In response to the EU’s ambitious climate agenda, the Netherlands is adopting significant amendments to its Energy Transport Decree by 2026. These updates, driven by the revised Renewable Energy Directive (RED III), aim to make substantial cuts in greenhouse gas emissions across all transport sectors. From road and maritime to aviation, the Netherlands' 2026 obligations highlight renewable energy benchmarks and carbon intensity (CI) scores as critical metrics for compliance. This article unpacks the 2026 obligations, explaining how they impact sector-specific targets, compliance pathways, and the role of “free space” provisions for flexibility.

Introduction to the 2026 Renewable Energy Obligations

The shift to RED III places greater emphasis on emissions reductions through renewable energy use in transportation. By 2026, the Netherlands will replace its existing bio-based trading certificates, known as HBEs, with emissions reduction units (EREs). These new ERE certificates not only mandate that energy sources be renewable but also prioritize low-carbon technologies, quantified by CI scores. This focus on CI-based measurements reflects an evolution from simply requiring renewable energy use to incentivizing higher quality, impactful emissions reductions.

AFS Energy, a leader in renewable energy solutions, plays a pivotal role in helping organizations navigate these complex new directives. By offering customized compliance solutions, emissions trading, and renewable energy sourcing services, AFS Energy provides clients with the strategic guidance necessary to meet and exceed RED III mandates.

Overview of Sector-Specific Obligations for 2026

The new 2026 targets differentiate obligations across sectors, acknowledging each sector's unique capabilities and constraints in renewable energy adoption. Here is a sector-wise breakdown:

• Land Transport: Represented by Land Reduction Units (LREs), road transport has the highest emissions reduction target. Starting with a 14.4% renewable energy mandate in 2026, the target will rise to 22.6% by 2030. Land transport's stringent targets reflect the sector’s relatively advanced renewable adoption potential, pushing it to lead in biofuel and hydrogen usage with minimal allowance for “free space” trading, thus encouraging direct adoption of renewables.
• Inland Shipping: New to renewable obligations, the inland shipping sector (designated as ZREs) faces a 20% free space allowance, allowing a portion of its targets to be achieved through credit trading. This recognizes the early stage of renewable fuel availability in this sector and reduces immediate economic strain on smaller operators.
• Maritime Shipping: For maritime transport, the 2026 target mandates a 3.6% renewable energy share, which will grow to 8.2% by 2030. Maritime shipping can meet up to one-third of this requirement through free space credits, which can be traded across sectors to mitigate high costs and technical challenges of alternative fuel adoption. This flexibility makes the target manageable while fostering a gradual shift toward sustainable practices.
• Aviation: Aligning with the EU’s ReFuelEU regulation, the Netherlands mandates a renewable energy target of 5.3% by 2030 in aviation (AREs). Without additional national obligations, aviation companies can utilize flexible compliance options, including cross-sector credit trading, to meet this target. This approach recognizes the unique hurdles in renewable fuel adoption for aviation, creating a standard that is feasible and uniform across the EU.

AFS Energy offers tailored support in meeting these sector-specific obligations. Through its expertise in clean transport solutions, emissions trading, and renewable energy certificates, AFS Energy helps clients design sector-appropriate strategies that align with both EU and national targets.

Sub-Targets for Advanced Fuels and RFNBOs

To further decarbonize transport, RED III introduces sub-targets for advanced biofuels and renewable fuels of non-biological origin (RFNBOs) such as hydrogen. These advanced fuels are essential for sectors like road and maritime, which lack ready alternatives to conventional fuels. For example, hydrogen’s inclusion in the RFNBO sub-targets promotes infrastructure development, gradually preparing the sector for wider hydrogen adoption as a renewable fuel.

Additionally, the 2026 amendments provide refineries with a compliance pathway to coprocess renewable hydrogen with conventional fuels. This generates special RFNBO tickets called RAREs (refinery reduction units) for compliance, albeit with a lower multiplier of 0.4 to encourage direct RFNBO use in transport instead of refining. This mechanism aligns refineries with climate goals and boosts hydrogen’s market relevance, especially as the technology advances and becomes more feasible across sectors.

