What does RED III mean if you buy energy?

§ 01What RED III is

The Renewable Energy Directive is the European directive that sets how much renewable energy the Union has to use and what may count as "renewable" towards that. The third version — Directive (EU) 2023/2413, adopted in October 2023 — raises the binding 2030 target to at least 42.5 per cent of gross final consumption, with an aim of 45 per cent, and adds targets for individual sectors, including industry, transport and buildings. [1]

Member States have to transpose the directive into national law. The Netherlands does so partly through the annual obligation for energy in transport and the registration systems that go with it. [3] [4] Exactly how this is implemented nationally is still changing; this article sticks to what the directive itself sets out.

§ 02Four things the directive sets out

If you buy energy, four parts matter: [1]

• Sustainability criteria. Biomass, biogas and biomethane only count if the feedstock meets the requirements — for example no production on land with high biodiversity or a high carbon stock — and if the chain achieves a minimum greenhouse gas saving compared with the fossil fuel comparator. Which threshold applies depends on the application and on when the installation was commissioned.
• Mass balance. The sustainability characteristics of a consignment have to be tracked through the chain with a mass balance system: per site and per period, no more renewable energy may be booked out than was booked in. How that works is set out in the article on mass balance.
• Certification. Proof is provided through national schemes or through voluntary certification schemes recognised by the Commission, which check the entire chain. [2]
• The Union Database. For liquid and gaseous renewable fuels, the directive requires a European database in which transactions are recorded, so that the same consignment cannot be claimed twice. [1] [3]

RED III also introduces a separate category for renewable fuels of non-biological origin — in practice mainly renewable hydrogen — with its own targets for industry. Those fall outside the scope of this article.

§ 03What it means for buyers

RED III places obligations on member states and suppliers, not directly on you as a buyer. But the consequences do land with you, for three reasons.

First, the directive determines which energy may be reported as renewable. If you buy gas that hasn't been tracked through mass balance and recognised certification, then in the terms of the directive it isn't renewable energy — whatever the supplier says about it. That carries through into your own reporting under the CSRD and into tenders that refer to the directive.

Third, double counting and standalone claims are being systematically closed off. A certificate that has already been cancelled in another member state, or a claim that isn't attached to a registered consignment, loses its value. If you still rely on a supplier's declaration, you run the risk that the claim falls away at the first check.

§ 04Four questions for your next purchase

• Under which recognised certification scheme has this consignment been tracked? And can you produce the certificate? [2]
• What is the origin and which sustainability characteristics travel with it? Feedstock, production site, greenhouse gas data.
• What does the mass balance look like? System boundary, balancing period, who checks the balance.
• Is the consignment registered in the national register or the Union Database, and do I get a reference to it?

If you get a concrete answer to all four, you're buying renewable energy in the terms of the directive. If one of them gets you a shrug, you're buying a claim.

§ 05How Powercrumbs fits in

The Powercrumbs chain answers these questions physically: origin per consignment, a transport and swap log per delivery, metered consumption on site, and an evidence file you can produce per project — the Proof Trail. On the question about a recognised certification scheme, the answer today is that the chain does not fall under one: the gas is not injected into the grid and no certificate travels with it. Sustainability assurance on the source side differs per site; which scheme applies there, you hear per project in the intake meeting. How RED III, CSRD and CBAM relate to one another, and what answer the evidence file gives to each requirement, is set out in the regulatory framework. Want to know what this means for your own site? Start with the fossil replacement scan.

This article explains how the system works; it is not legal advice. For your specific obligations, consult national legislation and your adviser.

§ 06References

• European Union — Directive (EU) 2023/2413 of 18 October 2023 amending Directive (EU) 2018/2001 (RED III) — targets, sector targets, sustainability criteria, mass balance and the Union Database.Legislation · primary · Official Journal of the EUPrimary
• European Commission — Explanatory material on the revised Renewable Energy Directive and the recognised voluntary certification schemes.Policy explanation · EUHigh
• Netherlands Emissions Authority (NEa) — Dutch implementation: annual obligation for energy for transport, registration and the Union Database for gaseous fuels.Regulator · nlHigh
• Netherlands Enterprise Agency (RVO) — Information on the national implementation of RED III and what it means for businesses.Implementing agency · nlHigh

Full references (titles, dates, links) to follow.

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