• Germany advanced RED III transposition last week, introducing explicit quotas for RFNBO (Renewable Fuels of Non-Biological Origin) for the first time
• Siemens, Atmen, and TURN2X have built the first end-to-end model for RED III-ready renewable gas production at TURN2X's commercial e-methane plant in Miajadas, Spain
• The Miajadas plant is fully operational, with 100 percent of its output sold under long-term offtake agreements, proof that green gas can be produced, certified, and delivered at a commercial scale today.

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(Munich, March 10, 2026)  Last week, Germany took a significant step toward closing remaining gaps in renewable fuel regulation. The Bundestag held the first reading of the Second Law on the Development of the Greenhouse Gas Reduction Quota, which will transpose RED III into national law and, for the first time, introduce explicit quotas for green hydrogen and e-fuels in the transport sector.

While most of Europe works toward RED III compliance, industrial offtakers are already demanding certified molecules as regulatory deadlines near. Siemens, Atmen, and TURN2X, all based in Munich, have developed the first end-to-end model for RED III-ready renewable gas production, from automated plant operations to certified product delivery. The plant of the future is already running at TURN2X's first commercial e-methane plant in Miajadas, Spain.

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TURN2X produces climate-neutral e-methane by combining green hydrogen with biogenic CO₂. The company plans to scale this model across Europe, aiming to cover 10 percent of Germany’s gas demand by 2031. Miajadas demonstrates the commercial viability of this pathway, with 100 percent of its renewable gas output sold under long-term off-take agreements. 

Intelligent operation and an ecosystem approach by Siemens

Siemens provides the industrial backbone for this model, including advanced automation systems, digital twin technology for remote plant operation, and standardised, secure deployment of future facilities.

Siemens adopts an ecosystem approach, collaborating with leading partners such as Atmen rather than developing every component in-house. “This is exactly how we at Siemens want to go forward in renewable energies,” says Philipp Glaser, Siemens Digital Industries. “We want to partner with the best solutions so our customers get innovation, technology, and speed of implementation.”

The data infrastructure layer provided by Atmen

Atmen, a regulatory technology company, provides the certification data layer. At Miajadas, this enabled the site to reach full RFNBO certification, making automated compliance part of day-to-day operations.

“Certification isn’t a nice-to-have; it’s market access and business case realization,” says Flore de Durfort, CEO of Atmen. “Our platform turns operational data into verifiable, auditable proof that keeps production continuously certification-ready so that renewable fuel producers can scale with confidence.”

The plant of the future, run by TURN2X

For TURN2X, combining Siemens’ industrial technology with Atmen’s compliance layer creates a blueprint for rapid, reliable expansion.

“Scaling across Europe brings two challenges: maintaining operational excellence and meeting increasingly complex certification requirements for renewable fuels,” says Dr.  Dominik Schollenberger, CTO of TURN2X. “The Miajadas plant shows that when intelligent operations and built-in compliance come together, e-methane can scale with the reliability our customers expect.”

The three companies share a single goal: scaling green energy production with intelligence, trust, and speed.

The plant of the future isn’t a vision. It’s running today in Miajadas.

About TURN2X

TURN2X develops and operates projects using its proprietary technology to produce e-methane by combining biogenic CO₂ with green hydrogen. The company focuses on scalable, infrastructure-ready renewable gas solutions that support industrial decarbonization and energy security.

About Siemens 

Siemens AG (Berlin and Munich) is a leading technology company focused on industry, infrastructure, mobility, and healthcare. The company’s purpose is to create technology that transforms everyday life for everyone. By combining the real and the digital worlds, Siemens empowers customers to accelerate their digital and sustainability transformations, making factories more efficient, cities more livable, and transportation more sustainable. A leader in industrial AI, Siemens leverages its deep domain know-how to apply AI – including generative AI – to real-world applications, making AI accessible and impactful for customers across diverse industries. Siemens also owns a majority stake in the publicly listed company Siemens Healthineers, a leading global medical technology provider pioneering breakthroughs in healthcare. For everyone. Everywhere. Sustainably. In fiscal 2024, which ended on September 30, 2024, the Siemens Group generated revenue of €75.9 billion and net income of €9.0 billion. As of September 30, 2024, the company employed around 312,000 people worldwide on the basis of continuing operations. Further information is available on the Internet at www.siemens.com.

