Dutch biomethane industry seeks import safeguards and continued SDE++ support

Platform Groen Gas supports biomethane imports, but wants market opening to preserve investment in Dutch production.

Creating demand in the Netherlands does not necessarily create production in the Netherlands.

The association’s 2 October paper calls for comparable European competitive conditions and measures to support domestic expansion.[1]

It combines acceptance of imports with safeguards covering five areas: market access, traceability, competition, emissions accounting and domestic support.[2] Each is compared below with what the legislative package already provides.

How far the legislative package already meets each call 5 issues

IssueLargely providedPartly providedLeft to EU reform

Import access and timing Access open; no phase-in

Certificates and traceability GO and PoS both required

Comparable competitive conditions Only overlapping operating subsidy excluded

Allocation of emissions reductions Post-2030 Effort Sharing reform

Continued domestic support Monthly switching; new awards to end

EnDepth reading of the comparison below. Detail and sources for each issue follow.

Import access and timing

Partly provided

Platform Groen Gas position

Imports should complement domestic production, with a responsible phase-in rather than unrestricted reliance on foreign supply.

Legislative package

The revised bill already accommodates eligible foreign production. The government removed Dutch-only production and injection requirements following European Commission objections concerning free movement of goods. An amendment to restore those restrictions was rejected on 6 October.[3]

Certificates and traceability

Largely provided

Platform Groen Gas position

Accept guarantees of origin (GOs) and proofs of sustainability (PoS) through transparent, accredited systems, including the Union Database.

Legislative package

This broadly matches the proposed architecture: the draft decree requires both a GO and PoS, while the bill requires sustainability certification and mass-balance accounting. Buying a foreign GO alone would not establish compliance eligibility.[4]

Comparable competitive conditions

Partly provided

Platform Groen Gas position

Address differences in feedstock rules, waste and nitrates regulation, and subsidies before large-scale imports serve the obligation.

Legislative package

The draft already excludes production for which an operating subsidy has been paid, without distinguishing Dutch from imported gas. This addresses overlapping operating support; it does not equalise national production costs or regulatory burdens.[4]

Allocation of emissions reductions

Left to EU reform

Platform Groen Gas position

Attribute the reduction to the country consuming the gas.

Legislative package

The government supports consumption-based attribution through post-2030 reform of the Effort Sharing Regulation. However, its current explanation assigns reductions from grid-traded biomethane to the country of injection. The Dutch bill does not itself change that accounting framework.[5]

Continued domestic support

Partly provided

Platform Groen Gas position

Retain a strong SDE++ safety net until complementary measures are sufficient, including agricultural emissions measures and better commercial use of biogenic CO₂ and fertilisers.

Legislative package

The government already envisages monthly switching between SDE++ and mandate sales, rather than combining both for the same monthly production. However, it intends to stop issuing new SDE++ awards once the obligation provides sufficient financing certainty. The association seeks continued protection, not a fully specified replacement scheme.[6]

The disagreement is about when safeguards must be in place, rather than whether imports should be allowed at all. Platform Groen Gas wants competitive conditions addressed before substantial import reliance; the legislative approach opens access while retaining eligibility controls and complementary domestic measures.[2]

Order of steps in each approach Safeguard or eligibility control

Platform Groen Gas

FirstAddress differences in feedstock rules, waste and nitrates regulation, and subsidies

↓

ThenSubstantial import reliance, phased in to complement domestic production

↓

ThroughoutSDE++ safety net retained until complementary measures are sufficient

Legislative package

FirstAccess opened to eligible foreign production, with GO + PoS and the operating-subsidy exclusion as eligibility controls

↓

ThenAnnual monitoring of domestic production, imports and buy-out use; new SDE++ awards stop once the obligation provides financing certainty

↓

After 2030Consumption-based attribution, subject to Effort Sharing Regulation reform at EU level

The paper does not quantify its safeguards.[2]

Numerical import ceilingNot specified

Binding phase-in timetableNot specified

Additional support budgetNot specified

A compliance credit is not the same as a national emissions-accounting benefit. Imported biomethane can contribute to a supplier’s Dutch blending obligation without its associated reduction being credited to the Netherlands under the current Effort Sharing accounting described by the government. Matching certificates and preventing double claims are necessary, but do not resolve this separate accounting question. The government’s proposed solution requires European reform, rather than a different Dutch certificate-transfer procedure.[5]

An SDE++ safety net is not permission to stack revenues. Producers holding an SDE++ award would be able to choose the subsidy route or the blending-obligation route month by month. This can protect financing while allowing participation in the mandated market, but it does not create an automatic subsidy top-up on mandate-backed production. The government also distinguishes operating support from investment grants: it states that investment support for demonstration projects can be combined with the obligation.[5]

Continued SDE++ availability would preserve an alternative to mandate revenues while the market develops. The lobbying objective is to prevent support being withdrawn prematurely.

Making large-scale imports conditional on addressing regulatory and subsidy differences could protect Dutch producers’ competitive position while limiting suppliers’ lower-cost procurement options. As the GO-plus-PoS requirements largely mirror the draft legislation, the substantive lobbying demand is for additional competitive safeguards.

The lower house adopted an annual monitoring requirement separating domestic production, imports and use of the buy-out mechanism. That provides a basis for assessing whether the obligation stimulates Dutch investment or increasingly relies on foreign supply — but it is a review mechanism, not a domestic market-share guarantee.

Consumption-country attribution would strengthen the Dutch policy rationale for imports by aligning supplier compliance with national emissions accounting. This depends on European reform: certificate safeguards alone cannot deliver it.