GHG quota reform 2026: what changes for biomethane.
With the Second Act to Further Develop the GHG Quota, the Bundestag transposed RED III in April 2026. For biomethane in the fuel market, the basis of revenue changes.
What has been decided
- The GHG quota rises from 12 percent in 2026 to 65 percent by 2040.
- Double counting of advanced biofuels, including biomethane from Annex IX feedstocks, ends for all volumes placed on the market from 1 January 2026, without transition.
- The sub-quota for advanced biofuels is made permanent and rises to 9 percent by 2040.
- Legitimate-expectation protection is restricted: volumes already recognised can be revoked if it later turns out they did not meet the sustainability criteria.
- Aviation and marine fuels are excluded from the quota obligation.
What it means for biomethane
Biomethane from manure and residues remains in demand through the sub-quota. But the end of double counting halves the arithmetic quota contribution per volume. Contracts still priced with double counting need to be reassessed.
At the same time, the GHG value becomes more important. An individual, robust calculation matters more than ever. Extreme values based on questionable assumptions become riskier with the restricted protection.
What to do now
- Check existing contracts for double counting and renegotiate where necessary.
- Calculate GHG values individually and audit-proof.
- Document mass balance and chain of custody without gaps.
How the fuel market works for biomethane in principle is described on the Transport fuel market page. Transport fuel market
This article provides context and is not legal or tax advice. As of October 2026.
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