Germany · Treibhausgasminderungs-Quote · § 37a BImSchG
One obligation, kept as a file per year.
SERIES READ FROM ZOLL STATISTICS · LADDERS FROM BGBL. 2026 I NR. 163
Pick the year. Everything below is that year.
Measured · Zoll statistics 2015–2024
● The law moved
Legislated · BGBl. 2026 I Nr. 163 → 2040
The series so far — who actually filled it
Zoll, Statistische Angaben 2015–2024
Ten measured years. Hydrogen appears once in the whole record — 182 t in 2021 — and is invisible at this scale: the market the RFNBO tab prices does not exist in this fulfilment record yet. From 2026 the § 3b floor makes it exist.
WHAT THE QUOTA MAKES A UNIT WORTH · EVERY FULFILMENT OPTION
WILLINGNESS TO PAY · § 37a BImSchG · FEED-IN POINT

What one unit is worth to an obligated party — every year of the contract.

Commercial willingness-to-pay for ANY fulfilment option of the German GHG quota, at the producer’s delivery point: pick the row, set the offtake profile across its uses, and the tonne price either from your own assumption or from the year-by-year path the cost-minimal national portfolio clears at. The credit itself is not recomputed here — it comes from the same engine that fills the official workbook below, so the multiplier of § 3 Abs. 5 der 37. BImSchV, the electricity factor of § 5 Abs. 3 der 38. BImSchV, the drive-efficiency factor of § 3 Abs. 6 Nr. 3 (RFNBO) and § 13 Abs. 5 Nr. 3 (biogenic hydrogen) der 37. BImSchV and the exclusions of § 37b Abs. 8 BImSchG reach this panel by construction, not by a second implementation.

