Reviewed by Vincent Crausaz, Business Developer · Updated May 2026
Regulatory Compliance · GermanyBEHG-Compliant
Regulatory status reviewed: April 2026
BEHG-Compliant
Biomethane Supply in Germany
Germany’s Fuel Emissions Trading Act is increasing the cost of fossil gas. Certified biomethane offers a compliant route to reduce fossil exposure within the German framework when sustainability proof, mass balance and registry handling are correctly managed. BioGem Express supports sourcing, certification coordination and delivery across regulated European markets.
260Biomethane upgrading plants in Germany (2025)
11.5 TWhInjected into the gas grid in 2025
€55–65/tCO₂2026 nEHS certificate corridor
Understanding BEHG
What is the BEHG and why does it matter?
The Brennstoffemissionshandelsgesetz (BEHG) — Germany’s Fuel Emissions Trading Act — requires the entities that place fuels on the German market to acquire CO₂ certificates for the associated emissions. In practice, the legal obligation sits primarily with fuel suppliers and other market participants upstream, while large gas consumers are affected commercially through pricing, supply structures and reporting requirements, as outlined by DEHSt’s guidance on the national emissions trading system.
Since its introduction in 2021, the BEHG has steadily increased CO₂ pricing pressure on fossil gas. In 2026, certificates move into an auction-based corridor of €55 to €65 per tCO₂, before ETS II takes over from 2027, according to DEHSt. For gas-intensive operators, this makes compliant renewable gas procurement increasingly strategic.
Certified biomethane offers a direct route to lowering fossil exposure. Where compliant biomethane is sourced, certified and documented correctly, the obligated party can reduce the fossil share that would otherwise trigger BEHG certificate costs.
Sustainability proof has been mandatory for biomethane used under the EU ETS since 2022. With the current ETS I carbon price at roughly €55–60 per tCO₂, the cost advantage of certified biomethane over fossil gas is approximately €16 per MWh of CO₂ avoidance — a figure that grows significantly as allowance prices rise.
BEHG at a glanceFull nameIn forceApplies toFuels coveredBaseline2026 pricingAuthorityRegulation
Brennstoffemissionshandelsgesetz
January 2021
Entities placing fuels on the market; gas consumers affected commercially
Natural gas, heating oil, petrol, diesel
GHG reduction: ≥70% (2021–2025) / ≥80% (from 2026)
Certificate corridor: €55–65/tCO₂
DEHSt (Federal Environment Agency)
BEHG + RED sustainability rules; ETS II from 2027
Compliance mechanism
How biomethane addresses BEHG obligations
Certified biomethane can support BEHG compliance when sustainability certification, Nabisy proof and mass-balance documentation are correctly aligned.
01
Produced & certified
Biomethane is produced from organic feedstocks — including agriculture residues, manure, biowaste and crop — and upgraded to natural gas quality. For BEHG use, the relevant sustainability proof is typically verified under recognised RED voluntary schemes such as ISCC EU or REDcert EU.
02
Injected & tracked
Certified biomethane is injected into the gas grid and tracked through contractual documentation and mass balance. For the German BEHG framework, Proof of Sustainability (PoS) and Nabisy-linked verification are central; Guarantees of Origin can support disclosure, but according to ISCC EU Mass Balance Guidance they do not replace PoS.
03
Obligation reduced
The obligated party uses the certified biomethane volumes and associated sustainability proof within the reporting framework. This reduces the fossil share subject to BEHG certificate costs and supports audit-ready reporting to the competent authorities.
Certification requirements
What BEHG-compliant biomethane requires
Not all biomethane qualifies for BEHG compliance. Specific sustainability, traceability, and documentation standards must be met throughout the supply chain.
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Sustainability certification
Biomethane used for BEHG purposes is typically verified under recognised RED voluntary schemes such as ISCC EU or REDcert EU. In practice, the key thresholds are a greenhouse-gas reduction of at least 70% for installations starting operation from 2021 to 2025 and at least 80% from 2026, as reflected in the ISCC EU system documents and industry guidance.
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Eligible feedstocks
There are no direct restrictions regarding the feedstock mix. What matters is whether the required greenhouse-gas reduction is achieved. Certification of the biomethane plant operator is crucial and decides whether the biomethane is eligible for BEHG.
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Full chain of custody
Documentation must cover the full supply chain — from feedstock origin to final use. Mass balance must be maintained throughout the chain of custody, and the relevant proof must be robust enough to avoid double counting and support audits.
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GHG reporting to DEHSt
The obligated entity must be able to substantiate the relevant volumes and sustainability information within the German reporting framework. BioGem Express supports clients with the documentation package needed for compliant, audit-ready handling.
