport sector.
1.3.4 Decarbonisation of the aviation sector
Even though the aviation sector currently remains out of scope in most climate policies due the
importance of its international component, the Dutch government has intentions to introduce climate
policies for this sector as well. First of all, the government supports EU-level initiatives to improve the
level playing field between aviation and other sectors through the reform of the fiscal framework for
aviation fuels.22 Next to this, the Netherlands is in favour of introducing a blending obligation for
sustainable aviation fuels, preferably at the EU level. The Dutch government intends to lobby at the EUlevel for such an obligation in the coming years, but if no obligations are implemented by 2023 the
government intends to introduce a national obligation from that year onwards.23 Lastly, the Dutch
government intends to promote the manufacture of synthetic kerosene in the Netherlands and is
planning for the country to become a frontrunner in this area.

21

Gear Up (2021) Inzet van biobrandstoffen uit voedsel- en voedergewassen in de transportsector.
VVD, D66, CDA & ChristenUnie (2021) Coalitieakkoord 2021 – 2025 – Omzien naar elkaar, vooruitzien naar de
toekomst.
23
Kamerbrief IENW/BSK-2020/24484 - Kamerbrief ontwikkelingen duurzame brandstoffen luchtvaart.
22

12

Analyse overgang sturen op CO2

2 Alternative fuel use in Dutch transport
2.1 Historical evolution (2011-2020)
2.1.1 Liquid biofuels dominate renewable energy use under the Jaarverplichting
Over the past decade, liquid biofuels have represented the lion’s share of the renewable energy
consumed in the Dutch transport sector. In 2020, they accounted for 94% of the sector’s total
renewable energy consumption. Since the early 2010s, biodiesel has been the most important type of
biofuel in the Netherlands, more specifically in the form of Fatty Acid Methyl Esther (FAME) which is
made by combining vegetable oils with methanol. In 2011, FAME represented roughly two thirds of the
total biofuel consumption, with about 70% of it from conventional feedstocks and the rest from residue
streams (subject to a x2 multiplier under the RED) (Figure 2-1). In 2020, FAME still represented 69% of
the renewable energy consumed in the transport sector, but conventional feedstocks were almost fully
replaced by double-counting feedstocks, which accounted for 99.7% of all FAME feedstocks in 2020 predominantly used cooking oil (UCO) (>75% of all FAME). In 2020, the use of conventional biofuels from
feed and fodder only represented 1.8% of the energy consumption within road and rail transport 24 and
about 1% of the domestic transport energy use, meaning that the Netherlands remained well below the
RED cap of 7% for such fuels.
2.1.2 The mix of renewable energy carriers in transport is diversifying
Since 2018, the diversity of renewable fuels and energy sources consumed in the transport sector
increased substantially, in particular with Hydrotreated Vegetable Oil (HVO), biomethane, advanced
bioethanol and electricity (Figure 2-1). The increase in the use of HVO coincides with the start of
operations of the Neste biorefinery in Rotterdam, and comes as a complement to the large quantities of
FAME, which can be blended with diesel only up to 7% (V/V), on the Dutch market. The increase in the
contribution of electricity to the total renewable energy use in transport has been driven by the strong
uptake of electric passenger cars. In 2015, battery electric vehicles only represented 0.1% of the Dutch
car fleet,25 but by 2020 this had already grown to 2%. The total numbers of cars with a plug (battery
electric and plug-in hybrid electric cars) on Dutch roads increased from over 43 000 in 2015 to 360 000
at the end of November 2021,26 representing roughly 4%27 of the entire car fleet.

Eurostat (2021), https://ec.europa.eu/eurostat/web/energy/data/shares
8 967 cars – RVO (2021) Trendrapport Nederlandse Markt personenauto’s - out of a total fleet of 7.9 million – CBS
(2021) Personenauto's; voertuigkenmerken, regio's, 1 januari.
26
RVO (2021) Cijfers elektrisch vervoer.
27
Based on a total car fleet of 8.8 million cars – CBS (2021) Personenauto's; voertuigkenmerken, regio's, 1 januari.
24
25

13

Analyse overgang sturen op CO2

Consumption (PJ)

Figure 2-1 Renewable energy use in transport falling under the scope of the Jaarverplichting, 2011-20.
40

Renewable electricity

35

HVO - Advanced and UCO & animal fats

30

FAME - Advanced and UCO & animal fats

25

FAME - Conventional

20

Biogas - Advanced and UCO & animal fats

15

Bioethanol - Advanced

10

Bioethanol - Conventional

5

Other biofuels from advanced, UCO and
animal fats feedstocks

0
2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

Other conventional biofuels

Source: NEa (2021) Rapportage Energie voor vervoer in Nederland 2020.
Note: the renewable energy quantities represented in this graph are real quantities (i.e. multipliers removed) for
which HBEs were generated (the figure thus includes a certain quantity of biofuels delivered to the maritime sector
and for which HBEs were generated).

2.1.3 Biofuel use in the maritime sector
In the Netherlands, the maritime sector is an important energy-consuming sector within transport (45%
of the transport sector’s energy use, vs. 11% at EU level).28 As described in 1.3.1, HBEs can be traded
between different transport subsectors, and as a consequence HBEs can be submitted in one subsector
while the actual renewable fuel is being used in another. This is has been happening with large
fractions of the UCO-based FAME for which HBEs are being submitted. From all biofuels for which HBEs
were generated under the Jaarverplichting in 2020, 30% was actually delivered to the maritime
sector,29 with a large share of biofuels delivered going to international shipping, while this sector
doesn’t fall under the scope of the Jaarverplichting. This is disadvantageous for the achievement of the
transport renewable energy target of the RED II (which includes only road and rail energy) as well as for
some of the national GHG reduction targets for the domestic transport sector. In addition, the RED II
includes a 1.7% cap on Annex IX.B feedstocks (UCO and animal fats) by 2030, while in 2020 UCO-based
fuels accounted for over half of all HBEs booked into the system and the volume of HBEs submitted for
UCO-based fuels was equivalent to over 4% of liquid fuel energy use in the domestic transport sector in
2020.
In order to better align the HBE system and the use of renewable fuels with the achievement of
national targets, the Dutch government has decided to implement several measures aimed at reducing
the use of UCO-based FAME in the maritime sector. From 2021 onwards, HBEs can only be issued to the
maritime sector for biofuels from advanced (Annex IX.A) feedstocks and for RFNBOs. Therefore, UCObased biofuels will no longer generate HBEs when used in the maritime sector.30
Under the RED II, the renewable energy target for transport applies to road and rail transport, but
maritime and aviation fuels have the possibility to opt-in to contribute to the target. In the RED II
revision proposal, the maritime and aviation sectors are included. For the Netherlands, the domestic

28

Source: “Ramping-up Renewable Fuels” webinar, Platform Hernieuwbare Brandstoffen (30/11/2021)
NEa (2021) Rapportage Energie voor vervoer in Nederland 2020.
Staatsblad 2021, 619 - Besluit van 20 december 2021 tot wijziging van het Besluit energie vervoer in verband met
de implementatie van Richtlijn (EU) 2018/2001 van het Europees Parlement en de Raad van 11 december 2018 ter
bevordering van het gebruik van energie uit hernieuwbare.
29
30

14

Analyse overgang sturen op CO2

shipping31 and aviation sectors are projected to account for only 4.7% of the domestic transport energy
demand in 2030.32 If international shipping and aviation were to be counted towards renewable energy
or GHG intensity reduction targets, the biofuels delivered to the maritime sector in the Netherlands
could make a significant contribution.

