HVO and biodiesel: which EREs apply?

HVO and FAME

HVO is hydrotreated oil from biomass. Conventional FAME biodiesel consists of fatty acid methyl esters. Both can replace fossil diesel or be blended with it. For EREs, the supplier must demonstrate the biogenic share actually supplied.

The name HVO100 describes the HVO content. It does not establish an ERE type or a guaranteed emissions reduction.

The REV feedstock classification distinguishes, for example:

• Used cooking oil and category 1 or 2 animal fats: ERE-B.
• Eligible feedstocks on the advanced list: potentially ERE-G.
• Food and feed crops: ERE-C, where the feedstock is permitted.
• Category 3 animal fat: ERE-O, with a factor of 0.5.

Which supplier can book the supply?

Liquid biofuels are normally booked by a supplier holding an excise warehouse permit, called an AGP permit in the Netherlands. Certain registered consignees and importers can also qualify. Buying HVO for a vehicle does not give the customer a separate right to book it.

The booking party must substantiate the supply under the excise rules. It also needs certification under a recognised European sustainability scheme and a mass balance for the final storage location. This records the quantities of sustainable fuel entering and leaving the site.

A proof of sustainability, or PoS, supports the feedstock origin and lifecycle emissions. It does not by itself demonstrate physical supply. Delivery records and evidence of the biogenic share are also needed. The NEa sets out these separate requirements.

How many EREs are generated?

The REV uses the biofuel quantity, its energy content and the difference between the fossil reference of 94 grams CO₂-equivalent per MJ and the lifecycle emissions on the PoS. For the same quantity, lower lifecycle emissions generate more EREs. Any feedstock factors also apply.

The fuel must first meet the minimum emissions saving. For biofuels produced in installations that began operating from 1 January 2021, this is at least 65%. Different thresholds apply to older installations. A general sales claim about CO₂ savings does not replace the PoS.

Road transport, inland shipping or maritime shipping

The destination determines whether LREs, BREs or ZREs can be generated. Conventional biofuels are excluded from inland shipping. Maritime shipping permits only G and O: HVO from used cooking oil is category B and does not generate EREs there.

Request the exact feedstock and PoS before delivery. Agree which party books the supply. For a seagoing vessel, also document how any FuelEU Maritime and ETS claims will be supported; separate evidence rules apply.