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Ministerial scheme for double counting of advanced biofuels


The Ministerial scheme for the double counting (or double disclosure) of advanced biofuels was published on 9 December 2009. The complete text of this scheme is available (in Dutch) here.

The following sections provides information on the following aspects of this scheme:


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1. Summary of the Ministerial scheme for double counting advanced biofuels

This is a Ministerial scheme that falls under the Transport Biofuels Act 2007  (in Dutch: Besluit biobrandstoffen wegverkeer 2007).

This legislation was published in 2007, and has since been modified several times, for example in order to allow double counting of advanced biofuels (in Dutch: wijziginsbesluit). The scheme aims to encourage the development of more sustainable biofuels. It allows double counting of these biofuels if the quantitative obligations for biofuels are achieved. The start of the scheme has been backdated to 1 January 2009.

2. Why has this scheme been implemented?

This scheme results from a desire by the Lower House of Parliament to implement double counting of more sustainable biofuels as quickly as possible. The scheme also includes the preliminary implementation of part of the European Directive.

The complete implementation of this Directive under   Dutch legislation, which must be finalised before the end of 2010, may lead to future amendments or modifications to the current scheme for double counting advanced biofuels.

3. Biofuels to which this scheme applies

This scheme applies to biofuels that are produced from waste, residues and lignocellulosic material, and includes a list of the various definitions of waste.

Only raw materials that cannot be used for more valuable applications than for generating electricity or heat, composting or using lignocellulosic components (such as animal fodder) are eligible for double counting. If an alternative application exists for a particular raw material, then a market analysis must be used to prove that there is an excess of this material available, in order to be eligible for double counting. Biofuels made from lignocellulosic material are always eligible for double counting. The scheme is further only applicable to biofuels with a greenhouse emission reduction of at least 35%.

4. Ways in which companies should determine the greenhouse gas emission reductions of biofuels that are eligible for double counting

The greenhouse gas emissions should be determined using the Appendix attached to the legislation.

Standard values for several combinations of biofuels and raw materials are shown in the table contained in Part B of Appendix I. For combinations that are not included in this table, companies should make their own calculations following the methodology described in Part C of Appendix I.

5. Proving that biofuels meet the criteria for double counting

In order to prove that biofuels are eligible for double counting, companies must send information to the Ministry of VROM annually, as part of their reports concerning the obligatory market share of biofuels (see article 4, clause 3,   of the Ministerial Scheme for the Administration of Biofuels (in Dutch: Ministeriële Regeling Administratie Biobrandstoffen).

This should take the format used in Appendix II of the scheme. For biofuels listed in Appendix III, only part of Appendix II needs to be completed. This concerns biofuels that are produced from lignocellulosic parts of raw materials, raw glycerine, used cooking oils and fats, or animal fats. Companies only need to supply information showing that the information concerns these types of biofuels. The information supplied by companies must be accompanied by a so-called 'verification statement', which should provide a reasonable amount of certainty that the information supplied by the company meets the criteria for double counting the particular batch(es) of biofuel.

6. Criteria to which the inspection institutes must comply in order to issue a verification statement under the framework of this scheme

Inspection institutions that are authorised to issue verification statements must be accredited according to the information standard NEN-EN ISO/IEC 17020, type A. The institution must also be accredited by the RvA (Council for Accreditation) for the additional tasks relating to the double counting of biofuels, or must have completed the preliminary process to achieve accreditation, even if the complete procedure is not yet finalised.


Inspection institutes use the verification protocol  (in Dutch: verificatieprotocol [pdf - 1 Mb]) that has been developed by the Ministerial scheme for double counting advanced biofuels. This protocol consists of basic rules, procedures and guidelines for verifying double-counted biofuels. The verification process consists of two phases. The first, preparatory, phase is where the auditor gathers all the necessary information from the manufacturer (and, where necessary, from distributors), and visits the production site. On the basis of this information the auditor conducts a risk-analysis and draws up a verification plan. The second phase consists of the actual audit and random checks, with reports of the tasks implemented and the conclusions drawn. If all criteria have been met, the inspection institute issues a verification statement at the end of phase two.

7. History of the verification protocol for double counting advanced biofuels

In August 2009, SenterNovem commissioned KEMA to draw up a verification protocol. After developing an initial draft protocol, KEMA and Control Union implemented three trial verifications at biofuel manufacturers.


After evaluating these trials, a final version of the protocol was drawn up (in Dutch: eindrapport [pdf - 984 Kb]). SenterNovem is currently responsible for managing the verification protocol.

8. Is there an English-language version of the Ministerial scheme for double counting advanced biofuels?

Yes, there is an English version: Double Counting Order.

VROM and GAVE make no official translation of the verification protocol. We have no problem if others choose to translate this text and make it available to foreign inspection institutes, for informational purposes. With respect to both documents (Ministerial scheme for double counting, and the verification protocol for double counting), the Dutch-language version is legally binding. In other words, where there are interpretational differences, the Dutch version is valid. Use translations at your own risk.

9. Further information

Further information on the scheme and the verification protocol is available via the following documents:
• Scheme for double counting advanced biofuels (Double Counting Order [pdf - 373 Kb])
• Verification protocol for double counting advanced biofuels (in Dutch: Verificatieprotocol dubbeltelling betere biobrandstoffen [pdf - 1 Mb])
• Final report by KE (in Dutch: Eindrapport KEMA [pdf - 984 Kb])
• Previous questions 


On 29 October 2009, SenterNovem organised an informational meeting on the Ministerial scheme for double counting advanced biofuels and the verification protocol. The presentations from this meeting are available (in Dutch) here.

Should you have any further questions on the Ministerial scheme for double counting advanced biofuels, please contact SenterNovem: Simone te Buck (gave@senternovem.nl).

Most recent change | 08-01-2010