New Italian National Biofuel System: complete guide to Ministerial Decree of August 7, 2024

Introduction

The new Italian National Biofuel System, introduced by the Ministerial Decree of August 7, 2024, marks a turning point for all operators in the Italian biofuels supply chain. Published in the Official Gazette on August 26, 2024, and effective the following day, this measure significantly updates the previous decree of November 14, 2019, extending the scope of sustainability certification.

In this article, we will analyze in detail the new provisions introduced, the differences from the old scheme, the new economic operators required to obtain certification, and the fundamental deadlines for the transition.

What is the new Italian National Biofuel System?

The National Sustainability Certification Scheme represents the Italian system for ensuring that biofuels, bioliquids, and other renewable energy sources comply with the environmental and social sustainability criteria established by European directives. The regulatory update was necessary to align national legislation with the provisions of Legislative Decree 199/2021, which transposes the RED II Directive (2018/2001/EU) on the promotion of energy from renewable sources into Italian law.

The new Italian National Biofuel System addresses the need to guarantee transparency and traceability throughout the entire supply chain, from raw material to consumption, allowing certified operators to access national incentives and contribute to the European Union’s decarbonization goals.

Analyzing the substantial differences between the DM of August 7, 2024, and the DM of November 14, 2019

The new Decree introduces structural changes that go far beyond a simple technical update, significantly altering the regulatory landscape compared to the 2019 Decree.

Extension of the Scope of Application

The most significant difference concerns the extension of the certification scope. While the DM of November 14, 2019 focused exclusively on biofuels and bioliquids intended for transport, the new National Biofuel Scheme includes a much broader scope.

The certification system now covers not only all biofuels (biofuels, bioliquids, biomass fuels and biogas for transport), but also extends to: Renewable fuels of non-biological origin (RFNBO – Renewable Fuels of Non-Biological Origin), including green hydrogen; Recycled carbon fuels (RCF – Recycled Carbon Fuels); and Biomass fuels for electricity and heat production (with certain exclusions for plants below specific power thresholds).

This extension reflects the technological evolution of the sector and the expansion of decarbonization objectives, including for the first time in the Italian certification system non-biological energy sources such as renewable hydrogen.

New Strengthened Sustainability Criteria

The DM of August 7, 2024, introduces more stringent requirements in several areas. For example, in terms of greenhouse gas emission reduction, a minimum reduction of 65% is required for biomethane intended for transport, while the threshold rises to 80% for other energy uses. The decree also mandates a reinforced traceability obligation with more accurate monitoring systems throughout the entire supply chain, and a new classification of non-conformities detected during audits, coupled with stricter procedures for certificate suspension and revocation.

Procedural Changes and Timelines

The new Italian National Biofuel System introduces several changes in operational procedures:

• Reduced timelines for declarations: certified sustainability declarations must now be issued within shorter timeframes compared to the past (30 days instead of the previous 60 days).
• Mandatory final audit: in the event of a change in the certification body or scheme, a closing audit with a positive outcome is now mandatory.
• Surveillance audits: stricter requirements are imposed on the timing of periodic checks, with immediate consequences in case of non-compliance.

The new economic operators obligated to obtain Certification

One of the most significant impacts of the new Italian National Biofuel System concerns the extension of the certification obligation to new categories of economic operators, previously exempt.

Producers of electricity and heat from Biomass

The DM of August 7, 2024, establishes that producers of electricity and/or heat from direct combustion biomass fuels, along with their suppliers, must now be certified to access incentive mechanisms.

This extended category includes cogeneration plants, industrial thermal power plants, and electricity generation plants powered by forest or agricultural biomass, as well as all suppliers of solid biomass intended for these plants. The certification obligation for this sector came into force on May 28, 2025, although some exceptions are provided for plants below certain power thresholds.

Users of Bioliquids

The decree introduces the certification obligation into the national system for the first time for operators in the sector of Renewable Fuels of Non-Biological Origin (RFNBO) and Recycled Carbon Fuels (RCF).

This scope includes: green hydrogen producers, operators producing fuels from recycled carbon, and the entire supply chain of these innovative fuels. These operators are required to demonstrate compliance with the conditions established by Delegated Regulation (EU) 2023/1184, particularly regarding additionality, temporal matching, and the origin of renewable energy used.

Read the article on green hydrogen certification.

EU ETS Scope

A relevant new development concerns operators subject to the EU Emissions Trading System (EU ETS). Producers of electricity and heat can now voluntarily seek certification to demonstrate the zero-emission factor of the biomass used, thus gaining advantages in emissions accounting.

How to manage the transition for already certified operators

For companies already certified under the DM of November 14, 2019, the new decree provides a 12 month transitional period to comply with the new requirements. The transition will take place progressively during scheduled annual surveillance audits.

