RED III: the transposition deadline passed on 21 May 2025. Poland among the delayed

The transposition deadline for the Renewable Energy Directive RED III expired on 21 May 2025. The directive entered into force in November 2023 and changed the rules of EU renewable energy policy: it raised the binding target for the share of renewable energy to 42.5% in 2030 (with an indicative 45%), introduced new sub-targets for transport, industry, heating and buildings, and tightened the sustainability criteria for bioenergy. Most Member States did not manage to implement it in time.

What RED III changes for biogas

For the biogas and biomethane industry three elements are most important: new support rules and sustainability criteria (including a higher emission-reduction threshold for installations commissioned after 20 November 2023 – in Germany 80% instead of 70%), targets in transport (both the share of renewable energy and a reduction in emission intensity, with a sub-target for advanced fuels and RFNBO), and requirements in industry, where renewable fuels in thermal processes are desired. Transposition also covers the Union Database, that is the mandatory registry for tracking renewable fuels.

State of implementation

Member States were obliged to notify the Commission of implementing measures, and most did not manage complete transposition. If transposition is missing, the Commission may start infringement proceedings: first a letter of formal notice, then a reasoned opinion, and finally referral of the case to the Court of Justice of the EU and a demand for financial penalties.

Poland has been implementing RED III in stages. The amendment of the Act on Biocomponents and Biofuels (February 2025) set the transport targets. Work was under way on provisions on mapping RES potential and renewable acceleration areas (OPRO), on rules for energy cooperatives and tenant prosumers, and on an amendment of the Act on Renewable Energy Sources that was to complete transposition.

Significance for the industry in Poland

The delay in transposition has practical consequences: operators do not know the final sustainability criteria, the rules for registering fuels in the Union Database, or the requirements for sub-targets in transport and industry. For biomethane plants this means uncertainty when concluding long-term contracts with customers who must demonstrate compliance with RED III. For the market in guarantees of origin and certificates it is key that national rules be consistent with EU rules.

For businesses the practical conclusion is that projects planned for 2026–2030 should already today adopt the tightened RED III emission-reduction criteria (in Germany, for example, 80% for new energy installations), even if Polish provisions are passed later.

What next

Member States that did not manage transposition may expect letters from the Commission under the infringement procedure. Poland has been implementing RED III in stages: the amendment of the Act on Biocomponents and Biofuels (February 2025) set the transport targets, and further provisions – including on mapping RES potential and renewable acceleration areas – were in preparation. For the industry, the rules on sustainability and on registering fuels in the Union Database, and decisions on national criteria for bioenergy, will be key.