Annex IX of the EU Renewable Energy Directive is a short list with a large commercial effect. Whether a feedstock sits in Part A, Part B or neither changes the value of the fuel made from it and how closely auditors examine its origin. This article explains the structure of Annex IX, how the 2023 revision of the directive (RED III) uses it, and what buyers should check. It is a general guide, not legal advice.
Where Annex IX comes from
Annex IX was introduced into EU renewable energy law in 2015 and carried into the recast Renewable Energy Directive, Directive (EU) 2018/2001, known as RED II. Directive (EU) 2023/2413, known as RED III, amended RED II and raised its ambition but kept Annex IX as the reference list for waste- and residue-based feedstocks. The Commission can amend the list by delegated act, and did so in 2024, so always check the current consolidated version rather than an older summary.
Why the list matters
For transport, RED III gives Member States a choice between a renewable energy share of at least 29% by 2030 or a greenhouse-gas (GHG) intensity reduction of at least 14.5%. Within that framework:
- Fuels from Part A feedstocks count towards a combined sub-target for advanced biofuels, biogas and renewable fuels of non-biological origin (RFNBOs) of 1% in 2025 and 5.5% in 2030, of which at least one percentage point must come from RFNBOs.
- Fuels from Part B feedstocks are limited to 1.7% of the energy supplied to transport, although a Member State can ask the Commission to adjust that limit where justified.
- Fuels from food and feed crops remain capped at no more than one percentage point above each Member State's 2020 share, with an overall maximum of 7%.
- Multipliers, which let certain fuels count at more than their energy content, are retained for some pathways, but how they apply depends on how each Member State transposed the directive.
ReFuelEU Aviation also uses Annex IX to define many of the biofuels that count towards its SAF obligation.
Annex IX Part A: advanced feedstocks
Part A lists feedstocks that are generally harder to convert. They include:
- Wastes: the biomass fraction of mixed municipal waste, separately collected biowaste from households, and the biomass fraction of industrial waste that is not fit for use in the food or feed chain.
- Agricultural and processing residues: straw, bagasse, grape marcs and wine lees, nut shells, husks, and corn cobs cleaned of kernels.
- Forestry residues: bark, branches, leaves, sawdust, black and brown liquor, lignin and tall oil, among others.
- Specific residues: palm oil mill effluent (POME) and empty palm fruit bunches, tall oil pitch, crude glycerine, animal manure and sewage sludge.
- Other materials: algae grown on land, and other non-food cellulosic and ligno-cellulosic material.
Most Part A materials need advanced conversion technologies. A few, notably POME oil, tall oil pitch and crude glycerine, suit existing lipid or biogas routes, which makes them particularly sought after.
Annex IX Part B: used cooking oil and animal fats
Part B has historically contained two feedstocks:
- Used cooking oil (UCO).
- Animal fats classified as categories 1 and 2 under the EU animal by-products regulation.
The 2024 delegated act added further materials, so check the current list before assuming a feedstock is excluded. Category 3 animal fats are not listed. Part B feedstocks are easy to process into biodiesel, HVO and SAF, which is why their contribution is capped.
Part A vs Part B at a glance
- Typical lipid examples: Part A includes POME oil, tall oil pitch and crude glycerine; Part B includes used cooking oil and category 1 and 2 animal fats.
- Role in RED III: Part A counts towards the advanced-fuel sub-target; Part B is capped at 1.7% of transport energy, subject to national adjustment.
- Processing: most Part A materials need advanced conversion; Part B materials suit conventional FAME, HVO and HEFA units.
- Market value: in markets that reward advanced fuels, Part A lipids typically trade at a premium to Part B materials.
What is not in Annex IX
Many lipids traded as fuel feedstocks are not listed, including virgin vegetable oils, category 3 animal fats, palm fatty acid distillate (PFAD) and many acid oils. Not being listed does not make a feedstock ineligible: fuel from these materials can still count towards the overall targets if it meets the sustainability and GHG criteria, but it does not benefit from the Annex IX provisions, and some markets treat materials such as PFAD as co-products with limited or no incentives. Where an acid oil or other residue is argued to fall within a Part A category, such as industrial waste not fit for food or feed, acceptance depends on the national authority. Our guide to POME, acid oil and soapstock explains how those residues are produced.
National transposition matters
RED III is a directive, so each Member State writes its own rules: some use an energy-share obligation, others a GHG-intensity quota, and multipliers, caps and residue classifications differ. The UK's Renewable Transport Fuel Obligation uses its own feedstock list. A feedstock that is valuable in one market may be worth less in another.
What buyers should check
- The feedstock category stated on the proof of sustainability, and whether your national authority accepts it.
- Evidence of the points of origin, mill or plant behind the material.
- Registration of the consignment in the EU's Union Database (UDB) where your supply chain is within its scope.
- Certificate validity and scope for the specific site and material; ask for the certificate scope with your quotation.
- Separation of Part A, Part B and non-Annex IX material in storage and in your mass-balance records.
For more on matching feedstocks to conversion routes, see our buyer's guide to waste and residue feedstocks and our pages for SAF producers.
Frequently asked questions
Is used cooking oil in Annex IX Part A or Part B?
Part B. Used cooking oil and category 1 and 2 animal fats are the established Part B feedstocks. Their contribution to transport targets is capped at 1.7% of transport energy under RED III, subject to national adjustment.
Is POME an advanced biofuel feedstock?
Palm oil mill effluent and empty palm fruit bunches are listed in Annex IX Part A, so fuels made from them can count towards the advanced sub-target. Because of its value, POME oil is subject to close checks on origin and volumes.
Is PFAD in Annex IX?
No. PFAD is not listed in Annex IX. Its treatment as a residue or a co-product varies between countries and schemes, and several markets give it limited or no incentive.
Does double counting still apply under RED III?
Multipliers remain for some pathways, but their use depends on national transposition and on whether a country uses an energy-share or a GHG-intensity target. Check the rules in your destination market.