From HBEs to EREs in the Netherlands – New income opportunities for smaller businesses and households in electric mobility

The European Union (EU) and the Netherlands aim to reach climate neutrality by 2050, meaning net-zero greenhouse gas (GHG) emissions. To reach this goal, interim targets have been set for 2030. Figure 1 highlights the most important ones. While EU member states largely have flexibility in how they achieve these targets, they are required to implement a range of European directives. One of these is the revised Renewable Energy Directive (RED III). This directive requires member states to accelerate the deployment of renewable energy across all sectors.

In the transport sector, this can be achieved in two ways: by targeting the share of renewables in final energy consumption or by targeting GHG emissions reductions. Until 2026, the Netherlands applied the first approach. As of January 1, 2026, following the transition from RED II to RED III, the country has adopted the second. This approach is referred to as the fuel transition obligation (BTV: brandstoftransitieverplichting). Fuel suppliers are therefore no longer required to supply a minimum share of renewable energy and demonstrate compliance by surrendering HBEs. Instead, they must achieve a mandatory percentage of GHG emissions reductions (by supplying renewable energy) and demonstrate compliance by submitting EREs.[1]

[1] Source: Parliamentary letter on the progress of RED III implementation in transport (in Dutch).

An ERE equals 1kg of CO2-equivalent (CO2e) emissions reduction compared to a fossil reference, on a well-to-wheel basis.[2] The addition of “e” (equivalent) indicates that this includes not only carbon dioxide (CO2), but also methane (CH4) and nitrous oxide (N2O).[3] The emissions of these gases are assessed on a well-to-wheel basis, thus including the extraction of fuel and raw materials, refining, transport and distribution, and final energy use.

An ERE is a tradable certificate that demonstrates the amount of CO2e avoided by using renewable energy instead of fossil energy. Companies and households can generate EREs by supplying renewable energy to the transport sector and registering these deliveries in the Energy for Transport Registry (REV), managed by the Netherlands Emissions Authority (NEa). This process is referred to as “registration.” Fuel suppliers can generate EREs themselves and thus act as a registered party (inboekers) and/or purchase them from other parties to comply with their fuel transition obligation.

[2] The EU has set the fossil reference value at 94 grams per MJ.

[3] The extent to which greenhouse gases other than CO2 contribute to global warming is expressed in terms of their impact relative to CO2, known as the CO2 equivalent. CO2 has a CO2 equivalent of 1, compared with 28 for methane and 265 for nitrous oxide. Methane is therefore a greenhouse gas that is 28 times more potent than CO2_. Source: De Energietransitie uitgelegd (2024).

Based on the feedstock used to produce them, six distinct categories of EREs can be identified: one for electricity (ERE‑Es), one for renewable fuels of non-biological origin (RFNBOs), such as hydrogen and e‑fuels (ERE‑Rs), and four for biofuels (ERE‑Cs, ERE‑Gs, ERE‑Bs, and ERE‑Os). In addition, there are refinery reduction units (RAREs). These are generated using renewable hydrogen in refineries and therefore constitute a specific subtype of ERE‑Rs. Figure 2 provides an overview of the different ERE categories. The large number of categories reflects the government’s intention to promote the use of certain types of renewable energy (such as RFNBOs) while limiting others (such as conventional biofuels).

When generating EREs, the subsector in which the delivery of renewable energy takes place (land-based transport, inland shipping, or maritime shipping) matters. EREs generated in the land-based transport sector are also referred to as LREs. EREs in inland shipping are called BREs, and those in maritime shipping are referred to as ZREs. Not all types of EREs can be generated in each subsector. In total, this results in a classification of 16 different ERE types (see figure 3).

By 2030, the transport sector must achieve an overall GHG emissions reduction of 14.5%. To meet this target, fuel suppliers must reduce the GHG emissions associated with the fuels they supply by a specified percentage each year. This percentage increases annually. Separate targets have been set for the land-based transport, inland shipping, and maritime shipping subsectors. The fuel transition obligation does not apply to aviation, but this subsector has its own decarbonization targets as described in ReFuelEU Aviation.

To determine how many EREs fuel suppliers have to surrender, all parties subject to the BTV must register their fuel deliveries from the previous calendar year in the REV, managed by the NEa, by March 1 of each year (with 2027 being the first year of reporting). Registrations of fuel deliveries to inland shipping and maritime shipping must be verified by an independent verifier.[4] Fuel suppliers must then hold a sufficient number of EREs in their REV account by April 1 to comply with their obligation.

