Ben Salt is a senior commercial analyst at Peninsula. Image Credit: Ben Salt / LinkedIn

The bunker market in Europe can expect to see years of complexity ahead from a fragmented implementation of the EU's Renewable Energy Directive (RED) across the continent, according to global supplier Peninsula.

The latest revision of the directive, RED III, sets targets for the share of renewables in the EU's energy mix by 2030, and is in the process of being rolled out across the continent, but without firm controls from Brussels on exactly how it should be implemented. The Netherlands has been among the first out of the gate to bring the directive into its domestic law this year, and has chosen as part of its targets to impose a renewable energy requirement onto fuel sales to the shipping industry at its ports. 

The bunker market is in the process of adjusting to this change, and can expect to see further complexities as different member states implement the directive in different ways, Ben Salt, senior commercial analyst at Peninsula, said in an interview with Ship & Bunker.

"It's just created a very complex ARA market," Salt said.

"You had MFMs introduced to some ARA ports as well, so you've had a situation where some ARA ports have RED III, some have MFMs, and it's all happening at the same time.

"A lot of it for us is about being in a position to guide shipping companies through that process."

The Regulation

At an EU level, the regulation requires the transport sector to ensure a 29% share of renewables in energy consumption, or a minimum 14.5% reduction in GHG intensity.

In many markets, progress towards this target is reflected by the issuance of tickets, tradable certificates used to demonstrate compliance with decarbonisation goals.

For marine fuel suppliers in the Netherlands, the practical effect means sellers of conventional marine fuels need to declare a certain quantity of ZRE tickets either through the sale of biofuels or procuring them from others.

“Suppliers don’t need to physically blend the fuel, but must hold compliance tickets at year-end in proportion to the total emissions from delivered bunker volumes," Salt said.

"That’s why it’s very important for a bunker supplier in the Netherlands to now be monitoring its ticket exposure and ensuring that it has the right amount of tickets to comply."

In the Netherlands, maritime compliance tickets are known as ZRE tickets.

"Each ticket represents a 1 kg CO2e reduction in emissions and can be traded within the Dutch system," Salt said.

"Similar to other market-based mechanisms, this framework helps ensure the industry collectively meets its GHG reduction targets in the most efficient way.

“They’re priced like any other market instrument, on a daily basis, with movements driven not only by supply and demand but also by the biofuel blending economics at any given point in time.

"Recently, conventional marine fuels have risen much faster than biofuels, which have been less affected by the Iran war. This has lowered additional biofuel blending costs, which in turn typically supports lower biofuel ticket prices.”

ARA Impact

Image Credit: Ship & Bunker / Data Credit: Port of Rotterdam / Port of Antwerp-Bruges

The Netherlands has imposed its RED III target for the bunker industry since the start of this year, while Belgium has yet to implement RED III.

This has meant that Rotterdam has had an additional regulatory cost to contend with this year compared to neighbouring Antwerp.

The effect has been clear: in the first quarter Rotterdam's bunker sales dropped by 648,399 mt from the previous quarter, reaching the lowest level since at least 2009, while those at Antwerp-Bruges gained 662,506 mt over the same period.

Peninsula has seen the Rotterdam versus Antwerp premium reach $20/mt this year, Salt said.

This tallies with Ship & Bunker data, which show an average premium for Rotterdam VLSFO over Antwerp of $12/mt in 2026 so far, compared to an average premium of just $0.50/mt in the second half of 2025.

Fragmented Implementation

The Netherlands is not expected to reverse its decision to include maritime fuel sales in its targets now the impact has become clear, Salt argued.

“I think it would be very unlikely," he said.

"It’s important to remember that decisions like this are made in the Dutch parliament, it’s not made at the local authority level.

"In the bunker industry we look at this very much through a bunker lens, but this is a policy that ultimately affects the whole of the transport sector in the Netherlands.”

But while the position of the Netherlands is now clear, those of other EU member states is much less so.

“I think it will be very fragmented; we’ll see lots of different approaches," he said.

"From what we’ve seen so far, specifically regarding RED III for maritime, you’ve got some member states only targeting domestic vessels.

"Some may include oceangoing vessels like the Netherlands, and some aren’t looking at maritime at all.

“Meanwhile, the types of biofuels qualifying under different schemes can vary."

It had originally been expected in the market that the Netherlands and Belgium would implement RED III at the same time, Salt said.

"I think there was a common understanding that Germany would proceed as well, but in the end, it was just the Netherlands that went ahead out of the three, launching in 2026.

“There are reports that Belgium is likely to implement RED III in 2027, including maritime, but nothing has been confirmed and we are awaiting the final details.”

This means that further Red III ‘arbitrage’ situations are likely to emerge between now and 2030, Salt argued.

"I don’t know whether every country will enact a maritime-specific target, but I think you will have more than just the Netherlands,” he said.

“We could easily see a situation where neighbouring countries implement RED III concurrently, but with different scopes - for example, one applying it to oceangoing vessels and another to domestic shipping. These are the kinds of divergences likely to emerge in the coming years.”

Upside for Biofuel Sellers

The corollary of the pain for conventional bunker suppliers at Rotterdam this year is that biofuel suppliers are seeing benefits, Salt said.

"There’s two markets in the Netherlands at the moment, you have the conventional market and the biofuel market," he said.

"When you sell conventional, you create a ticket exposure, so when you’re quoting conventional you have to factor in the cost for the required tickets to cover your exposure.

"But the flip side is when you’re offering biofuels, you’re actually generating these surplus tickets, which allows the Dutch biofuels market to be incredibly competitive.

"Peninsula offers both conventional and biofuels, and for people looking to lift biofuels in the region, the Netherlands remains highly competitive.”

This effect can be seen in comparing prices for B30-VLSFO blends in Rotterdam to the B25 blend more commonly sold in Singapore. Rotterdam B30 has traded at an average discount of $3.50/mt to Singapore B25 so far this year, according to Ship & Bunker prices, compared to an average premium of $53/mt in the second half of 2025.

“In anticipation of RED III, Peninsula has significantly expanded its biofuel capabilities, and is better positioned than ever to support customers seeking to transport goods globally with a lower carbon footprint," Salt said.

“With biofuel blending premiums still low versus conventional fuels, there’s also a great window of opportunity right now for buyers to meet compliance obligations at low costs.

“Beyond the Netherlands, we operate physical biofuel supply across Europe and have delivered biofuels at more than 20 ports worldwide—positioning us to support customers wherever their demand is.”