EREs in the Netherlands: what EV charging operators need to know in 2026

Biotickets expert Thomas Liu of Targray explains how EREs are booked, traded, and priced, and why verified charging data is paramount.

The Netherlands introduced emissions-reduction units, or EREs, in 2026 as part of its updated renewable transport system. For charge point operators (CPOs), the change creates an opportunity to generate value from eligible EV charging activity. It also introduces new requirements for documentation and booking.

How does a charging session become a tradable ERE? What determines its market value? And what should a CPO consider when choosing a booking service provider?

We discussed these and more with Thomas Liu, Biofuels and Bio-tickets expert at Targray, Last Mile Solutions’ partner for ERE trading and market access. Targray is an international supplier and trader of renewable fuels, feedstocks, and environmental commodities. Established in Montreal in 1987, the company works across global sustainable commodity markets.

EREs at a glance

• What they are: tradable units representing CO₂-equivalent chain-emission reductions from eligible renewable energy supplied to transport.
• Who can benefit: companies and, since 2026, private individuals whose eligible electricity deliveries are booked through a booking service provider.
• How they are created: eligible charging data is validated and booked in the Register Energie voor Vervoer (REV).
• How they are sold: EREs can be transferred to obligated parties that use them towards their renewable transport requirements.
• Why data matters: every booked volume needs accurate, traceable and auditable supporting evidence.

1. What EREs are

Let’s start with the basics. What are EREs?

Thomas Liu: An emissions-reduction unit, or ERE, is a tradable unit representing one kilogram of CO₂-equivalent chain-emission reduction from eligible renewable energy supplied to transport. For EV charging, EREs can be generated when eligible electricity delivered to an electric vehicle is correctly measured, documented, and booked.

EREs can also be generated from other eligible renewable energy sources,  such as biodiesel and biomethane.

What changed when the Netherlands moved from HBEs to EREs?

Thomas Liu: The transition changes the unit used to account for renewable transport performance. The ERE system focuses on CO₂-equivalent chain-emission reduction rather than accounting only for the amount of renewable energy supplied.

The underlying charging activity is nothing new. What has changed is how that activity is measured and recorded, together with the introduction of the booking service provider role. This makes it possible for smaller volumes from individual charging points to be aggregated and brought into the tradable market.

2. How charging activity becomes an ERE

How does the process work from a charging session to an ERE in the REV?

Thomas Liu: In the Dutch system, the focus is primarily on the charging point rather than the individual driver. Electricity is treated as the fuel delivered to the vehicle.The eligible electricity is then booked in the Register Energie voor Vervoer, or REV, against the relevant connection. The next step is to prove that charging took place and how much electricity was delivered to an electric vehicle. This is done through Charge Detail Records, or CDRs, which provide evidence of the charging event, the relevant charger, and the electricity delivered. Where applicable, MID-certified meters are required to complete a booking.

So in simple terms, the process is: measured charging electricity, eligibility checks, booking in the REV, and then ERE issuance.

What is the role of the booking service provider?

Thomas Liu: A booking service provider brings together smaller volumes that would otherwise be difficult to manage individually. It also manages the booking process and can transfer or sell the resulting EREs, for example to a fuel supplier with a greenhouse gas (GHG) reduction obligation.

So, our role is to combine regulatory expertise, data management and market access. The partnership we have with Last Mile Solutions vertically integrated the entire system. Together we efficiently scale the process and reduce both administrative work and data risk.

The REV rollout experienced delays. What happened?

Thomas Liu: At the time of our interview in August 2026, the updated REV had opened for existing account holders. On 14 August, the Dutch Emissions Authority, or NEA, announced that these account holders could book renewable energy deliveries and transfer available EREs.

The booking service provider role is one of the new elements in the system. It adds a mandate step and a process for allowing providers to aggregate and submit CPO volumes.

The main challenge for the NEA and auditing bodies is to clarify what evidence is acceptable and how information must be retained and presented. For providers working with large volumes of customer data, it is not enough for the data simply to exist. It needs to be accessible, accurate, traceable, and auditable.

3. How ERE trading and pricing work

How are EREs traded?

Thomas Liu: EREs are traded over the counter, or OTC. That means buyers and sellers negotiate directly rather than trading through a central exchange.

The market largely includes obligated parties and renewable energy supplier, EV charging for example. The price available in an OTC transaction can depend on volume, timing credit terms etc.

A large institutional transaction can involve millions of EREs, while an individual household or small business may generate a much smaller volume. Booking service providers can aggregate those smaller volumes into tradable tranches.

“Our aim is to provide a transparent, market-linked basis for payment and reduce exposure to short-term fluctuations.”

– Thomas Liu, Biofuels and Biotickets Expert, Targray

How does the pricing model used by Targray and Last Mile Solutions work?

Thomas Liu: The aim is to provide a transparent, market-linked basis for the price and reduce exposure to short-term fluctuations.

Targray does not set the pricing reference unilaterally.

Rather than basing the price on one isolated transaction, we use independent third-party market assessments throughout the entire compliance year. The applicable commercial terms should specify the exact reference, calculation period, and payment mechanics.

Does that guarantee the highest price available on any given day?

Thomas Liu: Nobody can guarantee that. Even if you could, that would not necessarily create much value. What’s more important is to reduce dependence on the timing of a single transaction.

Our approach is designed to protect the customer from short-term market volatility and give them a more stable commercial outcome over time. It also helps safeguard the long-term value of the underlying charging assets, rather than making the economics depend on whether one sale happened on a particularly good or bad day.

After all, operating charging infrastructure is a long-term business. The pricing approach should reflect that.