Legal basis: Quota trajectory per BImSchG § 37a Abs. 4 as amended by the Second GHG-Quota Act (BGBl. 2026 I Nr. 163) — 26.5 % by 2030 → 65 % by 2040. RFNBO multiplier per § 3 Abs. 5 der 37. BImSchV; RFNBO minimum share and its 120 €/GJ backstop per § 3b; electricity multiplier per § 5 Abs. 3 der 38. BImSchV; drive-efficiency factors per the Anlage zur 37. BImSchV. German hydrogen transmission per BNetzA WANDA Festlegung GBK-24-02-2#4 (25 €/kWh/h/a HHV, CPI-adjusted); Danish per Energinet DHB1 (stakeholder range 10–20).
Fulfilment option
THG-saving basis
Target Value − Actual CI — the marginal truth of the intermediate route, in every year: credit = mult × E × (FFC × (1 − Q %) − actual CI). The host fuel keeps its full fossil accounting (the § 37a Abs. 5 Nr. 7 firewall forbids it any CI benefit), so the multiplied RFNBO energy enters the party’s REFERENCE VALUE on top of an unchanged book (§ 3 Abs. 5 37. BImSchV) — every multiplied GJ raises the own reduction duty by mult × E × FFC × Q, netting the naive comparator credit down to the target gap: mult×E×(FFC−CI) − mult×E×FFC×Q = mult×E×(FFC(1−Q)−CI). For hydrogen, methanol or methane fed in as an intermediate this holds in all years, 2040 included.
GHG saving of the delivered product90%
20 %60 %100 %
Market drivers
Initial quota price300€/tCO₂
100350600
Grows 2 %/a from this 2025 anchor. The ceiling is the levy of § 37c Abs. 2 BImSchG: 0.60 €/kg CO₂eq = 600 €/t — no rational party pays more for a tonne than the levy on the tonne it fails to save.
Initial gas price30€/MWh
1080150
Gas price change2.0% p.a.
−100+10
Initial ETS price65€/tCO₂
30115200
ETS growth5.0% p.a.
Offtake agreement
Contract start year2030
202720332040
First year of RFNBO delivery. Watch the multiplier fade-out (2037–2040) move in and out of the contract window.
Offtake tenor15years
5 yr12 yr20 yr
Contract duration.
Annual price escalation2.0% p.a.
0 %2.5 %5 %
P₀ is set such that the offtaker's NPV equals the yearly-WtP NPV (offtaker indifference).
Offtaker WACC8.0%
Discount rate for the offtaker-indifference levelization.
Producer WACC8.0%
Project WACC for discounting the escalating contract cash flow.
Transmission (entry + exit)
DE tariff (WANDA)25€/kW/a
BNetzA Festlegung · reviewed every 3 yr + CPI.
DK tariff (Energinet)15€/kW/a
Final tariff pending · stakeholder range 10–20 €/kW/a HHV.
Load factor8000h/a
Booked capacity hours · converted via 39.4 kWh/kg HHV.
Subquota support floor
Under the German RFNBO minimum share (§ 3b of the 37. BImSchV), WtP is floored at the next-best RFNBO procurement price; the statutory backstop is the 120 €/GJ levy on the shortfall — 14.40 €/kg H₂ · 2,390 €/t MeOH · 432 €/MWh CH₄. Only kicks in if the market-driven WtP falls below it.
Alternative RFNBO price7.0€/kg
3 €7.5 €12 €
Levelized WtP at Feed-In
—€/kg H₂
Flat equivalent price · offtaker-indifference over the contract tenor.
Producer levelized
—€/kg H₂
Escalating contract cash flow discounted at Producer WACC — the LCOH a hydrogen project has to beat, and the levelized revenue any other producer sees.
Contract price path (nominal)
Year 1 · 2030—
→
Year 15 · 2044—
Pₜ = P₀ × (1 + e)^(t−1)
Annual WtP at feed-in · contract window shaded
Floor
Contract price
Methodology — Quotas per BImSchG §37a(4) (BGBl. 2026 I Nr. 163). Multiplier per § 3 Abs. 5 37. BImSchV: 3.0 through 2036 → 2.5 / 2.0 / 1.5 / 1.0 (2037–2040+). Basiswert 94.1 gCO₂/MJ through 2025 and 94.0 from 2026 (§ 3 38. BImSchV as amended by BGBl. 2026 I Nr. 163); the reduction slider derives a product CI from the 94 g comparator a saving is measured against — § 10 Abs. 1 und 2 der 37. BImSchV with Part A of Delegated Regulation (EU) 2023/1185, the same figure as Annex V Part C point 19 of RED II. SMR reference: 0.048 MWh of gas per kg H₂ — a stated process assumption, equal to 69 % conversion onto the heating value, not a legal value — times 0.202 tCO₂/MWh, which is a legal default: natural gas carries 56.1 tCO₂/TJ of net calorific value in Annex VI Table 1 of the Monitoring and Reporting Regulation (EU) 2018/2066 (IPCC 2006 GL), and 56.1 × 0.0036 = 0.202. The two give 9.7 kg CO₂ per kg H₂ at the reformer — the stack term, with no upstream methane in it. Transmission: tariff € / kW / a × 39.4 kWh/kg HHV / load factor. Methanol mode: outputs in €/t (1 t = 1,000 kg); transport is commercial freight, not a network tariff; fossil anchor either quoted (EUA embedded) or derived as gas × 9.4 MWh/t (≈34 GJ) + EUA × 0.5 tCO₂/t + conversion margin — the cost floor of a European gas-based plant, while the traded price is import parity. Methane mode: outputs in €/MWh (50 MJ/kg LHV, 1 kg = 1/72 MWh); counterfactual is natural gas + EUA at 2.75 kgCO₂/kg (stoichiometric, assumes RFNBO zero-rating in the buyer’s ETS balance); the deduction is a grid & balancing fee per MWh. Credit formulas: Intermediate (additive) = mult × E × (FFC × (1 − Q %) − actual CI); Direct fuel (substitution) = mult × E × (FFC × (1 − Q %) − actual CI) + E × FFC × Q % — the displaced fossil litre leaves the reference basis, so the duty rises only by (mult − 1) × E — only where a fossil litre is displaced; for an intermediate, for electricity and for methane both bases coincide and the switch is inert; Reported = mult × E × (FFC − actual CI) per § 37a Abs. 4 S. 1 und 3 BImSchG (declared under § 37c Abs. 1) — the figure that goes on the report, and the one a naive price-indexation clause grabs. It is not offered as a saving basis above, because it is a marginal willingness to pay under neither route: the intermediate case nets to the additive basis and the direct-fuel case to the substitution basis, which meets the reported figure exactly from 2040 (multiplier 1); before that it overstates the intermediate case by ~40 % in 2030 and ~3.6× in 2040 at 90 % reduction. Contract logic: yearly WtP is levelized at Offtaker WACC to P_flat. With escalation e, P₀ is set so that the escalating stream's NPV at Offtaker WACC equals the yearly WtP NPV (offtaker indifference). Producer LCOH discounts that contract stream at Producer WACC. Who is obligated: § 37a Abs. 1 BImSchG obliges whoever places energy-tax-liable petrol or diesel on the market; the fuel counts as placed when the energy tax arises (Abs. 1 Satz 2), and the obligated party is the Steuerschuldner under the Energiesteuergesetz, or the Einlagerer in the cases of § 7 Abs. 4 EnergieStG (Abs. 3). A refinery is therefore obligated for the fuel it releases for consumption as tax debtor, not for what it produces; producing fuel with RFNBO hydrogen as an intermediate (§ 37a Abs. 5 Satz 1 Nr. 6 and 7) is a fulfilment option whose tonnes belong to whoever places that fuel — at an integrated company both roles coincide, at a merchant refinery they are two contracts. Low-carbon hydrogen: the one provision that names it, § 37a Abs. 5 Satz 1 Nr. 8 BImSchG, admits electrolytic low-carbon H₂ from obligation year 2031, only as an intermediate in the production of conventional fuels, and only once an ordinance under § 37d Abs. 2 Satz 1 Nr. 13 allows it — the 37. and 38. BImSchV (June 2026) contain no such provision, so it is not an option here.
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