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Blog10 August 20263 min read

The same word "obligation" requires different things in different countries

The UK counts volume, Germany counts a reduction rate, Korea counts the blending ratio of one pair. Same word, different requirements — and the difference decides the certificate price.


Discussing certificate prices, the usual explanation is "government support is thicker there". True, but to use it in practice you have to go one step further.

What is that government support, specifically? Reading four countries' schemes in the source documents answers it.

They count different things

United Kingdom (RTFO) — counts the volume of renewable fuel supplied. A certificate is issued per litre (or equivalent), with double the certificates for certain wastes and residues, dedicated energy crops, and RFNBOs.

Germany (THG-Quote) — counts not volume but the greenhouse gas reduction rate of the fuel. The statute reads "die verpflichtende prozentuale Minderung der Treibhausgasemissionen bei Kraftstoffen".

Korea (RFS) — counts what percentage of biodiesel was blended into automotive diesel. The required share for 2024–2026 is 4.0%.

Denmark is a different kind of thing. Not a mandate but a producer support scheme, and currently moving from subsidy to tender.

Why the difference decides the price

Counting by volume means blending a specified fuel at a specified ratio, and anything that is not that fuel does not enter the calculation. Counting by reduction rate means any route that cuts emissions enters.

A different way of counting changes what a producer earns from the public scheme, and therefore how much a voluntary certificate has to add on top. The coverage rates of 27%, 55% and 83% from report 2 come from here.

※ Each figure in this article was confirmed directly in that country's government, parliamentary or regulatory documents.


This article expands one section of LCS EAC special report 4, Different Schemes, Different Shares. The full report works from documents published by the UK Department for Transport, the German Bundestag, the Danish Energy Agency and the Korea Energy Agency as primary sources, and does not reproduce figures that were not confirmed in a primary source.

The document behind this article

Different Schemes, Different Shares

The UK, Germany, Denmark and Korea count different things

PDF · 5 pp. · 0.7 MB

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