HVO100 AND SUSTAINABILITY

Why companies relying on HVO will soon have a problem

Many organizations think their sustainability is sorted. They refuel with HVO100, report significant CO₂ reduction and proudly communicate that their fleet runs ‘fossil-free’. On paper it checks out. But does it hold up in reality?

READ THE ANALYSIS

WHAT DOES WORK

THE MATH THAT DOESN’T ADD UP

HVO is only sustainable when it checks out

HVO is only sustainable when produced from genuine waste streams: used cooking oil, waste oils, residual products. Those volumes are limited.

However, demand for HVO is growing explosively. Europe alone needs more sustainable fuel than there are demonstrably available waste streams worldwide. That means only one thing: the system relies on assumptions. And as soon as a market depends on assumptions rather than physical availability, risk emerges.

This is not a small marginal detail. It is a fundamental miscalculation on which the entire sector is built. If we consume more than can be honestly produced, the books don’t balance somewhere. Who pays the difference, and how?

“Current HVO100 consumption in Europe already exceeds the theoretical maximum production capacity based on genuine waste streams.”

SOURCE: CIRCULARISE — SUPPLY CHAIN TRACEABILITY →

CERTIFICATES ARE NOT RAW MATERIALS

A certificate is an administrative document, not a physical raw material

Companies rely on certification. That seems logical, because a certificate suggests control. But a large portion of HVO entering Europe comes through long international chains. With multiple links. Multiple countries. Multiple audits. Often without physical on-site inspection.

Virtually all HVO100 carries an ISCC certificate. In 2023, ISCC certified no less than 92.4% of the 3.7 billion liters of renewable fuel delivered in the EU. The question few companies ask: if I can’t verify it myself, who can?

When volumes exceed demonstrable collection capacity, there is no technical problem. There is a structural problem.

92.4%

of EU renewable fuel certified by a single body

→ ISCC

71.4%

of that volume originating from outside the EU, outside direct oversight

9%

of UCO collection points actually physically inspected

→ T&E

THE REPUTATION RISK NOBODY MENTIONS

These are not theoretical risks

Today companies proudly report their CO₂ reduction thanks to HVO. The trend in Europe is clear: regulations are tightening, inspections are intensifying and CO₂ claims are being scrutinized more critically. When that happens, risk shifts from producer to user. Reputational damage is more expensive than fuel.

The fraud is documented, recent and persistent. Click on a case for more detail.

MEI 2025

EcoSolution Limited, VAE / Hongkong — FRAUDE

2023-HEDEN

Palm oil via China: structurally circumventing EU rules — STRUCTUREEL

STRUCTUREEL

Certification volumes above physical production capacity — SYSTEMISCH

DEC 2025

Henan Zhenghong Resources Environmental Engineering, China — UITGESLOTEN ISCC

DEC 2025

Zhongshan Bailina Lighting Electric Appliance, China — UITGESLOTEN ISCC

OKT 2025

Alem Agro Holding, Kazachstan — UITGESLOTEN ISCC

SEP 2025

Zhoushan Dadi Bioenergy Technology, China — UITGESLOTEN ISCC

SEP 2025

Hubei Xinming Bioenergy Technology, China — UITGESLOTEN ISCC

This is a selection. View the complete ISCC exclusion list →

SUPPLY CHAIN

The route of a liter of “sustainable” fuel

What does the chain look like when things go wrong? From plantation to tank, step by step. The system makes it impossible for the end user to distinguish.

📍 Palm oil plantation
Indonesia / Malaysia

→

🏭 Chinese refinery
Export & processing

⚠️ Relabeling as UCO/POME
FRAUDEPUNT #1

→

📄 Certificate shell company
FRAUDEPUNT #2

📦 EU Import
‘certified waste stream’

→

⛽ HVO100 in your fleet
green on paper

Schematic reconstruction based on documented fraud patterns (DLG, T&E, BLE 2023-2025). Not all HVO100 follows this route, but the system makes it impossible for the end user to distinguish.

THE NEXT REALITY: HIGHER PRICES

When supply shrinks, prices rise

Stricter European regulations. CO₂ levies on transport. Tightening of controls on biofuels. When the supply of “genuine” sustainable volumes is limited, prices rise. That is not an opinion, it is market dynamics.

Companies fully dependent on HVO will then face higher costs, limited availability and uncertainty about their sustainability reports. A temporary solution then becomes a structural vulnerability.

Why does this system hold up now? Partly because it is politically convenient. In the EU, advanced biofuels like HVO count double towards sustainability targets. As long as certificates keep coming in, there is little institutional incentive to truly scrutinize the chain.

● RISK SIGNAL AFTER 2026

Not a question of if, but of when

We saw the same pattern with solid biomass: years of criticism, documented abuses, and then an abrupt tightening. Experts expect new European CO₂ levies (ETS2) to increase pump prices by

€0,70 per liter. In a scenario where

oil prices also rise, a price towards €3.00 per liter is realistic. Companies now heavily investing in HVO100 are building exposure to both reputational risk and cost risk.

Source: UFOP / Biofuels News →

ENVIRONMENTAL BALANCE

What real sustainability actually requires

Real sustainability requires energy sources that physically check out. Not just administratively. That means: short, verifiable chains; production from demonstrable waste streams; transparency about origin; regional availability; scalability without international dependency.

Electrification makes sense where possible. But for heavy transport and energy-intensive applications, fuel remains necessary. That is where the strategic question lies.

Even when palm oil is openly classified as palm oil and not as a waste stream, production involves large-scale deforestation in Southeast Asia. When the actual origin is factored in, the environmental balance of large-scale HVO100 use is in many cases worse than that of fossil diesel.

“When the actual origin of the feedstock is factored in, the environmental balance of large-scale HVO100 use is in many cases worse than that of fossil diesel.”

SOURCE: DLG — BIODIESEL: THE SCAM WITH HYDROGENATED VEGETABLE OILS →

WHY BIOGAS IS FUNDAMENTALLY DIFFERENT

HVO is a transitional phase

HVO is not inherently bad. In limited volumes, with genuine waste streams, it can be valuable. But it is not an end strategy. Companies that base their entire sustainability on HVO are building on a foundation dependent on scarce raw materials, international supply chains, administrative certification and changing regulations.

Biogas is produced from local and regional waste streams: manure, sludge, organic waste. The chain is short. The origin is verifiable. Volumes are linked to physical production in Europe. It is not a global trade flow based on certificates, but a local energy system. That makes it structurally more robust.

Criterion	HVO100 (current)	Biogas
Supply chain fraud risk	High ↑	Low ↓
CO₂ reduction (demonstrable)	Uncertain ~	High ↑
Price risk after 2026	High ↑	Moderate ~
Waste stream scalability	Already exceeded ✕	Great potential ↑
Regulatory risk	High ↑	Limited ~

The uncomfortable conclusion

The energy transition demands choices that hold up: even when rules change, prices rise and controls are tightened. Companies that dare to look at structural solutions now are building a strategy that is not dependent on scarcity or paper.

The question is whether HVO can still be the basis of your sustainability strategy in five years.

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