LTO Nederland believes that the proposed green gas blending obligation offers insufficient certainty that new production capacity will be added in the Netherlands. The organization wrote this in its submission of August 12 for the online consultation on the ministerial regulation, which closed a day later. LTO supports the cabinet's ambition to substantially increase green gas production but questions the implementation.
The scheme aims at chain emission reduction, calculated via the CI score for carbon intensity. LTO also sees an advantage in this, because routes with high climate performance, such as mono-digestion of manure, receive an additional incentive, and because this allows the sector to transition from subsidies to stable market demand in the long term. The objection lies in what the system does not guarantee.
Existing installations can fulfill the obligation.
According to LTO, green gas is indispensable for the energy security of the Netherlands, “provided it is produced in the Netherlands”. According to the organization, this is where the problem lies. The scheme rewards realized emission reductions but does not guarantee that new installations will be added.
LTO points out two ways in which the targets can be met without any additional construction. A significant part of the obligation can be fulfilled using existing Dutch production capacity for which the SDE++ subsidy is expiring, or with foreign certificates and production flows. In both cases, the objective is formally met, while scaling up in the Netherlands fails to materialize.
In addition, the known bottlenecks for new projects remain unchanged. LTO cites permitting, nitrogen space, grid capacity, financial certainty via the existing SDE++, and clarity regarding manure valorization. According to the organization, without progress on these dossiers, it is uncertain whether the desired expansion will materialize, regardless of the impact of the blending obligation on demand.
The reasoning behind the call is that Dutch users bear the costs of the scheme, and that the market demand created thereby should benefit Dutch production capacity as much as possible. LTO asks the Cabinet to examine how demand stimulation can be more strongly linked to new capacity, and to focus not exclusively on emission reduction but also on broader goals. Mentioned are methane and nitrogen reduction, manure valorization, circular agriculture, regional energy production, and energy security. According to LTO, production capacity in the Netherlands requires a tailored approach that must be tackled on an area-by-area basis and in collaboration with involved parties.
Chairman Ger Koopmans states that it is precisely the accumulation of societal benefits that makes green gas valuable for the Netherlands. According to LTO, mono-digestion of manure, especially in combination with daily fresh manure removal and manure valorization behind the digester, contributes not only to energy but also to the agricultural transition and a revenue model for farmers.
Why steering towards Dutch production is difficult
LTO states that the obligation may not be fulfilled with imported green gas, foreign certificates, or foreign production flows. An exclusion of foreign green gas was previously included in the legislative proposal and has since been removed.
This is evident from the advice of the Council of State of 18 March 2026. Following notification of an earlier version, the European Commission issued a detailed reasoned opinion, after which the proposal was amended. In the current version, foreign green gas is no longer excluded. However, the matter is not yet closed: the Commission sent a further response with questions on 16 February 2026, to which the Netherlands replied on 3 March. The Council of State advises the Cabinet to address the relationship to the free movement of goods and services and to the freedom of establishment in greater detail, and to resubmit the proposal if the notification procedure leads to substantial changes.
The Advisory Division also raised a concern regarding the supervision. The Union database, in which transactions involving renewable fuels are registered, is currently only partially operational, and it is unclear when this will change. According to the Division, this raises the question of how reliable supervision of links abroad is possible, and whether it is responsible to start the obligation as long as that database is not fully operational.
How the obligation works
Energy suppliers will soon be required to deliver an increasing amount of green gas to end users annually. They comply with this requirement using green gas units, where one unit represents one kilogram of avoided CO2 equivalent across the entire chain. The number of units depends on the supplier's market share. Through an annual growth path, this must reach a chain emission reduction of 2,85 megatons by 2031. The units are tradable; it concerns a national trading system that is not based on European legislation. The Dutch Emissions Authority (Emissions Authority) oversees this.
Dutch green gas production is currently around 300 million cubic meters per year. The intended effective date of the obligation is January 1, 2027. For households, the explanatory memorandum to the bill estimates the additional costs at a maximum of sixty euros per year in 2031, noting that they will likely turn out lower.
Sources: LTO Nederland , input for the consultation on the Green Gas Blending Obligation Regulation, 12 August 2026, and the advice of the Advisory Division of the Council of State on the Green Gas Blending Obligation Act, 18 March 2026
Photo: scharfsinn86, Adobe Stock
