The draft suggests Portugal will opt for renewable energy share targets, rather than a GHG intensity target which countries such as Germany and the Netherlands intend to adopt as part of their implementation plans. This suggests that the Portuguese transport markets will not see a premium for manure biomethane (negative GHG intensity) over standard waste (low GHG intensity), as observed in Germany.

As per RED III, renewable fuels of non-biological origin (RFNBOs) are officially recognised and can have a multiplier of two in renewable share calculations, similar to advanced biofuels. For non-road sectors, stacking multipliers for renewable fuels are 1.2 and 1.5 for advanced biofuels and RFNBOs respectively.

For reference, multipliers are a method of encouraging the uptake of certain renewable energy sources by allowing them to count for more than their actual energy content when determining renewable energy share. See our previous article for more information.

Targets are prescribed for the individual transport sectors – road, maritime and rail – with the exception of aviation. Also included in the draft were fuel sub-targets and interim 2027 targets, summarised below.

For comparison, RED III has transport sector sub-targets of the transport sector of 5.5% for advanced biofuels and RFNBOs, and 1% for RFNBO with these targets being single counted. Thus, the Portuguese ambitions for RFNBOs are lower (0.6% single count for road and rail, 0.4% for maritime) than expected. On the other hand, they are leaning into advanced biofuels more strongly, particularly in the road sector (7.5% advanced biofuel and RFNBO, single count).

RED III does not prescribe a combustible fuel target, but rather an overall 29% renewable share (including multipliers). Viewed against the Portuguese road sector target for combustible renewables, the difference is only 1%. This suggests electric vehicles (the main difference between the two categories) are only expected to play a minor role in comparison to biofuels heading towards 2030.

Interestingly, no caps are put forward for RED III Annex IX Part B (restricted waste feedstock) fuels, although this is likely to be set later. Further, while aviation is not included or obligated, it leaves the door open for aviation fuels to be credited towards overall transport targets.

Biomethane Guarantees of Origin

Portugal has already established a gas GO register and has commenced transacting biomethane Guarantees of Origin (GOs), although the domestic market is still in its infancy with less than half a TWh cancellations for 2025 to date. Nevertheless, the RED III implementation draft explicitly covers renewable gas GOs. Article 47, detailing general GO issuance, has provisions for sub-hourly production intervals for gas and a simplified registration process for facilities under 50 kW, congenial to more granular GO reporting and smaller producers respectively.

Article 50, specific to renewable gas GOs states all GOs are to be accompanied by proof of sustainable production. While what constitutes acceptable proof is not specified, voluntary scheme certification (e.g. ISCC) is likely to be sufficient to fulfill this role. This potentially sets the scene for a certified disclosure market for Portuguese gas.