Why is there talk today of a major comeback for the GHG bonus ?
Guillaume DE LA FOREST: The GES premium market has been turbulent since its launch in 2020. The German and Swedish blending mandates, based on GHG emissions reductions rather than energy targets as in France, strongly boosted demand between 2020 and 2022. Several factors then disrupted the market. Sweden drastically reduced its mandate in 2023, from 30% to 6%. Germany, meanwhile, maintained an ambitious and growing mandate, but introduced the concept of double counting in 2022 for certain biofuels made from certain types of waste (Annex IX Part A of the RED).
In concrete terms, what impact did double counting have on the market?
L. T.: Our core activity is vegetal transformation. We exclusively process rapeseed, giving priority to French origin, supplemented with imports depending on seed availability and our customers’ needs. These seeds are valorized through several outlets: vegetable oils for human consumption, protein-rich meal for animal feed, and renewable energy for transport decarbonization.
G.DLF.: It created a massive competitive advantage for waste-based products. Indeed, when 1 tonne of Annex IX Part A biofuel with a 90% GES emissions reduction is blended in Germany, it saves 3.15 tonnes of CO₂. Thanks to double counting, this is multiplied by two, resulting in 6.3 tonnes of CO₂. By comparison, 1 tonne of rapeseed biodiesel with a 90% GHG emissions reduction saves 3.15 tonnes of CO₂, while 1 tonne of standard rapeseed with a 60% GHG emissions reduction saves 2.11 tonnes of CO₂. In other words, 1 tonne of Annex IX Part A biofuel is equivalent to 3 tonnes of rapeseed with a 60% GHG emissions reduction.
This system led to widespread fraud, with 2.7 to 2.9 MMT of biofuels and waste-based oils imported from China in 2022 and 2023, in a European biodiesel market of 17 MMT.
Guillaume DE LA FOREST
Market Analyst at Saipol
What changes are expected in 2026?
G.DLF.: Germany plans to end double counting in order to comply with the RED III Directive, which prohibits it for GES-based mandates. This is a major change: rapeseed, and especially low-GES rapeseed, will once again become highly competitive compared with waste-based oils. In addition, ending double counting will lead to a significant increase in physical demand, since 40% of the German mandate has so far been met by “virtual” tonnes of CO₂. However, we will need to remain vigilant: the German Parliament has not yet adopted this decision, even though it has broad support within the biodiesel industry. The vote is expected during the first half of 2026.
Can this development be considered a long-term trend ?
L. T.: Many of the projects are already completed. Others are underway or scheduled in the coming months. For example, upgrading our second sewage treatment station is planned for November. The objective is full regulatory compliance by the first quarter of 2026. We already observe a marked improvement in our indicators, which shows the installations are stabilizing.
These are major projects that take time to execute — from detection of the need, design and costing, through to actual implementation. On a facility like ours, which operates year-round, the largest investments are generally planned year to year and executed during technical shutdowns. In addition, there are maintenance and improvement tasks for our installations on a daily basis: it is the work of our teams to integrate these projects into the life of the plant with a great deal of agility.
How are the teams experiencing this transformation?
G.DLF.: Yes. Following Germany’s lead, the Netherlands will also switch from an energy-based mandate to a GES-based mandate from 2026, with double counting prohibited, while France will adopt a mixed energy- and GES-based mandate from 2027. This opens up strong prospects for the low-GES biofuels market, and therefore for farmers implementing low-carbon farming practices.
How is Saipol supporting the sector in this context ?
G.DLF.: In a market undergoing a strong recovery, data reliability is a major issue. Saipol addresses this requirement through its Empreinte programme, which guarantees full regulatory compliance across the entire sector.
Beyond traceability through the OleoZE digital platform, Saipol provides comprehensive support through grain storage organizations, particularly for soil analyses to be carried out from 2027 onwards, which are essential for complying with the regulatory requirements governing the marketing of low-GES biofuels (with ESCA*) from crops harvested in 2023 onwards. Empreinte by Saipol was designed to provide peace of mind and security in the face of complex regulations, drawing on expert teams that deploy pragmatic solutions tailored to on-the-ground needs.
*ESCA : Emission Saving from Soil Carbon Accumulation.
