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Germany’s national Power-to-Liquid quotas

As part of my research, I closely follow recent developments regarding Germany’s national Power-to-Liquid (PtL) quotas for aviation and would like to share the key updates with you.

🔹 What do PtL quotas mean?

Power-to-Liquids (PtL) refers to liquid hydrocarbons produced using electricity, water, and CO₂ as inputs. Based on these characteristics, PtL quotas cover targets and obligations for hydrogen-based fuels, such as e-SAF for aviation.

🔹 What happened in Germany?

In September 2021, Germany adopted ambitious PtL quotas for aviation through amendments to the Federal Immission Control Act (BImSchG).
These mandatory national quotas required a minimum share of RFNBOs in aviation fuel of:
- 0.5% in 2026
- 1% in 2028
- 2% in 2030.
The basis for adopting such ambitious quotas was the German PtL roadmap for aviation fuels, published in April 2021.
However, these national PtL quotas were more ambitious than those established under the ReFuelEU Aviation Regulation, which introduces a minimum PtL sub-quota only from 2030 onwards.
As a result, the European Commission opposed the German national quotas, emphasizing the binding nature of ReFuelEU Aviation as an EU regulation that replaces national PtL quotas for aviation.

🔹 How was this PtL quota issue resolved?

In October 2024, the German Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV) announced revisions to the national PtL quotas for aviation.
In June 2025, BMUV published the Draft Law for a Second Law on the Further Development of the GHG Reduction Quota (the Draft Law on the GHG Reduction Quota), proposing the removal of national PtL quotas for aviation from the BImSchG.
In December 2025, the national PtL quotas for aviation were formally abolished through the Draft Law on Accelerating the Expansion of Geothermal Energy Plants, Heat Pumps and Heat Storage Facilities, and on Amending Other Legal Framework Conditions for the Climate-Neutral Expansion of Heat Supply.

➡️ The German PtL quota will expire on January 1, 2026.

✅ What’s next?

The PtL quotas for aviation are included in the Draft Law on the GHG Reduction Quota and will be based on the minimum share of e-SAF set out in the ReFuelEU Aviation Regulation.

If you have any questions about PtL quotas, I’d be happy to discuss them.

🔗 The Draft Law: Gesetz zur Beschleunigung des Ausbaus von Geothermieanlagen, Wärmepumpen und Wärmespeichern und zur Änderung weiterer rechtlicher Rahmenbedingungen für den klimaneutralen Ausbau der Wärmeversorgung sowie zur Änderung des Baugesetzbuchs und zur Änderung des BundesImmissionsschutzgesetzes

🔗 Source: Bundesrat beschließt Abschaffung der nationalen PtL-Quote

Posted By : admin 12 Dec, 2025

Updates about RED III and ReFuelEU Aviation in Germany

Updates about Transposition of RED III and ReFuelEU Aviation in Germany

On 10 December, the German Federal Cabinet approved the draft of a Second Law on the Further Development of the Greenhouse Gas Reduction Quota.

This quota, as the central legal instrument for reducing greenhouse gas (GHG) emissions from fuels, shall gradually make refueling more climate-friendly. It specifies the extent to which fuel suppliers must reduce CO2 emissions by using sustainable biofuels, renewable hydrogen-based fuels, or electricity for electric vehicles.

➡️ The Draft of Law is available via this link: Entwurf eines Zweiten Gesetzes zur Weiterentwicklung der Treibhausgasminderungs-Quote

✅ Key Points of the Draft Law:

📌 The draft law implements the amendments to the Renewable Energy Directive (RED III), whose targets must be achieved by 2030. To provide greater investment security, the German government extends the timeline to 2040, going beyond the RED III, to support long-term corporate investment planning.

📌 The law serves to implement the ReFuelEU Aviation Regulation at the national level with regard to fuels.

📌 The draft law includes amendments to the Federal Immission Control Act (BImSchG) and the Regulation on the crediting of electricity-based fuels and co-processed biogenic oils towards the greenhouse gas quota (37th BImSchV).