2.2 Transport fuel projections to 2030
2.2.1 EU trends
At the EU level, shifts in the use of renewable energy carriers for transport are taking place, not only
with regards to the uptake of EVs, but also in relation to the types of biofuels and feedstocks used.
In a context of declining liquid fuel demand, the International Energy Agency (IEA) suggests that
European biofuel demand may remain relatively weak (+13% growth between 2021 and 2026) in
comparison with other regions, even with enabling policies in place such as the RED II (IEA, 2021).
Accounting for the Fit-for-55 package of new or revised policy proposals, among which the main biofuel
demand growth drivers are ReFuelEU Aviation and the RED II revision proposal, this biofuel demand
growth could be about three times higher. It estimates that HVO (in part thanks to its high blending
prospects), FAME and biojet fuels would be the primary drivers of the demand growth, and that there is
scope for FAME production growth in Europe to replace imports.
The Netherlands being among the top five biofuel net exporting countries globally, the IEA expects the
country to maintain its position within the next five years, although with lower net exported volumes to
satisfy in-country demand.
According to a study by CE Delft specifically looking at UCO as a feedstock, at the EU level, the demand
for UCO and UCO-based fuels is expected to grow substantially, from 2.8 Mt in 2019, to over 6 Mt in
2030.33 The increase in demand for UCO is driven by two main changes in EU policy:


The use of conventional biofuels is capped and needs to decline towards 2030, increasing the
need for Member States to look for alternative biofuel feedstocks34;



In response to heavy debates on indirect land-use change (ILUC) (caused by the use of palm oil
in particular) for biofuel production, the EU has adopted a delegated act in 2019 capping
biofuel production from feedstocks with high ILUC risk at 2019 levels and imposing a gradual
phase out for the period 2023-30.

As the use of Annex IX.B feedstocks is in most countries below the 1.7% cap, many Member States could
seek to replace part of their declining feedstock supply with UCO.35
2.2.2 Projected evolution of renewable energy in transport in The Netherlands
According to the national projections for the Netherlands based on existing policies, liquid fuel demand
in transport is expected to decline marginally in the period leading to 2030, from 437 PJ in 2020 to 432
PJ in 2030, whereas the overall energy consumption in the sector is expected to grow slightly (Figure
2-2).36 Towards 2030, renewable energy obligations for transport fuels as well as a new renewable
energy mixing obligation for aviation will contribute to continued growth of biofuel use in the Dutch
transport sector. By 2030, the estimated consumption of biofuels in domestic transport lies at around
31

Including fishing ships
PBL (2021) Klimaat en energieverkenning 2021.
CE Delft (2021) Used Cooking Oil (UCO) as biofuel feedstock in the EU. https://cedelft.eu/wpcontent/uploads/sites/2/2021/04/CE_Delft__200247_UCO_as_biofuel_feedstock_in_EU_FINAL-v5.pdf
34
Ibid.
35
Ibid.
36
PBL (2021) Klimaat en energieverkenning 2021.
32
33

15

Analyse overgang sturen op CO2

44 PJ, compared to 26 PJ in 2020. Within domestic transport, road transport is bound to remain by far
the largest energy consumer (Figure 2-3). In road transport, electrification is expected to continue,
especially in the passenger car segment, but also in the vans and trucks sectors. It is estimated that the
electricity consumption of the transport sector will increase from roughly 7 PJ in 2020 (of which 75% is
used by rail) to 26 PJ in 2030, with 11 PJ for electric cars and 19 PJ for road transport overall. As a
consequence of the increasing role of electricity in road transport (Figure 2-3), electricity is expected
to account for 35% of the HBEs that will be issued in 2030 compared to a projection of 2% for 2022.37,38
Figure 2-2 Historical and projected final energy use in domestic transport in the Netherlands, 2015-30

*The figures for 2020 are based on preliminary data.
Source: PBL (2021) Klimaat en energieverkenning 2021.
Figure 2-3 Projected energy consumption in domestic transport in the Netherlands by transport mode, 2030

Source: PBL (2021) Klimaat en energieverkenning 2021.

37
38

PBL (2021) Klimaat en energieverkenning 2021.
See also section 3.3.1.

16

Analyse overgang sturen op CO2

3 GHG emissions accounting under the RED III
and impacts
3.1 GHG emissions savings of renewable fuels and energy sources
With the new target of the RED III, which is based on GHG emissions intensity reductions, the
contributions of the various renewable fuels and energy vectors delivered to the transport market
towards the target will be based on their specific GHG emissions per unit energy, along with different
GHG emissions savings accounting rules for electricity on the one hand, and for liquid and gaseous
biofuels on the other hand. The savings calculated for the various renewable fuels and energy vectors
are to be compared to an all-liquid fossil fuel baseline to derive the final GHG emissions intensity
reduction for transport, which needs to reach 13% in 2030 (Table 1-2). Table 3-1, Figure 3-1 and Figure
3-2 present current GHG emission factors and associated GHG emission savings for a variety of biofuelfeedstock pairs, for electricity and for RFNBOs, in 2020 (unless otherwise mentioned). Figure 3-3 shows
how renewable electricity savings compare to biofuels under both the RED II and the RED III.
Table 3-1 GHG emissions and savings as per RED III accounting rules, for selected renewable fuels and electricity
mixes

Ethanol – Advanced (Annex IX.A)

14.1

Counterfactual
(gCO2eq/MJ)
94
94

79.9

85%

FAME - Conventional

34.1

94

59.9

64%

FAME – Advanced (Annex IX.A)

13.3

94

80.7

86%

FAME – UCO and animal fats (Annex IX.B)

11.9

94

82.1

87%

HVO – Advanced (Annex IX.A)

14.6

94

79.4

84%

HVO – UCO and animal fats (Annex IX.B)

8

94

86

91%

Bionafta - UCO and animal fats (Annex IX.B)

6.3

87.7

93%

Biogas - Advanced (Annex IX.A)

19.3

94
94

74.7

79%

Biogas - UCO and animal fats (Annex IX.B)

18

94

76

81%

Renewable electricity
Electricity mix with 26% renewables (representative
of 2020 Dutch electricity mix39)
Electricity mix with 74% renewables (representative
of projected 2030 Dutch electricity mix40)
RFNBO with minimum GHG savings threshold (70%)

0

183

183

100%

135

183

48

26%

48

183

135

74%

-

-

-

70%

-

-

-

100%

Ethanol - Conventional

GHG
emissions
(gCO2eq/MJ)
30.5

RFNBO with 100% GHG savings

GHG emission
savings
(gCO2eq/MJ)
63.5

GHG
emission
savings (%)
68%

Methodological notes:
Column “GHG emissions”: The data displayed for biofuels was provided by RVO and NEa on 16/12/2021 and
represent 2020 values. For electricity, the numbers (in grey) were calculated from the renewable energy share of
the electricity mix considered, against a GHG emission factor of fossil-based electricity of 183 gCO2eq/MJ (the
numbers displayed therefore do not represent the actual GHG emissions of the Dutch electricity mixes).
RFNBOs: In the absence of representative GHG emission data for RFNBOs for the Netherlands, and of an explicit
counterfactual value against which to calculate absolute savings, 41 two indicative GHG emissions savings for
RFNBOs were considered: 70% (being the GHG savings threshold for RFNBOs to be eligible as a renewable fuel under
the RED (JEC, 2019)) and 100%.