Already certified economic operators must take prompt action: it is essential to update their management system, adjust documentation and operational procedures to meet the new requirements, prepare for verifications according to the new, more stringent standards, and implement the newly required traceability systems. The old DM of November 14, 2019, will be completely repealed on August 26, 2025, by which date all operators must be compliant with the new scheme.

Fundamental deadlines of the new Italian National Biofuel System

The DM of August 7, 2024, establishes a calendar of differentiated deadlines by sector, to ensure a gradual and sustainable transition toward the new requirements.

• August 27, 2024 – Entry into force: the decree became effective the day after its publication in the Official Gazette. From this date, new certifications must be issued according to the new scheme.
• August 26, 2025 – Repeal of DM of November 14, 2019: by this date, all previously certified economic operators must have completed the transition to the new scheme, and certifications issued under the old decree cease to be valid. Certification bodies must exclusively apply the new criteria.
• December 31, 2025 – Deadline for some supply chains: for certain categories of operators who started the certification process late (particularly bioliquid users certifying for the first time or operators who need to extend existing certification to new scopes), the maximum deadline to complete the process is set for the end of the year.
• June 30, 2026 – Extension for the solid biomass sector: the decree recognizes the specific nature of the solid biomass sector, granting a further extension. Operators who intend to benefit from this extension must have subscribed to and accepted the quote for sustainability certification with the certification body by the preceding deadlines and demonstrate concrete commencement of the certification path, complying with the established intermediate requirements. This extension was provided to allow forest operators, wood harvesting and processing companies, and pellet and chips producers to gradually adapt to the new and more stringent forestry sustainability requirements.

Sustainability requirements and emission reduction

The new Italian National Biofuel System places particular emphasis on the criteria for reducing greenhouse gas emissions throughout the entire production chain.

Emission Reduction Thresholds

The minimum percentage reductions in emissions compared to fossil fuels vary based on the intended use, reflecting the EU’s growing ambition in the fight against climate change and requiring operators to invest in production efficiency. The main thresholds are: a minimum reduction of 65% for Biomethane intended for transport and a minimum reduction of 80% for Biomethane intended for other energy uses. Specific requirements then apply to advanced biofuels based on the type and the year the plant became operational.

The Calculation Methodology

The decree refers to the technical standards UNI/TS 11429:2020 and UNI/TS 11567:2020 for the qualification of economic operators and establishes that the emission calculation must follow the methodology set out in Regulation (EU) 2022/996.

How to prepare for Certification under the new Italian National Biofuel System

For companies that need to certify for the first time or update existing certification, it is crucial to follow a structured process.

Step 1: verification of applicability

The first step is to verify whether your activity falls within the scope of the new Italian National Biofuel System. Certification is mandatory for economic operators who: produce, transfer, or use raw materials for biofuels destined for the Italian market; commercialize materials intended for biofuel production; produce electricity and/or heat from biomass and intend to access incentives; or operate in the RFNBO or RCF sectors.

Step 2: choice of Certification body

Accredited certification bodies for the National Biofuel System are listed on the MASE website. Key players include RINA, Bureau Veritas, CSQA, and ICIM. The choice should be based on specific experience in the relevant sector, knowledge of applicable technical standards, certification timelines, costs, and service delivery methods.

Step 3: implementation of the Management System

The core of the certification involves implementing a management system based on UNI standards 11429 and 11567, which must guarantee: complete traceability of raw material and energy flows, correct application of the mass balance system, documentation of all steps in the supply chain, accurate calculation of greenhouse gas emissions, and effective procedures for managing non-conformities.

Step 4: Certification Audit

The certification audit is conducted by the chosen body and includes:

• Documentary verification of the management system
• On-site inspection of facilities and operational procedures
• Traceability checks through sampling
• Verification of emission reduction calculations Issuance of the certificate upon successful outcome

Step 5: annual surveillance

Certification is valid for five years but requires annual surveillance audits to maintain compliance. These checks verify the maintenance of sustainability requirements, the updating of documentation, the correct application of the mass balance system, and the absence of critical non-conformities.

Competitive advantages of Certification

Obtaining certification under the new Italian National Biofuel System is not only a regulatory obligation to access incentives but also represents a strategic opportunity for companies.

Access to Public Incentives

Certification is a prerequisite for: benefiting from support mechanisms for biogas and biomethane production, accessing Guaranteed Minimum Prices (GMP) for biomass-fueled power plants, and obtaining Certificates of Consumption (CIC) for biofuels. Certified companies can also participate in national and European funding calls and measures.

Certified companies also gain a competitive advantage: they can demonstrate the sustainability of their products with objective and verified evidence, access premium markets that require sustainability guarantees, establish partnerships with major industrial players, and differentiate themselves from uncertified competitors.

Contribution to ESG Goals

Biofuels sustainability certification directly contributes to companies’ Environmental, Social, and Governance (ESG) objectives. It enables companies to demonstrably reduce their carbon footprint, improve their ESG rating, attract sustainability-focused investors, respond to increasing transparency demands from stakeholders, and anticipate future regulatory obligations regarding sustainability reporting.

