We cover two recent developments in France and Germany that have implications for biomethane without production subsidies.
On 16 June, the EEX announced that they had launched the French biogas certificate (“CPB”) register. The establishment of the register was an expected and necessary step towards implementing the French grid blending obligation.
Recapping the details of the program, an obligation will be placed on large gas suppliers to ensure a share of their offering to consumers is biomethane, with this share increasing yearly.
To prove compliance, suppliers must surrender (restitute) CPBs, which are issued to biomethane producers injecting into the French grid. Generally, one certificate is issued per MWh injected, although there is a reduction factor applied in certain cases (namely older plants).
To prevent overcompensation, the law makes CPB issuance mutually exclusive with GOs and any production subsidies. Biomethane volumes sold via a biomethane purchase agreement (BPA) also cannot be used to meet the obligation.
Under transparency provisions, the EEX will make available data regarding pricing (monthly average) and certificate issuance (six-monthly). The certificate register will also contain particulars on the associated plant and injection period for certificate volumes.
The penalty for non-compliance is slated to be EUR 100/MWh, which places a price cap on the CPB. Should demand outstrip supply, the value of these certificates will be close to the penalty, a rate which is expected to encourage the construction of larger capacity plants, which are excluded from the lucrative tariff rates available to smaller plants.
Furthermore, the EEX has clarified the interaction between the ETS 2 and CPBs, where the certificates represent zero emissions biomethane usage. This would further increase the value of the CPB beyond avoiding the blending obligation penalty.
Later that week (19 June 2025), the German Federal Ministry for the Environment (“BMUKN”) published draft amendments to the GHG-quota law (“THG-Quote”). The proposed changes will have the effect of bringing the scheme in alignment with RED III and extending targets to 2040.
The draft also sets out a 2040 target, of 53% reduction (corresponding to a 77% share in renewable energy in transport) building on the existing 2030 target of 25% reduction set under RED II.
While not directly related to biomethane, the draft also extends RFNBO sub-targets to 2040, where a 12% share is expected.
The THG-quote will now apply across all transport sectors, including maritime and aviation. However, the draft highlights that renewable fuel eligibility is sector constrained. For example, a fuel supplier offering both aviation and road fuel cannot simply purchase excess biomethane (which is not a SAF) to help meet aviation targets.
Of concern are the impending EU obligations for renewable fuel in shipping (FuelEU Maritime) and aviation (ReFuelEU Aviation). In the case of maritime, the obligation is placed on different actors (maritime fuel suppliers for THG, shipping companies for FuelEU Maritime). However, the principles of avoiding double counting (PoS can only claimed once) suggest obligations must be met with separate fuel volumes, in which case end-users would ultimately bear the burden of two similar compliance schemes. It is unclear what mechanisms are in place, or will be implemented to avoid such distortions.
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