This follows from the previous submission in May 2024, which was withdrawn on 19 November 2025 (the same day the revised version was sent for advice), due to concerns over restricting compliance to domestically produced renewable gas, citing EU Directive 2015/1535 (which has curbs on implementing requirements that are not technical specifications).

The new draft allows for sustainability-certified imports to be counted towards the obligation, also acknowledging that domestic production alone is unlikely to meet the demands required for grid decarbonisation.

Nevertheless, the bill remains restrictive – green gas production in the EU, which is injected into the grid, is credited in the country of production. The exception is physical import of green gas (that is, physical separation chain of custody). This restriction has parallels to the German GHG-quota prior to 2023, where international biomethane had to be physically transported to be accounted as a renewable fuel, at least up to the German border, whereupon it could be injected into the national grid. However, the Berlin-Brandenburg Finance Court ruling 1 K 1168/20 ended the GHG-quota import restriction in law.

In any case, the door is left open for imported grid biomethane, provided the Union database (UDB) can reliably be used to assign emissions savings to parties, preventing double counting.

The bill now sits with the Cabinet, before heading to parliament. Practical implementation is slated for 2027.

Other changes

The blending scheme considers lifecycle emissions of the gas, meaning the quality of the biomethane will determine the compliance value – that is, manure biomethane with negative emissions will have greater value per MWh than a standard waste biomethane. Coinciding with this, the overall scheme targets are now stated in terms of CO2 emissions reductions (2.85 Mt savings by 2031), rather than renewable gas volumes, which was initially envisaged in an early public consultation 2023 draft (1.6 bcm green gas production by 2030).

The GGE (Groengaseenheid, or green gas unit) is the tradable certificate used to prove compliance with the Dutch blending obligation and allows biomethane producers to be compensated for emission reductions. A Guarantee of Origin (GO) for 1 MWh of unsupported biomethane production is cancelled for a commensurate amount of GGEs, issued by the NEa (the Dutch Emissions Authority), with each GGE representing 1 kg CO2 equivalent emissions reductions. This requires the GHG intensity of the biomethane, which is listed on the Proof of Sustainability (PoS), although the associated CO2 savings will also be prescribed on the GO. While this process has largely remained unchanged since the 2023 draft, the current draft emphasises the link of the GO with the PoS and also notes that when the UDB is fully operational it will become the only place permitted to transact PoS, which will require an update of GGE procedures.

A target buyout price of EUR 450/tCO2 has been set, slightly down from the EUR 500/tCO2 put forward at the earlier consultation phase in September 2023. The exact level will be determined by an administrative order at a later date although it should be noted that this level is comparable to buyout/penalty levels set in various Member State RED (Renewable Energy Directive) transport schemes which focus on GHG intensity reduction (EUR 600/tCO2 for Germany, and CZK 10/kgCO2 for Czechia – around EUR 400/tCO2). The compensation from the blending scheme for biomethane (which will be strongly influenced by buyout price) is expected to be competitive with transport markets, as well as domestic production support via the SDE++.

The main parties covered under the blending scheme are gas suppliers, and their annual requirement will depend on the reporting of recent delivery volumes, creating additional administrative overhead. However, suppliers already report similar data under ETS 2 requirements. While the ETS 2 start has been delayed to 2028, reporting related to fuel usage commenced in 2025; this ETS 2 reporting will form the basis for determining supplier obligations for the blending scheme, and this is expected to reduce regulatory and implementation burdens.

All in all, the changes should make the blending obligation proposal more palatable, being in closer agreement with EU single market principles and adopting an emissions-based approach. We can expect further changes in the scheme with a European biomethane sector in flux, including the development of competing Member State schemes and practical operation of the UDB.