Fuel transition obligation – land-based transport

All fuel suppliers that deliver at least 500,000 liters[5] of gasoline, diesel, or heavy fuel oil per calendar year to road vehicles, rail vehicles, mobile machinery (including mobile construction machinery, agricultural tractors, forestry machinery, and recreational vessels), and stationary installations fall within the scope of the BTV. Figure 4 provides an overview of this obligation. Notably, EREs registered in other subsectors (inland shipping and aviation) cannot be used at all to meet the land-based transport obligation. The use of ERE‑Cs and ERE‑Bs is limited. This also applies to RAREs, the use of which counts toward the target for ERE‑R.

[4] The total number of EREs required is determined as follows: Required EREs = obligation [%] * (fuel supplied [l] * fuel LHV [MJ/l]) * 94 [g/MJ] /1,000.

[5] This refers to the total volume of fuel, including any blended biofuels.

Fuel transition obligation – inland shipping

Fuel suppliers serving the inland shipping sector were not covered by the HBE system that was in place until 2026. All fuel suppliers that deliver at least 500,000 liters of red diesel[6][7] per calendar year to inland vessels now fall within the scope of the BTV. Figure 5 provides an overview of this obligation. Notably, the use of ERE‑Cs is not permitted at all, while the use of RAREs and ERE‑Bs is limited. Despite these limits on the use of ERE‑Bs (biofuels produced from waste oils and fats, such as used cooking oil), inland shipping can meet most of its 2030 BTV using this type of ERE.

[6] This refers to the total volume of fuel, including any blended biofuels.

[7] This refers to red diesel subject to the applicable excise duty rate for gas oil.

Fuel transition obligation – maritime shipping

As with inland shipping, fuel suppliers serving the maritime sector were not covered by the HBE system that applied until 2026. As of 2026, they fall within the scope of the BTV if they supply at least 500,000 liters of diesel oil, gas oil, or marine fuels[8] per calendar year to maritime shipping. Figure 6 provides an overview of this obligation. Notably, the use of ERE‑Cs is not permitted at all. The same applies to ERE‑Bs, even though this type of EREs can play a significant role in inland shipping. The use of RAREs in this subsector is also capped.

[8] This refers to the total volume of fuel, including any blended biofuels.

Fuel transition obligation by type of ERE-Es

Figure 7 provides an overview of the fuel transition obligation by ERE type. It shows that the government places limits on the use of conventional biofuels (ERE‑Cs), biofuels produced from waste oils and fats (ERE‑Bs), and RAREs. RAREs may only be used to meet the sub‑target for ERE‑Rs, up to a specified limit. This does not apply to ERE‑Rs, which can also be used to meet the overall target.[9]

[9] Source: Subdoel RFNBO's in vervoer | Nederlandse Emissieautoriteit (in Dutch).

EREs are traded bilaterally. As a result, there is no uniform pricing, and it is therefore not possible to speak of a single price for EREs. As noted earlier, there are sixteen different types of EREs for which prices are determined separately. In addition, market liquidity remains limited, as the system is still in its early stages. Consequently, it is questionable to what extent current prices provide a good indication of future price developments in the short and long term.

Based on publicly available information and historical HBE prices, RaboResearch has developed a qualitative assessment of the relative prices of different ERE types (see figure 8). This assessment does not distinguish between subsectors. In practice, however, prices may vary across subsectors – for example, an ERE‑B in the land-based transport sector may be more or less expensive than an ERE‑B in inland shipping, as different sub‑targets and caps apply to each subsector. Because inland shipping and maritime shipping can meet part of their BTV using certain types of EREs from other subsectors, ERE prices across subsectors are partly interdependent.

International developments also play an important role in the pricing of EREs. To date, each EU member state has implemented its own system to comply with RED III. As such, the Netherlands has introduced the ERE system, which is based on GHG emissions reduction and applies to land-based transport, inland shipping, and maritime shipping. Germany operates a similar system (the GHG quota), but only for land-based transport. Other member states have opted for systems based on the volume of renewable energy supplied, measured in energy units. The UK[10] operates a system based on the volume of renewable energy supplied, measured in volumetric units. As a result, certain renewable transport fuels may generate higher returns in some countries than in others.

A Dutch ERE is not interchangeable with a German GHG quota or with similar “tickets” from other countries. However, their prices are still partly driven by supply and demand for these foreign tickets. For example, if suppliers of renewable transport fuels receive higher revenues for delivering one liter of hydrotreated vegetable oil (HVO) – a synthetic diesel produced in part from used cooking oil – in Germany, they will prefer to supply HVO to the German market. This could lead to higher prices for ERE‑Bs in the Netherlands, as supply of renewable energy available to generate ERE-Bs declines.

[10] The UK is no longer an EU member state but has its own energy and climate policy.

