Published on May 13th 2025 on our platform
Yesterday, the Ministry of Economy opened a new consultation about the project to replace the TIRUERT system by a GHG mandate, called “Incitation à la Réduction de l’Intensité Carbone des Carburants (IRICC)”.
The government has released its RED3 transposition plan for transport, which contains many details but still lacks crucial feedback from stakeholders, invited to comment until 10 June 2025. The timing for adoption before the end of 2025, and enforcement from 2026, is stretched but workable.
The main takeaways of our analysis of the documents are the following:
- The table below provides all the targets, sub-targets, and caps proposed for the 2026-2035 period, intending to provide long-term visibility to the market, switching from a year-to-year supervision used during the past decades.
- Only the GHG targets and the penalty levels would be written in the law, leaving the power to the Ministry to set/adapt all the other components.
- Minimum energy contents for specific pools will limit obligated parties’ flexibility.
- Specific obligation would be set for natural gas and LPG used in the road/non-road sector from 2028.
- Renewable electricity supplied to the road sector would remain fully eligible with the multiplier 4 until 2030; from 2031, the renewable electricity supplied from the grid to passenger cars would progressively be limited until it would be capped at 50% in 2035.
- The GHG methodology to apply to renewable electricity from 2026 is not yet confirmed.
- The application of 9A/RFNBO sub-targets and crop/9B/AF C3 caps is not entirely clear at this stage.
- They should mainly concern the road sector, as the specific 1.2% e.c RFNBO target for aviation and maritime, mentioned in the RED3, would apply. This remains to be confirmed.
- The H2 sub-target may include both renewable and low-carbon (from nuclear power), despite only renewable is eligible for the RED3 target if used in road or used at refineries.
- The proposal of a specific GHG target for the aviation sector comes as a surprise, as it would create a national obligation higher than Refuel EU, which is a clear breach of the regulation. This will certainly be subject to adjustments.
- Penalties in case of non-compliance would be set at EUR 700/mt CO2eq savings missing for all GHG targets.
- Penalties for energy targets applied to diesel/gasoline/natural gas/LPG would of EUR 40/GJ missing and to 9A/RFNBO of EUR 80/GJ missing.
- TIRUERT certificates still valid on 31 December 2025 would be transferred to the IRICC system with a maximum validity of 6 months, under conditions set by the Ministries of Energy and Customs.