39

PBL (2021) Klimaat en energieverkenning 2021.
PBL (2021) Klimaat en energieverkenning 2021.
41
The release of EC proposals for delegated acts relative to the GHG methodology for RFNBOs is pending (T&E
(2021), EC (2022)).
40

17

Analyse overgang sturen op CO2

Figure 3-1 Absolute GHG emission savings as per RED III accounting rules for selected biofuels and electricity
mixes

Renewable electricity
Electricity mix with 74% renewables…
Bionafta - UCO and animal fats (Annex IX.B)

HVO – UCO and animal fats (Annex IX.B)
FAME – UCO and animal fats (Annex IX.B)
FAME – Advanced (Annex IX.A)
Ethanol – Advanced (Annex IX.A)
HVO – Advanced (Annex IX.A)
Biogas - UCO and animal fats (Annex IX.B)

Biogas - Advanced (Annex IX.A)
Ethanol - Conventional
FAME - Conventional
Electricity mix with 26% renewables…
0

20

40

60

80

100

120

140

160

180

200

Absolute emission reduction compared to benchmark (gCO2eq/MJ)
Methodological notes: see notes to Table 3-1 (in particular regarding the absence of RFNBOs from this figure).
Figure 3-2 Relative GHG emission savings as per RED III accounting rules for selected renewable fuels and
electricity mixes

Renewable electricity
RFNBO with 100% GHG savings
Bionafta - UCO and animal fats (Annex IX.B)
HVO – UCO and animal fats (Annex IX.B)
FAME – UCO and animal fats (Annex IX.B)
FAME – Advanced (Annex IX.A)
Ethanol – Advanced (Annex IX.A)
HVO – Advanced (Annex IX.A)
Biogas - UCO and animal fats (Annex IX.B)
Biogas - Advanced (Annex IX.A)
Electricity mix with 74% renewables…
RFNBO with 70% GHG savings
Ethanol - Conventional
FAME - Conventional
Electricity mix with 26% renewables…
0%

10%

20%

30%

40%

50%

60%

70%

80%

90% 100%

% Emission reduction
Methodological notes: see Table 3-1 and notes to Table 3-1.

3.1.1 Biofuels and biogas
All biofuels or biogas from Annex IX.A or Annex IX.B feedstocks (comprising advanced feedstocks, UCO
and animal fats) have GHG emission savings against their liquid fossil fuel benchmark (94 gCO2eq/MJ) of
around 80-90% (Figure 3-2 and Table 3-1). Conventional feedstocks (to produce bioethanol or FAME)
have GHG emissions savings of 64-68%.
Under the RED II, which applies a x2 multiplier for Annex IX.A and Annex IX.B biofuels and no multiplier
for conventional biofuels, there is a factor two between the contribution of both types of biofuels per
unit energy towards the renewable energy target. With the GHG-based accounting system and target of
the RED III, and because the specific GHG emissions savings from conventional biofuels are relatively
close (closer than a factor 2 difference) to those of advanced and Annex IX.B biofuels (Table 3-1 and

18

Analyse overgang sturen op CO2

Figure 3-1), the difference in their respective contributions to the target per unit energy is narrower
under the RED III than under the RED II.
3.1.2 Electricity
Absolute GHG emissions savings per unit energy
As shown in Table 3-1 and Figure 3-2, under the conditions of the RED III, at equal quantities,
renewable electricity is the renewable energy source allowing for the highest GHG emissions
abatement42 as is it considered to be fully zero-emission and its savings are calculated against a higher
counterfactual than for liquid and gaseous fuels.
Considering that the Dutch electricity mix will contain 74% of renewables in 2030,43 a vehicle charging
from such a grid would allow the realisation of 74% GHG emission savings per unit energy fuelled, which
corresponds to an absolute GHG emissions reduction of 135 gCO2eq/MJ (against electricity’s fossil
counterfactual value of 183 gCO2eq/MJ). This value surpasses any absolute emissions savings from
biofuels, which reach a maximum of 88 gCO2eq/MJ (for bionafta produced from Annex IX.B feedstocks)
(Figure 3-1). Under the RED III accounting method for liquid and gaseous biofuels, the GHG emissions
savings of the latter cannot exceed 94 gCO2eq/MJ, which represents their liquid fossil fuel
counterfactual aginst which their emissions savings are to be calculated.
The absolute GHG emissions savings per unit energy from an electricity mix with 26% renewables (as the
Dutch electricity mix in 2020)44 are lower than those of any biofuels present on the Dutch transport
market in 2020 (Table 3-1 and Figure 3-1).
Contribution to renewable energy and to GHG emissions reduction vs. biofuels
As shown in Figure 3-3 (light green bars), there is, under the RED II accounting mechanism, a x4 factor
in the contribution of one energy unit of renewable electricity vs. one energy unit of conventional
biofuels towards the renewable energy target, due to the mulitpliers in place (Table 1-2). For
renewable electricity vs. advanced and Annex IX.B biofuels, this factor is x2.45
With the RED III and the emission factors for biofuels in the Netherlands used across this chapter (Table
3-1), the differences in absolute GHG emissions savings for renewable electricity vs. biofuels (against
their respective counterfactuals), remains close to a factor 2 when considering advanced and Annex
IX.B biofuels, and is around 3 when considering conventional biofuels (dark green bars). It is worthwhile
to note that, accounting for the better energy efficiency of electric vehicles (EVs) vs. internal
combustion engine vehicles (ICEVs), more units of biofuel per vehicle and per unit distance are needed
to achieve same final GHG savings in ICEVs as for renewable electricity in EVs.

42

Along with 100% renewable RFNBOs, see discussion on RFNBOs in the next section.
PBL (2021) Klimaat en energieverkenning 2021.
44
PBL (2021) Klimaat en energieverkenning 2021.
45
Because of a x4 multiplier for renewable electricity and a x2 multiplier for advanced and Annex IX.B biofuels.
43

19

Analyse overgang sturen op CO2

Figure 3-3 Effective multipliers per unit energy for renewable electricity against conventional and Annex
IX.A/Annex IX.B biofuels, under RED II and RED III methodologies

Renewable electricity
vs. Annex IX.A/Annex IX.B biofuel

Renewable electricity
vs. conventional biofuel

0

1

2

RED III effective multiplier

3

4

RED II multiplier

Methodological notes:
RED II multipliers are derived from Table 1-2.
RED III effective multipliers are calculated from the difference in absolute emissions savings between renewable
electricity and the average emission savings of conventional biofuels, and from the difference in absolute emissions
savings between renewable electricity and the average emission savings of Annex IX.A and Annex IX.B biofuels
(Figure 3-1).