Suppliers of renewable transport fuels will allocate their different types of fuels strategically across countries to maximize returns. Conversely, fuel suppliers in the Netherlands subject to the BTV will seek to use as much of the lowest‑cost ERE types as possible to meet their compliance requirements.

Expected use of EREs – land-based transport subsector

In the land-based transport subsector, we expect fuel suppliers to first use ERE‑Cs, ERE‑Bs, and RAREs up to their respective limits. RAREs are used despite their relatively high cost because they remain cheaper than ERE‑R, for which a minimum requirement applies that can be partly met using RAREs. While additional use of ERE‑Rs is allowed, it is not likely to happen given the anticipated high cost of this ERE type. ERE‑Gs are also subject to a minimum requirement. As a result, a remaining gap of approximately 13% must be filled to achieve the 28.4% GHG emissions reduction target in 2030 (see figure 9). This gap can be filled with ERE‑Os, ERE‑Gs, and ERE‑Es (and in theory also ERE‑Rs, although this is considered unlikely due to the high expected cost). Since the availability of ERE‑Os is expected to be limited, the remaining 13% will largely need to be met using ERE‑Es and ERE‑Gs. Two scenarios may emerge. In the first, supply of ERE‑Es remains limited. In this case, ERE‑Gs will also be required to fill the remaining 13% gap. As a result, ERE‑Gs will set the price, and ERE‑E prices will be relatively high. In the second scenario, the electrification in the land-based transport subsector accelerates rapidly, resulting in sufficient supply of ERE‑Es to fill the remaining gap of 13% without the need for ERE‑Gs. In this case, ERE‑Gs will not set the price, and ERE‑E prices will be lower.

Expected use of EREs – inland shipping subsector

We expect fuel suppliers in the inland shipping subsector to use the lowest‑cost ERE types as much as possible. These are ERE‑Bs and RAREs, both of which are subject to limits. ERE‑Cs cannot be used. ERE‑Rs can be used, but since the mandatory sub‑target for this ERE type in inland shipping can be fully met with RAREs, we expect it to be met using RARES. Some inland vessels may (partly) operate on methanol (an RFNBO) by 2030, but we expect the use of this fuel to remain marginal at that time. The same applies to the use of battery electric inland vessels. As a result, a gap of approximately 3% remains to meet the 14.5% GHG emissions reduction target in 2030 (see figure 10). Nearly all of this gap (2.9%) can be filled using ERE‑Gs and ERE‑Os from other sectors. We expect part of this gap to be filled with inland‑shipping ERE‑Os and ERE‑Es, the latter will primarily come from the supply of shore power. If the land-based transport subsector electrifies rapidly and meets most of its remaining target using ERE‑Es, it is possible that ERE‑Gs and ERE‑Os from land-based transport will be used in inland shipping.

Expected use of EREs – maritime shipping subsector

The maritime shipping subsector has a BTV of 8.2% in 2030. The use of ERE‑Cs and ERE‑Bs is not permitted. The use of RAREs is limited. As a result, a gap of 7.88% remains, of which 2.5% may be filled using certain ERE types from other subsectors (see figure 11). We expect this gap to be largely filled with ERE‑Gs and ERE‑Os (partly from other sectors), with only a limited contribution from ERE‑Es (shore power) and ERE‑Rs. In the scenario where the land-based transport subsector electrifies rapidly, maritime shipping is likely to use up to 2.5% of ERE‑Es generated in land-based transport.

To generate EREs, companies must meet certain requirements. These requirements vary by ERE type.[11] Organizations must engage an independent verifier to confirm that the registered renewable energy supplies comply with all regulatory requirements. In addition, the NEa conducts periodic audits of registrations.[12]

Registration of ERE-Es

The owner of an electricity connection is the entity that can generate ERE‑Es, provided that the owner supplies electricity to the transport sector. This may, for example, be a logistics company that charges electric trucks using its own charging infrastructure, or the operator of public charging stations or shore power connections. A key requirement is that the entity must at least supply 2m kWh of electricity per year. Smaller companies and households cannot realistically meet this threshold on their own. A new feature compared to the HBE system is that the registration of supplied renewable electricity can be done via so‑called registration service providers. These providers can register the supply of renewable electricity on behalf of third parties (both companies and households) if they register at least 2m kWh of electricity or hold at least 200 authorizations from third parties.[13] Those third parties must be the owners of the electricity connections for which the registration service provider registers electricity supplies. An additional requirement for generating ERE-Es (via a registration service provider) is that the electricity must be supplied via a connection that is used exclusively for supplying electricity to transport.[14] If this is not the case (as is typically true for households), the meter must be MID‑certified (i.e., compliant with the EU Measuring Instruments Directive).

