The Netherlands is currently transitioning its energy compliance framework from an energy-based system (HBEs) to a greenhouse gas-based system (EREs), effective January1, 2026. Driven by the EU's Renewable Energy Directive (RED III), this shift introduces a specific mandate for maritime and inland shipping sectors that previously participated only on a voluntary opt-in basis.

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The Economic Calculus of International Shipping

In the world of international shipping, fuel is a commodity defined by money and time. For a massive container ship or a Rhine barge, the decision of where to refuel is dictated by a brutal economic calculus. This reality places the Dutch government in a difficult position: forcing a global industry to go green while competitors across the border continue to offer the status quo. The Netherlands recent decision to scale back its 2026 maritime GHG mandate from 3.6%to 2.9% is a pragmatic admission that climate leadership has its limits. While the mandate signals a bold step toward a zero-emission future, it also highlights a growing gap in the European level playing field. As the Netherlands attempts to pioneer sustainable fuels, it faces the pioneer's penalty the risk that high environmental standards in Rotterdam will lead to bunker tourism in Antwerp and Hamburg.

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Why the Mandate is Unique to the Netherlands?

While RED III is an EU-wide directive, the implementation and subgoals are decided by each member state themselves. As the Netherlands has the largest bunker hub in Europe, Rotterdam, the Netherlands feels a greater responsibility to regulate maritime emissions. By creating a domestic mandate, the Dutch government aims to stimulate a local market for advanced biofuels (Annex IX-A) and RFNBOs (e-fuels, hydrogen). Besides that, Belgium has faced delays in its implementation of the REDIII, creating a temporary regulatory gap. While Germany has a mature GHG quota (THG), it primarily focuses on road transport, leaving international maritime largely untouched for now. The Netherlands is essentially the guinea pig of the REDIII market. To prevent massive bunker tourism (ships fueling in Antwerp or Hamburg to avoid costs), the Dutch Ministry recently scaled back the 2026 targets (e.g. maritime reduced from 3.6% to 2.9%) as a temporary mitigation step until neighboring countries align. If the Dutch mandate stayed too high, fuel prices in Rotterdam would spike, driving ships to bunkering hubs in other countries.

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The Shift from HBE to ERE

The move to a GHG-based mandate fundamentally changes how fuel suppliers operate and how tickets are valued. Under the old system, a Gigajoule (GJ) of energy was thestandard unit, 1 GJ of renewable energy supplied was valued at 1 HBE. Now, the market will reward GHG intensity. Fuels that offer the highest CO2 savings (like HVO) will generate more compliance units (EREs) per litre than fuels with lower savings. The Dutch mandate has a strict stance on feedstocks, Annex IX-B (e.g. Used Cooking Oil). These are restricted or treated as fossil volumes in certain maritime contexts to prevent low-quality compliance, Annex IX-A (Advanced Feedstocks). The mandate heavily incentivizes these,leading to a price premium for advanced fuels. Long-term, this creates a Carbon Hierarchy. Suppliers will stop hunting for the cheapest litres and start hunting for the highest carbonsaving molecules.

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Pricing and Competitiveness

Because fuel suppliers must now include the cost of GHG compliance in their bunker prices, Rotterdam has seen a temporary price increase compared to neighboring ports.

The Premium Gap: Market reports suggest a 10-15% shift in some bunkering demand toward Belgium or Germany where these specific RED III costs haven't fully landed yet.

Cross Sector Flows: Maritime suppliers can source up to 0.9% of their obligation from the road/inland sectors, creating a new flow of tickets between different transport markets.

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Long term outcome

The Rotterdam port as one of the biggest ports in Europe has been a major bunker hub for many years, the focus is on incentivizing infrastructure for green fuels. 2026 will be a difficult year for the Dutch bunker market, with the only European country that implemented a 2.9% maritime mandate, making neighboring countries more attractive for cheaper bunker fuels. In short term the Dutch ports will face challenging times. Shipping is a market of margins and Rotterdam’s green premium will lead to temporary surge in bunker tourism to Antwerp and Hamburg. However, if we look past the 2026 horizon it’s a massive strategic investment for the future. The Dutch ports will eventually gain an advantage. Mainly because of the investments in green infrastructure like Holland Hydrogen1, the CO2 pipeline and ammonia and methanol bunkering terminals. The future of shipping is not just about moving cargo; it’s about managing carbon. By being the first to build a transparent, GHG-based bunkering market, Rotterdam is ensuring its status as Europe's most vital port for another century.