Brief context
The Renewable Energy Directive (RED) is the EU's primary regulatory instrument for decarbonising transport fuels. RED II (2018) established double counting for UCO-based biodiesel: 1 litre counts as 2 "green" litres in country-of-blend reporting. RED III (2023, implementation 2025–2026) shifts the emphasis.
The central change in RED III is stricter supplier-side ISCC documentation. The question of UCO origin is addressed through real-time mass-balance accounting.
Three changes that matter for Ukraine
1. Cap on double counting in the fuel blend
RED III limits the share of double-counted categories to 1.7% of the total transport fuel volume per year (country-level). In countries with large UCO import volumes (Netherlands, Germany), quota fills quickly, so trade contracts should be planned well ahead.
2. Higher traceability bar
From January 2026 — mandatory registration of points-of-collection in the pan-European Union Database (UDB). Every partner establishment must have a system entry. Registration is performed by the collection operator.
3. Lab confirmations for exporters
Every UCO batch exported to the EU from 2027 onwards requires a laboratory passport issued by an accredited lab. Accreditation details to be confirmed.
What changes for the operator
Operationally — a substantial IT load: UDB integration, lab APIs, online mass-balance sync. EKO-OYLIS treats compliance infrastructure as an ongoing investment. For clients, the changes remain invisible — same container, same schedule, same manager.
Conclusions
RED III is not "competition drives up price" but "the bar has risen, small collectors without compliance will leave the market". For EKO-OYLIS partners, preparation for the transition is already underway.