Companies that have delivered an amount of renewable liquid biofuel to the Dutch market can register this delivery in their account in the Energy for Transport Registry (Register Energie voor Vervoer, REV). In return, they will receive renewable energy units (HBEs), the quantity and type of which is determined by the type of feedstock used.
The procedure for registering deliveries of liquid biofuels to the transport market is in line with the system and principles used in the Excise Duty Act.
Conditions for registering
Proof is required that deliveries of liquid biofuels registered were delivered to the Dutch market and were also sustainable.
1. Delivery to the Dutch market
Physical delivery of the liquid biofuel must have been to the Dutch market. Liquid biofuel is typically delivered as a bio-component in a mineral oil, such as diesel or petrol. Under the Excise Duty Act, the delivery of such biofuel to the Dutch market qualifies as a taxed delivery that has been released for consumption.
The registering company must demonstrate through its excise duty records that the taxed delivery has been released for consumption. The taxed delivery can be released for consumption by the registering company itself or, in certain cases, by a licensed excise warehouse keeper that receives the delivery from the registering company (see below in the ‘Release for consumption of taxed delivery: fuels and end users’ section). The link to the release for consumption establishes that the taxed delivery is only to be registered at the end of the supply chain, in principle by the final link in the supply chain.
The basic rule can be rendered simply as: the registering company must be able to demonstrate through its own records that the registered taxed delivery has been released for consumption (as a component of mineral oil). This means that the registered biofuel must have been released for consumption by the registering company itself. In certain cases, it is also permitted to register taxed deliveries that are made under suspension of excise duty. In that case, instead of releasing the fuel for consumption and paying the excise duty, the registering company delivers it to another licensed excise warehouse keeper, which is then liable for the excise duty. Whether this is permitted depends on the type of fuel released for consumption as a taxed delivery and the type of end user to which it has been delivered. Furthermore, the type of fuel determines whether additional evidence must be provided. The table below shows for each combination of fuel and end user whether the biofuel to be registered must have been released for consumption by the registering company itself, or whether it is also possible to register a delivery made to another licensed excise warehouse under suspension of excise duty.
Release for consumption
Destination
Fuel
Release for consumption / AGP-AGP
Other highlights
Road vehicles, non-road mobile machinery*, agricultural tractors, forest machinery and pleasure crafts, aggregates and fixed cranes
Biofuel in EN228-petrol, EN590-diesel, and LPG/LNG
Release for consumption
Or
Supply under suspension of excise duty payment in the case of “ABC-transactions”***
Supply under suspension:
Must take place with a tank truck
Release for consumption must be demonstrated when claiming delivery
Road vehicles, non-road mobile machinery*, agricultural tractors, forest machinery and pleasure crafts, aggregates and fixed cranes
Biofuel in “off spec”** petrol and diesel, including EN15940-diesel, and HVO100
Release for consumption
Invoice and receipt necessary to prove delivery at destination
Inland shipping (propulsion and naval stores of inland ships)
Biofuel in “on and off spec” petrol and diesel**, including EN15940-diesel, LPG/LNG
Release for consumption
Or
Supply under suspension of excise duty payment when using a bunker service provider
Supply under suspension:
Must have a bunker declaration (prove of excise duty exemption) of the bunker service provider in administration when claiming delivery
No interconnected transport movements
Maritime shipping (propulsion and naval stores of seagoing ships)
Biofuel in “on and off spec” petrol and diesel, including EN15940-diesel, LPG/LNG, medium and heavy fuel
Release for consumption
Or
Supply under suspension of excise duty payment when using a bunker service provider
Supply under suspension:
Must have a bunker declaration (prove of excise duty exemption) of the bunker service provider in administration when claiming delivery
Only claim delivery when it concerns advanced biofuel
No interconnected transport movements
Aviation
Biofuel in medium oils (kerosene)
Release for consumption
Or
AGP-AGP supply
By truck or direct pipeline to an airport
* In this table, the ‘Non-road mobile machinery’ category does not include inland navigation vessels.
** In this table, references to ‘on/off spec’ for petrol and diesel are understood to mean: compliance or non-compliance with the environmental specifications in Annex I of Directive 98/70/EC and Annex II of Directive 98/70/EC
** Section 1.4 of the Policy Rules on Excise Legislation (Beleidsregels accijnswetgeving) concerning A-B-C transactions between holders of excise warehouse licences for mineral oils relating to pick-up transactions per truck at depots and refinery loading areas).
The types of end users list in Appendix 1 to the Regulations is exhaustive. This means that deliveries of liquid biofuel to other types of end users are not eligible for registration.
In order to prove that it has released a quantity of liquid biofuel for consumption, the registering company must demonstrate that the petrol or diesel met the environmental specifications for petrol or diesel.
Only liquid biofuels that have been physically delivered to the Dutch market may be registered. A registering company must provide proof of the physical delivery of a quantity of biofuel by taking a sample and having it analysed. This is described in detail in Annex 1 (Part B) of the Dutch Energy for Transport Regulations.
