Author Image Posted By : admin 22 Jun, 2025

Renewable Energy Directive (RED III) implementation in Germany

RED III implementation in Germany

The German Federal Ministry for the Environment has submitted a draft bill for the further development of the GHG reduction quota for consultation with associations. The law serves to implement the requirements of the amended Renewable Energy Directive (RED III).

✅ The main changes:

📌 General overview:

  • The mandatory percentage reduction in GHG emissions for fuels will be set until 2040 and will gradually increase to 53%.
  • The GHG reduction quota must be met by all fuel suppliers for all transport sectors.
  • The separate quota for RFNBO in aviation will be replaced by a general quota for all transport sectors.
  • The quota for advanced biofuels will be increased and the double counting will be abolished.
  • Renewable fuels can only be counted if on-site inspections by government inspectors are possible.

💧 The minimum shares of RFNBO for the transport sector is:

  • 0.1 % from 2026,
  • 0.5 % from 2028,
  • 1.5 % from 2030,
  • 2 % from 2032,
  • 3 % from 2034,
  • 5 % from 2035,
  • 7 % from 2037,
  • 9 % from 2039,
  • 12 % from 2040.

📊 For the calculation of the reference value against which the GHG reduction must be achieved, the energetic quantity of the RFNBO multiplied by a factor of:

  • 3 from the commitment year 2024,
  • 2.5 from the commitment year 2035,
  • 2 from the commitment year 2036,
  • 1.5 from the commitment year 2037,
  • 1 from the 2038 commitment year.

The factors shall additionally be multiplied by 1.5 if the respective fuel is used in aircraft or vessels.

✈️ Aviation:

  • Previous PtL Quotas for aircrafts (in paragraph 4a § 37a) are excluded;
  • New PtL Quotas are defined under the ReFuelEU Aviation Regulation;
  • An aviation fuel supplier is defined as anyone who, on a commercial basis or within the framework of commercial enterprises pursuant to the Energy Tax Act, places on the market aviation turbine fuel under subheading 2710 19 21 of the Combined Nomenclature.
  • Penalties for non-compliance with PtL Quotas by aviation fuel suppliers:
    • for SAF – EUR 4,700 per tonne;
    • for e-SAF – EUR 17,000 per tonne.

➡️ Source: Referentenentwurf eines zweiten Gesetzes zur Weiterentwicklung der Treibhausgasminderungs-Quote