Understanding the EU and NL carbon emission obligation schemes for SAF production

For: a Sustainable Aviation Fuel (SAF) producer

[August – October 2024]

A Sustainable Aviation Fuel (SAF) producer focused on the Netherlands, asked studio Gear Up to assist them in identifying their obligations under the EU Emissions Trading System (ETS) and the Dutch national CO₂ taxation scheme.

For this analysis, studio Gear Up assessed the (future) participation requirements of the SAF producer under EU ETS based on their production set-up.

Volume of ETS 1 emissions

We calculated the volume of emissions that would fall under the scope of ETS 1 on basis of the fuels used at the site. Based on benchmark values established by the European Commission, we estimated how many free allowances the SAF producer may receive, and how this would develop over time. We also assessed how other legislation could impact this free allowance allocation, such as the Carbon Border Adjustment Mechanism (CBAM). Together, this leads to an understanding of how many allowances the SAF producer would have to buy in the market.

Dutch national carbon tax scheme explained

Also, we explained the Dutch national carbon tax scheme which will apply to all EU ETS obligated installations in the Netherlands. This scheme works alongside the EU ETS and includes specific rules, such that a part of the emissions may be subjected to additional taxes; and the applicable volumes and costs may change over time. We estimated what this could mean for the cost that the SAF producer can expect from these combined carbon pricing schemes, under the current ruleset.

High blends of renewable fuels for the heavy-duty fleet in the Netherlands

KiM Netherlands Institute for Transport Policy Analysis (Kennisinstituut voor Mobiliteit – KiM) commissioned studio Gear Up to conduct research to explore the options for high-blends of renewable fuels in the heavy-duty fleet. This research served as input for KiM’s (2025) report: Renewable fuels in high blends in road freight transport , which provides recommendations for Dutch policy makers aiming to shape climate action in the road sector. The study sets out to explore alternative fuel options available to heavy-duty vehicles given that there is “uncertainty about the pace of truck electrification”.

sGU recommendations for practical certification guidelines intermediate crops

Intermediate crops are crops planted and harvested between main crops in a crop rotation scheme. Their development, on top of existing food and feed farm output, offer additional volumes of feedstocks for the bioeconomy without requiring additional land. studio Gear Up assessed the benefits of intermediate crops, the bottlenecks for their development and deployment and provided recommendations for certification of these crops in the frame of the Renewable Energy Directive.

Consequences of ETS2 implementation on A-B-C deliveries of renewable fuels

Our research for the Ministry of Infrastructure and Water Management shows that the introduction of the new ETS2 emissions trading system can have important consequences for these constructions. Because these A-B-C supply constructions play a major role in the Dutch fuel market, this is expected to make the use of A-B-C supplies less attractive for fuel suppliers, with market shift and concentration likely to result.