Rijkswaterstaat, the Dutch government’s infrastructure and water management agency, announced in December 2024 that, from 1 January 2025, the valuation of HVO in its MKI protocol (the agency’s framework for calculating and verifying the environmental cost score of tender bids) would be equalised with diesel for equipment and vehicles.
The agency linked the change directly to the Schoon en Emissieloos Bouwen (SEB) route map, under which signatories are phasing down support for biofuels in sectors where enough emission-free alternatives already exist. For what it calls “dry” equipment, meaning vehicles and non-road machinery, Rijkswaterstaat says that threshold has been reached, so HVO is no longer being stimulated.
That line is even clearer in the SEB procurement guide. The document says sustainably produced HVO can deliver a quick CO2 gain when used instead of fossil diesel, but adds that switching to HVO is not regarded as a necessary step towards zero-emission construction. It also warns that structurally promoting HVO for equipment that already has zero-emission alternatives could delay the transition. For that reason, the guide states that HVO has no place in the procurement guidance.
In practice, this means that contractors can still use HVO but it is no longer treated as a sustainability lever deserving extra encouragement in public procurement where battery-electric or other zero-emission options are already considered viable.
Why the Dutch line is shifting
The policy change comes as HVO is facing growing scrutiny on several fronts.
One is the emissions argument. A Dutch government report published in March 2025 found that HVO generally has no or only a negligible effect on particulate matter and NOx emissions in Stage V non-road diesel engines fitted with a properly functioning NOx catalyst and particulate filter. The report did find lower particulate emissions for Stage V engines without exhaust-gas aftertreatment, but for the newest construction machinery the local air-quality case for HVO appears limited.
Another issue is feedstock availability and cost. The Netherlands Institute for Transport Policy Analysis (KiM) said in October 2025 that HVO and FAME are currently the main renewable fuels used in heavy-duty transport, but warned that biofeedstocks for both are ultimately limited in availability while demand is likely to rise, including from sectors such as shipping and aviation. KiM also noted that FAME is cheaper than HVO, underlining the cost pressure around renewable diesel.
There is also increasing scrutiny of supply-chain integrity. In April 2025, Transport & Environment published research arguing that reported use of palm oil mill effluent (POME) in European biofuels exceeds what is plausibly available globally, suggesting a high likelihood of fraud in part of the market. That is not an official Dutch government source, but it helps explain why HVO has become more politically sensitive.
