The Netherlands’ proposed green-gas obligation would create a market for
The proposed trajectory reaches 2.85 million tonnes of CO₂-equivalent savings annually from 2031, with green-gas volumes depending on the emissions performance of the supply used. The central policy question is whether this demand obligation will finance additional production—or primarily increase the value of existing supply—while keeping costs acceptable for gas consumers.
Certified lifecycle savings each year from 2031, held flat through 2035.
Estimate only. Not a production quota, and not a guarantee of Dutch supply.
€0.45 per GGE. An authorised alternative to certificates, not a fine.
Bill 36.947 would amend the Environmental Management Act and Economic Offences Act, creating a new Title 9.9 covering supplier obligations, the certificate registry, supervision and enforcement. The numerical targets and detailed operating rules sit below the Act: the draft implementing decree, or AMvB, sets the annual trajectory and banking arrangements; the draft ministerial regulation sets buy-out prices and detailed certification and registry requirements. Both implementing instruments completed public consultation during July–August 2026.
The obligation would cover suppliers serving network-connected gas consumption within the Dutch ETS2 sectoral scope, including households, commercial buildings, smaller industry, horticulture and CNG filling stations. It is not a blanket obligation across all Dutch gas consumption, particularly consumption already within ETS1. Liability would rest with suppliers, not directly with consumers or biomethane producers.
Eligible suppliers would book qualifying renewable-gas deliveries into the Netherlands Emissions Authority’s register, receive GGEs and trade or surrender them. Each supplier’s obligation would reflect its share of covered gas deliveries. Manure-digestion pathways can receive particularly favourable treatment where the applicable methodology recognises avoided methane emissions. The incentive rewards certified abatement across the supply chain, rather than gas volume alone.
Hover or tap a delivery year. Figures are annual, not cumulative.
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| Delivery year | Savings, MtCO₂e | Volume, mln m³ | Buy-out, €/tCO₂e |
|---|---|---|---|
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THESE ARE PROPOSED ANNUAL—NOT CUMULATIVE—FIGURES. THE BUY-OUT SCHEDULE INCORPORATES APPROXIMATELY 2% ANNUAL INDEXATION.
The 840 million m³ estimate depends on the assumed feedstock and emissions-performance mix, and does not guarantee that this volume will be supplied or produced additionally in the Netherlands.
Qualifying gas would require both a guarantee of origin and a corresponding proof of sustainability, supported by the relevant supply-chain accounting. An unrelated origin certificate would not establish compliance eligibility.
Eligible production from other EU countries would be permitted; the government removed an earlier Dutch-only restriction following European Commission objections concerning free movement of goods. Dutch projects would therefore compete with eligible imports, rather than receive an exclusive domestic market.
Eligible producers could switch monthly between SDE++ operating support and the quota route. The same output cannot receive both forms of support, although qualifying investment assistance can remain compatible. Nor can the same batch generate both GGEs and transport-fuel compliance units.
Suppliers could buy out up to 100% of their obligation. The proposed 2027 price is €450/tCO₂e, equivalent to €0.45 per GGE. This is an authorised alternative to surrendering certificates, not a non-compliance fine. The buy-out should constrain suppliers’ willingness to pay for GGEs, but it provides neither a minimum certificate price nor a guaranteed producer revenue. Receipts would enter the Treasury; payment would not itself purchase replacement green gas or represent delivered emissions savings. Legal compliance could consequently fall short of the policy’s intended physical and climate outcomes.
Suppliers could bank surplus GGEs up to 10% of their annual obligation, but not in a year when they use the buy-out. Excess units would expire. Settlement follows the delivery year: obligations arising from 2027 deliveries would be settled on 1 August 2028.
The current package is less ambitious than the earlier 1.6 bcm quota proposal. The government reduced the intended requirement in response to concerns over achievable supply, feedstock availability and consumer costs, moving to the present carbon-based target and indicative 0.84 bcm volume for 2031.
The MPs’ amendments address four fundamental choices: when the obligation starts, who pays, which supply qualifies and how strongly future demand is protected. None has yet been adopted. Amendment no. 15 replaces no. 13, while no. 18 replaces no. 16.
The bill was introduced in May 2026, followed by June technical and stakeholder hearings, written scrutiny in July, and the government’s response and revised text on 3 September. The legislative committee debate began on 7 September and is scheduled to continue on 21 September.
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Parliamentary passage remains outstanding. The Tweede Kamer must decide on the amendments and bill. An approved text then goes to the Eerste Kamer, which may accept or reject it but cannot directly amend it. Enactment, publication and the applicable commencement arrangements follow.
The implementing rules have a separate timetable. In its 3 September reply, the government reported that notification of the framework bill under the EU technical-regulations procedure had concluded, while notification of the lower rules was imminent. Those rules face a three-month standstill. A detailed opinion from the Commission or another member state would extend that period by three months and, according to the government, prevent a January 2027 launch. Ordinary questions would not automatically extend it.
Since the original draft, the 15 September budget package has proposed a temporary reduction in horticulture’s reduced energy-tax rates in 2027, intended to compensate for the green-gas obligation’s additional costs. This is a fiscal proposal alongside the quota—not an exemption under Bill 36.947 or evidence that the obligation has been enacted.
The disagreement cuts across the value chain. Infrastructure operators favour durable demand, producers question whether certificate revenues will finance new plants, and consumer-facing organisations challenge the allocation of costs.
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The latter could offer greater price certainty, but requires explicit choices on funding, eligible applications and allocation of risk.
EURO CENTS PER CUBIC METRE, EXCLUDING VAT. TRACK MAX 10 CENTS.
ACM has stated that suppliers cannot increase agreed fixed supply prices merely because the obligation enters into force. Suppliers may therefore face compliance costs before they can reflect them in new retail contracts.
There is a further distributional effect: with an absolute national target, falling covered gas demand—or exemptions that leave the target unchanged—increases the certificate requirement per remaining cubic metre. Relief for one group can shift costs onto another unless the trajectory or funding arrangements also change.
A credible mechanism for creating renewable-gas demand — not yet a guaranteed investment case.
The proposal offers a credible mechanism for creating renewable-gas demand and rewarding lifecycle savings. Its effectiveness will depend on whether that demand becomes additional, verifiable supply supported by durable investment, rather than predominantly higher certificate prices or buy-out payments.
Parliament should therefore assess the amendments together. Changes to coverage, price limits and commencement alter the market’s scale and investment value; they are not independent consumer-protection adjustments.
The appropriate success measures are additional output, commissioned capacity, verified emissions savings and costs borne by consumers—not simply GGEs surrendered. Bill 36.947 could establish a valuable biomethane market, but its final design must connect compliance demand with the conditions needed to build and operate new production.
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