ERE‑Es can only be generated through the supply[15] of renewable electricity. Not all electricity supplied via the electricity grid is renewable. Therefore, to determine how many ERE-Es are created from supplying electricity to the transport sector, a certain share of total electricity supplied is labeled as “renewable.” By default, the average share of renewable electricity in the Dutch electricity mix from two years prior is used. For example, if a household supplies 1,000kWh of electricity to an electric vehicle via a private charging point in 2026, 50.54% of this electricity is considered renewable.[16] This results in the creation of 333 ERE‑Es.[17]

Registration of 100% renewable electricity

There are two ways to generate ERE‑Es for which 100% of the electricity supplied is considered renewable. The first is supply via a dedicated cable. This is a connection between a power producer (such as a wind or solar farm) and a nearby electricity offtaker. A dedicated cable is not part of the public electricity grid.

The second option is the generation and supply of electricity at the same cadastral property. In both cases, Certificates of Origin are required to certify the renewable nature of the electricity supplied. This requirement makes it difficult for households and many businesses to adopt this approach.

If this condition is met, supplying 1,000kWh of fully renewable electricity to an electric vehicle in 2026 will generate 659 ERE‑Es. This is nearly double the amount based on the average share of renewable electricity in the Dutch electricity mix. However, this share is expected to increase over time, reducing the difference in ERE‑E generation between supplying 100% renewable electricity and grid electricity.

[11] For a full overview, see Inboeken hernieuwbare energie vervoer | Nederlandse Emissieautoriteit (in Dutch).

[12] The number of EREs registered is determined using the following equation:
Number of EREs = volume registered [l or kg] * LHV [MJ/l or MJ/kg] * (94 [g/MJ]-E [g/MJ])/1,000.
Where 94g/MJ represents the fossil reference value, and E is the emissions factor of the biofuel. For biofuels produced from category 3 animal fats (as listed in Annex IX‑B), a correction factor of 0.5 applies. This equation does not apply to ERE‑Es.

[13] Parties that register ERE‑Es alongside other types of EREs are not required to meet this threshold.

[14] This may also be done via a secondary allocation point.

[15] The term “supply” may be confusing in this context, as it does not refer to energy suppliers delivering energy to consumers, but rather to owners of electricity connections supplying electricity to the transport sector.

[16] In 2024, the share of renewable electricity in the Netherlands was 50.54%. Source: StatLine - Hernieuwbare elektriciteit; productie en vermogen (in Dutch).

[17] The number of ERE‑Es registered is determined using the following equation:
Number of ERE‑Es = electricity supplied [kWh] * renewable share [%] * 183 [g/MJ] * 3.6 [MJ/kWh]/1,000
Where 183g/MJ represents the fossil reference value, which differs from the reference value used for the calculation of all other ERE types.

As of this year, many companies supplying fuels to the transport sector (land-based transport, inland shipping, and maritime shipping) fall within the scope of the BTV. As a result, they must supply a growing share of renewable energy, thereby reducing the GHG emissions associated with the fuels they deliver. They can do this in two ways: by supplying renewable energy themselves and generating the corresponding EREs, or by purchasing EREs from other parties.

The latter option creates opportunities for companies and households to generate income. They can do so by charging electric vehicles using their own charging infrastructure and generating ERE‑Es (via a registration service provider). In early 2026, ERE‑Es generated for land-based transport using grid electricity yielded approximately EUR 0.15 to EUR 0.17 per kWh, while ERE‑Es generated using 100% renewable electricity yielded roughly double that amount. When generating ERE‑Es via a registration service provider, the net returns are typically lower. Some providers offer a fixed (low) fee, while others offer compensation that is (partly) linked to the market price of ERE‑Es. The trade-off is that users avoid the need to handle administrative processes or engage a verifier themselves. The option to generate ERE‑Es via a registration service provider is new compared to the HBE system and opens up a new revenue stream for smaller businesses and households.

However, the size of this additional income stream remains uncertain. Prices may rise or fall in the coming years, and predicting the direction of price movements is difficult, partly because international developments can influence ERE prices in the Netherlands. In addition, the BTV has currently only been defined until 2030. It remains unclear whether and how the BTV and the ERE system will continue beyond that point. It is clear, however, that the difference in ERE‑E revenues between charging with grid electricity and charging with 100% renewable electricity will continue to decline as the electricity mix becomes increasingly sustainable. It is also clear that at some point governments will stop incentivizing the decarbonization of the transport sector (and other sectors), because targets have been met and fossil fuels are no longer the reference point.

All of this means that the ERE system can provide an attractive financial upside for companies and households, but that both the magnitude and duration of these revenues are uncertain.