An agreement within reach, but blocked

The European Renewable Energy Directive requires fossil fuel suppliers to ensure an increasing share of renewable energy in road transport. Suppliers of renewable electricity, hydrogen or other renewable fuels receive e-credits for this, which fossil fuel suppliers can purchase to meet their obligations. This mechanism already exists  under the supervision of the FPS Economy, but urgently needs to be amended following the most recent revision of the European directive. The transposition of the new targets set out in RED III Transport is absolutely essential to ensure the mechanism continues to function and to provide the necessary incentives to various sectors, including the hydrogen and EV sectors. EV Belgium called on the competent minister in April 2025 to take the necessary action, but this call has not yet been heeded. 

Belgium has long since exceeded the European deadline for transposing RED III Trasport. Whilst our neighbouring countries are continuing to expand their frameworks for renewable energy in transport, Belgian investors in electric transport and charging infrastructure are still waiting for clarity. This delay comes at an economic cost. However, transposition is explicitly mentioned in the federal coalition agreement. A broad coalition of companies from the energy, transport and industrial sectors recently reiterated their call to the government in a joint letter, urging it to bring the targets into force on 1 January 2027. At government level, an agreement is within reach, but a formal decision is still pending. 

An unnecessary political deadlock, according to EV Belgium., according to EV Belgium. The delay in reaching this decision has had a direct impact on the value of e-credits, which has plummeted over the past year from approximately €18 to €5 per credit, corresponding to a fall from €0.07 to €0.02 per kWh. By way of comparison: in the Netherlands, where RED III Transport has already been implemented, the average value currently stands at €0.10 per kWh. By  2026, this will have cost the Belgian charging point sector just under €4 million in investment capital. By the end of 2027, this is estimated to rise to more than €27 million. The scale of this figure demonstrates why policy certainty is essential.

We are simply having to cope with the current energy crisis and the associated price shocks. While we are in control of the implementation of RED III Transport ourselves, and this will lead to greater independence from these oil price shocks. Various reports from abroad (including TU Delft) explicitly show that greater electrification (can) reduce overall costs – even for people with diesel and petrol cars – because electricity is cheaper than biofuels for meeting the target. An argument in favour of Belgium’s transposition of RED III Transport.

What is at stake

Economically:

The payback period for a charging hub falls under a well-functioning system. This has a real impact on investment and the ultimate charging price for consumers. A credit system can therefore literally make the difference between investing and pulling out. At present, investors are moving to our neighbouring countries, causing growth in charging infrastructure in Belgium to stagnate since the last quarter of 2026. The Netherlands and Germany have already implemented RED III Transport, with new targets in place since 2026. France will follow from 2027. There, every kWh of renewable electricity yields a stable return, which is reinvested in our economy, jobs and mobility. Companies planning to invest millions of euros in charging hubs are now looking primarily to those neighbouring countries. Every month of delay increases the risk that companies will move their operations across the border.

Competition in the transport sector:   

Although we are a European frontrunner when it comes to the electrification of passenger cars in Belgium, we are lagging behind when it comes to vans and trucks. For a logistics hub such as Belgium, this poses a real risk. Stable E-credits for charging can also make a real difference to the business case for an electric truck. Our neighbouring countries already offer this benefit to their logistics operators, but Belgium does not, and thus risks losing its competitiveness.

Climate:

This cost-effective CO₂ reduction measure remains unused for an unnecessarily long time, even though it has no impact whatsoever on public finances as it is a self-sustaining system. Road transport accounts for almost 29 per cent of our greenhouse gas emissions, a share which, according to the latest report from the Flemish Energy and Climate Plan, is the only one to have risen since 1990. Making road transport more sustainable is the most efficient way to reduce these emissions. Without ambitious targets, Belgium is missing out on a key lever for meeting its European climate commitments, running the risk of fines or having to make costly purchases of emission allowances from abroad. Moreover, technical and affordable solutions for reducing CO₂ emissions are already available in the transport sector. Those who fail to make use of them are shifting the burden onto industry, agriculture and households, where such reductions are often more difficult and more expensive to achieve.

What is needed now

The transposition of RED III Transport, which is set out in the coalition agreement, and the European deadline has long since passed. Any further delay undermines the legal certainty that investors are seeking, and opens the door to European infringement proceedings. The increased targets resulting from this legislation provide significant leverage for making the transport sector more sustainable and – as proven by various studies abroad – cost the public virtually nothing.

Evidence of this can be found abroad (including TU Delft), where it has been explicitly demonstrated that greater electrification can reduce overall costs – including for people with diesel and petrol cars – because electricity is cheaper than biofuels when it comes to meeting the target. 

• In the Netherlands, for example, it is estimated that the transposition of RED III will – thanks to its timely transposition – result in a fall of 2 eurocents per litre for petrol and a rise of up to 0.09 euros per litre for diesel.

• In Germany, the cost of implementing RED III is estimated at between 0.05 and a maximum of 0.15 cents per litre. The clear message is that this ‘cost’ is being invested in the German economy. 

• In France, the government itself states that the changes will result in an increase of “quelques centimes d’euros par litre” (a few eurocents per litre) compared with the current system.

There are therefore strong arguments in favour of Belgium’s transposition of RED III Transport, provided it is done properly. Without the transposition of RED III Transport, the phasing out of polluting, expensive fossil fuels and the installation of charging points (including competitive charging rates) will come under increasing pressure. It is therefore important that the government takes the necessary next steps in the very near future:

1. Ensure the transposition of RED III Transport, which comes into force on 1 January 2027, including its ambitious targets. Investors and end-users are counting on that date.

   • Given the political process that lies ahead, this will most likely take partially effect retrospectively in 2027 (f.e. the Royal Decree). This need not be a problem in itself, as it has also happened in the Netherlands, Germany and Spain.

   • Targets that are set too low keep credit prices low and undermine precisely the investments that the directive is intended to promote. A specific target for renewable electricity could boost the value of the credits even further.

1. Renewable electricity is already the largest and fastest-growing renewable energy source in road transport. The revised framework must urgently recognise: 

   • Credits that reflect the actual amount of renewable energy. 

   • Credits that are accepted at all charging points, including private ones. 

     • The same Dutch analysis suggests that taking home-charged electricity into account could mitigate the estimated price rise by 2 to 5 cents/l compared with a scenario without home charging. 

     • The same can be said of recognising the actual amount of renewable energy. 

2. A predictable and technology-neutral framework, with a register that operates in a legally certain and straightforward manner. This ensures that credit remains a reliable source of funding for the transition. 

   • The current barriers and administrative burdens associated with the register must be reduced so that smaller operators and transport companies can also take part.

No one in Belgium can choose when the next energy crisis will strike or what the price of oil will be tomorrow. What we can do, however, is choose to implement RED III Transport ambitiously and provide the necessary guarantees for investors, jobs and a competitive charging price. The coalition has the agreement within its grasp. We call on it to finalise this this autumn, so that the new targets come into force on 1 January 2027. Anyone wishing to assess RED III must consider both sides of the equation: the perceived additional costs at the pump, on the one hand, and the value of renewable electricity, the investments it enables, and the economic damage caused by further delay, on the other. The Belgian government must make the underlying pump price more transparent and urgently provide clarity on the implementation of REDIII Transport.

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