Complying with the obligation to reduce greenhouse gas emissions in 2020

Companies comply with their obligation to reduce greenhouse gas emissions by surrendering renewable energy units (HBEs: hernieuwbare brandstofeenheden) in the Energy for Transport Registry (REV: Register Energie voor Vervoer) on 1 April 2021. In addition, they can surrender emission reduction units (UERs: Upstream Emission Reductions).

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

Companies subject to an obligation to reduce greenhouse gas emissions need to have an account in the REV. They must register their fuel deliveries for 2020 before 1 March 2021.

See also: Obligation to register fuel deliveries.

The expectation is that they will largely or fully comply with their obligation to reduce greenhouse gas emissions by complying with the annual obligation in 2020. They must have sufficient HBEs of the correct type and possibly additional UERs in their account no later than 31 March 2021.

In 2020, the REV will display the following, based on the registered fuel deliveries, under the ‘Indication annual and reduction obligation’ menu item:

  • Which obligation for 2020 is the highest and therefore leading: the annual obligation or the obligation to reduce greenhouse gas emissions,
  • The required number of HBE Advanced (HBE-A), HBE Conventional (HBE-C) and HBE Other (HBE-O) to fulfil the highest obligation,
  • Whether the balance is sufficient to comply with the highest obligation.

HBE contribution to emission reduction

Regardless of their type, all HBEs are assigned a contribution to reduction in kilograms CO2-eq. Surrendering HBEs for the annual obligation thus also results in a claim of kilograms of CO2 for the emission reduction obligation. From 2019 on, the NEa will annually announce the value for the HBE contribution to emission reduction (HBE-reductiebijdrage)  on 1 April at the latest.

The reduction value is based on the contributions of different fuel types to the reduction of greenhouse gas emissions. In the case of the claimed deliveries of renewable energy, the reduction value reflects the reported amounts and emission factors from the previous calendar year. For the ‘better’ fossil fuels (LPG, LNG and CNG) the value  reflects the amount delivered to the transport sector in the preceding calendar year and the standard emission factors. See the Reference data for fuels listed in the registry.

Value for 2020

The HBE contribution to emission reduction (HBE-reductiebijdrage) for 2020 is 46 kg CO2-eq. This value reflects the average CO2 emission reduction for each HBE that was created in 2019 and serves as an indication of the amount of reduced CO2 emissions by the use of HBEs in the current year.

The underlying data for the HBE contribution to emission reduction 2020 will be published in the NEa Energy for Transport report 2019 (in Dutch).

Crediting of UERs from 2020

Once the annual obligation has been complied with, a company can surrender additional HBEs or can use Upstream Emission Reductions (UERs) to comply with the remaining obligation to reduce greenhouse gas emissions. These are units from projects that started after 1 January 2011 and where the emission of greenhouse gases is reduced in the pre-refining stage (upstream).

The units must come from the German UER registry or from a project activity in accordance with the clean development mechanism in the Kyoto protocol; CDM projects. Because not all CDM project activities satisfy the requirements, Annex 9 of the Energy for Transport Ministerial Regulation contains a list of suitable project activities. The certified emission reductions (CERs) that are issued for an emission reduction from the calendar years 2019 and 2020 are eligible for conversion into UERs.

Companies wishing to make use of this must ensure that a number of UERs from the German UER Registry or CERs from the Kyoto Protocol Registry have been transferred to the NEa before 1 March 2021. The transfer must be accompanied by a signed letter stating which operator the UERs or CERs are intended for. The NEa will then credit a corresponding number of UERs to the relevant operator’s account in the REV.

The NEa will process requests to credit UERs from 1 January 2020 onwards, because credited UERs cannot be banked (and consequently they would be debited on the following year-end closing). Further information about the procedure to be followed will be given on request.

Actions performed automatically on 1 April 2021

The REV will perform a number of actions automatically on 1 April 2021.

First of all, the REV will deduct the number of UERs from the account. This is followed by the number of HBEs per type matching the highest obligation: the annual obligation or the obligation to reduce greenhouse gas emissions. When doing so, the limit on HBE-C will also be applied to the obligation to reduce greenhouse gas emissions. Then, the REV deducts  the remaining HBEs, with the exception of the amount that the operator is allowed to carry over to the next year. UERs cannot be banked, any surplus will be written off.

See also: Complying with the annual obligation and Banking limit.

NEa reports on the progress of the obligation to reduce greenhouse gas emissions

In the run-up to the obligation to reduce greenhouse gas emissions, the NEa will publish an annual report for the Netherlands as a whole in the Energy for Transport in the Netherlands Report. This will also discuss the contributions from biofuels and ‘better’ fossil fuels.

See also: Energy for Transport reports