In this regulatory compliance report, the research team from VITO and RWE explored in the framework of ECO2Fuel, how the European Union’s evolving legal framework for Renewable Fuels of Non-Biological Origin (RFNBOs) — synthetic fuels produced from renewable electricity and captured CO₂ — is shaping the future of CO₂-to-fuel technologies.
Here are 6 main takeaways from the report.
- EU climate policy driving CO₂-to-fuel innovation
Europe is placing CO₂ conversion and RFNBO production at the centre of its clean energy transition. The report highlights how EU policies, such as the Renewable Energy Directive and the Fit for 55 package, are encouraging large-scale electrochemical CO₂ reduction technologies, including those developed within the ECO2Fuel project.
RFNBOs — including synthetic methanol, ethanol, and e-fuels — are increasingly recognised as key enablers for decarbonising hard-to-abate sectors such as aviation, shipping, and heavy transport.
- Renewable Energy Directive (RED III) targets for RFNBOs
The updated Renewable Energy Directive (RED III, 2023) sets a binding 42.5% renewable energy target by 2030, with new measures to promote RFNBO deployment:
- A minimum 1% RFNBO share in transport by 2030
- Double-counting incentives for RFNBOs and advanced biofuels
These provisions are designed to accelerate the market growth of renewable, electricity-based CO₂ fuels across the European Union.
- Fit for 55: integrating CO₂ fuels into the EU’s climate roadmap
The EU Fit for 55 package aims to cut greenhouse gas emissions by 55% by 2030 and introduces several key initiatives relevant to RFNBOs:
ReFuelEU Aviation: mandating synthetic fuel use to increase from 1.2% in 2030 to 35% in 2050
FuelEU Maritime: introducing progressive greenhouse gas reduction targets for shipping fuels
ETS and ETS2: extending carbon pricing to transport and buildings, creating stronger incentives for low-carbon CO₂ fuels
Together, these policies provide a foundation for expanding CO₂-based renewable fuel production throughout Europe.
- RFNBO compliance and sustainability requirements
The ECO2Fuel report underlines the strict sustainability criteria that must be met for RFNBO certification under EU law. To qualify, fuels must utilise additional renewable electricity rather than diverting existing renewable capacity, deliver at least 70% lower greenhouse gas emissions compared with fossil fuels, and comply with new EU Delegated Acts that standardise emission accounting, verification, and renewable energy sourcing with time and location alignment. These measures ensure that RFNBOs genuinely support EU decarbonisation objectives.
- The 2035–2040 “Sunset Clause” on fossil CO₂
A significant regulatory shift — the “Sunset Clause” — will take effect between 2035 and 2040, marking the end of fossil-derived CO₂ as a recognised source of “avoided emissions.” Future RFNBO facilities will therefore need to rely on direct air capture (DAC) or biogenic CO₂, both of which involve higher production costs. Without transitional arrangements, this shift could challenge the economic feasibility of early-stage CO₂-to-fuel projects.
- Life-Cycle Assessment and emission performance
The ECO2Fuel report includes life-cycle assessments of several CO₂-to-fuel pathways, including CO₂-to-methanol, CO₂-to-ethylene, and electrochemical CO₂-to-sustainable aviation fuel (SAF). All current pathways comply with RED III emission thresholds (<28.2 gCO₂eq/MJ) when industrial CO₂ is considered an avoided emission. Once the Sunset Clause applies, however, only pathways using DAC or biogenic carbon will remain compliant.
The report concludes that RFNBOs are essential to achieving the EU’s net-zero ambitions, particularly in sectors that are difficult to electrify directly.
ECO2Fuel’s electrochemical CO₂ conversion technology supports this vision by transforming captured carbon into sustainable, renewable fuels.
