Navigating the NGER Low-Carbon Fuel Reforms: Why Co-Processed Blends and HVO100 Offer Two Very Different Paths
The Australian Government recently amended the National Greenhouse and Energy Reporting (NGER) scheme, formally introducing reporting pathways for co-processed low-carbon liquid fuels. For heavy transport, mining and construction businesses working toward emissions targets, the regulatory landscape has shifted meaningfully.
While the new NGER rules are a genuinely positive step forward for the industry, there's a real difference in how these fuels impact an end-user's operational and reporting reality.
As traditional domestic refineries begin offering co-processed fuel capabilities, fleet managers and sustainability teams need to understand the product, its efficacy in reducing emissions and its reporting requirements. Understanding the difference between a refinery's co-processed blend and a pure, standalone product like 100% Hydrotreated Vegetable Oil (HVO100) is key to mapping an effective decarbonisation strategy.
What Changed in the NGER Update?
The latest NGER amendments establish co-processed liquid fuels as recognised low-carbon fuel categories. This allows the certified biogenic (renewable) portion of these blended fuels to receive a zero reportable Scope 1 carbon dioxide emissions factor.
For the industry, this is a welcome advancement. It gives traditional diesel refiners a framework for integrating renewable waste feedstocks, like used cooking oil (UCO) directly into existing local supply lines, and it's a meaningful step toward reducing the carbon intensity of the national fuel pool.
However, while this reform clears a regulatory path for refinery blending, it isn't an automatic emissions windfall for heavy industrial end-users.
The Reality of Refinery Co-Processing: Understanding the Dilution Factor
Co-processing occurs when, for example, a traditional refinery injects raw bio-feedstocks into its existing crude oil refining towers alongside conventional diesel. It's an efficient way to make use of existing refinery assets, but engineering and fuel quality constraints limit how much bio-feedstock a standard refinery can process at once.
Raw bio-feedstocks behave differently to crude oil under high temperatures, presenting metallurgical and chemical challenges, including higher hydrogen consumption and equipment corrosion risk, within refining assets built for fossil crude. Because of these physical constraints, commercial co-processed fuels typically enter the market as low-percentage renewable blends, rather than as a fully renewable product.
For the end user of the co-processed fuel, under the updated NGER rules, only the specific certified renewable fraction of that fuel can be reported as zero Scope 1 emissions. The remaining, dominant portion still has to be reported and accounted for as standard fossil diesel. For a business facing steep, near-term emissions reduction targets, the majority of fuel spend on a co-processed blend is still going toward fossil emissions.
This matters most for large-volume emitters under real time pressure - mining and heavy haulage operations facing Safeguard Mechanism baselines, for example. Because only the certified renewable fraction of a co-processed blend counts, a site would need to purchase and run a substantial volume of fuel before that translates into a meaningful Scope 1 reduction. Switching to 100% HVO100 delivers the full benefit from the first litre, which matters when the reduction needs to show up in this year's numbers, not gradually as blend ratios improve over time.
Two Paths, Side by Side
The HVO100 Distinction: Neat Delivery vs. Shared Pools
Unlike co-processed refinery fuels that are integrated into shared fossil fuel infrastructure, pure HVO100 is manufactured in dedicated, standalone biorefineries and traded, stored and delivered as a 100% neat, unblended product.
Because HVO is fully hydrotreated and purified before it reaches a customer's tank, it's chemically near-identical to conventional diesel - the difference being that there are Zero Scope 1 emissions against the entire fuel delivery.
When you choose a segregated product like RD2Go's HVO100, the operational math is direct:
No shared-pool dilution - you're getting 100% renewable content directly in your tank, not a fuel that's overwhelmingly conventional fossil diesel.
Maximum impact per litre - because the product is undiluted, every drop running through your fleet works to lower your reported carbon footprint.
Physical fleet decarbonisation - beyond compliance accounting, it allows corporate boards and sustainability teams to confidently state that their physical site operations are running entirely fossil-free.
Immediate Local Air Quality Benefits - because pure HVO100 burns much cleaner than fossil diesel and contains virtually no aromatics or sulfur, switching to an undiluted product delivers significant on-site pollution reductions. Operating neat HVO100 cuts tailpipe particulate matter by up to 30–50%, slashes nitrogen oxides and drastically reduces carbon monoxide and unburnt hydrocarbon emissions. For underground mining, heavy transport fleets, and close-quarters construction sites, this significantly improves worker health and eliminates heavy exhaust odors.
The NGER Reform Timeline
The chart below traces how NGER's treatment of renewable fuels has built up over four consecutive reporting years, culminating in the extension to co-processed fuels.
Moving Forward with Certainty
Both co-processed refinery blends and segregated HVO100 fuel relies on robust certification systems to verify and track the sustainability of their feedstocks - the difference between the two products isn't the rigour of the paperwork, it's the concentration of renewable content in what actually reaches your tank.
At RD2Go, our established trading networks and dedicated storage mean we can deliver high-quality, undiluted HVO100 to your operations immediately, backed by ISCC PLUS mass balance certification .
Co-processing is a genuinely useful structural upgrade for the country's baseline fuel grid, and it will play a growing role as domestic supply scales up. But for companies looking to maximise emissions reductions within their existing fuel infrastructure today, pure, unblended HVO100 remains the more direct path.
Ready to explore how 100% pure HVO100 fits into your corporate emissions strategy? Contact the team at RD2Go today to discuss your fuel requirements and secure an audit-ready, low-carbon supply.
Related RD2Go Articles & HVO Information
→ HVO and Carbon: How Renewable Diesel Reduces Emissions Across Every Scope
→ Renewable Diesel vs Fossil Diesel: What It Means For Emissions In Australia
→ Fossil Diesel, Biodiesel, HVO & SAF: What's the Difference?
→ Diesel, Dust and Deadlines: Mining's 2026 Diesel Compliance Guide
→ OEM HVO Approvals for Use in Engines, Machinery, Trucks and Generators
Disclaimer:
This article is general information only and does not constitute legal, tax, accounting or compliance advice. NGER reporting obligations vary by entity and facility, and OEM fuel approvals vary by engine model. Readers should seek independent advice specific to their circumstances, confirm current NGER requirements with the Clean Energy Regulator, and confirm HVO100 compatibility with their equipment manufacturer.