FAQ

If, as part of mass balancing, biomethane quantities are allocated by feedstock prior to entry into the dena Biogas Register and this is documented in the audit report, we recommend including a note in the corresponding BAD that is relevant for verification purposes and indicates this allocation (e.g., “The quantities were allocated by feedstock for accounting purposes.”).

This serves as documentation in accordance with Section 44b(5) of the EEG 2023, which stipulates that the allocation of quantities into feedstock-specific sub-quantities, as well as the assignment of the feedstocks used, must be documented as part of the mass balance. This documentation also serves to support the calculation of feed-in tariffs for CHP plants under the EEG 2009.

If the accounting breakdown is performed within the dena Biogas Register, it is documented in a standardized manner as before and included in the Biogas Register extract.

If this remark, which is relevant for verification, is missing from a BAD that has already been marked as “green,” the information can be added retroactively in an additional BAD for that quantity.

The manufacturer’s nameplate serves as the basis for specifying “capacity” and “rated output”; these terms are used synonymously in the EEG.  Accordingly, these figures do not depend on the actual annual amount of biomethane produced. The corresponding criteria 11, 12, 32, 33, and 34 are therefore facility-specific, which is indicated by (a) in the dena Biogas Register’s criteria catalog.

The basis for this interpretation can be found in the explanatory memorandum to the EEG 2012 (German Bundestag Printed Paper 17/6071):

Regarding Section 3(6) of the EEG, the following description explains how the legislature defines “rated output”: The “installed capacity” corresponds to the maximum continuous output possible based on the technical specifications, which is generally expected to be identical to the generator’s rated output as certified by the manufacturer.

This definition can also be applied to gas processing technology.

The commentary on Annex 1 (Gas Processing Bonus) notes that “capacity” and “rated output” are used interchangeably in the EEG: Pursuant to Section 27c(2), the bonus may be claimed for electricity generated from biogas, including biogas from the anaerobic digestion of biowaste, sewage gas, and landfill gas. A substantive change from the previous technology bonus for gas processing is the increase in the capacity thresholds (rated output) up to which the gas processing bonus is granted, from 350 and 700 standard cubic meters to 700 and 1,400 standard cubic meters, respectively.

Yes, the parallel verification of biomethane quantities in both verification systems is possible and even necessary in certain cases.

One example of this is the use of biomethane within the framework of the Fuel Emissions Trading Act (BEHG). On the one hand, this requires proof of sustainability, which is recorded via the BLE's NABISY system. On the other hand, additional criteria that are not covered by NABISY can be provided via the dena Biogasregister in accordance with the criteria matrix.

Requirements for parallel verification in the dena Biogasregister

The following points must be observed to ensure that parallel verification is documented in a comprehensible manner:

Audit report:

• The auditor or assessor who carries out the audit of the biomethane quantity as part of the BAD must explicitly note the parallel verification in the audit report.
• This entry serves as proof that the biomethane quantities are recorded simultaneously in both systems without any discrepancies.

Prohibition of double marketing:

• Parallel verification does not mean that biomethane quantities may be used simultaneously in different marketing paths. If the verification is rebooked or retired in one system, it must also be rebooked/retired in the other system.  

Quantities that are recorded in both the dena Biogas Register and Nabisy and for which no biogas register extract is required because they are used solely as fuel can be permanently decommissioned in the dena Biogas Register. To do this, these quantities are transferred to the dena trustee account.

The account number for the transfer within the Biogas Register is: denatreuhBK15001

Please send us an email with a brief explanation to support(at)biogasregister.de if you are transferring or have transferred quantities to the dena trustee account. The registry will then permanently deactivate the quantities. Should you require proof, we will send it to you on request. For your own records, you can download the transfer document directly from the Biogasregister.  

The smallest amount that can be recorded as a production batch in the dena Biogas Register is 1 kWh.

For international transfers via ERGAR, the smallest unit is currently 1 MWh.

For various reasons, it may occur that a contractually agreed delivery cannot be made after all, or only partially, and replacement quantities must be procured. Especially if the delivery period has already begun, problems may arise with the mass balancing of the quantities. An interpretation aid on this topic can be found here:

Design aid for mass balancing for replacement purchases

In ERGAR, the system used to process international transfers in the dena Biogas Register, there are specific biomass codes for reporting information on the biomass used, which each connected register can define on its own. There are currently seven biomass codes for the dena Biogas Register. For the substrate criteria EVK 0, EVK 1, EVK 2a, and EVK 2b stored in the dena Biogas Register, the following mappings apply:

For example, if a quantity of biomethane is to be exported to a registry connected to ERGAR, and EVK 0 has been specified in a BAD, the ERGAR Biomass Code DENA 2 is used in this transfer.