Our role
Your ETS biomethane partner
ETS compliance isn’t a once-a-year exercise — it’s a live obligation with monitoring, reporting, and verification running continuously. The documentation behind your biomethane supply has to hold up to independent audit. That’s the standard we build to.
As a specialist biomethane trading company operating across regulated European markets, BioGem Express works with certified producers, accredited voluntary scheme bodies, and registry operators to deliver volumes where the sustainability proof is complete — every time, not just on paper.
“Carbon compliance is a numbers game. The ETS counts every tonne. We make sure the documentation behind your biomethane is as solid as the gas itself.”
Vincent Crausaz — Business Developer, BioGem Express
- Sourcing of biomethane from verified European producers under recognised RED voluntary schemes
- Full documentation support for BEHG reporting, including certification and registry handling through dena for GoOs and Nabisy for PoS
- Long-term supply agreements with price stability in volatile markets
- Coverage of multiple frameworks: BEHG, GEG, EU ETS
- Access to both voluntary disclosure markets and compliance-driven biomethane structures across Europe
- Expert guidance on regulatory changes — RED implementation, ETS II and German registry developmen
FAQ
Key questions on BEHG & Biomethane
The BEHG (Brennstoffemissionshandelsgesetz) is Germany’s Fuel Emissions Trading Act, requiring companies that place fossil fuels on the market to purchase CO₂ certificates for associated greenhouse gas emissions. It primarily applies to entities that place fuels on the German market, while industrial gas consumers are usually affected commercially rather than being the direct obligated party. DEHSt supervises the system.
Yes. Certified biomethane can be used within the BEHG framework when the relevant sustainability proof is correctly documented. For BEHG use, recognised RED certification and Nabisy-linked proof are central, and the required GHG reduction thresholds must be met.
BEHG-compliant biomethane is typically verified under recognised RED voluntary schemes such as ISCC EU or REDcert EU. Complete chain-of-custody documentation and the relevant Nabisy-linked proof are required for robust reporting and audit purposes.
The BEHG is a CO₂ pricing framework for fossil fuels placed on the market. The GEG (Gebäudeenergiegesetz) governs renewable heat requirements in buildings. Both frameworks can involve biomethane, but the proof logic differs: BEHG relies on RED-based sustainability verification and Nabisy, while GEG follows a different evidence structure.
BioGem Express is a Swiss-based biomethane trading company specialising in certified biomethane supply across regulated European markets. We source volumes from verified producers, coordinate the certification and documentation chain, and support utilities and energy companies navigating BEHG-related procurement and reporting requirements.
Referenced sources
Sources used on this page
This page is written for commercial readability, and its key regulatory and market statements are grounded in public sources from the European Commission, competent certification bodies, and leading energy market analysts.
Key figures include the ETS I carbon price of ~€55–60/tCO₂ and biomethane spot price of €10–15/MWh from the dena Biomethane Industry Barometer 2025; the 85% demand signal from the same barometer; ETS II projections of €149/tCO₂ by 2030 from BloombergNEF; and confirmation that sustainability proof has been mandatory since 2022, as documented in ISCC guidance.
Market dataBiomethane Industry Barometer 2025
German Energy Agency (dena), 2025. Sector benchmark for the German biomethane market, including plant numbers, capacity, market trends and demand developments.
German gas marketGas Balance 2025
Die Gas- und Wasserstoffwirtschaft / Zukunft Gas, 2025. Used here for the current German biomethane market framing, including around 260 upgrading plants and roughly 11.5 TWh injected into the grid in 2025.
BEHG / nEHSUnderstanding national emissions trading (nEHS)
DEHSt, accessed March 2026. Source for the legal logic of the German national emissions trading system, the upstream obligation, and the 2026 price corridor of €55–65 per tCO₂.
German registryNabisy — Sustainable Biomass System
Federal Office for Agriculture and Food (BLE). Public information page for Germany’s governmental sustainability proof system for biomass.
Mass balance / proof logicISCC EU Mass Balance Guidance, Version 1.2
ISCC System GmbH, December 2025. Used here for the clarification that Guarantees of Origin may serve as supplementary evidence but cannot replace the ISCC EU Proof of Sustainability.
Certification frameworkISCC System Documents
SCC official documentation hub. Relevant for RED-based certification, chain of custody, GHG methodology and compliance documentation.
Explore further
Related regulatory frameworks
Ready to discuss BEHG-compliant supply?
Our team is available to assess your compliance needs, explain the certification process, and structure a long-term biomethane supply solution tailored to your regulatory obligations.
