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Implementation of RED3 requirements: Transition period and ‘grandfathering clause’

The European Commission recently informed Better Biomass and other EU-recognized certification schemes about two issues related to the implementation of the sustainability requirements laid down in the Revised Directive EU/2018/2001, commonly known as RED3. Better Biomass has implemented the RED3 requirements through the Interpretation Document RED III, which has now been incorporated into the +A1:2025 versions of the scheme documents. The relevant issues are (1) the transition period and (2) the ‘grandfathering clause’.

Transition Period

The Commission has clarified that no general transition period will be granted for the implementation of the RED3 requirements after 21 May 2025. The following rules apply to Better Biomass-certified companies:

All Better Biomass audits must be conducted from May 21, 2025, in accordance with the new version of the Better Biomass scheme documents (the +A1:2025 versions of the scheme documents contain the sustainability requirements as laid down in RED3);
Biofuels, biomass fuels, and bioliquids produced and certified before May 21, 2025, in accordance with the old version of the Better Biomass scheme documents (the 2015 versions of NTA 8080-1 and NTA 8080-2, NCS 8080:2018-08, and Interpretation Document No. 8) remain valid (these 2015/2018 versions contain the sustainability requirements as laid down in RED2, the previous version of the European directive);
Biofuels, biomass fuels, and bioliquids produced after 21 May 2025 must comply with the sustainability requirements of the new 2024+A1:2025 versions of the Better Biomass scheme documents, even if they are made from feedstock stored before 21 May 2025.

The Commission’s clarification above is in line with Better Biomass’s previous communication regarding the effective date of the new scheme documents.

‘Grandfathering Clause’

The so-called ‘grandfathering clause’ is laid down in Article 29(15) of the revised Directive EU/2018/2001 (RED3). The transitional provision allows certain biofuels, bioliquids, and biomass fuels to continue to comply with the RED2 sustainability requirements until 31 December 2030, instead of the RED3 sustainability requirements. More specifically, it concerns biofuels, bioliquids, and biomass fuels produced in installations in the EU that received a subsidy decision or other financial support from an EU Member State before 20 November 2023. A condition is that a Member State has individually decided to apply the transitional provision to its financial support instrument and subsequently communicates this decision to the EU-recognized certification systems.

In other words, biofuels, bioliquids, and biomass fuels may comply with version 2015/2018 of the Better Biomass scheme documents instead of version 2024+A1:2025 until 31 December 2030, provided that all of the following conditions are met:

The biofuels, bioliquids, or biomass fuels were produced in an installation in an EU Member State;
The installation received financial support from the Member State concerned, and that support was granted before 20 November 2023;
The Member State in question has decided to use the grandfathering clause and has informed Better Biomass of this decision.
Better Biomass has informed its certificate holders and certification bodies of the Member State’s decision.

To date, Better Biomass has not been informed by any EU Member State of any decisions regarding the grandfathering clause. This means that there are currently no exceptions to the required implementation of version 2024+A1:2025 of the Better Biomass scheme documents, as explained above under “transition period.”

In the future, Better Biomass will communicate any information it receives regarding decisions by EU Member States regarding the grandfathering clause to its certificate holders and certification bodies.

If you have any questions or require support in interpreting these requirements, please feel free to contact us.

Addendum Flemish regulations to the Guidelines for self-declaration disposers

Nederlandse versie

On July 11, the Better Biomass Committee of Experts adopted the Addendum regarding Flemish waste regulations and Flemish fertilizer regulation. This addendum substantiates Better Biomass’s recognition of the Flemish regulations regarding the registration and reporting of waste and animal manure as equivalent (paragraphs 2 and 3). It also explains that the self-declaration requirement does not apply to waste collected from Flemish households (paragraph 4).

This addendum should always be read in conjunction with the full Guidelines for Self-Declaration for Disposers of Waste and Residues, published by Better Biomass in June 2025. This document states that Better Biomass may recognize requirements in legislation and regulations for waste and residues as equivalent if they guarantee compliance with Better Biomass’s requirements regarding the self-declaration. For collectors subject to these laws and regulations, this means they do not need to receive and manage self-declarations from the supplying disposers, and that risk-based auditing of the disposers as part of the collector’s certification process is generally not required.

All information can be found on the page: Current Certification Documents under the heading Interpretation Documents and Templates.

Guideline for self-declaration of disposers and Update of scheme documents

Nederlandse versie

On the page: Current certification documents you will find a number of changes.

