THG-Quote & Biomethane — Germany's GHG Quota for Transport Fuels
Germany's THG-Quote (Treibhausgasminderungsquote) has driven biomethane demand in the transport sector since 2015. From 2026, RED III transposition reshapes the system: advanced biofuel quota raised to 2%, double counting abolished, anti-fraud measures tightened. BioGem Express delivers Nabisy-registered biomethane volumes structured for the new framework.
What is the THG-Quote, and why does it shape the biomethane market?
The THG-Quote (Treibhausgasminderungsquote — GHG reduction quota) is Germany's primary regulatory instrument for decarbonising transport fuels. In place since 2015, it requires fossil fuel distributors to reduce the lifecycle GHG emissions of the fuels they place on the market. Biomethane used as Bio-CNG or Bio-LNG generates GHG reduction credits that fossil suppliers can buy to fulfil their quota — creating the structural demand that has shaped the German biomethane transport segment for the past decade.
Within the THG-Quote system, manure-based (Gülle) biomethane historically delivered the highest commercial value. The reason: under RED methodology, the credit for avoided methane emissions from open-air manure storage offsets production emissions, producing very low or even negative GHG intensity values per MJ. This translates directly into a quota credit advantage. According to S&P Global's European Biomethane Outlook (2025), the THG-Quote has created strong positive margins for biomethane certified by Proof of Sustainability — particularly for unsubsidised manure-based volumes.
The market structure is changing. The quota price has effectively settled at the Pönale (penalty) level for non-fulfilment, and the RED III transposition into German law — draft published June 2025, in force from early 2026 — reshapes several mechanics. Biomethane traders and producers planning multi-year supply must understand both the current system and the post-2026 framework.
The German RED III transposition takes effect early 2026. Advanced biofuel sub-quota: 1% → 2%. Double counting (Doppelanrechnung) abolished — meaning the same physical MWh no longer counts twice for advanced biofuels. UER credits removed. Automatic quota adjustment on overfulfilment introduced. Anti-fraud measures tightened for advanced biodiesel imports (notably from Asia). From 2027, prior-year overfulfilments can be credited again — likely with a price-dampening effect. Net impact: more physical biomethane required to fulfil the quota, but per-MWh financial multipliers reduced.
RED III THG-Quote reform — before vs. after
| Element | Before 2026 | From 2026 (RED III) |
|---|---|---|
| Advanced biofuel sub-quota | 1% | 2% |
| Double counting | Allowed (Doppelanrechnung) | Abolished |
| UER credits | Permitted | Removed |
| Quota adjustment on overfulfilment | Manual / not automatic | Automatic |
| Carryover of overfulfilment | Limited | From 2027: prior years can be credited |
| Anti-fraud (advanced biodiesel) | General customs framework | Tightened anti-fraud measures |
Source: German RED III draft regulation (June 2025); Naumann & Etzold / DBFZ (2025) — Szenarien zur THG-Quote.
How biomethane fulfils the THG-Quote
Three steps connect a certified biomethane volume to a GHG reduction credit recognised by Germany's transport sector quota.
Biomethane certified & injected
Biomethane is produced from RED-eligible feedstock — manure, organic waste, energy crops, or residues — and certified under ISCC EU or REDcert EU. The lifecycle GHG value is calculated per the producer's specific feedstock pathway. Manure-based biomethane typically delivers the lowest (and sometimes negative) GHG intensity values, which translates directly into commercial advantage under the quota.
Registered in Nabisy
The Proof of Sustainability is registered in Nabisy, Germany's national sustainability registry operated by the DEHSt (Deutsche Emissionshandelsstelle). The PoS travels through the supply chain — producer, trader, fossil fuel distributor — with mass-balance documentation. Nabisy is mandatory for biomethane volumes used to fulfil the THG-Quote; a separate Biogasregister entry may also be required for some accounting paths.
Quota credit applied
The fossil fuel distributor uses the biomethane volume's certified GHG reduction value against its annual quota obligation. The credit is calculated against the fossil reference (RED methodology) — biomethane with low GHG intensity generates more quota credit per MWh. Under the post-2026 framework, double counting is no longer applied, so the credit reflects the physical energy and the actual GHG saving — without the historical multiplier.
