Yπουργείο Περιβάλλοντος και Ενέργειας

Δικτυακός Τόπος Διαβουλεύσεων

• Σχόλιο του χρήστη 'Matthías Ólafsson' | 13 Απριλίου 2026, 12:17

  Μόνιμος Σύνδεσμος

  The eFuel Alliance appreciates the opportunity to provide feedback on the Greek national specifications for RED III, while we acknowledge the 2026 binding date, the current targets and regulatory gaps risk making Greece a late mover in the European eFuel market. We propose the following improvements: 1. Elevate RFNBO Ambition to secure investment The current 1% RFNBO sub-target for 2030 provides insufficient demand to trigger industrial-scale projects. With vast wind and solar energy resources coming online in 2026 and onwards, Greece has the potential become a hub for PtX deployment in Europe, a role already assumed by Spain and Portugal. In order to realize its potential, Greece must leverage the opportunity presented by the RED by imposing a higher minimum RFNBO obligation and spur the development of a new industry. To secure competitive positioning, Greece should adopt 5% RFNBO sub-quota with an interim 1%step in 2028, benchmarking against other European maritime and transport hubs such as Finland and Belgium that have integrated an obligation of 4% and Spain at 2.5%. It is worth noting that a 5% mandate would only result in a modest price increase of 6-8 euro cents per liter of petrol/diesel. Assuming a 8% blend, pump prices remain competitive at approximately €1.88-2.09 per liter. Finally, a longer-term demand signal would provide added certainty to Greek RFNBO deployment. Thus we´d recommend adopting a 2040 RFNBO obligation of 8-12% such as 2. Emphasize physical deployment of renewable fuels Artificially inflating compliance figures without physically displacing fossil fuels by use of multipliers is generally discouraged. We emphasize that such mechanisms weaken essential demand signals, noting that multipliers – such as the 2x road/rail and 1.5x aviation/maritime factors proposed for Greece - can reduce actual fuel supply to a negligible fraction of the stated target. To ensure the environmental integrity of the Greek transposition, we strongly recommend replacing these multipliers with quotas based on actual physical energy content, mirroring the successful and transparent model adopted in Finland. Eliminating these distortions is the only way to provide the market visibility and planning security required to attract large-scale investment in domestic RFNBO production capacity 3. Clarify penalty structure The currently proposed penalty structure is opaque and ill fit for purpose. Greek fuel suppliers failing to meet renewable targets face administrative fines ranging from €1,000 to €1,500,000. The specific penalty is determined based on the severity, frequency, and consequences of the violation, with a three-year window for identifying repeat offenders. To incentivize fuel deployment over buy-out strategies, penalties must be intelligible, predetermined and explicitly exceed production costs. A stringent energy content-based penalty of at least €80–120/GJ such as those deployed by Germany and France would serve as a more comprehensive signal to market actors. 4. Harmonize maritime disparities Uncoordinated national maritime targets risk creating a regulatory patchwork that distorts fuel bunkering strategies and complicates the path for producers to meet localized needs. While Greece proposes a 1.2% maritime RFNBO sub-target for 2030, this level of ambition is vastly overshadowed by the 2.6% quotas introduced in the Netherlands and Belgium, creating clear regional disparities in fuel availability. We argue that without a harmonized EU trajectory, developers face a maze of varying targets which ultimately increases the cost of capital and weakens investment signals for the Greek fleet. Therefore, Greece must harmonize its approach to maritime fuel supply obligations and ensure its domestic incentives lead to cross-border price stability. eFuel Alliance The eFuel Alliance an interest group that advocates for the political and societal acceptance of eFuels and for their approval. We represent more than 160 companies, associations, and consumer organizations along the entire value chain of eFuel production. We stand for fair competition and equal market conditions for all relevant emissions reduction solutions. We are firmly committed to greater climate protection and aim to ensure that the significant contribution of eFuels to sustainability and climate protection is widely recognized. Our goal is to enable the industrial production and widespread use of CO₂-neutral fuels made from renewable energy sources.