Biomethane in transport: the NCW, RED III and what it means for bioCNG and bioLNG in 2026

Biomethane in transport, that is bioCNG and bioLNG, can count towards renewable targets in transport, but only once the sustainability criteria are met and provided it does not simultaneously receive operating support under the Act on Renewable Energy Sources. The RED III directive sets targets for 2030, and in Poland from 1 January 2026 the National Indicative Target (NCW) is calculated by energy value, with multipliers and caps. As a result, a biomethane producer chooses between support and sale on the transport market.

EU targets under RED III

Directive (EU) 2023/2413, amending Directive 2018/2001, requires Member States to ensure that by 2030 fuel suppliers deliver:

• at least 29% renewable energy in transport or a 14.5% reduction in greenhouse gas emissions intensity;
• a combined share of advanced biofuels and biogas from feedstocks listed in part A of Annex IX, together with RFNBO, of at least 1% in 2025 and 5.5% in 2030, including RFNBO of at least 1% in 2030;
• a cap for fuels from part B of Annex IX (1.7%) and a cap for food and feed crops (no more than 1 percentage point above the 2020 share, and no more than 7% in total).

The transposition deadline for most provisions expired in May 2025. These values should be verified in the text of the directive before making a decision.

The Polish NCW after the changes

The Act of 21 February 2025 amending the Act on Biocomponents and Liquid Biofuels (Dz.U. 2025, item 303) rebuilt the NCW: some provisions apply from 1 April 2025, others from 1 January 2026. According to the consolidated text of July 2025:

In the Act on Biocomponents, the gaseous biocomponent is biomethane within the meaning of Article 2(3c) of the Act on Renewable Energy Sources (also in compressed or liquefied form), so bioCNG and bioLNG can be counted on the numerator side, although the denominator consists of liquid fuels and liquid biofuels.

The rule of separation from support

Article 83s of the Act on Renewable Energy Sources provides that biomethane that has received support under Chapter 4a (installations up to 1 MW converted to electrical capacity) is not taken into account in meeting the NCW obligation. The amendment passed by the Sejm on 4 September 2026 extends this rule to support from biomethane auctions. In practice this means a choice:

1. Support under the Act on Renewable Energy Sources — predictable revenue, but the biomethane does not count towards the NCW.
2. The NCW market — sale to entities meeting the target; requires sustainability certification and feedstock documentation.
3. The on-site refuelling market — guarantees of origin for fuel used at the station cannot be transferred.

What is needed for biomethane to count in transport

• Sustainability and emission-reduction documentation: for transport fuels from installations commissioned after 1 January 2021 the minimum greenhouse gas reduction is 65% (RED II); check the thresholds in force in RED III and in national legislation.
• Mass balance accounting when biomethane flows through the gas grid.
• Registration of the producer with KOWR or URE and reports covering sales for the purposes of the NCW.
• Compliance of feedstocks with Annex 1 for counting with the multiplier.

Conclusions for market participants

• Producers. Calculate revenue from support and revenue from the NCW market; the choice rules out accumulation. Feedstocks from Annex 1 improve the position in the NCW.
• Fleet and station operators. Ask for sustainability documents and the mass balance rule; bioCNG and bioLNG refuelled on site have separate rules on guarantees.
• Entities meeting the NCW. Take into account the change of measure to energy value, the multipliers, the caps and the changed substitution fee rules from 2026 (general provisions repealed, and in 2026–2029 it is transitionally permitted after meeting the thresholds of Article 35d - see the table)

Questions before signing a contract for biomethane for transport

• Does the buyer meet the NCW, or does it buy biomethane for its own fleet needs?
• Who provides the sustainability documents and which certification scheme is required?
• Does the price assume the multiplier for feedstocks from Annex 1 and how will it change after the caps change?
• How are guarantees of origin settled if the biomethane is refuelled on site?
• What happens to the contract if the producer moves to support under the Act on Renewable Energy Sources (which rules out counting towards the NCW)?

Regulatory risks

• Changes to the level of the NCW and the caps — regulations or amendments may change the counting parameters.
• Changes to certification and mass balance rules in EU implementing acts.
• Divergent transposition deadlines — national provisions enter into force in stages (2025–2030).
• Exclusion of accumulation — the choice between support and the NCW requires an earlier strategic decision, because a later change may be impossible.

This text is for information only and does not constitute legal advice; before an investment or formal decision, check the current wording of the legislation and consult a lawyer or the relevant authority.