Feedstocks and double-counting

Please note: the information available on this page is only relevant for 2018-2021.

There is a strong relationship between feedstocks that are eligible as more valuable HBE Advanced and HBE Other and for double-counting: the crediting of twice the number of HBEs.

Annex IX of the Renewable Energy Directive (RED) plays a central role in this. Annex IX shows the feedstocks that the European Commission has decided are worthy of a stimulus in regard to conventional biofuels from agricultural and energy crops. The Dutch system is also set up for this.

Proof of sustainability as the basic principle

Companies must specify the feedstock from which the biofuel has been produced when submitting their claim. They must base this on the feedstock as stated in the Proof of Sustainability or the Guarantee of Origin (the latter in the form of a Vertogas certificate).

The Energy for Transport Registry (REV: Register Energie voor Vervoer) contains a list of feedstocks as used in sustainability systems (ISCC in particular). If the template for the Proof of Sustainability does not include a specific feedstock for a claim, companies can contact their voluntary scheme or NEa.

Annex IX, Part A and Part B, and double-counting

Annex IX includes a Part A, which shows feedstocks that are used for biofuels for which the claim results in HBEs Advanced, this includes waste materials and residues in particular. Annex IX, Part B includes two feedstocks (used cooking oil and animal fats) for which the biofuel that is produced results in the crediting of HBEs Other following the claim.

Feedstocks in Annex IX (both Part A and Part B) are eligible for double-counting. This means that the claim for biofuel from the feedstocks mentioned there results in the crediting of twice the number of HBEs. This is an additional stimulus for delivering and claiming delivery of biofuel from waste and residue flows.

Biofuels from feedstocks other than those mentioned in this annex are single-counting by definition. In that case, a claim can result in the crediting of HBE Other or HBE Conventional, depending on whether or not it is a (by) product of a crop.

List of industrial waste

Annex IX, of Part A of the Directive, contains a description of the biomass fraction of industrial waste under section d). This is a broad category of feedstock, for which further clarification of what this is understood to include is given at national level. This is done in a list of feedstocks in Annex 5 of the Energy for Transport Regulations. Only feedstocks included in this national list are considered to be biomass fraction of industrial waste in the Netherlands. This list includes feedstocks which the Ministry of Infrastructure and Water Management has determined to be waste. Additions will be made to this list where necessary.

Companies can submit a request by providing information about the feedstock to the NEa. A form for information about feedstocks will be included here in the near future. Until then, you can contact the NEa Helpdesk. The NEa will evaluate these requests and advise the Ministry of Infrastructure and Water Management about inclusion in the regulation. The Ministry will make the final decision on this.

Non-modification declaration

To ensure that only biofuels based on the correct feedstocks are eligible for HBE Advanced or HBE Other, and therefore for double-counting, feedstocks should not be intentionally modified. Intentional modification is when, for instance, waste flows are created intentionally or flow volumes are increased by mixing in other material flows.

Companies submitting claims must demonstrate that feedstocks have not been intentionally modified. Only when this is done HBE Advanced or HBE Other will be credited.

Approval of voluntary schemes

Sustainability systems approved by the European Commission are key to determine the absence of intentional modification. As of 1 January 2019, three voluntary schemes have been approved by the Ministry of Infrastructure and Water Management, in cooperation with the NEa:

• ISCC-EU
• Better Biomass
• RSB EU RED

Other voluntary schemes will be assessed on request.

Approval of voluntary schemes consists of assessing the degree to which used methods and procedures provide guarantees to ensure non-modification of waste streams. The declaration of non-modification has been included in the template for Proofs of Sustainability. Based on this, companies can indicate in the Energy for Transport Registry (REV) that they have a declaration of non-modification.

What does this mean for companies submitting liquid biofuel claims?

As of 2019, companies submitting claims for biofuels from waste streams have to:

Make use of an approved sustainability system to be able to claim HBE Other or HBE Advanced;

Actively indicate they possess a non-modification declaration when submitting claims. Only when this is done HBEs Other or HBEs Advanced will be credited to their account. If no non-modification declaration exists, only HBEs Conventional (single-counting) will be credited;

Possess a non-modification declaration as part of their sustainability documentation.

ISCC

Companies with ISCC-EU certification need to declare ‘non-modification’ on the proof of sustainability they draw up for NEa. This is done by filling in ‘Yes’ to the following statement on the recently updated ISCC template:

“The raw material meets the definition of waste or residue according to the RED, i.e. it was not intentionally produced and not intentionally modified, or contaminated, or discarded, to meet the definition of waste or residue.”

RSB

Companies with RSB EU RED certification need to declare ‘non-modification’ on the proof of sustainability they draw up for NEa. This is done by filling in ‘Yes’ to the following statement on the recently updated RSB template:

“Compliance with the sustainability criteria according to Article 17(3) to (6) Renewable Energy Directive was audited and certified.”

What does this mean for companies submitting gaseous biofuel claims?

Points 1 and 2 as mentioned above (“What does this mean for companies submitting liquid biofuel claims?”) also apply to companies submitting claims for gaseous biofuels. However, these companies do not possess their own certified location. The production location of the green gas fed to the grid is the last certified link of the chain. This location will thus need to be certified by an approved voluntary scheme. Currently these are: Better Biomass, ISCC-EU, and RSB EU RED.

The Guarantee of Origin (issued by Vertogas) and the double-counting certificate do not include an explicit non-modification declaration. Because the production location is certified and audited, the NEa regards the presence of the Guarantee of Origin and the double-counting certificate as proof of non-modification and therefore does not ask for an additional non-modification declaration.

Summary of HBE compensations per feedstock type

Below, you will find a general summary of the feedstock types, the type of HBE and number of HBEs that will be credited for a claim. Naturally, the claim only results in HBEs if the sustainability has been demonstrated.

The complete summary by individual feedstock level, as included in the Energy for Transport Registry, can be found at the topic Energy for Transport Registry.

Conditions for double-counting

Companies that want to claim a biofuel as double-counting in the REV, must have a double-counting certificate for this biofuel. This certificate proves that double-counting has been confirmed by an independent verifier and complies with the legal conditions. The verifier must be competent to perform the double-counting verification.

The double-counting certificate and the Proof of Sustainability must clearly relate to the same feedstock.