About Atmen

Atmen (atmen.co) is a regulatory technology company providing the data infrastructure that powers trusted certification of industrial products. Atmen focuses on automating certification and enabling large-scale, verifiable supply chain transparency across energy-intensive industries. 

Founded in January 2023 by energy and regulation experts Flore de Durfort, Quentin Cangelosi, and Erika Degoute, Atmen has raised €6.3M to date to build technology that certifies industrial goods, starting with renewable gases. 

Headquartered in Munich, the company's platform is deployed across industrial sites in 9 countries, automating certification workflows and enabling verifiable proof of product attributes throughout the supply chain.

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RED III is one of the EU’s key mechanisms for turning transport decarbonization ambition into market demand. It requires Member States to set binding obligations for fuel suppliers, determining how renewable fuels and renewable electricity can help reduce the carbon intensity of transport.

Spain has been a key market to watch. More than half of its electricity generation already comes from renewables, and the southern European country also holds some of Europe's largest biomethane production potential. While the ingredients for significant renewable fuel production are in place, the market has been waiting for greater clarity on the demand side.

That clarity arrived on 23 July 2026, with the publication of Royal Decree 611/2026.

The decree translates key RED III transport provisions into a Spanish framework running through 2040, with mandatory annual decarbonization obligations applying from 2027.

The obligations fall first on fuel suppliers, rail fuel suppliers, the wholesale and retail petroleum operators, LPG distributors, natural gas commercialisers and direct consumers that place fuels on the Spanish transport market. For them, the decree changes what they must deliver, prove and account for. For renewable fuel producers and traders, it defines where new demand will come from and under what conditions.

Beyond the top-line obligation, the decree sets dedicated subtargets and compliance routes for advanced biofuels, biogas and RFNBOs, each with its own trajectory through 2040.

So, what changes under the new Royal Decree, and what do those changes mean in practice for renewable fuel producers and the buyers they supply?

GHG reduction becomes the new backbone

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‍The changes at a glance:

• GHG reduction becomes the main compliance metric, with annual targets differentiated by transport mode through 2040, while fuel-specific subtargets remain in energy terms.
• Advanced biofuels and biogas start from a stronger near-term position, while RFNBO requirements build more gradually and accelerate after 2030.
• New flexibility mechanisms broaden how compliance can be met, including limited substitution and cross-counting of eligible volumes across certain fuel and transport subtargets.
• Qualifying RFNBOs gain an additional route into transport compliance through the new sujetos habilitados certificate mechanism.
• The framework is backed by real enforcement: non-compliance with renewable-fuel obligations can constitute a very serious infringement, and a separate draft implementing order proposes compensatory payments for annual shortfalls.

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Under Spain's previous framework, renewable fuel obligations were primarily expressed in energy content. Royal Decree 611/2026 changes the center of gravity: annual GHG-reduction targets now provide the overarching compliance framework, while fuel-specific subtargets remain in energy terms.

The direction will feel familiar to those tracking the Dutch transition from HBEs to EREs, where emissions reduction, rather than renewable energy volume, now carries the weight. Germany's framework uses a similar architecture, combining an overarching GHG-reduction obligation with dedicated fuel subtargets.

Spain applies that logic through its own modal trajectories. For road transport, the GHG-reduction target starts at 8.5% in 2027, rises to 17.6% in 2030 and reaches 30% in 2040.

The headline target only tells part of the story. The fuel-specific subtargets beneath it show where demand actually starts to build, and how differently each pathway is treated:

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The scale becomes clearer against the EU minimum. RED III sets a combined 5.5% share for advanced biofuels, biogas and RFNBOs by 2030, including at least 1 percentage point from RFNBOs. Spain sets separate road-transport subtargets of 5.5% for advanced biofuels and biogas and 2.5% for RFNBOs, before the flexibility mechanisms available under the decree are taken into account.