📌 It introduces definitions of aviation fuel suppliers and distributors, as well as penalties for aviation fuel suppliers that fail to comply with their obligations under the ReFuelEU Aviation Regulation with regard to the share of sustainable aviation fuel (SAF):

EUR 4,700 per tonne for SAF
EUR 17,000 per tonne for synthetic aviation fuels or e-SAF.

📌 It defines the eligibility criteria for e-SAF and renewable hydrogen for aviation.

📌 It establishes minimum shares of RFNBOs for fuel suppliers (excluding aviation fuel suppliers):

0.1% from 2026
0.5% from 2028
1.2% from 2030
1.5% from 2032
2.5% from 2034
4.0% from 2036
5.0% from 2037
6.0% from 2038
7.0% from 2039
8.0% from 2040

☑️ Next Steps:

The law will enter into force on the second day after its publication in the Federal Law Gazette.
The Draft Law must now be submitted to the Federal Council (Bundesrat) and the German Bundestag for debate. Approval by the Federal Council is not required. However, the Bundestag may still introduce amendments.
After adoption by the Bundestag, the law can be submitted to the Federal President for signature and then published.
The legislative process is expected to be completed in the first quarter of 2026.

🔗 Source: Klimafreundlicher tanken, neue Nachfrage für grünen Wasserstoff: Bundesregierung beschließt Gesetzesnovelle zur Treibhausgasminderungs-Quote

Posted By : admin 16 Nov, 2025

Green Hydrogen & RFNBO Criteria

Institute of Energy Economics at the University of Cologne gGmbH (EWI). Green hydrogen production under RFNBO criteria ‐ Analyzing the system and business case perspective.

Today I took a closer look at a new EWI study: “Green hydrogen production under RFNBO criteria – Analyzing the system and business case perspective” (2025).

✅ Key Takeaways:

This analysis examines the impact of the RFNBO criteria on green hydrogen production from system and business perspectives, with particular attention to how the criteria affect costs, capacity expansion, and the need for system flexibility.

📌 From a system perspective:

Implementing all RFNBO criteria increases electrolysis capacity by over 3% across Europe to meet predefined demand, while average full-load hours decline by around 200 hours.
Applying all RFNBO criteria with hourly matching increases average hydrogen supply costs by around 10 EUR/MWh (+8%) across Europe, driven primarily by additionality requirements and the shift from daily to hourly matching.
In Germany, expected to be the largest hydrogen offtaker in Europe, the impact on marginal hydrogen costs is higher than the EU average (+16%).
These effects highlight distributional impacts between sectors: while marginal electricity costs decline due to surplus renewables entering the market, additional system costs remain within the hydrogen sector. This implies a cost shift from electricity consumers to hydrogen producers.
Average EU electricity costs fall by around 5%, and marginal CO₂ certificate costs by around 2%.
Applying all RFNBO criteria adds over 25 GWel of additional RES capacity across Europe. In Germany, total installed RES capacity increases by 17%.
Adding RFNBO criteria reallocates capacities from the electricity market to hydrogen production.
With stricter temporal correlation requirements, hydrogen production increasingly relies on RES with high full-load hours (onshore and offshore wind), leaving more volatile solar generation to the electricity market.

📌 From a business perspective:

Tighter matching requirements push portfolios toward dedicated renewables and short-term flexibility.
Under Hourly Matching and a baseload supply profile, PV is often combined with large batteries; adding hydrogen storage can shift flexibility from the electricity sector to the hydrogen sector.
Results show that LCOH are more sensitive to constraints from the business perspective: in the baseline, they rise from around 150 EUR/MWh (No Criteria) to almost 180 EUR/MWh (Hourly Matching), an increase of +19%, with the largest jump occurring between Daily and Hourly Matching.
Sensitivity analyses reveal a much stronger impact than in the system perspective, especially under Hourly Matching, where LCOH range from about 170 EUR/MWh up to 370 EUR/MWh.
The difference between Monthly and Hourly Matching spans from roughly 15 EUR/MWh to over 90 EUR/MWh.