In addition, the contribution of renewable energy towards GHG emissions reductions is to be calculated
against a liquid fossil fuel baseline GHG intensity (Table 1-2), which enhances the contribution of
renewable electricity savings vs. a case where the contribution of renewable electricity savings would
be calculated against a fossil electricity baseline (which is higher than a liquid fossil fuel baseline). An
illustrative example is provided in Table 3-2, based on the calculation of the GHG emissions intensity
savings of 5 MJ of renewable electricity within a total energy mix of 50 MJ of electricity plus 50 MJ of
liquid fossi fuels (100 MJ in total). In case A, the renewable electricity’s contribution to GHG emissions
intensity reduction is calculated against a liquid fossil-fuel baseline of 94 gCO2eq/MJ, in line with the
RED III methodology. In case B, the baseline considered is that of the respective counterfactuals for
electricity and for liquid fuels (183 gCO2eq/MJ and 94 gCO2eq/MJ respectively), applied proportionally to
the total electricity and total liquid fuels used in the system. The comparison between both cases
shows that the methodology applied under case A allows for a higher contribution of the 5 MJ of
renewable electricity in the 100 MJ system (-9.7% GHG emissions intensity), than the methodology
under case B (-6.6% emissions intensity). Varying the proportions of electricity and liquid fuels in the
overall energy system or varying the quantities of renewable electricity in both cases lead to similar
outcomes, with the GHG emissions intensity reduction in case A being higher than in case B.
Table 3-2 Illustrative comparative example of GHG emissions intensity savings in an energy system made of
50 MJ liquid fuels and 50 MJ electricity, as per two baseline calculation methodologies.

Baseline methodology :

B. Liquid fossil fuel and fossil
electricity
(proportionally to liquid fuels
and electricity in the system)

A. All-liquid fossil fuel
(in line with RED III
methodology)

Liquid fossil fuel emission factor (gCO2eq/MJ)

94

Fossil electricity emission factor (gCO2eq/MJ)
GHG emissions savings from 5 MJ renewable
electricity in the system (gCO2eq)
Baseline GHG emissions intensity (gCO2eq/MJ)
GHG emissions intensity of the system
(gCO2eq/MJ)
GHG emissions intensity reduction from the
baseline (%)

183
915

20

94

138.5

85

129

9.7%

6.6%

Analyse overgang sturen op CO2

3.1.3 RFNBOs
The RED II revision proposal explicitly suggests to introduce a 2.6% mandate for RFNBOs in addition to
the transport GHG emissions intensity reduction target, and the RED II provisions a 70% GHG emissions
savings threshold for RFNBOs to be eligible as a renewable fuel. However there is no available
representative GHG emission factor for RFNBOs at the Dutch level (no HBEs for RFNBOs were registered
in 2020), and the counterfactual and methodology to estimate the emissions savings and contributions
towards RED III targets of RFNBOs are still to be defined (see Table 3-1 and its notes).

3.2 Calculated impact of the RED III accounting mechanism for renewable fuels
in the Netherlands in a 2020 timeframe
In order to estimate the respective impact of the RED II and the RED III methodologies (based on
quantities of renewable energy and multipliers for the former, and on GHG emissions reductions for the
latter) on renewable fuels and energy sources for transport, we calculated the relative contributions of
the renewable fuels in use in 2020 in the Netherlands46 (Figure 2-1) to transport renewable energy or
GHG emissions reductions. The results are presented in Figure 3-4.
Figure 3-4 Contribution of the renewable transport fuels and energy sources in use in the Netherlands to total
transport renewable energy (without and with mulitpliers - 1 & 2) and to transport GHG emissions
tionreductions (3), 2020
to
rene
wabl
e
ener
gy
in
real
ter
ms
(100
%=
36
PJ)

100%

Renewable electricity
Bionafta - Advanced

90%

HVO - Advanced

80%

Biomethane - Advanced

70%
FAME - Advanced
60%

Bioethanol - Advanced
FAME - Conventional

50%

Bioethanol - Conventional

40%

FAME - animal fats
30%

Biomethane - UCO
20%

Bionafta - UCO
HVO - UCO

10%

FAME - UCO

0%
1. Contribution to
renewable energy in
real terms
(100% = 36 PJ)

2. Contribution to
3. Contribution to transport
renewable energy
GHG emissions savings
including RED II multipliers
according to RED III
(100% = 65 PJ)
methodology
(100% = 2.8 MtCO2eq)

Sources: NEa (2021) Rapportage Energie voor vervoer in Nederland 2020 (Tabel I and Tabel II).
Methodology note on multipliers applied: Conventional fuels – no multiplier; Renewable electricity – x4 multiplier;
all others – x2 multiplier.
Methodology note on GHG emissions reductions: the GHG emissions factors and counterfactuals applied are those
presented in Table 3-1.

46

For which HBEs were submitted

21

Analyse overgang sturen op CO2

Methodology note on abosulte figures: 36 PJ represent the real quantity of renewable energy use in transport
falling under the scope of the Jaarverplichting (see Figure 2-1). 65 PJ represent the quantity of renewable energy
use in transport falling under the scope of the Jaarverplichting, including multipliers. 2.8 MtCO2eq represent the
GHG emissions savings from the renewable energy use in transport falling under the scope of the Jaarverplichting,
calculated against a liquid fossil fuel baseline of 94 gCO2eq/MJ.

1.

In 2020, UCO-based fuels contributed, by their actual quantities supplied to the market (case 1), to
55% of all transport renewable energy for which HBEs were submitted. The share of Annex IX.B
biofuels goes up to 66% when including FAME produced from animal fats. 18% of the renewable
energy supplied to the transport sector was fuels from conventional feedstocks, while advanced
biofuels contributed to 15%. Renewable electricity, with less than 1%, was the smallest contributor
to transport renewable energy use.

2.

When applying the RED II multipliers to the renewable fuels and energy sources delivered to the
transport sector, Annex IX.B biofuels reach a relative contribution of 72% (+6 percentage points
from case 1). The increase of the relative contribution of advanced biofuels is marginal (+1
percentage point) and renewable electricity’s contribution grows to 1.4%. The contribution of
these fuels is inflated from the real quantities that are used thanks to the multipliers applied (x2
for Annex IX.A and Annex IX.B biofuels, and x4 for renewable electricity). The relative contribution
of conventional biofuels, which do not benefit from a multiplier, shrinks to 10% (-8 percentage
points from case 1).

3.

Applying the RED III methodology and calculating the relative contribution of the various renewable
fuels and energy sources towards the total GHG emissions saved from transport renewable energy
in 2020, the relative contributions resemble more those of the real renewable energy quantities
(case 1) than those of the energy quantities as calculated under the RED II (case 2). This is because
the GHG emissions savings of conventional biofuels and of Annex IX.A and Annex IX.B fuels (Figure
3-2) are closer to each other than the gap generated by double-counting Annex IX.A and Annex IX.B
fuels under RED II while not applying any multiplier to conventionals (as mentioned in 3.1.1). Only
the contribution of renewable electricity would roughly double from case 1 - as in case 2 - to 1.5%.