The Spanish trajectory also extends well beyond 2030. By 2040, both the advanced biofuels and biogas subtarget and the RFNBO subtarget reach 11%. For comparison, Germany currently sets 2040 minimum shares of 9% for advanced biofuels and 10% for RFNBOs.

While RED III itself sets these fuel-specific minimums at EU level only through 2030, Spain gives buyers and producers a defined demand trajectory through 2040, offering considerably more visibility on how these renewable fuel pathways are expected to contribute over time.

Advanced Biofuels and Biogas: Why the Near-Term Opportunity Is Stronger

Advanced biofuels and biogas enter the new framework from a much higher starting point than RFNBOs, making them especially relevant in the first years of compliance.

They also play a role in the RFNBO ramp-up. Through 2032, advanced biofuels and biogas can substitute part of the RFNBO subtarget, within flexibility corridors that differ by supplier profile. 

Road fuel suppliers without refining capacity in Spain can use up to 1.5 percentage points in 2030, while those with refining capacity can use up to 1 percentage point (Article 14.3). Until 2030, low-carbon electrolytic hydrogen produced from renewable electricity can also qualify as a substitute under this flexibility (Article 14.1.b). 

For buyers, that creates more room to combine different qualifying pathways while RFNBO supply scales.

The framework also allows excess advanced biofuel and biogas energy to count across road and maritime subtargets, within defined limits and once the relevant obligation has first been met.

Not all biofuel pathways are treated equally, however. The maximum contribution from food- and feed-crop-based fuels will be set by ministerial order and cannot exceed 7% of total transport energy. Biofuels and biogas produced from Annex I Part B feedstocks are generally capped at 1.7%, subject to the adjustment conditions established in the decree.

What does Spain's RED III framework mean for RFNBO producers?

For RFNBOs, the story is different: the demand signal strengthens as the substitution flexibility falls away. Under Article 14, the mechanism allowing other eligible fuels to substitute part of the road RFNBO subtarget drops to zero from 2033. For obligated buyers, that increases the importance of securing qualifying RFNBO supply as the dedicated subtarget continues to rise.

Spain also creates a route for qualifying RFNBOs to generate transport compliance value even when the physical fuel is consumed elsewhere. Under defined conditions, eligible RFNBO producers can act as sujetos habilitados and request renewable-fuel certificates for RFNBOs sold or consumed in Spanish industry, or used as a final product in transport. Those certificates can then be transferred to obligated fuel suppliers and used towards transport decarbonization targets.

That creates an important link between industrial offtake and transport compliance: where and how an RFNBO is consumed can affect the compliance value attached to it.

Spain's Production Support Mechanisms

The Royal Decree strengthens the demand side, but Spain is also supporting part of the supply side through separate funding mechanisms.

For renewable hydrogen, one example is Spain’s participation in the European Hydrogen Bank’s Auction-as-a-Service scheme. In May 2026, Spain awarded €439.4 million to three renewable hydrogen projects representing 250 MW of electrolysis capacity. The projects had been preselected at EU level but missed European funding after the auction budget was exhausted.

The support follows the Hydrogen Bank model: a fixed premium linked to verified and certified hydrogen production, paid for up to ten years.

While these programs sit outside Royal Decree 611/2026, they complete the picture: Spain is combining stronger regulatory demand with measures to help new production capacity reach the market.

Non-Compliance Costs: What Gives the Law Teeth

The framework does not rely on targets alone. Royal Decree 611/2026 classifies non-compliance with obligations linked to biofuels and other renewable liquid and gaseous fuels as a very serious infringement under Spain’s Hydrocarbons Act.

A separate draft ministerial order for the future SICCRE certification system also proposes compensatory payments for annual shortfalls of:

• €600 per tonne of CO₂ equivalent for modal GHG-reduction targets
• €2,110 per tonne of oil equivalent for the advanced biofuels and biogas road subtarget
• €4,180 per tonne of oil equivalent for the RFNBO road subtarget
• €2,110 per tonne of oil equivalent for the advanced bioalcohol and maritime renewable-fuel subtargets

The consultation on that draft closed on 15 September 2026, and the proposed amounts are not yet final. If adopted, they would add an explicit economic cost to falling short of the targets, on top of the sanctions framework already established in the Royal Decree.

