The Netherlands is gearing up to implement significant amendments to its Energy Transport Decree by 2026, aligning with the European Union's updated Renewable Energy Directive (RED III). These updates aim to reduce greenhouse gas (GHG) emissions across transport sectors, from roadways to maritime and aviation. As the U.S. takes its own steps toward decarbonization, the Netherlands’ policy changes offer valuable lessons and potential opportunities for American businesses.

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Key Changes Under the 2026 Renewable Energy Obligations

1. Transition to Emissions Reduction Units (EREs)
   The Netherlands will replace its bio-based trading certificates (HBEs) with emissions reduction units (EREs). These certificates not only require renewable energy use but also emphasize low-carbon technologies measured by carbon intensity (CI) scores. This shift moves beyond simply using renewable energy to prioritizing impactful emissions reductions.
   For the U.S., where renewable energy credits (RECs) are widely used, adopting a CI-based approach could bolster GHG reduction strategies and attract global investment in clean technologies.
2. Sector-Specific Targets
   Each transport sector has unique obligations under the 2026 framework, recognizing their varying readiness for renewable energy adoption:
   • Land Transport: Expected to lead with a renewable energy mandate starting at 14.4% in 2026 and rising to 22.6% by 2030. The U.S. could mirror these ambitious goals by enhancing federal and state incentives for biofuels and hydrogen adoption.
   • Maritime and Inland Shipping: These sectors are allowed “free space” provisions, enabling operators to partially meet renewable targets through emissions trading. For U.S. coastal and shipping industries, adopting similar flexibility could facilitate renewable adoption without excessive economic strain.
   • Aviation: Renewable energy obligations align with the EU’s ReFuelEU regulation, promoting sustainable aviation fuels (SAFs). U.S. airlines can anticipate increasing global demand for SAFs, opening opportunities for domestic production and export.
3. Sub-Targets for Advanced Fuels and RFNBOs
   RED III introduces targets for advanced biofuels and renewable fuels of non-biological origin (RFNBOs), such as hydrogen. Refineries can comply by co-processing renewable hydrogen with conventional fuels, aligning with broader decarbonization goals.
   The U.S. hydrogen sector, supported by tax credits under the Inflation Reduction Act (IRA), is well-positioned to scale production and supply hydrogen-based fuels to meet international demand.

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Implications for the U.S. Market

1. Learning from a CI-Driven Framework
   The Netherlands' focus on carbon intensity provides a model for measuring the quality of renewable energy. For the U.S., integrating CI scores into existing frameworks like the Renewable Fuel Standard (RFS) or state-specific programs could drive more effective GHG reductions.
2. Expansion of SAF and Hydrogen Markets
   As the Netherlands and the EU push for SAFs and hydrogen adoption, U.S. producers stand to benefit from increased export opportunities. Meeting stringent EU standards will require investment in advanced fuel technologies, offering long-term economic gains.
3. Flexible Compliance Mechanisms
   The “free space” provisions allow certain sectors to trade emissions credits, making renewable adoption more manageable. A similar approach in the U.S. could encourage industries with high decarbonization costs, like shipping and aviation, to transition more smoothly.
4. Boosting Infrastructure Development
   Meeting RED III’s goals requires significant investment in renewable fuel infrastructure, a challenge also faced in the U.S. Enhanced public-private partnerships and incentives could accelerate the deployment of refueling stations, hydrogen pipelines, and SAF production facilities.

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Navigating Compliance: The Role of AFS Commodities

Meeting the complex obligations of RED III requires strategic planning and a clear understanding of renewable energy policies. With expertise in emissions trading, renewable energy sourcing, and advanced compliance solutions, AFS Commodities offers tailored support for businesses navigating this evolving landscape. From helping clients secure renewable fuels to optimizing emissions credits, AFS Commodities enables companies to meet their obligations efficiently while advancing their sustainability goals.

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By transforming regulatory challenges into strategic opportunities, AFS Commodities empowers businesses to thrive in the transition to renewable energy.