➡️ Source: EWI (2025). Green hydrogen production under RFNBO criteria ‐ Analyzing the system and business case perspective.

Posted By : admin 13 Nov, 2025

Hydrogen Mechanism

🔹 New milestone for the EU hydrogen market! 🔹

On 12 November, the European Commission launched the first call for interest under the Hydrogen Mechanism, which is a key step to connect potential suppliers and buyers of renewable and low-carbon hydrogen and its derivatives across the EU.

🔗 Official announcement

🔗 Hydrogen Mechanism platform

💡 What is the Hydrogen Mechanism?

An online platform that supports market development for renewable and low-carbon hydrogen and its derivatives, such as ammonia, methanol, and electro-sustainable aviation fuel (eSAF).

📅 Key timeline:

12 Nov 2025 – 2 Jan 2026: Submission phase: Suppliers are invited to submit supply offers.
19 Jan 2026: Publication of anonymised supply offers.
19 Jan – 20 Mar 2026: Off-takers express their interest.
31 Mar 2026: Results available to participants.

➡️ Why it matters:

Connects future demand and supply, reducing market uncertainty;
Increases transparency and visibility of potential partners;
Facilitates hydrogen infrastructure and financing access;
Encourages market engagement and new business opportunities.

The Hydrogen Mechanism is another important step toward building a hydrogen market.

The Hydrogen Mechanism under the EU Energy and Raw Materials Platform. Update

Submission phase: Opening 12 November 2025 until 2 January 2026. Suppliers are invited to submit supply offers.
Publication of call for interest: 19 January 2026. Publication of anonymised information sheets about the supply offers.
Expression of interest: Opening 19 January 2026 until 20 March 2026. Off-takers are invited to express their interest.
Results: 31 March 2026. Results are available to participants of the call.

Posted By : admin 12 Nov, 2025

World Energy Outlook 2025

☑️ The World Energy Outlook 2025 (WEO-2025) of International Energy Agency considers the following scenarios:

📌 Current Policies Scenario (CPS): A snapshot of policies and regulations that are already in place.

📌 Stated Policies Scenario (STEPS): Encompasses a broader range of policies, including those that have been formally proposed but not yet adopted, as well as other official strategy documents that indicate the intended direction of policy.

📌 Net Zero Emissions by 2050 Scenario (NZE Scenario): Describes a pathway to reduce global energy-related CO₂ emissions to net zero by 2050, while recognising that each country will follow its own route.

☑️ Key Takeaways

📌 Electricity

Electricity demand grows much faster than overall energy use in all scenarios: it rises by around 40% to 2035 in both the CPS and the STEPS, and by more than 50% in the NZE Scenario.
Electricity currently accounts for only 21% of total final energy consumption globally, yet it is the key energy source for sectors representing over 40% of the global economy, and the main energy source for most households.
A pivotal issue for electricity security is the pace at which new grids, storage facilities, and other sources of power system flexibility are developed.
Investments in electricity generation have surged by almost 70% since 2015, reaching USD 1 trillion per year, while annual grid spending has increased at less than half that pace to around USD 400 billion.
The explosive growth in electricity demand for data centres and AI is concentrated in advanced economies and China. Investment in data centres is expected to reach USD 580 billion in 2025. A tripling of electricity consumption by data centres by 2035 will represent less than 10% of total global electricity demand growth, but it will be highly concentrated geographically. More than 85% of new data centre capacity additions over the next ten years are expected in the United States, China, and the European Union.

📌 Renewables

Renewables grow faster than any other major energy source in all scenarios, led by solar photovoltaics.

📌 Nuclear Power

Another common element across scenarios is the revival of nuclear energy, with investment rising in both traditional large-scale plants and new designs, including small modular reactors (SMRs).
More than 40 countries now include nuclear energy in their strategies and are taking steps to develop new projects.

