EU Renewable Compliance Explained: How RED, UDB, and National Registries Fit Together

Europe’s sustainability compliance framework for biofuels, biogas, and renewable feedstocks looks complex from the outside, but at its core, it’s built on one legal foundation and two tracking layers: EU-level infrastructure and national-level reporting systems.
Here’s a clear overview of how it all fits together.

1. The Foundation: RED II and RED III

Everything starts with the Renewable Energy Directive (RED), the EU law governing how Member States count renewable energy toward climate targets.

• RED II (2018) set sustainability and greenhouse gas (GHG) criteria for biofuels, biogas, and biomass fuels.
• RED III (2023) updates these rules, introduces tighter GHG thresholds, and mandates the Union Database (UDB) for tracking transactions across the EU.

In short:

RED sets the rules. Every other system, ISCC, REDcert, Nabisy, UDB, exists to prove compliance with those rules.

2. The EU Layer: Certification and the Union Database

a. Voluntary Certification Schemes

The European Commission recognizes independent certification systems (e.g., ISCC EU, REDcert EU, 2BSvs) to audit and verify sustainability and traceability.
These schemes issue certificates to operators across the supply chain, producers, traders, converters, confirming that their materials meet RED requirements.

b. The Union Database (UDB)

The UDB is the EU’s digital ledger for renewable fuels.
Every certified operator in scope must register and record each batch movement, feedstock, country of origin, GHG value, and volume, to ensure no double counting across borders.

Over time, the UDB will replace national spreadsheets and emails with a unified, cross-border transaction trail.

Together, certification and the UDB form the EU-level compliance backbone.

3. The National Layer: Registries and Reporting

Each member state still needs to run its own system for quota accounting, tax incentives, and domestic reporting.

These systems collect national data, even as the EU-level UDB ensures cross-border traceability.

Country	National System	Key Document	Role
Germany	Nabisy (BLE)	Proof of Sustainability (PoS)	Tracks all fuels counted toward German quotas. Mandatory entry for every certified batch.
Netherlands	REV (NEa)	HBE Credit Records	Manages national renewable energy credits (HBEs). Aligning with UDB for full traceability.
Italy	GSE / INS	Sustainability Declaration (SD)	Validates ISCC or REDcert declarations for incentives and national compliance.
France	DGEC Registry	Digital Declaration	New system under RED III to track renewable fuels and enforce blending targets.

These national registries will not disappear under RED III. They remain the reporting tools for local quota and incentive systems.

4. How It All Connects

A typical transaction follows this chain:

1. Certification: A company is audited and certified under a voluntary scheme like ISCC EU.
2. Recording: Each batch is logged into both the national system (e.g., Nabisy, REV) and, where applicable, the UDB.
3. Reporting: Operators submit data to national authorities for tax and compliance purposes.
4. Verification: Auditors cross-check that certificates, database entries, and physical records align.

So the flow looks like this:

RED III → Voluntary Scheme → UDB → National Registry → Member State Reporting

5. What’s Common Everywhere

Across all EU countries, the same rules apply:

• Sustainability and GHG criteria come from Articles 29–31 of RED III.
• Only EU-recognized voluntary schemes (ISCC, REDcert, etc.) can verify compliance.
• The UDB is mandatory for fuels in the transport sector.
• National authorities still handle quota targets and financial incentives.

6. What Still Differs by Country

What varies is how each country collects and manages the data:

• Document formats differ: Germany uses PoS; Italy uses SDs; the Netherlands uses REV entries.
• Reporting detail varies: Some countries require recipient IDs, vessel names, or delivery notes.
• Integration speed differs: early adopters like Germany and the Netherlands are already connected to UDB; others (Italy, France) are phasing in.

7. The EU Compliance Stack (Simplified)

• Voluntary schemes prove sustainability.
• UDB ensures EU-wide traceability.
• National systems manage local reporting and quotas.

8. Key Takeaways

• RED III is the law: the common foundation across the EU.
• UDB is the new, centralized EU ledger for renewable fuel traceability.
• Voluntary schemes (like ISCC EU) certify operators and authorize data entry into the UDB.
• National registries still handle domestic quotas, taxes, and incentives.
• For full compliance, companies must satisfy both EU-level (UDB + certification) and national-level requirements.

In short:

The EU’s renewable compliance landscape is layered. RED sets the rules, voluntary schemes verify them, UDB tracks them, and national systems report them.

Conclusion

Europe’s renewable compliance system may seem complex, but it’s built on a clear structure: RED sets the legal framework, voluntary schemes verify sustainability, the UDB ensures EU-wide traceability, and national registries handle local reporting. Together, they create a transparent and reliable system for tracking renewable fuels.

For companies, compliance means aligning all three layers—certification, UDB reporting, and national systems. In essence, this framework ensures that every renewable fuel counted toward EU targets is truly sustainable, verifiable, and traceable.