On 24 June 2025, the Dutch Ministry for Infrastructure and Water Management released the draft “Implementation of RED III” regulation to transpose the EU’s Renewable Energy Directive III. This draft outlines obligations for renewable energy uptake in the transport sectors, land, inland shipping, and maritime, while notably excluding aviation. This is aimed at eschewing instances of double counting of renewable energy contributions from raw materials enlisted under Annex IX of RED II. It follows an EU Commission request to comply by 25 May 2025 on setting designated acceleration zones and further aligning with EU timelines (implementation beginning in 2026)
The proposal mandates a phased increase in the share of renewable energy in transport fuels, from 14.4% in 2026 to 27.1% by 2030, using a GHG-based accounting system referred to as Energy Reduction Units. Obligated suppliers, with overall consumption more than 500,000/year, will be required to surrender EREs annually. While EREs from the land transport sector can be used to meet shipping obligations, the reverse will not be permitted.
The draft sets a cap on crop-based biofuels at 1.2% of total energy for the land sector, consistent through 2030. For biofuels based on Annexe IX Part B feedstocks such as used cooking oil and animal fats, the land sector is capped at 4.29%, inland shipping at 11.07%, and the maritime sector is excluded altogether.
The Dutch government has also opted to decouple the EU-wide 5.5% advanced biofuels and 1% RFNBO sub-targets, allowing them to be met separately. Renewable hydrogen used in refineries will count towards a separate RAREs (Refinery Assigned Reduction Effort) obligation, offering another pathway for compliance.
A hydrogen “correction factor”, which would reduce the creditable value of hydrogen as a fuel, will not be applied in the near term, and may only be introduced after 2030, reflecting the government’s commitment to support the direct use of hydrogen.
To maintain fuel quality standards, the Netherlands will retain its current B7 biodiesel blend limit, despite EU provisions allowing up to B10, citing concerns about compatibility with older diesel vehicles.
The existing Dutch renewable fuel credit system, known as HBEs, will be converted into EREs effective from 1 April 2026. Credit banking will be allowed, with a limit of 10% for obligated parties and 4% for registered entities.
The phased renewable energy targets and crediting mechanisms provide regulatory clarity for investors and market participants. For India, the clear caps on conventional feedstocks, combined with rising RFNBO and advanced biofuel targets, signal a growing demand for renewable hydrogen and synthetic fuels within the EU. This may make it exigent to re-adjust our focus from the existing cooking oil and animal fat markets towards investments in advanced biofuels. The delay in applying a correction factor for hydrogen further strengthens the case for direct hydrogen use, particularly in refining applications. These provisions align well with India’s strengths in low-cost renewable hydrogen production and create a scope for technology transfer, supply partnerships, and strategic advisory roles targeting Europe’s evolving clean fuels market.
This draft regulation provides clarity on the Netherlands’ implementation approach and introduces a structured compliance mechanism that emphasizes the role of advanced biofuels and renewable hydrogen in transport decarbonization. For emerging producers and exporters of renewable hydrogen and e-fuels, including Indian developers, this framework offers regulatory signals worth monitoring closely.



