The European transport sector is facing unprecedented pressure to rapidly decarbonize under the European Union's revised Renewable Energy Directive (RED III). While various member states are updating their national frameworks, the Netherlands is executing one of the most significant regulatory overhauls in its history.

Starting in 2026, the Dutch government is completely phasing out its volume-based biofuel compliance system in favor of a strict, carbon-based methodology. For electric vehicle (EV) charging operators, biomethane suppliers, and obligated fuel companies, this transition from Hernieuwbare Brandstofeenheden (HBEs – Renewable Fuel Units) to Emissiereductie-eenheden (EREs – Emission Reduction Units) fundamentally alters how renewable energy is valued and monetized.

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The Legacy System: Why HBEs are Phasing Out

Until the end of 2025, the Dutch transport decarbonization market operated under the HBE framework. Under this system, companies that delivered renewable energy directly to the transport sector—such as grid-connected EV charging stations or biofuel blenders—could generate tradable HBE certificates.

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The math behind the old system was simple:

• 1 HBE was issued for every 1 gigajoule (GJ) of renewable energy physically delivered to the transport sector.

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While this successfully stimulated initial volumes of renewable fuels, it had a major environmental flaw: it rewarded raw energy quantity rather than actual carbon displacement. Under the HBE system, a gigajoule of a moderately clean biofuel generated the exact same compliance credit as a gigajoule of an ultra-low-carbon fuel derived from circular waste.

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The 2026 Paradigm Shift: Enter the ERE

In 2026, the Netherlands will align with the carbon-centric goals of RED III by introducing the ERE system. This marks a definitive shift from counting energy volumes (GJ) to calculating actual greenhouse gas (GHG) emission reductions, which are expressed directly in carbon dioxide equivalents (CO2-eq).

Under the ERE model, the financial reward is directly linked to how much carbon a renewable energy carrier keeps out of the atmosphere.

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Under the incoming rules, the higher the value of the calculation, the greater the number of EREs generated per unit of energy supplied. This carbon-focused valuation instantly reshapes the commercial landscape:

1. Premium for Waste and Manure Feedstocks: Very-low-carbon fuels, such as Bio-LNG and Bio-CNG produced from certified animal manure and organic waste, will see their compliance value skyrocket. Because their upstream emissions are counted as zero, they deliver massive carbon savings compared to fossil diesel, making them highly sought after by obligated fuel suppliers.

2. Incentive for Smart EV Charging: Electricity supplied through registered charging connections will be valued strictly on the carbon displacement of the power grid, giving a strong competitive edge to public and private charging operators who can prove their electricity is backed by high-quality renewable certificates.

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Who is Eligible to Generate EREs?

The criteria for generating EREs remain highly specific and legally technical. Only the registered connection owner who directly supplies renewable energy to the Dutch transport grid is eligible to claim and generate these certificates. This includes:

• Owners of public and private EV charging stations with a registered Dutch grid connection.

• Operators of grid-injection systems delivering biomethane or Bio-LNG to transport fleets.

Because the market is highly dependent on precise metering, registry compliance, and audited land histories, mistake-free administrative execution is mandatory to unlock this revenue stream.

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Mitigating Risk and Maximizing Returns with AFS Energy

Transitioning from a volume-based HBE model to a complex, carbon-audited ERE model requires deep regulatory insight and direct market access. Navigating the registration, carbon-saving calculations, and subsequent trading of these highly specialized compliance units can be an administrative headache for businesses.

AFS Energy acts as a trusted, full-cycle compliance partner. Our experienced team handles the entire process on your behalf—from verifying your grid connection eligibility and reporting your data to monetization through our extensive European buyer network. Whether you are an EV charging network operator looking to optimize your returns or an obligated fuel supplier seeking to secure your 2026 carbon compliance targets, we provide the expertise and digital tools to ensure a seamless transition.

To explore how your business can generate, trade, and monetize ERE certificates under the new Dutch transport framework, visit our clean transport page and speak with an advisor today.