Open Letter to the European Commission Revision of Annex V and VI of the Renewable Energy Directive (Directive (EU) 2023/2413, RED III): Ensuring Accurate Greenhouse Gas Accounting for Manure-Based Biogas and Biomethane

The authors argue that the current RED III methodology over-credits manure-based biomethane by using unrealistic baseline assumptions for manure management and incorrectly treating manure as a zero-emission waste feedstock. They call for a revision of the default avoided-emissions credit and a reassessment of system boundaries to include upstream livestock emissions.

• The current methodology for manure-based biogas and biomethane can result in greenhouse gas savings exceeding 210 percent relative to the RED fossil fuel comparator, effectively treating these pathways as climate-negative fuels.
• The default avoided-emissions credit (esca) of –45 g CO₂eq/MJ is based on the assumption that manure is stored in highly emitting open-pit or slurry systems, which the authors claim does not reflect current agricultural realities. The International Council on Clean Transportation estimated a more realistic avoided methane credit of approximately –19.5 g CO₂eq/MJ.

APA

Changing Markets Foundation (n.d.). Open Letter to the European Commission Revision of Annex V and VI of the Renewable Energy Directive (Directive (EU) 2023/2413, RED III): Ensuring Accurate Greenhouse Gas Accounting for Manure-Based Biogas and Biomethane. https://changingmarkets.org/wp-content/uploads/2026/07/Open-Letter-RED-III-Annex-V-and-VI-–-Manure-Based-Biogas-and-Biomethane.pdf

Chicago

Changing Markets Foundation. Open Letter to the European Commission Revision of Annex V and VI of the Renewable Energy Directive (Directive (EU) 2023/2413, RED III): Ensuring Accurate Greenhouse Gas Accounting for Manure-Based Biogas and Biomethane. n.d. https://changingmarkets.org/wp-content/uploads/2026/07/Open-Letter-RED-III-Annex-V-and-VI-–-Manure-Based-Biogas-and-Biomethane.pdf.

Wikipedia

{{cite press release |author=Changing Markets Foundation |title=Open Letter to the European Commission Revision of Annex V and VI of the Renewable Energy Directive (Directive (EU) 2023/2413, RED III): Ensuring Accurate Greenhouse Gas Accounting for Manure-Based Biogas and Biomethane |url=https://changingmarkets.org/wp-content/uploads/2026/07/Open-Letter-RED-III-Annex-V-and-VI-–-Manure-Based-Biogas-and-Biomethane.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{changingmarketsfoundationndopen, author = {{Changing Markets Foundation}}, title = {{Open Letter to the European Commission Revision of Annex V and VI of the Renewable Energy Directive (Directive (EU) 2023/2413, RED III): Ensuring Accurate Greenhouse Gas Accounting for Manure-Based Biogas and Biomethane}}, publisher = {Changing Markets Foundation}, url = {https://changingmarkets.org/wp-content/uploads/2026/07/Open-Letter-RED-III-Annex-V-and-VI-–-Manure-Based-Biogas-and-Biomethane.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }