The feedstock for a sustainable biofuel is a significant factor in determining the HBEs credited for a registering.
The type of feedstock determines whether the HBE credited is HBE Advanced, HBE Annex IX Part B, HBE Conventional or HBE Other. The feedstock also determines whether the biofuel is eligible for double-counting.
Importance of Annex IX of the Renewable Energy Directive
Annex IX of the Renewable Energy Directive plays a key role in the crediting of HBEs:
Part A of Annex lists feedstocks for biofuels, predominantly waste materials and residues, for which registering will result in HBEs Advanced.
Annex IX, Part B list feedstocks (such as used cooking oil and animal fats) which, when used to produce biofuel, results in the crediting of HBEs Annex IX-B.
Feedstocks listed in Annex IX (both Part A and Part B) are eligible for double counting. This means that registered deliveries of biofuel produced from listed feedstocks result in twice the number of HBEs being credited. This is an additional stimulus for delivering and registering biofuel produced from waste and residue flows.
Biofuels from feedstocks other than those mentioned in this appendix are single-counting by definition. In that case, a registration can result in the crediting of HBE Other or HBE Conventional, depending on whether or not it is a (by-)product of a crop.
Annex IX, Part A, of the Directive contains a description of the biomass fraction of industrial waste under section d). This is a broad category of feedstock. Further clarification of what this means is given at national level. This has been done in a schedule of feedstocks in Annex 5 of the Energy for Transport Regulations. Only feedstocks included in this national schedule are considered to be biomass fractions of industrial waste in the Netherlands. This schedule includes feedstocks which the Ministry of Infrastructure and Water Management has determined to be waste. Additions will be made to this list where necessary.
Companies can submit a request by providing information about the feedstock to the NEa. Please contact the NEa Helpdesk about this. The NEa assesses these requests together with other bodies, including the Netherlands Enterprise Agency, and issues an opinion on inclusion in the Regulations to the Ministry of Infrastructure and the Environment. The Ministry will then make the final decision on this.
Below is a general summary of feedstock types and the type and number of HBEs that will be credited for registration of biofuel produced from the relevant feedstock. It should go without saying that registration will only result in HBEs being credited if proof of sustainability is provided, using a document with information matching the double counting certificate.
Feedstocks and double-counting
Feedstock
HBE type
Double-counting possible?
Annex IX, part A
Advanced
Yes
Annex 5 of Regulation
Advanced
Yes
Annex IX, part B
Annex IXb
Yes
Crops or (by-)products of crops
Conventional
No
Palm or soy*
None
No
Other feedstocks
Other
No
* Certified low ILUC biofuel produced from soy or palm oil is eligible for HBE Conventional. However, the Climate Agreement states these feedstocks will not be used in the Netherlands.
An overview of all individual feedstocks currently included in the Energy for Transport Registry can be found under Energy for Transport Registry. This overview only lists feedstocks that currently appear in the REV and the associated credits. It is not an exhaustive list of all possible feedstocks. If a feedstock does not appear in the overview, it is not in use yet.
With regard to deliveries of gaseous biofuels, greened using Vertogas certificates, this overview outlines the type of HBE and eligibility for double-counting for each feedstock used according to the Vertogas system.
Conditions for double-counting
Companies that want to register a biofuel as double-counting in the REV, must have a double-counting certificate for this biofuel. This certificate proves the double-counting was confirmed by a verifier and meets the legal requirements. The verifier must be authorised to perform a double-counting verification.
The double-counting certificate and the Proof of Sustainability must clearly refer to the same fuel and feedstock.
Registering a biofuel as double counting in the REV requires proof in the form of a double-counting certificate. This certificate is to be issued by an accredited double-counting verifier that meets the statutory requirements.
Double-counting verifiers must perform their verification activities in a detached and impartial manner. In addition, double-counting verifiers must be accredited for the double-counting component of the renewable energy for transport scope by the Dutch Accreditation Council (RvA: Nederlandse Raad voor Accreditatie) or a national accreditation body in another Member State of the European Union (EU).
Double-counting verifiers may also perform audits if they have demonstrably commenced an accreditation procedure but have not yet completed it. The following institutions are currently accredited to perform double-counting verifications:
Control Union Certifications B.V.
DEKRA Certification B.V.
Quality Services Inspection B.V.
Information regarding the accreditation process is available from the Accreditation Council (RvA: Raad voor Accreditatie).
The requirements for double-counting verifications have been set out in Annex 7 of the Energy for Transport Regulations. Verifiers must perform their activities in accordance with the verification protocol that they have drawn up and which has been approved by the NEa.
Verifiers can no longer issue double-counting certificates if a company has had its sustainability certificate withdrawn. This withdrawal is reason to assume that the records prior to the withdrawal are not a true reflection of the actual situation. In these cases, the approved verification protocol used by the verifier in respect of double-counting and the standard auditing procedures set out in this protocol are no longer adequate to obtain a reasonable degree of certainty that the biofuel accounted for in the double-counting certificate is free from material misstatements. This means that the double-counting verifier cannot meet the legal requirements. Consequently, no double-counting certificate can be issued for the biofuels marketed by the company.
The Dutch legislation and regulations stipulate that previously issued proofs of sustainability remain valid. Double-counting certificates that were issued unjustifiably can be withdrawn by a verifier. If a withdrawn double-counting certificate was already used in registering deliveries, the HBEs credited will also be affected.
A double-counting certificate serves a proof of double-counting for the registering company. The certificate confirms that a registered quantity of biofuel meets the double-counting criteria set by the legislation and regulations.
Verifiers issue a double-counting certificate to the producer of the double-counting biofuel provided that the requirements have been met. Annex 7 of the Energy for Transport Regulations provides details on the requirements applicable to the preparation and contents of the certificate.
Via the biofuel producer, the certificate will ultimately find its way to the company that wants to register biofuel as double-counting in the REV. When registering a biofuel delivery, registering companies can only use the double-counting certificate if the characteristics on the sustainability certificate match those on the double-counting certificate.
Numbering and splitting of certificates
Each double-counting certificate has a unique number starting with the identifier code of the verification body. The registering company must specify the number of the double-counting certificate when registering deliveries as double-counting in the REV.
Quantities of double-counting biofuel are sometimes split and resold to multiple buyers. In such cases, the double-counting verifier will withdraw the original double-counting certificate and issue new double-counting certificates to each party, which will state the leading number of the withdrawn certificates. Both the new number and the leading number must be specified when registering a delivery.
Verifiers are responsible for managing the unique numbers for the certificates they issue. Incorrect management or entry of any reference or leading numbers by a verifier or company may result in error messages in the REV.
Proof of sustainability as the basic principle
Companies must specify the feedstock from which the biofuel has been produced when submitting their registration. They must base this on the feedstock as stated in the Proof of Sustainability or the Guarantee of Origin (GO), i.e. a Vertogas certificate.
The Energy for Transport Registry (REV) contains a list of feedstocks used in voluntary schemes (ISCC EU in particular). If the template for the Proof of Sustainability does not include a specific feedstock for a registering, companies can contact their voluntary scheme or the NEa.