By leveraging its extensive network and experience, AFS Energy helps businesses secure RFNBOs and advanced biofuels that align with their compliance needs. With options like Power Purchase Agreements (PPAs) and Gas Purchase Agreements (GPAs), AFS Energy ensures that clients not only meet their targets but also benefit from stable, cost-effective renewable energy sources.

Free Space Provisions Across Sectors

The “free space” provisions in RED III give certain sectors flexibility to partially fulfill their renewable targets through emissions trading rather than direct renewable fuel adoption. This flexibility is instrumental for industries where the adoption of renewable fuels is either financially or technically challenging. Here’s a closer look at how free space provisions work across sectors:

• Maritime Shipping: Operators in this sector can use free space credits to cover up to a third of their target, allowing them to trade credits with other sectors if renewable options are prohibitively expensive or technologically complex.
• Aviation: This sector enjoys the maximum flexibility under RED III, permitting full compliance through credit trading rather than direct fuel use. This exemption harmonizes with the EU’s ReFuelEU directive for sustainable aviation fuels (SAFs), which aims to gradually increase SAF usage without overburdening the sector.
• Inland Navigation: Allowed 20% of its target through free space credits, this provision makes it affordable for smaller operators in the early adoption phase of renewable technologies.
• Road Transport: In contrast, the road sector has limited free space access and is expected to achieve most of its obligations through direct renewable fuel use. This restriction reinforces the “polluter pays” principle and spurs the sector to adopt renewable fuels, driving infrastructure and technology advancements that could ultimately support renewable energy adoption across all sectors.

AFS Energy, through its robust emissions trading and environmental commodity brokerage, facilitates access to these free space credits. This service enables clients in more challenging sectors to leverage market flexibility while still meeting their targets under RED III. By navigating free space provisions, AFS Energy helps clients manage costs effectively while advancing renewable energy use.

Meeting Compliance with RED III’s Complex Framework

The introduction of EREs, RFNBOs, and free space provisions creates a complex compliance framework that requires strategic planning. With over 15 types of tickets or credits under RED III, each with unique rules, multipliers, and eligible fuel types, companies need a thorough understanding to achieve and maintain compliance efficiently.

AFS Energy offers its clients the expertise and technology to navigate these complexities. Its AFS Energy Trading Platform provides seamless access to emissions allowances, real-time market data, and regulatory updates. Through tailored consulting and the Client Portal, AFS Energy empowers clients with actionable insights, market forecasts, and data management tools that streamline compliance, risk management, and reporting.

For companies obligated under the EU Emissions Trading System (EU ETS) and similar schemes, AFS Energy’s expertise in carbon compliance ensures that they stay ahead of regulatory changes, avoid penalties, and make informed investment decisions in low-carbon solutions. Additionally, AFS Energy’s commitment to carbon offsetting allows companies to further mitigate their carbon footprint by supporting verified emissions reduction projects globally.

Conclusion

The Netherlands' 2026 amendments to the Energy Transport Decree mark a decisive step toward a decarbonized future, reshaping compliance requirements across transport sectors. As RED III introduces new renewable energy targets, sector-specific obligations, and complex compliance mechanisms, organizations face a challenging path to full compliance. Successfully navigating this intricate framework requires not only a deep understanding of renewable energy policies but also the ability to leverage flexible provisions and advanced fuels strategically.

In this landscape, expert guidance is invaluable. AFS Energy, with its deep knowledge and customized solutions, is equipped to help businesses meet their 2026 obligations effectively and sustainably. By translating the complexities of RED III into actionable strategies, AFS Energy enables companies to transform regulatory challenges into a sustainable competitive edge.

With AFS Energy's expert guidance, you can transform your sustainability journey into a strategic advantage, fostering long-term success and resilience in an ever-evolving business environment.

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