In conclusion, based on the renewable fuel mix in the Netherlands in 2020 and with the GHG emission
factors given for each renewable (Table 3-1):


UCO-based fuels broadly maintain their relevance towards contributing to GHG emissions
reductions from renewable transport fuels compared to their contribution in real terms and
under RED II mutlipliers, given the large quantities in use and their high GHG emissions savings
compared to other renewable fuels.



Conventional biofuels are more favoured under the RED III accounting mechanism than under
the RED II, as their difference in GHG emissions savings with regards to other altneratives is
lower than their difference of treatment under RED II (no multiplier for conventional biofuels
vs x2 multiplier for other biofuels – see 3.1.1).



The use of renewable electricity is favoured under both RED II and RED III methodologies
compared to real terms, without a significant difference between the RED II and RED III cases
shown in Figure 3-4, given the small amount of renewable electricity submitted in the HBE
system in 2020 and somewhat limited difference in effective multipliers between electricity
and biofuels under the RED III accounting methodology compared to RED II (Figure 3-3, green
bars).

22

Analyse overgang sturen op CO2

3.3 Calculated impact of the RED III accounting mechanism for renewable fuels
in the Netherlands in a 2030 timeframe
3.3.1 Impact of electric vehicles
Contribution of EVs towards the 2030 Jaarverplichting target
It is projected that 1.1 million electric cars will be on the Dutch roads by 2030. Next to this, roughly
100 000 light commercial vehicles and 7 000-29 000 trucks are expected to be zero-emission that year,
along with around 5 000 zero-emission public buses.47 Even though renewable electricity only made a
rather modest contribution to reaching the Jaarverplicthing obligations in 2020, renewable electricity
use in road transport (including the relevant multipliers for renewable elctricity) would be sufficient to
achieve 35% of the Jaarverplichting target for 2030, according to national projections.48 This is a
substantial contribution, especially when accounting for the fact that roughly only half (47%) of the
electricity use by passenger cars is booked into the HBE system, due to high administrative burdens
making it not worthwhile for small users to book in their electricity use.49 If the rest of road transport
electrity projected for 2030 was also accounted for, the contribution of EVs to meeting the 27.1%
renewable energy target of the Jaarverplichting in 2030 would reach 73% (Figure 3-5). This leaves 26%
to 65%, depending on whether only part or all renewable electricity in use in road transport will be
counted towards reaching the target, to other types of renewable fuels.
Figure 3-5 Relative contribution of electric road transport towards the 2030 Jaarverplichting target

Note: The Jaarverplichting target considered in this figure in 27.1%. From 2022, this target was updated to 28%.
Source: PBL (2021) Klimaat en energieverkenning 2021.

EV emissions savings under the RED III accounting methodology
Applying the RED II revision proposal methodology in calculating the GHG emissions savings from the
road transport electric vehicles projected for 2030, assuming they are fuelled from grid electricity that
is composed of 74% renewable electricity, electric vehicles, responsible for 19 PJ energy use according
to national projections, would allow for 2.6 MtCO2eq savings. This corresponds to a GHG emissions
intensity reduction for all domestic transport of 5.6 gCO2eq/MJ,50 representing a 6% reduction of all
domestic transport GHG emissions intensity (this reduction is calculated against a liquid fossil fuel GHG
emissions intensity benchmark of 94 gCO2eq/MJ, in line with the RED III methodology). Therefore,
around half (46%) of the 13% GHG emission intensity reduction target under the RED II revision proposal,

47

PBL (2021) Klimaat en energieverkenning 2021.
PBL (2021) Klimaat en energieverkenning 2021.
49
For further information, see Trinomics report “Onderzoek kleine spelers elektrisch vervoer” for RVO, forthcoming.
50
Calculated from 458 PJ domestic transport energy use in 2030 (KEV 2020).
48

23

Analyse overgang sturen op CO2

applied to the entire Dutch domestic transport energy use, is met thanks to the EVs on the road by 2030
(Figure 3-6).
3.3.2 Impact of a cap on the use of used cooking oil and animals fats as feedstocks
In 2020, UCO-based FAME accounted for 53% of the renewables under the Jaarverplichging (including
double-counting) (Figure 3-4, case 2), or 49% on an energy basis (Figure 3-4, case 1). Its use is also
equivalent to over 4% of the total liquid fuel delivered to the domestic transport sector (section 2.1.3).
However, if the 1.7% cap on Annex IX.B biofuels applied, the physical volume of such fuels (of which
UCO-based FAME) counting towards the RED III target could only be 7.8 PJ in 2030,51 compared to 23 PJ
of Annex IX.B biofuels (of which 17 PJ of UCO-based FAME) counting under the Jaarverplichting targets
in 2020. When combining the impact of renewable electricity in road transport and the cap on Annex
IX.B biofuels by 2030, these energy carriers together can achieve 57% of a GHG emission intensity
reduction of 13% within the domestic transport sector (Figure 3-6). The remaining 43% of the total GHG
emission savings required therefore need to come from other renewable options. Part of the target will
be met by the already-existing, and increasing, renewable electricity use in rail transport as this sector
is under the scope of the RED III, complemented by advanced biofuels and RFNBOs which are subject to
mandates of 2.2% and 2.6%, respectively, under the RED III, and by conventional biofuels up to the 7%
cap of the RED (in 2020, HBEs submitted for advanced biofuels represented just over 1% of liquid fuel
use in the domestic transport sector in 2020, and HBEs submitted for conventional biofuels around 1%).
Figure 3-6 Contributions of renewable electrity use in road transport and Annex IX.B biofuels to an emissions
intensity reduction of 13% within the domestic transport sector in 2030, according to the RED III methodology.

Notes: For precisions on the methodology used for the calculations, see text in section 3.3.1 (for electric vehicles)
and 3.3.2 (for UCO).

Should international transport energy use be included in the scope of a 13% GHG emissions intensity
reduction target by 2030, a larger contribution from liquid or gaseous fuels (likely to be needed in large
quantities to decarbonise the international maritime and aviation sectors, as these are harder to
electrify) should be envisaged, compared to renewable electricity, than shown in Figure 3-6. This would
also theoretically imply more room for Annex IX.B biofuels than the 7.8 PJ mentioned above that result
from a 1.7% cap within domestic transport, should Dutch legislation allow them again in those sectors
(see section 2.1.3).

51

Assuming the 1.7% cap is applied to the projected energy use of the entire domestic transport sector in 2030
(458 PJ).