What factors influence ERE prices?

Thomas Liu: ERE prices are influenced by a combination of energy, biofuel and compliance-market fundamentals.

Crude oil prices matter because they affect the economics of conventional fuels. At the same time, renewable fuel prices and the cost of feedstocks such as waste oils and fats influence the cost of meeting transport obligations through biofuels. That, in turn, affects how attractive EREs are as an alternative compliance option.

There is also a global supply-chain element. Many biofuel feedstocks are internationally traded, so geopolitics, trade restrictions and disruptions can quickly affect costs. Logistics play a role as well. The current low water levels on the Rhine, for example, can restrict barge transport and push more volume onto higher-cost road or rail transport.

So ERE pricing is really the result of several connected markets moving at the same time.

How does Targray manage market exposure?

Thomas Liu: We manage exposure by trading across a broad range of connected products within the renewable fuels sector, rather than looking at EREs in isolation.

Targray is active in certificates as well as physical products such as HVO (Hydrotreated Vegetable Oil), FAME (Fatty Acid Methyl Esters) and related renewable-fuel feedstocks. Because these markets are closely connected but do not always react in the same way, having a diversified portfolio allows us to manage risk across different asset classes.

“By capturing value from different products, we can benefit from opportunities across different parts of the market and use a broader portfolio to manage our overall exposure.”

– Thomas Liu, Biofuels and Biotickets Expert, Targray

4. Why data validation matters

Why is documentation validation so important?

Thomas Liu: EREs need a clear chain of evidence. A booking service provider must be able to prove the relationship between its customers and kWh delivered.

The provider also needs to prevent duplicate submissions and retain records that can be retrieved for review or audit.

By using platform based data from our partner Last Mile Solutions. Together, we integrate the entire ERE value chain into the platform, making the process scalable and minimizing user friction

“ Together, we integrate the entire ERE value chain into the platform, making the process scalable and minimizing user friction.”

– Thomas Liu, Biofuels and Biotickets Expert, Targray

How strict is the NEA likely to be about data accuracy?

Thomas Liu: NEa sets the regulatory framework and the guidance for how ERE bookings should be verified. The independent auditor is responsible for checking whether the underlying booking data is accurate and properly supported.

Ultimately, though, the responsibility is likely to sit with the booking service provider. That means the provider needs to stay on top of the regulatory requirements, maintain a robust data process and communicate clearly with customers about what information is required.

“Ultimately, though, the responsibility is likely to sit with the booking service provider. That means the provider needs to stay on top of the regulatory requirements, maintain a robust data process and communicate clearly with customers about what information is required”

– Thomas Liu, Biofuels and Biotickets Expert, Targray

5. What the Targray-Last Mile Solutions partnership provides

What does the partnership do differently?

Thomas Liu: The key difference is that we connect the charging platform network directly to the ERE market.

Last Mile Solutions already sits at the source of the data through its platform and customer relationships. Targray brings the regulatory, commodity-market and trading expertise needed to turn that data into EREs and ultimately into revenue.

By combining those capabilities, we have created a trusted and scalable setup that customers can rely on and grow with over the long term.

What should a CPO consider when comparing ERE providers?

Thomas Liu:

• How will the charging data be collected , validated, and stored?
• When does the payment become final?
• How transparent is the pricing and value-sharing model?
• Does the provider have the capability to honour its commitments?
• What happens if a booked volume is rejected or cannot be delivered?
• How easily can the setup scale as charging volumes grow?

Why does financial resilience matter when providers pay customers in advance?

Thomas Liu: An advance payment can be attractive, but customers also need confidence that the provider will fulfil its obligations later. A provider may start paying customers based on expected volume, then. In an event of a shortfall would make it expensive or impossible to reconcile.

A credible provider should be able to demonstrate both operational controls and the financial capacity to honour its commitments.

6. What to expect in 2027

Which providers will be best placed to support the market?

Thomas Liu: This year is an important test for the system. The best providers are the ones support their customers over the longer term with reliable data, robust compliance processes, sufficient trading and administrative expertise, and the financial capacity to meet their commitments.

What changes would you like to see in the coming year?

Thomas Liu: More integrated data connections would be a major improvement. API-based connections and direct platform data flows could reduce the need to move information manually between CPOs, booking service providers, auditors, and the NEA.

Clearer guidance would also help with residential charging and owners’ association, or VvE, arrangements. Another important question is who should receive the benefit when the person using the vehicle is not the person paying for the electricity, as can happen with employer-paid vehicles, charge cards, and leasing arrangements.

What EREs mean for EV charging operators

EREs create an revenue opportunity from eligible EV charging and can strengthen the commercial relationship between CPOs and their customers.

Capturing that value, however, requires the reliable data, clear agreements and a clear communication.

Last Mile Solutions and Targray bring together charging-platform expertise and environmental commodities experience to make thus process efficient and stress-free for our customers.

Want to understand what EREs could mean for your charging network?

Glossar

CDR: Charge Detail Record: a record of an individual charging session.

CPO: Charge point operator: the party responsible for operating charging infrastructure.

EAN code: The unique identifier for an electricity or gas connection.

ERE: Emissions-reduction unit representing one kilogram of CO₂-equivalent chain-emission reduction.

FAME: Fatty acid methyl ester, a type of biodiesel.

HVO: Hydrotreated vegetable oil, a renewable diesel fuel.

NEA: Dutch Emissions Authority.

OTC: Over the counter: a bilateral trade made outside a central exchange.

REV: Register Energie voor Vervoer, the online system in which EREs are created and transferred.

VvE: Vereniging van Eigenaars, a Dutch owners’ association for a shared residential building.