From HBE to ERE: what changed for Dutch renewable fuel suppliers in 2026

On 1 January 2026, the Netherlands replaced its long-standing HBE system with a new framework: Emissie Reductie Eenheden, or ERE. Under the new system, renewable fuel suppliers are rewarded not for the energy content they put on the Dutch market, but for the CO2 reduction they actually achieve.

This is a meaningful shift. It changes how suppliers think about their inventory, their customer mix, and the value of every batch. This article walks through what changed, why, and what it means in daily operations.

What HBE was, briefly

HBE stood for Hernieuwbare Brandstof Eenheden, renewable fuel units. The system tracked renewable fuel deliveries on a volume and energy basis: a tonne of biofuel delivered to the Dutch road market generated HBEs in proportion to its energy content, weighted by feedstock category and target sector.

Three sub-categories existed:

• HBE-G for general transport
• HBE-A for advanced biofuels
• HBE-O for other categories

Suppliers built up HBE positions, traded them, and used them to meet their annual obligation under the Dutch implementation of RED II.

The system worked. However, it had one major limitation: it measured the input, not the output. Two suppliers delivering the same volume of biofuel with very different GHG profiles would generate roughly the same HBEs. The actual climate impact was not reflected in the credit.

What ERE changed

ERE measures emission reduction directly. The unit is grams of CO2 equivalent reduced, not energy delivered.

That means:

• A 70% GHG saving fuel generates more ERE per tonne than a 50% GHG saving fuel
• The supplier’s climate impact is directly reflected in their credit position
• The system rewards procurement of higher-GHG-saving fuels
• The system reaches sectors that the old HBE framework did not cover: inland navigation, maritime shipping, aviation

The transition was administered by the Nederlandse Emissieautoriteit (NEa). Existing HBE positions were converted to ERE on a one-time basis at the start of 2026. From that point forward, ERE is the active framework.

What this means in daily operations

Several practical shifts.

The GHG value on every PoS is now commercially valuable. Under HBE, the GHG saving on a PoS was a compliance datapoint. Under ERE, it is the basis for the credit. A 90% GHG saving fuel earns substantially more credit than a 65% saving fuel for the same physical volume. That is now visible in the price.

Procurement strategy needs to shift. Suppliers buying biofuel for the Dutch market have a stronger commercial reason to source higher-GHG-saving feedstocks. Advanced feedstocks, waste-based fuels, lower-CI pathways. The premium for these batches is now structural, not negotiated.

The reporting chain runs through the NEa. Suppliers report deliveries and CO2 reduction to the NEa. The NEa issues the corresponding ERE. The system is more directly tied to scheme-correct PoS documentation than the old HBE system was.

Sectoral expansion. ERE applies across road, inland navigation, maritime, and aviation, with separate sub-targets per sector. A supplier active in multiple sectors needs to track their position per sector and report accordingly.

How this interacts with the schemes

ERE is the Dutch national framework. It sits alongside, not instead of, the certification schemes.

A biofuel delivered to the Dutch market still needs an ISCC EU, REDcert, or 2BSVS PoS to be eligible. The PoS confirms the sustainability of the source. The ERE confirms the CO2 reduction achieved by delivering it.

In practice, the interaction matters operationally. The PoS carries the GHG value that determines the ERE. If the PoS is wrong, ambiguous, or missing, the ERE claim falls apart.

This is why scheme-correct PoS administration has become more important under ERE than it was under HBE. The PoS is no longer just compliance documentation. It is the input to the credit calculation.

What this means for the wider EU picture

ERE is one of the most explicit national implementations of the broader shift in EU renewable fuel policy. RED III emphasises emission reduction over energy content. FuelEU Maritime measures intensity, not volume. The EU Union Database (UDB) tracks traceability across borders.

The direction is consistent. The Netherlands is one of the first member states to put this fully into practice for a national framework. Other countries will follow, with their own variations.

For suppliers operating across multiple national markets, the implication is the same in every direction: the GHG value on each PoS matters more, and the documentation has to support the value precisely.

Practical considerations for suppliers

A few things worth doing in 2026 if you are a supplier to the Dutch market.

Audit your PoS GHG values. Make sure the GHG savings on incoming PoS records are accurate, well-supported, and traceable to the source. Defaulted values may be fine for some pathways, but actual values often deliver more ERE.

Review feedstock procurement. The premium for higher-GHG-saving feedstocks is now embedded in ERE. Procurement decisions should reflect that.

Track per-sector positions. ERE is sectoral. A supplier active in road and maritime needs separate positions per sector, with corresponding documentation.

Get the NEa reporting clean. Reporting toward the NEa under ERE is more data-intensive than HBE. Suppliers running on spreadsheets will find this harder than suppliers on dedicated compliance platforms.

Common questions

Did existing HBE positions disappear? No. Existing HBE positions were converted to ERE during the transition. From 1 January 2026, only ERE is active.

Does the same PoS work for ERE as it did for HBE? The PoS itself is unchanged. What changed is how the data on the PoS is used in the credit calculation. A PoS with a precise, well-documented GHG saving is worth more under ERE than under HBE.

Do I need to be scheme certified to participate? The fuel needs to carry a recognised scheme PoS (ISCC EU, REDcert, 2BSVS, or similar). The supplier reporting toward the NEa needs to operate within the standard regulatory framework.

Does ERE replace national registries like Nabisy? ERE is the Dutch national framework. Nabisy is the German equivalent. Each country operates its own. The EU UDB sits above all of them.

How FuelFWD handles this

FuelFWD treats national framework reporting as part of the standard compliance flow. For the Dutch market:

• ERE positions are tracked per sector (road, inland navigation, maritime, aviation)
• PoS GHG values are validated at extraction and carried through to ERE calculation
• NEa-ready exports are generated directly from the platform
• Cross-border operations can run ERE alongside Nabisy (Germany), Carbure (France), and the UDB without manual reformatting

The same data underpins every framework. The platform translates it into the format each one expects.

The bigger picture

The shift from HBE to ERE is one example of a broader pattern. National frameworks across the EU are moving from energy-based credit to emission-based credit. The PoS data that supports the credit becomes more valuable, and the supplier infrastructure that handles the data has to keep up.

For suppliers active in the Dutch market, 2026 is the first year of the new system. The ones who set up clean PoS administration and clean NEa reporting now will compound the advantage as the system tightens.