Dutch inland shipping faces challenges amid RED III delays in neighboring markets

Delayed RED III implementation in Germany and Belgium could create challenges for the Dutch inland shipping sector, with the Netherlands expected to implement RED III from Jan. 1, 2026.

The Netherlands is set to transition from the current HBE renewable energy units mechanism to the ERE emission reduction units system under RED III Renewable Energy Directive. Compliance will be divided across four sectors: LRE (land), ZRE (maritime), BRE (inland shipping), and RARE (refinery). The final Dutch RED III draft is awaiting senate approval before being transposed into national law.

However, market concerns have emerged regarding the effect of RED III implementation on the Dutch inland shipping sector, amid the slower progress of RED III implementation in neighboring Belgium and Germany.

"The [Dutch] inland shipping sector is lobbying to postpone the ERE system ... the implementation [of RED III] might be the end of the inland bunkering industry in the Netherlands," one Netherlands-based source said. He added that the delays in RED III implementation in Belgium and Germany mean that Dutch shipowners would choose to bunker in Germany and Belgium due to cost competitiveness.

The Dutch ERE system was designed on the understanding that RED III policies with neighboring member states would be aligned, a Netherlands-based source said. "The inland shipping sector will get harmed too much by the obligation; therefore, it [might be] postponed until Germany and Belgium will have an obligation as well."

"No offers on BRE, I don't think this market will see any activity soon," a third source said.

In May 2024, Belgium and the Netherlands signed a memorandum of understanding confirming that both countries will "align their 2030 national obligations following the revised Renewable Energy Directive for all sectors and their intermediate obligations for the maritime transport sector, and to have commeasurable intermediate obligations for the inland navigation sector."

Alignment between markets

RED III implementation in Germany and Belgium was targeted for Jan. 1, 2026, in Germany and Belgium. However, administrative roadblocks, complex parliamentary processes, and a lack of consensus among key ministries involved in drafting the bill have contributed to potential delays.

While the Dutch bill still awaits formal senate approval, the legal text of the legislation setting out the country's biofuel blending mandates until 2035 has been locked in since the bill passed the Dutch parliament, or Tweede Kamer, on Oct. 2. At the time, RED III passing the Tweede Kamer had reassured market participants of a timely transposition in neighboring markets, with Dutch officials confirming that the Netherlands was seeking to be aligned with neighboring markets.

"Our Belgian counterparts have confirmed once again that Belgium will implement the measure from January 1, 2026, [...] let us, as the Netherlands, strive for a level playing field [...] the same applies for my German colleague; we have also agreed that we will do this properly," Thierry Aartsen, the Dutch Minister for the Environment and Public Transport, said in a Tweede Kamer debate Sept. 29.

Subsequently, legal transposition of RED III has not been forthcoming in either Belgium or Germany and with less than four weeks until the end of the year, the market is widely skeptical that the bill will take effect in either market as planned from Jan. 1, 2026, onwards.

In Belgium, a public consultation on the bill closed on Nov. 14, where stakeholders were invited to provide feedback on the draft legislation. Within the initial draft, Belgium confirmed that it intended to transpose the bill by Jan. 1. Since the consultation closed, there has been no further news from the Belgian government, and market participants have widely expressed their expectation that full adoption will be delayed.

Similarly, in the German market, RED III was expected to be discussed in the Federal Cabinet, or Bundeskabinett, in the first week of October. The bill has subsequently been postponed for weeks amid a reported lack of consensus among the key ministries involved in drafting the legislation. At the time of writing, the topic is not due to be discussed in the cabinet for at least another two weeks, meaning that the remaining parliamentary procedure to ensure full legal adoption now cannot be completed before the end of the year. Market participants, therefore, anticipate that the most likely outcome will be a retroactive or delayed implementation

Amid these concerns that RED III could be delayed in both Belgium and Germany, the market now awaits a response from the Dutch government, with multiple sources noting that a delay to the Dutch obligation on inland shipping could be feasible due to concerns surrounding competitiveness.

The Dutch Emissions Authority was unavailable for comment at the time of writing.

Platts is part of S&P Global Energy.