PHB: Mass balance methodology for renewable fuels in transport / Massabalansmethodiek voor hernieuwbare brandstoffen in transport | 2025

Background

Since renewable fuels are used in the current fuel infrastructure, storage and engines, they will inevitably be mixed with fossil fuels at a certain time. 100% pure renewable fuel deliveries, segregated from the fossil fuel system, are technically possible but currently rare as they bring substantial additional logistics and costs. Moreover, segregated supply chains for renewable fuel deliveries lead to additional emissions at various steps in the supply chain (for instance due to additional truck transport), which goes against the intention of the Renewable Energy Directive. The regulator prescribes a set of rules on how to keep track of the sustainability characteristics of renewable fuels on basis of mass balance, but not explicitly on how to keep track of the volumes of these renewable fuels. To ensure the physical delivery of volumes to the transport markets, the Netherlands requires physical evidence at the point of delivery by means of lab testing and analysis (e.g. a ₁₄C-test) to confirm the physical green volume that is reported.

The Platform conducted a market study on mass balancing rules for the delivery of renewable fuels via interconnected infrastructures in the Netherlands and other Member States. The aim of the research was to better understand the application of the mass balance system in interconnected infrastructure, collect market experiences on the delivery of renewable fuels (such as biomethane and SAF) via pipeline or gas grid, and identify possible solutions to facilitate the use of existing interconnected infrastructures for the delivery of renewable fuels.

The study highlights the necessity of implementing a system of administrative transfer of information that keeps track of both sustainability characteristics and the renewable volumes through interconnected networks. Since the application of mass balance rules differs in other Member States, a unified EU-wide approach will be required to facilitate trade and avoid market distortions. In the meantime, a workable solution addressing the barriers that renewable fuel suppliers face in the Netherlands should be sought ultimately facilitating the upscale of renewable fuels in the system and accelerating the energy transition. Facilitating flexibility and maintaining integrity of the new supply chains is essential as more renewable fuels become available in the market and become increasingly difficult to track.

Takeaways

• This market study of Platform Renewable Fuels recommends improving text of the European legislation (RED) to explicitly allow for the administrative transfer of both information on the sustainability as well as the renewability of fuel volumes, by making use of mass balance principles. Market players already possess information about the sustainable volumes and information about the fuels delivered but report it to separate government bodies. The renewable fuel supply-chain will benefit from increased transparency if the application of the mass balancing rules accounts for the information that provides an administrative proof of the volumes, such as is the practice with a Guarantee of Origin (like for electricity), which is then coupled to a Proof of Sustainability (PoS) that confirms the sustainability.
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• The Platform Renewable Fuels recognises that market operators are following the prescriptions set out by the Voluntary Certification Schemes. These schemes, which are accepted by the European Commission, allow for the use of the mass balance system to confirm not only the sustainability, but also the renewability of a fuel volume. The Platform Renewable Fuels believes that if there is confidence in the integrity of the voluntary schemes, the requirementfor evidence of physical delivery at the point of delivery is superfluous.
  
• Platform Renewable Fuels recommends harmonisation of the use of the mass balanceprinciples for all energy carriers, electrons, gas and, liquid fuels. This will enable the many interactions that take place in the conversion of power-to-X,but also the use of biomethane as feedstock converted into methanol. The Platform also would like to underline that a physical test cannot be used to confirm the renewable character of a RFNBO. (The difference between a fossil-based hydrogen and renewable hydrogen cannot be distinguished in a lab-test).
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• The Netherlands Emission Authority is already combining Guarantees of Origin and the PoS to enable the market to apply the mass balance on the gas grid, in order to connect production and demand of biomethane. The Platform considers this a good practice for a European wide approach for the interconnected gas-and kerosine pipelines.
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• The Platform agrees with the points put forward by RVO that clarity should be provided for cross border trade to count consumption for statistical reporting on climate reduction, in order to avoid double counting.

Download

Read the full report (in Dutch) by downloading it on the right hand side or by clicking here.

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