Please note! A proof of sustainability (see below) is not a valid way of demonstrating that a delivery contained biofuel. It is proof of the sustainability of a biofuel.
The sampling and analysis relate to the fuel which the registering company has registered and delivered to the Dutch market. The analysis must be based on an accredited method intended for determining the presence of a biofuel and a representative sample. The analysis must be carried out by an ISO-/IEC 17025 laboratory, except where fatty acid methyl esters (FAME), bio-ethanol and ETBE are concerned.
For some biofuels, the registering company will need to obtain more than the customary evidence in order to check the specifications of a fuel. An example is HVO, which is difficult to distinguish from GLT using the usual analysis methods. Instead, this can be achieved with a C14 analysis (carbon dating). Although the use of C14 analysis is not mandatory, it is currently the only available solution that is in line with the frameworks set out in Appendix 1, Part B, of the Regulations.
Sampling and analysis must be carried out:
by the registering company, on the fuel leaving the excise warehouse location and being registered; or
by the registering company’s supplier, on the fuel arriving at the excise warehouse location of the registering company.
In the latter case, the registering company must be able to show, using reliable transfer and storage records for the location, that the biofuel it received from the supplier belongs to the same batch as the biofuel which the registering company delivered to the Dutch market.
This guidance (Dutch) provides further details regarding the sampling and analysis of biofuels.
2. Sustainability of the biofuel
The liquid biofuel to be registered must be sustainable and must be delivered from a physical location for which the registering company manages the mass balance of biofuels. While this location may be a private excise warehouse or the excise warehouse of a third party, it is crucial that the site the registering company uses to make the delivery from has been certified according to an accredited European voluntary scheme. In other words, the certification under the voluntary scheme used by the registering company must relate to the locations from which the delivery of the liquid biofuel is taking place.
In order to demonstrate the sustainability of biofuel delivered, the registering company will prepare a proof of sustainability for the NEa for the amount of the biofuel delivered, which the registering company must retain as part of its records. It is essential that the sustainability characteristics of the biofuel listed on the proof of sustainability match those of the registering in the Registry. Registering companies are not permitted to draw up a proof of sustainability for the fossil component of a fuel.
Once biofuel has been registered, it may not be resold as sustainable biofuel; the sustainability claim lapses when the delivery is registered. Therefore, the sustainability claim can only be redeemed by a single party by using renewable energy units (HBEs). This process is safeguarded by the registering company debiting the registered biofuels from the mass balance and specifying ‘NEa’ as the end user.
If a company cannot demonstrate the sustainability of biofuels, it will not be able to register those biofuels in the Energy for Transport Registry and consequently will not receive any HBEs for those biofuels.
Double-counting
Biofuels produced from specific feedstocks are eligible for double-counting. This means that a delivery of biofuels with a physical energy content of 1 GJ will accrue 2 HBEs.
Companies that want to have a biofuel registered as double-counting in the REV must have a double-counting certificate for this biofuel in their records. This certificate proves that the double-counting has been confirmed by an independent verifier and meets the legal requirements. The verifier must be competent to perform a double-counting verification.
The double-counting certificate and the proof of sustainability used for the registration must relate to the same fuel and feedstocks.
Other multipliers
Deliveries of liquid biofuel to aviation and marine shipping are subject to a specific multiplier. The multiplier for deliveries to aviation is currently set at 1.2, provided these are not deliveries of a conventional biofuel. The multiplier for deliveries to marine shipping is 0.8.
BE amount
=
Volume
(in l15)
x
Caloric value
(standard/variable*)
x
2
(double-counting)
x
0.8 or 1.2
(as maritime shipping / aviation
* For some biofuels, the Renewable Energy Directive does not specify a lower heating value. An example is refined petroleum. Where applicable, the registering company must then arrange for an ISO/IEC17025 accredited lab to establish the lower heating value of the relevant biofuel. In this case, the heated value specified must be representative of the fuel being registered. The registering company must have documentation that proves this. The lower heating value can be entered in the REV by the registering company itself. The document containing the reference data for the Energy for Transport Registry lists the lower heating values of biofuels that do have a default value in the Directive.
Registering liquid biofuels: data to be registered
When registering an amount of liquid biofuel that has been delivered, the registering company must enter the following data in the Registry:
the type of liquid biofuel;
the amount in litres at 15ºC;
the lower heating value (in the case of non-standard biofuels);
the location from which delivery took place;
the date or the period of the delivery;
the type of delivery (released for consumption or delivery under suspension of excise duty);
the voluntary scheme used;
the reference number for the proof of sustainability;
the feedstock(s) and country (or countries) of origin;
the greenhouse gas emissions factor in g CO2 eq/MJ.
indication of the start date of the location producing the biofuel;
In case of double-counting, the registering company will also enter the following information:
the number of the double counting certificate;
the number(s) of the withdrawn certificate(s) (in case of splitting).