Guidance and new template for self-declaration of disposers
According to the new scheme documents, collectors of residues and waste must have a self-declaration of all disposers (NTA 8080-1: 2024, chapter 6.1). This requirement comes from the revised Directive EU/2018/2001 (REDIII). The disposer declares which residues/waste are generated, and how much (per month/year). A guidance with additional instructions has been published, including a new template for a self-declaration for disposers.

Updated scheme documents
The amended versions of the scheme documents, marked by the addition of: +A1:2025, have been published. The recent changes and corrections have been integrated into this, as they were included in the Interpretation document RED III + corrections. This interpretation document has therefore been withdrawn. The new versions apply immediately, because they do not concern any technical changes.

Interpretation document REDIII and Template self-declaration disposers published

Nederlandse versie

The following new documents have been published on the page New certification documents as of December 2024.

Interpretation document REDIII
This interpretation document contains changes to comply with the revised Directive EU/2018/2001 (REDIII) plus a number of corrections to the new certification documents.
The European Commission requires that all organisations are audited against the REDIII requirements as of 21 May 2025. That is: the new scheme documents plus the interpretation document. This includes initial audits, recertification audits and surveillance audits.

Click here for the Interpretation document RED III

Template self-declaration of disposers
According to the new scheme documents, collectors of residues and waste must have a self-declaration of all disposers (NTA 8080-1: 2024, chapter 6.1). This requirement comes from the revised Directive EU/2018/2001 (REDIII). The disposer uses it to declare which residues/waste are generated, and how much (per month/year). An example template has been developed for a self-declaration for disposers.

Click here for the Better Biomass Template Self-declaration

Webinars Better Biomass 2024 editie

Per december 2024 zijn de nieuwe Better Biomass schemadocumenten gepubliceerd. Op de pagina Nieuwe certificatiedocumenten vindt u links naar de betreffende documenten. Komende maanden is het voor organisaties optioneel om gecertificeerd te worden volgens de nieuwe versies en per 1 juni 2025 worden alle audits (initiële audits, hercertificeringsaudits en surveillance audits) uitgevoerd op basis van de nieuwe schemadocumenten.

Better Biomass organiseert twee Webinars voor certificaathouders waarin een toelichting wordt gegeven op de nieuwe schemadocumenten. Hierbij wordt ingegaan op de wijzigingen ten opzichte van de vorige versies, om certificaathouders een beeld te geven hoe ze de nieuwe versies kunnen implementeren. Er zal ook worden toegelicht welke wijzigingen in het kader van RED III van toepassing zullen zijn.

Het webinar wordt op twee data gegeven, om u optimaal de kans te geven om erbij te zijn. De webinars vinden plaats op dinsdag 11 maart⋅10:00 – 11:30 en op donderdag 27 maart⋅09:30 – 11:00. Via onderstaande formulier kunt u zich inschrijven voor één van de twee edities. Na registratie ontvangt u een uitnodiging. Mocht u problemen ondervinden met onderstaand formulier dan kunt u zich ook aanmelden middels een email aan: info@betterbiomass.com

Update 27-03-2025: De webinars zijn geweest, registratie is niet meer mogelijk. Houd de website in de gaten voor nieuwe activiteiten

Implementation new scheme documents

Nederlandse versie

We are pleased to announce that the Dutch scheme documents are now also available in the NEN webshop as of early December. On the New certification documents page you will find links to the relevant documents.

Implementation period
With the availability of the Dutch documents, a period of 6 months will start, during which it is optional for organizations to be certified according to the new versions.

After 6 months, so as of June 1, 2025, a period of 12 months will start during which it will be mandatory for organizations to be audited according to the new scheme documents.. This includes initial audits, recertification audits and surveillance audits. In the case of surveillance audits, the certificate will also be replaced by a new version that refers to the 2024 scheme documents.

Further information
Further information about webinars and information material about the changes in the new version will follow as soon as possible via this website and via news items to Better Biomass members.

If you have any questions, please contact us at info@betterbiomass.com.

Publication and implementation new scheme documents

Nederlandse versie

We are pleased to announce that the revised English scheme documents are available in the NEN webshop. On the page Draft new certification documents you will find links to the relevant documents.
The new scheme documents are not yet in force, because the Dutch translation is currently still being worked on. This is expected to be completed in November for the NTA documents

Implementation period
The Committee of Experts Better Biomass has established the following with regard to the implementation periods. The implementation periods below will start as soon as the Dutch versions are available.

After the Dutch NTA documents become available (the Dutch NCS documents may follow later), a period of 6 months will start, during which it is optional for organisations to be certified according to the new versions.

