Is it mandatory to add emissions for compression on a PoS when the final use of the fuel is not known?

The biomethane compression factor accounts for the emissions associated with the compression of biogas to CNG pressure (25 MPa). Producers of biomethane must, by default, include emissions for compression in the GHG calculation. It is not allowed to omit emissions for compression when the use is unknown to the biomethane producer (including the cases where biomethane is injected into the grid).

If the biomethane will be subsequently used for sectors such as heating, cooling or electricity generation, the producer of the respective commodity shall cancel the original PoS (which includes compression emissions), i.e retract it from the national database it was issued to, and issue a new PoS. This new PoS will include the recalculated GHG emissions in accordance with the relevant market’s methodology and minimum savings requirements and allows for the potential removal of compression emissions when no compression took place.

When biomethane is redirected to a certified liquefaction unit for bio‑LNG production, the original PoS shall similarly be cancelled by the bio-LNG producer and a new bio‑LNG PoS will be issued by the liquefaction unit. In this bio-LNG PoS, the compression factor for biomethane can be also excluded from the GHG calculations.

If it is not clear on an incoming PoS whether emissions for compression have been added because they are not separately listed, i.e. a PoS from another RED II-recognized voluntary scheme or a national database, a subtraction is only possible if adequate proof can be provided that these emissions were added in the first place. In case default values from the Annex XI of the REDIII including compression were used, a subtraction of the compression factor is allowed.

The use of an actual emission factor for compression or liquefaction instead of the default compression value is only possible if the actual value can be accurately determined and verified by the Certification Body. This could be the case if agreements with an offtaker are in place to the extent that the location and conditions of compression are known to the final biofuel producer. If electricity from the grid is used in these processes, the national emission factors from the Implementing Regulation 2022/996 must be used.