Four mechanics that shape the THG-Quote biomethane market
The quota is well established, but its mechanics reward the prepared. Understanding feedstock economics, certification requirements, and the post-2026 transition is what separates a strong supply position from a weak one.
Manure-based feedstock premium
Manure-based biomethane achieves very low or negative GHG intensity values under RED methodology — driven by the credit for avoided methane emissions from open-air manure storage. This produces a structural premium under the THG-Quote system. With double counting abolished from 2026, the quota requires more physical biomethane volume, making low-GHG feedstocks more valuable, not less.
PoS via Nabisy — not GoO
THG-Quote compliance requires a Proof of Sustainability under ISCC EU or REDcert EU, registered in Nabisy. A standard Guarantee of Origin under RED Article 19 is not sufficient — the system requires mass-balance traceability through the fuel supply chain. This is the single most common confusion at the point of buyer onboarding.
Bio-LNG holds, Bio-CNG declines
CNG passenger car uptake in Germany has declined sharply in recent years; Bio-CNG demand follows. LNG trucks remain strong — supported by toll exemptions until end of 2023, ongoing operational economics, and reinforced by FuelEU Maritime demand pulling Bio-LNG into shipping. Producers and traders weighting their portfolio toward Bio-LNG are aligned with where the demand is structurally moving.
Anti-fraud measures from 2026
The RED III reform tightens anti-fraud measures, particularly targeting fraudulent advanced biodiesel imports. For biomethane producers and traders, this strengthens the value of clean, well-documented EU supply chains. Buyers running THG-Quote portfolios are increasingly cautious about origin verification — a documentation discipline trader's role becomes more important than ever in the post-2026 environment.
Your THG-Quote supply partner
The THG-Quote isn't going away — it's tightening. From 2026, the buyer who relied on double counting needs more physical volume; the buyer who relied on opaque origin documentation needs clean PoS chains; the buyer who structured around a 1% advanced biofuel sub-quota now operates against 2%. The reform creates pressure across the supply chain.
BioGem Express sources certified biomethane — manure-based, waste-based, and RED-eligible energy crops — across European producers, structures the Nabisy registry path, and delivers volumes to fossil fuel distributors and Bio-CNG / Bio-LNG operators with the documentation discipline the post-2026 quota demands. The boring parts done right.
"Volume is one thing. Documentation that survives an audit five years later — manure feedstock origin, GHG calculation, mass-balance trail — that's what makes a THG-Quote supply position durable."
Marcel Hüberli — Head of Sales, BioGem Express- Sourcing of certified biomethane for German transport — manure, waste, and RED-eligible energy crops with full PoS documentation
- Nabisy registry coordination — sustainability proof transfer to DEHSt with mass-balance integrity
- Strategic advisory on the RED III reform impact: 2% advanced sub-quota, double counting abolition, automatic adjustment
- Bio-CNG and Bio-LNG supply for fossil fuel distributors — including links to FuelEU Maritime Bio-LNG demand
- Long-term supply structuring via multi-year offtake agreements aligned with the post-2026 quota framework
- Connection to broader EU regulatory pathways including BEHG and EU ETS for buyers managing dual obligations
Key questions on THG-Quote and biomethane
The THG-Quote (Treibhausgasminderungsquote) is Germany's GHG reduction quota system for transport fuels, in operation since 2015. Fossil fuel distributors must reduce the lifecycle GHG emissions of the fuels they place on the market — measured against an annual benchmark. Biomethane used as Bio-CNG or Bio-LNG generates GHG reduction credits that fossil fuel suppliers can use to meet their quota. Manure-based biomethane historically delivered the strongest premiums under this system, because of its very low or even negative GHG intensity. From 2026, the system is being reshaped under RED III transposition: the advanced biofuel sub-quota rises from 1% to 2%, double counting is abolished, and anti-fraud measures are tightened.
