On 3 July 2025, the Ministry for the Ecological Transition and the Demographic Challenge (MITECO) opened the public consultation process for the Draft Royal Decree for the Promotion of Renewable Fuels, which partially transposes the revised Directive (EU) 2018/2001 (RED III) and redefines Spain’s transport decarbonisation goals for 2030.
The new legal framework sets a primary objective of 29% renewable energy penetration in transport or a 14.5% reduction in greenhouse gas (GHG) emissions by 2030, relative to 1990 levels.
It also introduces specific renewable energy sub-targets by fuel type, with a combined goal of 8% in advanced biofuels, biogas, and renewable fuels of non-biological origin (RFNBOs). The breakdown includes:
- 5.5% in advanced biofuels and biogas.
- 2.5% in RFNBOs.
- 1.5% additional RFNBOs used as intermediate inputs in refineries.
- 0.5% advanced bioethanol in petrol sales for road transport.
According to the Spanish Hydrogen Association (AeH2), the decree is welcomed for its “ambitious GHG emission reduction targets by transport mode, even exceeding those in RED III”.
AeH2 further highlights that the draft “sets specific sub-targets for RFNBOs, both for final and intermediate use, with flexibility mechanisms such as a credit system or ‘free space’ to support their integration in the value chain”.
The text defines differentiated modal targets for the period 2027–2030, including:
- 15.6% GHG reduction for road transport.
- 5.4% for non-electrified rail.
- 3% for domestic maritime navigation.
- Explicit recognition of the 6% aviation target set by the ReFuelEU Aviation Regulation.
Spain has made significant progress in advanced biofuels: by 2023, 2.3% of sales had already been achieved, exceeding the 1% mandatory target for 2025. As for biomethane, the country went from a single operational plant in 2022 to 18 plants by 2025, with 10 already injecting into the gas grid.
MITECO also introduces a new paradigm based on GHG emission reduction, aligning national targets with the emissions trading system and encouraging technology-neutral competition based on carbon footprint.
The Royal Decree introduces a certification system that recognises qualified entities capable of generating renewable fuel certificates and selling them to obligated parties. Renewable electricity credits can also be used, and providers with obligations in several modes can transfer surplus reductions across modes.
To strengthen compliance, the text establishes an annual monitoring and control system, with recognition of overachievement through transferable certificates and penalties for non-compliance. Fuel providers exceeding their targets may generate compliance certificates that other entities can use to offset shortfalls.
Clear criteria are set to define obligated entities, including wholesale suppliers of petroleum and gas products, retail distributors and direct consumers. It also recognises qualified entities that may participate in the certification system to trade credits or certificates.
The legislation also redefines the National Sustainability Verification System, encompassing four regimes: biofuels and bioliquids, biomass, biogas and gases, and RFNBOs and low-carbon fuels. This system is integrated with the European Union database to ensure traceability and prevent fraud. A compatible national platform will be used until full EU system integration is achieved.
Finally, the Royal Decree stipulates that the Guarantee of Origin System will also cover low-carbon gases, integrating all information on the sector of use and associated emissions. The guarantees will also be updated to include sustainability data and the end-use sector.
The new regulatory regime will enter into force on 1 January 2027, repealing Royal Decree 1085/2015. However, some articles will take effect upon publication of the new decree.
The public consultation period will remain open until 8 September 2025, and the AeH2 is already working on a joint sectoral submission, accompanied by a technical session with its working group to consolidate a shared sectoral vision.