After 6 months, a period of 12 months will start during which all organisations are required to be audited according to the new scheme documents. This includes initial audits, recertification audits and surveillance audits. In the case of surveillance audits, the certificate will also be replaced by a new version that refers to the 2024 scheme documents.

Effective date
The exact dates therefore depend on the availability of the Dutch NTA documents. This is expected to happen around 1 November, which will then mean that the new NTA documents will be mandatory from 1 May and optional until then. If they become available later, the dates will shift accordingly (the possibility of rounding down is reserved, for example if documents become available on 4 November, it will still be mandatory from 1 May).

Further information
Further information about the exact effective date will follow via this website and via news items to Better Biomass members.

New interpretation on GHG emissions calculation for co-digestion

Nederlandse versie

The Committee of Experts Better Biomass has approved the new addendum to Interpretation Document N°8 on Greenhouse gas emissions in case of co-digestion for the production of biogas or biomethane.

The addendum specifies that in case of co-digestion of different substrates in a biogas plant for the production of biogas or biomethane, greenhouse gas emissions shall be calculated as a single value for the whole amount of biogas or biomethane and not separately for each substrate used.

The Better Biomass Committee of Experts understands the impact of this interpretation, but also
underlines the importance of a level playing field in the market. Therefore, this interpretation will be
effective as from July 1st 2024. The GHG emission calculations of all biogas and biomethane
produced from that date shall comply with this interpretation.

Draft new certification documents available

Nederlandse versie

The DRAFT new documents for certification of biomass for energy applications and biobased products are available on this page. These are the versions as approved by the EC for Directive (EU) 2018/2001 (Renewable Energy Directive [RED II]) and the supplementary Implementing Regulation (EU) 2022/996 on rules to verify sustainability and greenhouse gas emissions saving criteria and low indirect land-use change-risk criteria from June 14, 2022.

Before these new documents can come into effect, a number of steps still need to be taken, including translation (NL), final editing and an assessment by the Dutch Accreditation Council. The documents have already been approved by the European Commission. The informative versions of the new scheme documents have been made available so that certificate holders have the opportunity to prepare for them.

It is important to take into account that the final versions may differ from these informative versions. No rights can be derived from these draft documents and the audits are currently carried out on the basis of the Current certification documents.

Better Biomass update

Nederlandse versie

We hereby inform you about a number of current developments.

Acceptance for IR 2022/996

After a number of assessment and adjustment rounds at the end of 2023, we received notice in (early) January that Better Biomass has been accepted by the EC for the Implementing Regulation (EU) 2022/996 on rules to verify sustainability and greenhouse gas emissions saving criteria and low indirect land-use change-risk criteria of June 14, 2022. This implementing regulation is a supplement to the REDII (Directive (EU) 2018/2001).
This does not yet include recognition for forest biomass criteria, Article 29(6) and 29(7) of Directive (EU) 2018/2001. The updates required for this will now be addressed as quickly as possible. Approval has been granted for the draft versions of the new scheme documents. The necessary steps will be taken in the near future to complete the revision of the Better Biomass scheme documents. This will still take some time. We will keep you informed as best as possible and a transition period will apply after publication, so that there is sufficient time for the new version to be applied.

Approval for RCVB

In December, the following additional scheme documents were submitted to RVO for approval in the context of the de Regeling conformiteitsbeoordeling vaste biomassa voor energietoepassingen (RCVB). At the end of December we received notice that this additional approval had taken place. This decision will be published in the Staatscourant.

This concerns the following documents:

Addendum to Interpretation Document N° 8 on reducing woody residual flows.
Addendum to Interpretation Document N° 8 on Bone Meal.
Addendum to Interpretation Document N° 8 on Acceptance of other schemes

Onboarding Union Database for Biofuels

The European Commission, as required by RED 2, is setting up a Union Database (UDB) to ensure transparency and traceability of renewable fuels. The intention is that certificate holders who supply renewable fuels for transport will book their biomass transactions here. (so only suppliers of transport fuels!)

All Better Biomass certificate holders within the scope of the UDB have had their certificate data uploaded to the UDB. As these are all biogas producers, no initial stock registration is yet required nor accounting for their transactions from January 1, 2024. This will only start after the technical links between the UDB and the respective national registers of Guarantees of Origin (GOs) will have been achieved. So we are waiting for a connection with VertiCer, among others. Until then, no transactions need to be recorded in the UDB for gaseous biofuels. We await further instructions on the implementation of the UDB for gaseous biofuel producers.