Complying with the obligations

Companies subject to an annual obligation as well as a reduction obligation are in effect using an HBE twice: once towards the mandatory share of renewable energy and once towards the reduction to be achieved. As such, the amount of HBEs to be achieved is determined by whichever obligation is the highest. The HBE reduction contribution for 2023 is set at 44 kg of CO2-eq./HBE. According to the NEa’s calculations, this is the value at which companies subject to: the annual obligation the reduction obligation having the required number of HBEs to meet their annual obligation for 2023, will automatically meet the reduction obligation for 2023. The HBE reduction contribution for 2024 is set at 49 kg CO2-eq./HBE. According to the NEa’s calculations, this is the value at which companies subject to: the annual obligation the reduction obligation having the required number of HBEs to meet their annual obligation for 2024, will automatically meet the reduction obligation for 2024.

To ensure they have a sufficient amount of HBEs in their account, companies may choose to:

• deliver and register renewable energy in the REV themselves (see Registry); and/or
• purchase some or all their HBEs from other companies.
• Companies can also use a combination of both options.

A company can transfer HBEs to the account of another company as soon as the company has HBEs in its REV account. It is up to the companies to make arrangements between themselves to regulate the trade in HBEs, including the prices. This is done outside of the REV, without any involvement from the NEa.

Based on the deliveries for final consumption, the ‘Indication annual/reduction obligation’ menu item in the REV shows the following throughout the year:

• The required number of HBE-G, HBE-C, HBE-B and HBE-O, and
• Whether the balance is sufficient to comply with the annual obligation and/or the reduction obligation.

On 1 May, a number of automatic transactions are carried out in the REV. First of all, the REV debits the number of HBEs per type according to the highest of the obligations. Then, the REV debits the remaining HBEs, with the exception of the amount that the company is permitted to carry forward to the next year. See Banking limit.

The REV debits the HBEs in a fixed order until the total annual obligation is met:

1. The number of HBE-G required for the subtarget
2. The number of HBE-C up to the limit
3. The number of HBE-B up to the limit
4. The number of HBE-O available
5. The number of HBE-G available
6. If necessary, an additional number of HBE-C, insofar as the limit has not yet been exceeded
7. If necessary, an additional number of HBE-O.

The banking limit is filled in a fixed order. The available HBE-G are used first, followed by the available HBE-O and HBE-B, and finally the available HBE-C.

Understanding the level of the obligations for 2023

The expectation is that, from April 2023 onwards, companies can use the REV to gauge level of the obligations for 2023. They can do this by entering the expected fuel deliveries for 2023 in the REV. Using the fuels entered, the mandatory percentages and limits related to the annual obligation and the HBE reduction contribution, the REV will calculate the number of HBEs required for both the annual obligation and the reduction obligation. This allows companies to see which of the two obligations will require the most effort. Companies can obtain this information under ‘Indication of annual obligation / obligation to reduce emissions’ or ‘Home’ in the REV menu.

Companies that do not have access to the REV yet or wish to know the scope of the obligations sooner can use this document (Dutch) to establish this. They can obtain an indication by filling in the expected fuel deliveries for 2023.