Penalties and non-Compliance

Failure to comply with the requirements of the new Italian National Biofuel System entails significant consequences for economic operators.

Suspension and revocation of Certification

The new decree introduces stricter criteria for managing non-conformities. The certification body can:

• Immediately suspend the certificate in case of serious or repeated non-conformities.
• Permanently revoke the certification if non-conformities are not resolved within established deadlines.
• Communicate the suspension/revocation to MASE and GSE, resulting in the immediate loss of incentives.

Inability to access incentives

Biofuels and biocombustibles produced during periods of non-compliance or without valid certification:

• Cannot benefit from any incentive scheme.
• Are not counted towards meeting legal obligations.
• Cannot be sold as certified sustainable products.

Administrative penalties

In addition to the consequences related to certification, operators risk administrative penalties for: false or misleading declarations about product sustainability, improper use of certificates or sustainability declarations, or failure to comply with traceability and documentation obligations.

The role of Accredited Certification Bodies

Certification bodies represent the key element of the system, ensuring impartiality and technical competence in verifications.

Accreditation Requirements

To operate within the new Italian National Biofuel System, bodies must be accredited by Accredia according to the UNI CEI EN ISO/IEC 17065 standard for product, process, and service certification, in addition to the RT-31 technical regulation specific to the biofuels sector and documented sectoral technical competence requirements.

Authorized Certification Bodies

The main certification bodies active in Italy for the new scheme are:

• SGS: active in all sectors, with particular focus on W/R
• Certiquality: historically rooted in the chemical industry sector
• Bureau Veritas: integrated services for the entire biofuel supply chain
• CSQA: specialization in the agri-food sector and agricultural biomass
• ICIM: technical expertise in plants and industrial processes
• RINA: consolidated experience in biofuel and biogas certification

Each body has developed specific competencies and can offer complementary services such as pre-audit consulting, personnel training, and support in implementing management systems.

Connection with other Sustainability Certifications

The new Italian National Biofuel System integrates with the international landscape of voluntary certification systems recognized by the European Commission.

Companies can choose to be certified according to voluntary schemes recognized by the EU as an alternative to or in addition to the national scheme:

• ISCC EU (International Sustainability & Carbon Certification) 2BSvs (Biomass Biofuels voluntary Scheme) REDcert Other recognized schemes listed on the European Commission website

The decision between the National Biofuel System and voluntary systems is determined by market requirements, export destinations, and client preferences.

Mutual Recognition

Certifications issued under schemes recognized by the European Commission are mutually recognized among Member States, facilitating intra-EU trade of sustainable biofuels and biofuels.

Voluntary Schemes do not recognize the Italian Scheme, whereas the Italian Scheme recognizes them, but with limitations.

Future outlook and regulatory evolution

The biofuels sector is continually evolving, with expectations of further regulatory developments in the coming years.

RED III Directive

The European Union has already adopted the RED III Directive (2023/2413/EU), which introduces even more ambitious targets for 2030 and 2050. Italy is expected to transpose this directive with further updates to the National Biofuel System, which could include strengthened sustainability criteria for forest biomass, new biodiversity requirements, and an extension of the scope to additional categories of innovative fuels.

Circular Economy and Innovation

The growing focus on the circular economy will likely lead to greater valorization of waste and by-products as raw materials, enhanced incentives for second and third-generation biofuels, and integration with circular economy certification systems.

Digitalization and Blockchain

The traceability required by the new Italian National Biofuel System could benefit significantly from the adoption of digital technologies. The expected developments include the use of blockchain platforms to ensure the immutability of traceability data, IoT monitoring systems for automated data collection, and complete digitalization of documentation and sustainability declarations.

Prometheus supports italian companies in the new Italian National Biofuel System

The technical and regulatory complexity of the new Italian National Biofuel System requires specialized expertise that few companies possess internally. Prometheus offers a complete consulting service that guides economic operators through every phase of the certification process, providing:

• Applicability analysis: verification of whether your company falls under the certification obligation.
• Gap analysis: assessment of the deviation from the requirements of the DM of August 7, 2024.
• Management system implementation: development of documentation and procedures according to UNI standards 11429 and 11567.
• Audit preparation: support in document preparation and staff training.
• Assistance during verifications and non-conformity management: presence and support in resolving any findings.

Don’t wait for the final deadlines: certify your company now. The new Italian National Biofuel System represents a challenge but also an opportunity to position yourself as a qualified operator in the renewable energy market. With progressively tighter deadlines and increasingly stringent requirements, the best time to start the certification process is now.

Contact Prometheus today for personalized consultation and discover how to obtain and maintain certification under the DM of August 7, 2024, ensuring your company access to incentives and a lasting competitive advantage in the sustainable biofuels sector.