RED III for biofuels: what changed, and the Union Database

RED III is Directive (EU) 2023/2413, which amends the Renewable Energy Directive (EU) 2018/2001. It entered into force on 20 November 2023 and had to be transposed by 21 May 2025. For biofuels, RED III replaces the 14% transport target with a choice between a 29% renewable share and a 14.5% cut in greenhouse gas intensity by 2030, and it moves the Union Database into its own article, with a wider scope, for tracing each consignment.

Operium is not ISCC-certified and has no role in certification or supervision.

What RED III is and when it applies

Directive (EU) 2023/2413 was adopted on 18 October 2023 and published in the Official Journal on 31 October 2023. It amends three acts: the Renewable Energy Directive, the Governance Regulation (EU) 2018/1999 and the Fuel Quality Directive 98/70/EC. The general transposition deadline was 21 May 2025; provisions on permitting had to be in national law by 1 July 2024.

"RED III" is shorthand for Directive 2018/2001 as amended, last consolidated on eur-lex on 16 July 2024.

RED III and RED II compared: the transport targets

	RED II (2018/2001 as adopted)	RED III (as amended by 2023/2413)
EU renewable share, 2030	At least 32%	At least 42.5%, with an effort towards 45%
Transport, 2030	At least 14% renewable share	At least 29% renewable share, or at least 14.5% greenhouse gas intensity reduction
Advanced biofuels and biogas (Annex IX, Part A)	At least 0.2% in 2022, 1% in 2025, 3.5% in 2030	Combined with RFNBOs: at least 1% in 2025 and 5.5% in 2030, of which at least 1 percentage point RFNBOs in 2030
Annex IX, Part B (such as UCO)	Limited to 1.7%; changes need Commission approval	Same limit, in both routes; the Commission may adapt it by delegated act (at least 1.7%)
Annex IX multiplier	May count twice	Counts twice towards the share targets; no multiplier in the greenhouse gas route
Food and feed crops	Up to 1 point above the 2020 share in road and rail, maximum 7%	Same limit, now measured against the whole transport sector

Member States with maritime ports shall also endeavour to reach at least 1.2% RFNBOs in maritime fuel from 2030.

In the greenhouse gas route each biofuel counts as the amount supplied times its greenhouse gas saving, so the declared emission value matters as much as the volume.

Sustainability and greenhouse gas criteria

For transport biofuels the saving thresholds in Article 29(10) did not change: at least 50% for installations in operation on or before 5 October 2015, 60% for those starting between 6 October 2015 and 31 December 2020, and 65% for those starting from 1 January 2021. The 70% threshold for renewable fuels of non-biological origin (RFNBOs), already in RED II for transport, moved to Article 29a and applies to all targets. The 70% for recycled carbon fuels, set in 2023 by Delegated Regulation (EU) 2023/1185 under RED II, is now in Article 29a as well.

Waste and residues other than agricultural, aquaculture, fisheries and forestry residues still only have to meet the greenhouse gas criterion. RED III added that Member States may require operators to sort mixed waste to remove fossil materials. High ILUC-risk biofuels stay capped at 2019 consumption and must decrease to 0% by 31 December 2030 at the latest.

Delegated Directive (EU) 2024/1405 of 14 March 2024 added feedstocks to Annex IX, such as damaged crops unfit for food or feed and intermediate crops.

Fraud prevention and voluntary schemes

As under RED II, Article 30(3) requires the independent audit to check that systems are protected against fraud, including that no material was intentionally modified or discarded to turn it into waste, for imported fuels as well. The geographic origin and feedstock type per fuel supplier must still be published annually, now in an easily accessible form.

Under Article 30(10) a Member State can ask the Commission to examine a source. After a German request in 2023 on biodiesel from China, the Commission reported systemic audit weaknesses in July 2025 but could not confirm fraud. For used cooking oil in practice, see HVO, FAME and UCO inspection.

Under Article 30(4) the Commission recognises voluntary schemes; under Article 30(5) a recognition lasts no more than five years. Member States may not require further evidence on elements a recognised scheme covers, and they supervise the certification bodies. Implementing Regulation (EU) 2022/996 sets the audit and mass balance rules. The Commission's list showed 18 formally recognised voluntary and national schemes in September 2026; how ISCC EU works is set out in ISCC EU and ISCC PLUS. That legal effect separates them from a private scheme such as GMP+ in feed.

The Union Database under RED III

RED II already required a Union database for transport fuels: operators were to enter transactions and sustainability data, including life-cycle emissions, from production to the fuel supplier placing the fuel on the market, and national databases could be linked to it. RED III moved it to Article 31a and changed it:

• the Commission had to set it up by 21 November 2024, for liquid and gaseous renewable fuels and recycled carbon fuels in all end-use sectors;
• data must be entered in a timely manner;
• final approval of transactions happens in the Union Database alone, also where data come in through a national database;
• aggregated data are public, with annual Commission reports on quantities, origin and feedstock (previously every two years);
• a delegated act may extend it upstream to where the raw material is produced or collected.

According to the Commission (consulted September 2026), the UDB was launched in November 2024 and covers about 31,000 individually certified economic operators, but is not used systematically by all. A timeline for full mandatory use is under discussion, and a draft delegated regulation for upstream raw material operators has been tabled.

RED III in the Netherlands

The Netherlands chose the greenhouse gas route: at least 14.5% less greenhouse gas from transport fuels in 2030. The Dutch Emissions Authority (NEa) calls its implementation the fuel transition obligation, in force since 1 January 2026 under sections 9.7 and 9.8 of the Environmental Management Act, the Besluit energie vervoer and the Regeling energie vervoer.

• Units. Emission reduction units (EREs) replaced the old renewable fuel units (HBEs). One ERE is one kilogram of CO2-equivalent saved against the European fossil reference of 94 g CO2-eq/MJ, and HBE balances left after the 1 May 2026 closure are converted at 46 EREs per HBE.
• Sectors. Land, inland shipping and maritime each have their own obligation; ERE types follow the feedstock, and Annex IX Part B biofuel is subject to a limit.
• Calendar. Deliveries are registered before 1 March and enough EREs must be on account before 1 April, for the first time in 2027 for 2026 deliveries. The renewed register opened on 17 August 2026.
• Supervision. Since 2022 the NEa has supervised the whole Dutch biofuel chain, with on-site inspections and sampling.

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