From Targets to Market Value

Spain’s new framework makes one thing increasingly clear: the compliance value of a renewable fuel depends not only on the molecule itself, but on the decarbonization performance and sustainability attributes behind it.

For buyers and offtakers, procurement therefore becomes more than securing renewable fuel volumes. They need products with the GHG profile, sustainability characteristics and certification evidence required to meet their own obligations.

For producers, much of that value is shaped before the fuel reaches the market. Depending on the pathway, decisions around feedstocks, renewable electricity sourcing, process inputs, logistics and allocation can influence the final GHG performance, and ultimately how well that product fits an offtaker’s needs.

Renewable fuels are becoming a GHG optimization game as much as a production game. The molecule matters, but so does the verified decarbonization value that travels with it.

That optimization is what Atmen Automate was built for: turning GHG and sustainability data into sourcing, allocation and certification decisions that extract more value from every qualifying supply chain.

Reach out to the team →

^{Last reviewed: early October 2026. Spain's renewable fuel framework is still being finalised through implementing orders; some figures and procedures referenced here remain under adoption.}

‍Frequently Asked Questions

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What is Spain's Royal Decree 611/2026?
Royal Decree 611/2026, published on 23 July 2026, is Spain's transposition of the EU's Renewable Energy Directive (RED III) for the transport sector. It sets Spain's transport decarbonisation framework through 2040, shifting renewable fuel obligations from energy volumes to annual GHG reduction targets differentiated by transport mode, with specific subtargets for advanced biofuels, biogas, and RFNBOs. Most provisions apply from 1 January 2027, over a year after the original EU transposition deadline of 21 May 2025.

What are Spain's GHG reduction targets for road transport under RED III?
Under Royal Decree 611/2026, Spain's road transport GHG reduction target starts at 8.5% in 2027, rises to 17.6% in 2030, and reaches 30% in 2040, broadly in line with RED III's ambition but implemented through Spain's own compliance architecture, combining overarching GHG targets with minimum energy-based subtargets for specific fuel pathways.

What are the RFNBO subtargets under Spain's RED III transposition?
Spain sets an RFNBO road transport subtarget of 0.2% in 2027, rising to 2.5% in 2030 and 11% in 2040, consistent with RED III's requirement that RFNBOs account for at least 1% of transport energy by 2030. Until 2032, fuel suppliers can substitute part of this subtarget with advanced biofuels and biogas, with a larger allowance for suppliers without refining capacity in Spain. From 2033, that flexibility closes entirely.

What does RED III require operators to demonstrate for RFNBO qualification?
Under RED III, operators must demonstrate that the electricity used is of renewable origin and that the fuel achieves at least 70% GHG savings against the fossil comparator, verified through an EU-recognised voluntary or national scheme.

Spain's framework applies these same requirements: connecting feedstock or electricity inputs, GHG performance, volumes, traceability, and certification into evidence that holds up to third-party audit.

Can RFNBOs used in Spanish industry count towards transport targets?
Yes, under specific conditions. Eligible actors can request renewable-fuel certificates for RFNBOs sold or consumed in Spanish industry. Those certificates can then be transferred to obligated fuel suppliers and used towards Spain's transport decarbonization targets, creating a compliance route for RFNBOs even when the physical fuel is consumed outside the transport sector.

What are the penalties for non-compliance with Spain's renewable fuel obligations?

A draft ministerial order whose public consultation closed on 15 September 2026 proposes compensatory payments for annual shortfalls:

• €600 per tonne of CO₂ equivalent for the modal GHG-reduction targets
• €2,110 per tonne of oil equivalent for the advanced biofuels and biogas road subtarget
• €4,180 per tonne of oil equivalent for the RFNBO road subtarget
• €2,110 per tonne of oil equivalent for the advanced bioalcohol and maritime renewable-fuel subtargets

Non-compliance with these obligations is also classified as a very serious infringement under Spain's Hydrocarbons Act. As of early October 2026, the compensatory payment figures are not yet final; the ministerial order has not yet been published in the BOE.