➡️ Source: International Energy Agency. World Energy Outlook 2025

Posted By : admin 5 Nov, 2025

Sustainable Transport Investment Plan

✈️ 🚢 EU launches the Sustainable Transport Investment Plan (STIP), accelerating renewable and low-carbon fuels for aviation and maritime transport

On 5 November 2025, the European Commission has unveiled its Sustainable Transport Investment Plan (STIP), a strategic roadmap to scale up investments in renewable and low-carbon fuels for the aviation and waterborne transport sectors.

This initiative marks a crucial step in delivering the ReFuelEU Aviation and FuelEU Maritime goals and strengthening Europe’s industrial leadership in sustainable fuels.

✅ Key highlights:

📌 Around 20 million tonnes of sustainable alternative fuels (13.2 Mt biofuels and 6.8 Mt e-fuels) will be needed by 2035.

📌 Estimated €100 billion investment is required to meet these targets.

📌 The EU aims to mobilise €2.9 billion by 2027, including:

€2 billion via InvestEU for sustainable fuel projects.
€300 million through the European Hydrogen Bank for SAF and SMF hydrogen production.
€133 million for R&I projects under Horizon Europe.
€446 million from the Innovation Fund for synthetic aviation and maritime fuel projects.
Launch of an eSAF Early Movers Coalition to mobilise €500 million for synthetic aviation fuel projects.

☑️ The STIP builds on three pillars:

📌 Strategic framework – identifying investment gaps and needs.

📌 Financing action – unlocking and de-risking private investments.

📌 External dimension – fostering global cooperation and fair competition for EU fuel producers.

By creating regulatory stability and new financing tools, STIP aims to make Europe a frontrunner in sustainable transport fuels, driving innovation, industrial leadership, and climate neutrality by 2050.

➡️ Source: Commission unveils the Sustainable Transport Investment Plan: a strategic approach to boost renewable and low-carbon fuels for aviation and waterborne transport

Posted By : admin 29 Oct, 2025

Federal Court of Auditors report

📢 Germany Must Revise Its Hydrogen Strategy under the Federal Court of Auditors (Bundesrechnungshof) Report

✅ Main Findings:

📌 The German government considers hydrogen a key pillar of the energy transition, aiming for Germany to become climate-neutral by 2045.

📌 The federal government has already allocated more than €7 billion in funding, mainly as subsidies, for 2024 and 2025. Despite this significant financial commitment, the objectives of the national hydrogen strategy have not yet been achieved.

📌 The Federal Court of Auditors found that both supply and demand for green hydrogen in Germany have not developed as planned. A sufficient hydrogen supply is intended to come from domestic production and at least half from imports. However, the German government will not meet its domestic production targets for green hydrogen by 2030, nor will anticipated import volumes cover the expected demand.

📌 Green hydrogen remains significantly more expensive than fossil fuels such as natural gas. Since competitive production or import prices are not foreseeable in the near future, long-term government subsidies are likely to remain necessary. To bridge the price gap between hydrogen and natural gas, import costs alone could place a burden of €3 to €25 billion on the federal budget by 2030.

☑️ Reality Check

The Federal Court of Auditors recommends that the Federal Government:

review the hydrogen strategy and its current implementation, reassessing whether and when green hydrogen can be made available in sufficient quantities, at competitive prices;
evaluate, as part of this review, the actual contribution the hydrogen economy can make to the energy transition as a whole;
revise the hydrogen strategy to ensure that supply, demand, and infrastructure are developed as synchronously and cost-effectively as possible; and
develop a “Plan B”, if necessary, to achieve climate neutrality by 2045, even without a permanently subsidised hydrogen economy.

➡️ Source: Bundesrechnungshof: Umsetzung der Wasserstoffstrategie stockt: Erhebliche Risiken für Energiewende, Industriestandort und Bundesfinanzen

Posted By : admin 22 Oct, 2025

Commission Work Programme for 2026

📢 The European Commission has just published its Work Programme for 2026, outlining key legislative and policy initiatives.