24

Analyse overgang sturen op CO2

4 Dutch landscape for renewable fuel
production
4.1 Domestic production
4.1.1 Liquid biofuel production in the Netherlands
There are around 12 large biofuel producers in the Netherlands with annual production capacities
exceeding 10 kilotonnes. Six of these facilities produce biodiesel (FAME), one produces HVO, two
produce bioethanol, one produces methanol and two produce other ethanol-related fuels. Figure 4-1
provides an overview of the production capacities for different biofuel types in the Netherlands divided
by feedstock type. HVO, FAME and methanol benefit from the largest production capacities. The HVO is
produced at NESTE’s biorefinery in Rotterdam. With its current production capacity, this facility is
already capable of covering 100% of the projected biofuel use in the Dutch transport in 2030 on its
own.52 Currently, the company produces 100 kilotonnes of renewable aviation fuels annually but is
planning to do an investment of 190 million EUR to increase its production capacity to 500 kilotonnes by
2023.53 Another large player is BioMCN, which produces biomethanol from glycerin. This plant has
recently expanded its production capacity from roughly 500 kilotonnes per year to 940 kilotonnes.54 The
company is considering to further develop renewable methanol production capacity in cooperation with
Nouryon, via synthetic methanol produced from renewable hydrogen and CO2.55
Figure 4-1 Overview of biofuel production capacity in the Netherlands by feedstock catergory and fuel type

Source: NVDB (2018) Overzicht productie capaciteit56 (production facilities marked as ‘production on hold’ were not
included in this figure).
Note: “Ethanol-related fuels” include MBTE and ETBE.

The Dutch government has been actively stimulating the use of UCO as a feedstock by allowing for
double-counting under the Jaarverplichting. Due to this possibility, significant production capacity for
UCO-based FAME has been developed in the Netherlands. In 2018, the RED II made the future of UCO52

The annual production capacity of the NESTE facility in Rotterdam is around 1 million tonnes, which is equivalent
to 44 PJ. According to the KEV 2020, the projected volume of biofuel consumption is also 44 PJ.
53
Neste (2021) Neste to enable production of up to 500,000 tons/a of Sustainable Aviation Fuel at its Rotterdam
renewable products refinery.
54
TerraTechMedia (2017) 100 miljoen euro voor tweede methanolfabriek van bioMCN.
55
Nouryon (2019) BioMCN gaat hernieuwbare methanol produceren met groene waterstof.
56
Obtained from personal exchange with the NEa. Data for 2 producers were updated by Trinomics.

25

Analyse overgang sturen op CO2

based biofuel production in the Netherlands uncertain as a cap of 1.7% was introduced for Annex IX.B
biofuels towards the renewable energy target for transport. In order to cushion the impact of this policy
change on Dutch FAME producers, the Dutch government decided to cap the UCO-based FAME levels at
10% from 2022 onwards.57 Even though not all UCO-based FAME delivered to the transport sector may
count towards the RED II and RED III targets due to this cap, the fuel can also be used in other sectors
or be exported. Before 2025, the Dutch cap for UCO-based FAME production will be re-evaluated.
However, given the scarcity of biobased waste and byproducts (the majority of UCO being imported
from outside Europe, see section 4.2) it is not unlikely that other uses of UCO, e.g. for the production
of HVO or sustainable aviation fuels, will push UCO-based FAME out of the market. On the other hand,
due to several changes in feedstock caps and phase-outs at the EU level, the demand for UCO is
expected to grow at EU level, meaning that demand for UCO-based FAME might remain in other
countries, giving Dutch producers the possibility to export this fuel if the Jaarverplichting reduces its
support.
4.1.2 Green gas production for transport
In 2019, roughly 15% of the biomethane produced in the Netherlands was used as bio-CNG in
transport.58 For a limited number of refuelling stations there is a direct connection between the biogas
upgrading plant and the station, but in most, the gas is supplied from the grid. In the latter case,
refuelling stations can still supply green gas to their clients as they back up their supplies by
Guarantees of Origin for Green gas.

4.2 Imports and exports
The Netherlands has significant trade flows when it comes to liquid biofuels. The country is a net
importer of bioethanol/biogasoline and a net exporter of biobased alternatives to diesel. However, the
export volumes for the latter are much higher than imports of the former, making the Netherlands a
net exporter of liquid biofuels (Figure 4-2). In 2019, a total of 51 PJ of pure and blended biodiesel
(including both FAME and HVO) was exported, compared to a volume of 23 PJ supplied to the Dutch
market under the Jaarverplichting, showing that two thirds of the biodiesel produced in the
Netherlands is exported. From the annual production figures for HVO (44 PJ) and the volume of HVO
supplied under the Jaarverplichting (2 PJ), it can be derived that most of the biobased alternatives for
diesel that is exported is in the form of HVO. It should be noted though that the feedstock for HVO and
FAME production is imported for a large part from outside the EU, especially from Asia. UCO for
instance originated for more than 50% from imports from Asian countries in 2020. 59
Whereas the Netherlands is a net exporter of biodiesel, the story is the other way around for
bioethanol, where the demand is virtually completely supplied by imports. The recently introduced E10
obligation has led to a further increase in bioethanol imports. For bioethanol, the largest part of the
feedstocks is derived from food crops or other food-related feedstocks, with corn, low-quality starch
slurry, wheat and sugarcane being the main feedstocks used. Among the various feedstocks for
bioethanol, corn mostly comes from the United States,60 sugarcane from South America, and wheatbased ethanol from Europe.
57

Staatsblad 2021, 619 - Besluit van 20 december 2021 tot wijziging van het Besluit energie vervoer in verband met
de implementatie van Richtlijn (EU) 2018/2001 van het Europees Parlement en de Raad van 11 december 2018 ter
bevordering van het gebruik van energie uit hernieuwbare.
58
GasTerra (2021) Panorama Groen Gas 2021.
59
NEa (2021) Rapportage Energie voor vervoer in Nederland 2020.
60
NEa (2021) Rapportage Energie voor vervoer in Nederland 2020.

26

Analyse overgang sturen op CO2

Figure 4-2 Trade balance of liquid biofuels for the Netherlands with positive flows reflecting imports and
negative flows reflecting exports

Source: Eurostat – Complete Energy Balances

27

Analyse overgang sturen op CO2

28

Analyse overgang sturen op CO2

5 Discussion and conclusions
By revising the scope and target formulation for renewable energy in transport, the RED II revision
proposal (RED III) potentially modifies the playing field in place in the Netherlands for various
renewable energy vectors stemming from the previous versions of the RED and the national
Jaarverplichting policy.
Table 5-1 presents GHG emission factors and associated GHG emission savings for a variety of biofuelfeedstock pairs, for electricity and for RFNBOs, in 2020 (unless otherwise mentioned). This table is
complemented by Figure 3-1 and Figure 3-2 which illustrate the relative emissions performance of these
various fuels, and are discussed in detail in Chapter 3. With the GHG-based system of the RED III
rewarding the lowest-carbon fuels by allowing them a greater contribution towards the target, the
relative emissions performance of the fuels presented in Table 5-1 may be modified with producers
striving to further improve the GHG emissions performance of their product to increase their GHGcompetitiveness and thus their relevance in contributing to the RED III transport target.
Table 5-1 GHG emissions and savings as per RED III accounting rules, for selected renewable fuels and electricity
mixes
GHG emission
savings
(gCO2eq/MJ)
63.5

GHG
emission
savings (%)
68%

14.1

Counterfactual
(gCO2eq/MJ)
94
94

79.9

85%

FAME - Conventional

34.1

94

59.9

64%

FAME – Advanced (Annex IX.A)

13.3

94

80.7

86%

FAME – UCO and animal fats (Annex IX.B)