The RED III transposition into German law, with the draft regulation published in June 2025, takes effect from early 2026. Key changes: the minimum quota for advanced biofuels rises from 1% to 2%, double counting (Doppelanrechnung) is abolished, UER credits are removed, automatic quota adjustment on overfulfilment is introduced, and anti-fraud measures targeting fraudulent advanced biodiesel imports (notably from Asia) are tightened. From 2027, overfulfilments from prior years can again be credited — likely with a price-dampening effect. For biomethane producers and traders, the reform reduces the financial multiplier per MWh but increases the underlying quota volume.
Manure-based (Gülle) biomethane delivers very low or negative GHG intensity values under RED methodology, because the credit for avoided methane emissions from open-air manure storage offsets production emissions. The S&P Global European Biomethane Outlook (2025) describes the German THG-Quote as having created strong positive margins for biomethane certified by Proof of Sustainability — particularly for unsubsidised manure-based volumes. With double counting abolished from 2026, the GHG intensity advantage of manure-based biomethane becomes more important, not less, because more physical energy is required to fulfil the quota. Producers with manure-based feedstock retain a strong commercial position.
Both Bio-CNG (compressed) and Bio-LNG (liquefied) biomethane qualify for THG-Quote credits when produced from RED-certified feedstocks. The market difference is in the vehicle fleet: CNG passenger car uptake in Germany has declined sharply, while LNG trucks remain strong, supported by toll exemptions until end of 2023 and continuing operational economics. Bio-LNG benefits additionally from FuelEU Maritime demand. Both fuels carry the same GHG accounting framework under THG-Quote — the certification chain (ISCC EU or REDcert EU under Nabisy) is identical, and the quota credit is calculated against the same fossil reference baseline.
Biomethane used for THG-Quote compliance must be certified under a recognised RED voluntary scheme — typically ISCC EU or REDcert EU — and registered in Nabisy, Germany's national sustainability registry operated by the DEHSt. The Proof of Sustainability covers feedstock origin, the lifecycle GHG value, and chain of custody from production to the fossil fuel distributor placing the fuel on the market. Mass-balance traceability is required throughout. Note: a standard biomethane Guarantee of Origin under RED Article 19 is not sufficient — THG-Quote compliance requires the PoS path with mass-balance documentation.
BioGem Express is a Swiss-based biomethane trading company operating since 2020, sourcing certified biomethane for German transport sector compliance under the THG-Quote. We work with manure-based, waste-based, and energy crop biomethane producers across Europe, structure the Proof of Sustainability path through ISCC EU or REDcert EU, coordinate Nabisy registry transfers to DEHSt, and deliver volumes to fossil fuel distributors and Bio-CNG / Bio-LNG operators. We also help buyers anticipate the RED III reform changes from 2026 — particularly the abolition of double counting and the rise of the advanced biofuel sub-quota to 2%.
Sources used on this page
This page is grounded in German federal regulation, RED III transposition documents, the DBFZ research institute, S&P Global market analysis, and ISCC certification documentation.
Key data used here: THG-Quote in operation since 2015 from German federal regulation; the RED III reform from early 2026 with advanced biofuel sub-quota rising from 1% to 2% and double counting abolished, from the German RED III draft regulation (June 2025); positive THG-Quote margins for unsubsidised manure-based biomethane certified by PoS from S&P Global European Biomethane Outlook (2025); and the Nabisy registry mandatory for THG-Quote PoS volumes from DEHSt operational documentation.
- RED III transposition German RED III Draft Regulation (June 2025)
- Quota analysis Naumann & Etzold / DBFZ — Szenarien zur THG-Quote (2025)
- Market analysis S&P Global — European Biomethane Outlook, Aug. 2025
- Sustainability registry DEHSt — Nabisy National Sustainability Registry
- Certification framework ISCC EU — Voluntary Scheme
- Industry barometer Biomethane Industry Barometer 2025
Ready to structure THG-Quote-compliant biomethane supply?
Our team sources certified biomethane — manure, waste, and RED-eligible energy crops — and structures Nabisy-registered PoS volumes for fossil fuel distributors and Bio-CNG / Bio-LNG operators. We help buyers and producers anticipate the post-2026 reform: 2% advanced biofuel sub-quota, abolition of double counting, tightened anti-fraud measures.