The main highlights for the Energy and Climate sectors:

🔹 Electrification Action Plan, including heating and cooling (non-legislative, Q1 2026)

🔹 Strengthening Energy Security (legislative, Article 194 TFEU, Q1 2026)

🔹 Update of the Governance of the Energy Union and Climate Action, including the phase-out of fossil fuel subsidies (legislative, Articles 192 & 194 TFEU, Q4 2026)

🔹Energy Union Package for the Decade Ahead

Development of CO₂ transportation infrastructure and markets (Q3 2026)
Establishment of the energy efficiency framework (Q3 2026)
Establishment of the renewable energy framework (Q3 2026)

🔹Omnibus to simplify energy product legislation (Q2 2026)

🔹 Climate Package for the Decade Ahead

Revision of national targets and flexibilities in the EU climate policy framework (Q4 2026)
Update of the EU Emissions Trading System (ETS) for maritime, aviation, and stationary installations, including the Market Stability Reserve (Q3 2026)

🔹European Integrated Framework for Climate Resilience (non-legislative & legislative, Article 192 TFEU, Q4 2026)

📄 Factsheet: “Explaining the Commission work programme 2026”

➡️ Source: European Commission Work Programme for 2026

Posted By : admin 20 Oct, 2025

How to Navigate the Transposition of RED III

How to Navigate the Transposition of RED III in EU Member States?

When trying to understand how RED III is being transposed across the EU, you can easily find a multiple of publications often with overlapping or even contradictory information.

To analyse this topic effectively, I recommend the following key resources:

1️⃣ Announcements of the European Commission

On 24 July 2025, the European Commission opened infringement procedures by sending letters of formal notice to 26 Member States for failing to communicate the full transposition of RED III into national law.
Member States were required to notify the transposition of the RED III by 21 May 2025.
Only Denmark has notified full transposition by the legal deadline.

👉 This means that as of July 2025, only Denmark had fully transposed RED III.

➡️ Source: Commission takes action to ensure complete and timely transposition of EU directives – key decisions on energy

2️⃣ Information on National Transposition in EUR-Lex

While EUR-Lex does not confirm full transposition, it provides a list of national measures adopted for implementing RED III, presented separately for each EU country.

➡️ Source: National transposition measures communicated by the Member States

3️⃣ Overviews by Associations, Research Centres, and Institutes

Such overviews can be very insightful but usually do not provide full information on RED III transposition. They often cover only some Member States or some parts of the RED III transposition such as hydrogen and others.

👉 Some useful publications from associations include:

Overview RED III implementation in EU Member States from the European Biodiesel Board (EBB)
Overview of Renewable Energy Spatial Planning and Designation of Acceleration Areas in Selected EU Member States

How to Navigate the Transposition of RED III

Commission takes action to ensure complete and timely transposition of EU directives - key decisions on energy

Posted By : admin 16 Oct, 2025

IEA Report: Delivering Sustainable Fuels

International Energy Agency. Report. Delivering Sustainable Fuels. Pathways to 2035

Sustainable fuels mean liquid biofuels, biogases, low-emissions hydrogen and hydrogen-based fuels – offer multiple benefits for the energy sector.

With well-designed policies, sustainable fuels can achieve major lifecycle emissions reductions compared with conventional fuels.

✅ IEA Policy Recommendations:

📌 Establish roadmaps, targets and support policies that are tailored to regional contexts and aligned with broader energy goals, while keeping a technology-open approach.

📌 Increase demand predictability to increase market confidence and attract investment.

📌 Cooperate in developing transparent and robust carbon accounting methodologies to enhance comparability and future interoperability, and enable performance-based policies and incentives.

📌 Support innovation to narrow cost gaps to accelerate economies of scale and cost reductions for emerging technologies.

📌 Develop integrated supply chains and address infrastructure needs to unlock long-term economic development opportunities.

📌 Make financing more accessible, especially in emerging and developing economies to de-risk investment and unlock the vast potential for sustainable fuels in these regions.

➡️ Source: International Energy Agency. Report. Delivering Sustainable Fuels. Pathways to 2035

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