THG-Quote &
Biomethane —
Germany's GHG Quota
for Transport Fuels

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 German THG-Quote has created strong positive margins for unsubsidized 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 unsubsidised 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%.