Does CO₂ sourced for RFNBO production need to be certified? In which cases does it need certification, and when can it qualify for eex-use credits?

CO₂ does not need to be certified simply because it is used in RFNBO production. However, the RFNBO producer must always provide evidence of the CO₂ origin and apply the correct GHG treatment.

Certification, or equivalent RED-compliance evidence, becomes relevant when the producer seeks to claim eex-use credits for biogenic CO₂ from the production or combustion of biofuels, bioliquids or biomass fuels. Without such evidence, the CO₂ may still be used as an input, but the producer cannot claim the eex-use credit for that CO₂. This credit is often important to meet the 70% GHG-saving threshold.

To qualify for eex-use credits, the CO₂ must fall into one of the eligible categories in Delegated Regulation (EU) 2023/1185, Annex, Point 10:

1. Emissions Trading System (ETS) / effective carbon-pricing CO₂
   CO₂ captured from an activity listed in Annex I of the EU Emissions Trading System (ETS) Directive, accounted for upstream under an effective carbon pricing system and incorporated into the fuel before the applicable deadline: 2036 for electricity-generation combustion CO₂ or 2041 for other eligible ETS sources.

2. Direct air capture
   CO₂ captured directly from the atmosphere.

3. Biogenic CO₂
   CO₂ from the production or combustion of biofuels, bioliquids or biomass fuels, provided the underlying fuel complies with RED sustainability and GHG-saving criteria and the CO₂ has not already received CO₂ capture/replacement credits.

4. RFNBO / RCF combustion CO₂
   CO₂ from the combustion of RFNBOs or recycled carbon fuels that meet the applicable GHG-saving criteria.

5. Naturally released geological CO₂
   CO₂ from a geological source that was previously released naturally.

CO₂ does not qualify for eex-use credits if it comes from fuel deliberately combusted only to generate CO₂ or if the same CO₂ has already received an emissions credit elsewhere.

Related question: If CO₂ is sourced from the production or combustion of biofuels, bioliquids or biomass fuels, what certification approach should be applied in order for the CO₂ to be eligible for emissions from existing use or fate credits?