11.9

94

82.1

87%

HVO – Advanced (Annex IX.A)

14.6

94

79.4

84%

8

94

86

91%

Bionafta - UCO and animal fats (Annex IX.B)

6.3

93%

19.3

94
94

87.7

Biogas - Advanced (Annex IX.A)

74.7

79%

Biogas - UCO and animal fats (Annex IX.B)

18

94

76

81%

Renewable electricity
Electricity mix with 26% renewables (representative
of 2020 Dutch electricity mix61)
Electricity mix with 74% renewables (representative
of projected 2030 Dutch electricity mix62)
RFNBO with minimum GHG savings threshold (70%)

0

183

183

100%

135

183

48

26%

48

183

135

74%

-

-

-

70%

-

-

-

100%

Ethanol - Conventional

GHG
emissions
(gCO2eq/MJ)
30.5

Ethanol – Advanced (Annex IX.A)

HVO – UCO and animal fats (Annex IX.B)

RFNBO with 100% GHG savings

Methodological notes:
Column “GHG emissions”: The data displayed for biofuels was provided by RVO and NEa on 16/12/2021 and
represent 2020 values. For electricity, the numbers (in grey) were calculated from the renewable energy share of
the electricity mix considered, against a GHG emission factor of fossil-based electricity of 183 gCO2eq/MJ (the
numbers displayed therefore do not represent the actual GHG emissions of the Dutch electricity mixes).
RFNBOs: In the absence of representative GHG emission data for RFNBOs for the Netherlands, and of an explicit
counterfactual value against which to calculate absolute savings, 63 two indicative GHG emissions savings for
RFNBOs were considered: 70% (being the GHG savings threshold for RFNBOs to be eligible as a renewable fuel under
the RED (JEC, 2019)) and 100%.

Important trends for the country for the 2020 decade that need to be taken into account in the context
of a revised RED target for 2030, along with other relevant policies for renewable energy in transport
from the Fit-for-55 package, are the following:
61

PBL (2021) Klimaat en energieverkenning 2021.
PBL (2021) Klimaat en energieverkenning 2021.
63
The release of EC proposals for delegated acts relative to the GHG methodology for RFNBOs is pending (T&E
(2021), EC (2022)).
62

29

Analyse overgang sturen op CO2

-

Road transport electrification;

-

The dominance of Annex IX.B biofuels, especially UCO-based biofuels, on the Dutch biofuel
market in 2020;

-

The importance of exports of liquid biofuels by the Netherlands over the past decade.

In light of the analysis carried out in the previous chapters, these aspects and the potential effects of
the RED II revision proposal (with insights relative to the other relevant Fit-for-55 policy proposals) are
specifically discussed in the following subsections, while opening the discussion to the new avenues for
transport renewable energy in the Netherlands.

5.1 Transport electrification
By 2030, 1.1 million electric cars are projected on Dutch roads. Road transport electricity use would
amount to 19 PJ64 (see section 3.3.1). The penetration of electric vehicles on the Dutch market will
mechanically drive up electricity consumption in the transport sector and with it, that of renewable
electricity (by 2030, the Dutch electricity grid is projected to include 74% renewables (Table 3-1)).
Under the RED III, renewable electricity (which was subject to a x4 multiplier under the RED II), is
considered zero-emission and still competes in a similar way as under the RED II with advanced and
Annex IX.B biofuels (which are subject to a x2 multiplier under the RED II and which represent the vast
majority of biofuels in the Netherlands). Renewable electricity’s contribution per unit energy to the
RED III GHG emissions reduction target is about three times larger than for conventional biofuels (Figure
3-3). As a result, it is mostly drivers other than the RED III and its change in methodology from the RED
II that may affect the respective shares of renewable electricity and renewable liquid or gaseous fuels
in transport in the future, namely policies targeting a shift in vehicle powertrains and the greening of
the electricity grid (a decline in liquid fuel demand for transport in Europe by 2026 is projected by the
IEA, and national projections for the Netherlands suggest a similar trend to 2030 (sections 2.2.1 and
2.2.2)). With the projected EV uptake by 2030, renewable electricity from the grid would suffice to
meet nearly half of a 13% GHG emissions intensity reduction in the Dutch domestic transport sector
(Figure 3-6), compared to nearly all of the Jaarverplichting target for 2020 being met by liquid or
gaseous biofuels (Figure 3-4). Only the second half of GHG emissions reductions would therefore need
to be met by liquid or gaseous renewable fuels (biofuels, biogas or RFNBOs). However, national
projections suggest a growth in the absolute demand for liquid biofuels for domestic transport by 2030,
to around 44 PJ (vs. 26 PJ today, i.e. +70%) (section 2.2.2), to which any new demand for the
international aviation and maritime sectors are to be added.

5.2 UCO-based fuels
One characteristic of the Dutch renewable fuel market is the dominance of Annex IX.B biofuels, and in
particular UCO-based biofuels, in the total renewable fuel supply to the transport sector (Figure 2-1,
Figure 3-4). Production facilities for such fuels have also been built in the country (section 4.1.1).
In 2020, the volume of HBEs submitted for UCO-based fuels was equivalent to over 4% of liquid fuel
energy use in the domestic transport sector (section 2.1.3).
Several (sometimes contradictory) trends and elements may play a role in the continued relevance of
UCO-based fuels among other renewable alternatives in the future, in particular :
-

GHG emissions intensity: The GHG emissions intensity of Annex IX.B-based liquid fuels (84%
of which were UCO-based fuels) in 2020 was low in comparison to other renewable options

64

This includes electric cars, but also commercial vehicles and buses.

30

Analyse overgang sturen op CO2

(6-11.9 gCO2eq/MJ), leading to GHG emissions savings against their liquid fossil fuel
counterfactual of 87% to 93%, under the RED III methodology. These are the largest savings
per unit energy of all types of biofuels considered in Table 3-1. This provides Annex IX.B
biofuels a competitive advantage when it comes to emissions savings per unit energy with
regards to other biofuel options.
-

RED cap on Annex IX.B biofuels: In both the RED II and its revision proposal, Annex IX.B
biofuels are capped to 1.7% of total transport energy. Given the high volumes and shares of
such fuels in the Netherlands in 2020 and their relevance in meeting the 2020
Jaarverplichting target, the role of UCO-based fuels in the Dutch transport sector by 2030
could be weakened for the purpose of not exceeding the RED cap, unless the Netherlands
requests an exemption (see section 4.1.1).

-

Exports of UCO-based fuels: If the demand for UCO-based fuels within the Netherlands
would decline because of the above-mentioned cap, it is likely that Dutch production
capacity would not need to suffer as the demand for UCO-based fuels in the EU as a whole is
still expected to grow, many other EU countries being far from the 1.7% cap for this biofuel
(see section 2.1.1). Nevertheless, FAME producers might see increasing competition from
market players that want to use UCO for producing higher-quality biofuels fit for road
transport or aviation.

-

UCO feedstock availability: Over half of the UCO feedstock used in transport fuels in the
Netherlands in 2020 was imported from Asian countries, in particular China (see section
4.2). Risks regarding the continuous feedstock availability throughout the next decade or
more to supply the Dutch market may therefore exist, in case the feedstock is prioritised for
domestic use (China and other Asian countries may scale-up UCO use domestically to reach
their own sustainability targets), or in case of any other physical, market-related or policyrelated cross-continental supply disruption arises.

