Missed over the summer: what the eFuel Alliance wants from RED IV – and why it matters for Switzerland

It landed in the middle of the summer holidays, which is why many in the Power-to-X community may have missed it: at the end of July 2026, the eFuel Alliance published its position paper on the upcoming revision of the EU Renewable Energy Framework – the “RED IV”. Speaking for more than 160 companies, associations and consumer organisations, including around 25 eFuel producers and project developers, the Alliance sets out what the next Renewable Energy Directive must deliver if renewable fuels of non-biological origin (RFNBOs) are to move from announcements to steel in the ground. We took the time to read it – and to ask what it means for Switzerland.

The starting point: 300 projects, 6 percent investment decisions

The paper builds on the eFuel Alliance’s study with Porsche Consulting, which we analysed here in May. More than 300 eFuel projects are in development worldwide, with a combined announced production capacity of 20 billion litres in 2030. Yet only 6 percent of these projects have reached a final investment decision. In the meantime, China has built up 60 percent of the global electrolyser production capacity, at prices 20 to 30 percent below Western competitors. The Alliance’s diagnosis is blunt: the technology is ready, the projects are on the table, and what is missing is a regulatory framework that turns announced capacity into bankable demand.

Demand: binding RFNBO targets to 2050

The central demand is a long-term, binding trajectory for RFNBOs in transport: at least 5 percent in 2035, 12 percent in 2040, 18 percent in 2045 and 25 percent in 2050. The current RED III stops at 2030, which leaves investors staring into a void exactly where the payback period of a Power-to-X plant begins. A quota path that reaches to 2050 would give project developers and their financiers the demand visibility that no subsidy programme can replace.

Harmonisation: one market instead of 27 rulebooks

A second block of demands targets the fragmented national implementation of RED III. Penalties for non-compliance range from roughly 11.5 euros per gigajoule in Poland to 132 euros in Belgium. Multipliers for RFNBOs vary between 1.5 and 3 depending on the sector and the member state – Germany, for instance, counts RFNBOs three times. The result is a patchwork in which the same molecule is worth very different amounts depending on where it is sold. The Alliance calls for harmonised penalties, harmonised multiplier rules, one Union Database instead of parallel national systems, and a clear sectoral delineation between road, aviation and shipping. Its underlying point deserves attention: multipliers make targets easier to meet on paper without putting a single additional litre of renewable fuel into the market. What the industry needs are real volumes.

Aviation and shipping: extend the SAF allowances, close the maritime gap

For aviation, the Alliance asks that the SAF allowances under the EU Emissions Trading System – which cover part of the price gap between fossil kerosene and sustainable aviation fuel – be extended beyond 2030 with a locked-in budget for eFuels. This is consistent with the demands in its response to the EU aviation strategy consultation. For shipping, the paper notes simply that a comparable instrument does not exist – and should. Both sectors are exactly where Swiss Power-to-X projects, from methanol-to-jet demonstration plants to e-methanol and e-ammonia, are positioning themselves.

Investment protection: fix the rules at final investment decision

Perhaps the most important demand for anyone trying to finance a plant is what the paper calls grandfathering: certification and production criteria must be fixed at the moment of the final investment decision and must not be changed retroactively. The Delegated Acts on RFNBO production have been under constant debate since their adoption, and the prospect of moving goalposts is one reason banks hesitate. Add to that the call to speed up implementation of the Union Database and the integration of third countries – since Europe will increasingly depend on imported RFNBO volumes from regions with abundant renewable energy – and the picture is one of an industry asking for stability more than for money.

Money is on the list, too: a reform of the Energy Taxation Directive with differentiated, reduced minimum rates for eFuels, continued support through IPCEIs, the Innovation Fund and the European Hydrogen Bank, and an expansion of the auction-as-a-service model for aviation and shipping. And, predictably controversial in Brussels, the recognition of vehicles running exclusively on renewable fuels as zero-emission in the CO₂ standards for new vehicles – a point where the Alliance’s own study cites Switzerland’s crediting mechanism under the CO₂ Act as a reference case.

What this means for Switzerland

Switzerland is not a member state, but the Swiss Power-to-X industry lives in the EU market. Swiss producers and technology providers sell into it, Swiss project developers finance against it, and any Swiss fuel that wants to count in Europe must pass through the EU certification chain. Three points follow. First, the RED IV quota path will do more to decide the bankability of Swiss projects than most decisions taken in Bern – which is why SPIN will follow the revision closely. Second, the 6-percent figure is a warning for Switzerland, too: announcements are cheap, and the country’s own regulatory hurdles are what stand between a demonstration plant and a commercial one, as we wrote in our analysis of the Hydrogen Bank auction. Third, the grandfathering demand is one Swiss policymakers can adopt directly: a plant that receives an investment decision under one set of rules must not be judged by another.

The full position paper is available on the eFuel Alliance website. The EU framework and its consequences for Swiss projects will certainly be part of the discussion at the Power-to-X Congress Switzerland on 22 September in Bern.

🤖 AI transparency: This text and its visual were created using AI, reviewed and approved by a human.