Below we highlight some of the changes since the June 2025 draft bill which was circulated for public consultation. The most significant change for biomethane stakeholders is likely the removal of the maritime sector from the GHG-quota, with other amendments offering added detail compared to the previous draft.
Consequential to biomethane markets is the removal of a GHG-quota obligation for the maritime sector, which was obligated under the previous draft’s amendments. Currently, maritime biomethane is used for FuelEU compliance purposes where, unlike the GHG-quota, production-subsidised volumes are acceptable. Inclusion of the maritime sector in the German GHG-quota would have resulted in additional unsubsidised biomethane demand for shipping.
The aviation sector is also removed from the GHG-quota obligations, including RFNBO quota targets in the current law (Section 37a, Paragraphs 2 and 4a). This offers some relief for previously obligated parties, with very little e-SAF global production capacity established, although this does not exempt the sector from targets in general, in particular ReFuelEU Aviation targets.
The trajectory for emissions reductions from the obligated transport sector has been revised upwards from the earlier draft, and the 2040 emission reduction target is now 59% compared to 53% previously.
This may be as a result of the exclusion of aviation and maritime transport, which have proven more difficult to decarbonise than the road-transport; without these lagging sectors there may have been pressure to set more ambitious targets. An increase in ambition in law should also encourage further investment in production capacity.
At the same time, the RFNBO quota target is also reduced – while the starting value remains unchanged (0.1% in 2026), it now ramps more slowly to 8% in 2040 (previously 12% in 2040).
Double counting (which allowed a MJ of advance biofuels to count for twice the actual emissions reductions) remains eliminated as in previous draft, although GHG-quota market value appears to have rallied in response over the last quarter, with increases in manure biomethane prices also finding support.
Under the Section 37b Paragraph 8 amendments, soy feedstock fuels are no longer explicitly excluded from the program, although the exclusion of palm oil remains. This suggests a more practical approach is being taken; recent trends as per BLE GHG-quota evaluation report 2024, suggests palm oil fuel claims are essentially non-existent, while soy fuels claims are dwindling but still significant (1.6 TJ in 2024, biomethane claims by comparison amounted to 6.2 TJ).
The new draft does not appear to materially change the status of the Union Database (UDB). However, there are additional explicit references to it, including in fee tables as part of the justification, as well as failure to enter the required data into the UDB being recognised in Section 62 as an administrative offense.
A further change in the draft is regarding exemptions from certain parties for GHG-quota obligations under Section 37a. The previous draft had sought to remove current exemptions for specific users, mainly those associated with security and emergency services. The prior removal was justified on the basis that there was no need to physically blend fuels, thus no major logistical hurdles are added via their inclusion. However, the current draft keeps these exemptions in, and even expands upon them, under the guise of security-of-supply. In any case, the fuel volumes involved with these public sectors are relatively low compared to the whole market and are unlikely to lead to large market changes.
Specialising in data, analysis, and insights for all significant low-carbon markets and renewable energy.
