Delays in the implementation of the UDB (Union Data Base) to replace the currently used Nabisy database which is broadly used by commercial players in the EU for transportation fuel, are now putting the EU mandates on both maritime and SAF at risk. Following the EUDR delay, a broad list of companies signed a letter of appeal to Von Der Leyen to postpone all related regulations regarding the UDB. The impact of this matter is not to be underestimated, as it will affect both FuelEU maritime and ReFuelEU rules and regulations. These two mandates amount to at least 2.0 million metric tons of additional mandated product for 2025. Meanwhile, BOGO continues to drop almost 2 standard deviations today to +$308/mt, which is still a $332/mt discount from where barge Fame0 is trading spot. It should be noted that BOGO was up 133.68% in the last 3 months despite this latest move. In the US, D4 RINs are adjusting to changing realities and have fallen 9% in the last week. Additional discussions on IRA costs are making headlines in the US, particularly the EV subsidy of $7500 for new cars that is embedded in the legislation through 2032. However, the little-discussed EV RINs plan is not being debated, but we all know that the EPA had a ready-made plan that was aborted at the last minute because of the IRA EV subsidy. This EV RINs plan will appear particularly attractive to any new leader of the EPA because it does not need to be legislated and can have an immediate impact on RINs prices.
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