Table 5-2 summarises the risks and opportunities identified in this study and discussed above for the
UCO-based fuels industry in the context of the RED III, other relevant policies and trends in transport
energy demand.
Table 5-2 Opportunities and risks for Dutch UCO-based fuels towards 2030
Opportunity

Risk

Low specific GHG emissions intensity and competitiveness within the
framework of the RED III GHG-based targets
Prospects for exports to other EU Member States

1.7% RED cap on Annex IX.B biofuels
Declining liquid fuel demand prospects
UCO feedstock availability

5.3 Other renewable fuels and energy vectors
5.3.1 Conventional biofuels
The use of conventional biofuels in the Netherlands in 2020 was well-below the RED cap of 7% (see
section 2.1.1). There could therefore be room for additional conventional biofuels towards 2030 and
their competitiveness with regards to other renewable transport energy vectors (advanced and Annex
IX.B biofuels, and renewable electricity) is somewhat increased under the RED III GHG-based
methodology and target than with the energy target and mutlipliers in place under the RED II (Figure
3-1 and Figure 3-3). However, other renewable energy vectors may be prioritised in contributing to the

31

Analyse overgang sturen op CO2

RED III target, namely because of the importance of UCO-based fuels in the Netherlands (see section
5.2), the electrification of the road transport sector and the high electricity shares in the rail sector,
the 2.6% RFNBO mandate and the 2.2% advanced biofuels mandate (see section 3.3.2, Figure 3-6 and
Table 1-2). In addition, future decisions of the Dutch parliament on imposing further limitations on the
use of food and fodder crops as biofuel feedstock could have substantial implications for the future of
conventional biofuels (see section 1.3.3).
5.3.2 Advanced biofuels
In 2020, HBEs for advanced biofuels were equivalent to just over 1% of liquid fuel use in the domestic
transport sector. By 2030, the mandate for advanced biofuels may increase from 1.75% (in the RED II,
without the x2 multiplier applicable to advanced biofuels)65 to 2.2% as per the RED III. There is
therefore scope for further advanced biofuels supply growth to the transport sector, as is being
observed for example for advanced bioethanol over the past couple of years (Figure 2-1).
5.3.3 RFNBOs
Although estimating the potential competitive advantage of RFNBOs vs. other transport renewable
energy vectors (biofuels or electricity) in the framework of the RED III is difficult (the methodology to
account for RFNBOs towards the GHG emissions intensity reduction target still needs to be clarified)
(see section 3.1.3), the proposal introduces a 2.6% mandate for these fuels (Table 3-1). From virtually
no or very marginal use in transport in 2020, RFNBOs will definitely need to be scaled-up by 2030 if the
mandate is to be met. There is currently a limited uptake of RFNBOs in a 2030 timeframe in national
projections for domestic transport (Figure 2-2).
The particularity of RFNBOs being that they encompass both hydrogen and liquid fuels, the future
growth of fuel-cell electric vehicles on the one hand, and the possible phase-out of certain types of
internal combustion engine vehicles on the other hand, will play an important role in investment
decisions to scale-up renewable hydrogen for fuel cell electric vehicles and/or liquid electrofuels
directly substituting other liquid fuels in internal combustion engine vehicles. Policies and industry
commitments for growing renewable fuel demand in harder-to-electrify sectors, such as aviation,
should also open new markets for RFNBOs aside of road transport.

5.4 Prospects in the maritime and aviation sectors
The maritime and aviation sectors are included in the scope of the RED III, which is not the case under
the current RED II, although maritime and aviation fuels can opt-in to contribute towards the RED II
energy target. Should the international component in both sectors be included in the RED III scope, the
total quantity of transport fuels subject to the GHG emissions intensity reduction target could be
significantly increased, as would therefore be the volumes of renewable energy needed to meet the
targets, given the importance of the maritime and aviation sectors in the Netherlands, in particular for
international maritime transport (see section 2.1.3). In addition, these sectors are the only ones for
which a mulitplier (x1.2) would be maintained under the RED III, albeit for advanced biofuels and
RNFBOs only. Encouraging this trend further, the new ReFuelEU Aviation and FuelEU Maritime
proposals, part of the Fit-for-55 package, suggest blending mandates of Sustainbale Aviation Fuels in
the aviation sector, and GHG emissions reductions targets in the maritime sector (see section 1.2.1).

65

Accounting for the multiplier, the advanced biofuel mandate under the RED II is 3.5%.

32

Analyse overgang sturen op CO2

The significant quantities of biofuels existing in the maritime sector (that generated HBEs and
contributed to meeting the Jaarveplichting targets for 2020, in particular (see section 2.1.3)) could
therefore also contribute in the future towards the RED III targets and the FuelEU Maritime proposal
and continue growing, however bearing in mind the limitations recently introduced towards Annex IX.B
biofuels from the maritime sector in generating HBEs and contributing to the Jaarverplichting targets
(see section 2.1.3), and the exclusion of Annex IX.B fuels from the RED III multiplier for maritime and
aviation. The significant domestic production of biofuels and the extent of its exports over the past
decade could constitute an opportunity for the industry to leverage on its existing capacity and knowhow to adapt and/or further scale-up renewable fuels production in those sectors, in particular
regarding high-grade aviation biofuels.

5.5 Domestic consumption and exports
The Netherlands are a net exporter of biofuels, in particular HVO (see section 4.2). In order to meet
future domestic biofuel demand (as mentioned in section 5.1, national projections suggest a 70% growth
in the absolute demand for liquid biofuels for domestic transport by 2030, to which any new demand for
the international aviation and maritime sectors are to be added), part of the currently-exported HVO
could be delivered to the domestic market, for its high blending prospects with diesel or to supply the
aviation sector. However renewable transport fuel demand, and within it biofuel demand, is bound to
continue growing in the road transport, maritime and aviation sectors across Europe. In this context, as
also mentioned in section 2.2.1, there is a large scope for FAME demand in particular to continue
growing in Europe over the next few years, of which the Netherlands has significant production capacity
(Figure 4-1). Many EU Member States do not yet reach the 1.7% cap on Annex IX.B-based biofuels (which
was the primary feedstock of FAME in the Netherlands in 2020), while the use of this feedstock in the
Netherlands is already high (see section 5.2). Finally, the Netherlands are a frontrunner when it comes
to transport electrification.66 Should other EU Member States reach a lower transport electrification
rate than the Netherlands by 2030, they may need to rely to a greater extent on renewable liquid fuels
for meeting their renewable transport targets, which could be partly supplied thanks to Dutch-based
production capacity (Figure 4-1).

66

IEA (2021) https://www.iea.org/reports/global-ev-outlook-2021

33

Analyse overgang sturen op CO2

Trinomics B.V.
Westersingel 32A
3014 GS Rotterdam
the Netherlands
T +31 (0) 10 3414 592
www.trinomics.eu
KvK n°: 56028016
VAT n°: NL8519.48.662.B01