The Horizon Europe topic HORIZON-CL5-2026-11-D3-04: “De-risking renewable fuel technologies through transnational pre-commercial procurement of renewable fuel industrial value chains” seeks to support the development, demonstration and de-risking of essential renewable fuel technologies and their industrial value chains through a transnational Pre-Commercial Procurement (PCP) approach. According to the European Commission, “an exceptional effort is needed to develop, demonstrate and de-risk essential renewable fuels technologies and establish their industrial value chains in a cost-effective way”. The action aims to bring renewable fuel industrial value chains to TRL 8 by the end of the project, accelerating market uptake and helping to overcome the “valley of death” between innovation and commercial deployment.
This Q&A document is intended to help stakeholders better understand the objectives, scope, eligibility conditions and implementation requirements of the call.
Disclaimer: These FAQs have been carefully compiled and summarized based on the information provided during the official European Commission information webinar for the HORIZON-CL5-2026-11-D3-04 call hosted by ETIP Bioenergy on 22 June 2026, as well as the accompanying presentation slides covering the call’s specific scope and the legal aspects of Pre-Commercial Procurement.
While we have placed the utmost care in accurately reflecting the discussions, explanations, and guidance provided by the European Commission experts, these questions and answers are intended strictly for informational and support purposes.
We strongly encourage all potential applicants to carefully read the official call description and to independently verify all requirements using official European Commission sources. For definitive and legally binding guidance, please always consult the EU Funding & Tenders Portal, the official Work Programme annexes, the applicable Model Grant Agreement, and the specific Horizon Europe Pre-Commercial Procurement application guidelines prior to forming a consortium or submitting a proposal.
Sources
Recording of the webinar Slides: Cluster 5 WP2026-2027 Destination 3 SET Plan Flagships Renewable Fuels – Maria Georgiadou Senior Expert, European Commission DG RTD
Slides: Legal aspects of Pre-commercial Procurement (PCP) calls – Lieve Bos, Policy Officer for Innovation Procurement Experimentation Space, European Commission DG RTD.
General Call Information and Objectives
The main aim of the call is to de-risk essential renewable fuel technologies that can contribute to domestic commercial fuel production beyond 2030 in a cost-effective way. The scope of the call is to issue a pre-commercial procurement (PCP) of R&D, validation, and possibly the first deployment of industrial value chains of essential renewable fuel technologies. This must be done through a competitive development in phases of entire industrial value chains, building upon existing knowledge on technology and value chain readiness. Specifically, the PCP will procure services to design and bring these industrial value chains of essential renewable fuel technologies to TRL 8 by the end of the action.
There will be one single project funded that will be granted the entire 40 million EUR allocated for this topic.
The project requires a "Transnational Buyers Group" consisting of a minimum of three independent legal entities from three different Member States or Associated Countries. At least two of these entities must be "public buyers" from different countries. The group must also designate one "lead procurer" to publish and coordinate the joint call for tender under their legal framework.
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The definition is broad and includes any contracting authority or entity bound by EU public procurement directives. It is not limited to traditional national or regional ministries, but also includes entities providing services of public interest, such as public transport operators, energy companies, water companies, airports, and harbors.
Private industry actors who intend to act as solution suppliers cannot participate in the proposal to avoid conflicts of interest. However, if industry players want to participate as a buyers, they can  join the consortium. Their commitment involves dedicating their time, effort, and alignment with the consortium to run the procurement.
Yes, they can participate as beneficiaries. Their typical role is to help promote market consultations, mobilize stakeholders, and assist public buyers in preparing the procurement by leveraging their established networks and expertise.
The intention of a PCP is to see multiple competing solutions financed. Public buyers can choose to tackle one common challenge using multiple sourcing to compare different solutions, or they can create different lots within their procurement to address multiple different challenges simultaneously.
Yes, research and innovation funding organizations and other entities can participate as beneficiaries. The buyers group can include additional other types of procurers that are providing services of public interest (E.g. Assisting buyers in preparing the PCP/PPI, dissemination activities) and share the procurement need. These entities may participate in the action, on condition that they are not potential suppliers of solutions sought for by the PCP/PPI and they have no other type of conflict of interest with the PCP/PPI.
Technology and Feedstock Requirements for the Pre-Commercial Procurement Tender that will be issued by the awarded The Pre-Commercial Procurement (PCP) Process Consortium
Proposals must encompass entire industrial value chains and they must build upon existing knowledge established through previous EU projects and research and development (RTD) studies, namely:
Based on these EC studies, the call explicitly lists seven examples of "essential" industrial value chains that comply with the scope:
- Production of advanced bioEthanol and further processing into ATJ-SPK
- ii.Biomass Gasification and FT-Synthesis to produce FT-SPK
- iii.Production of BioMethanol for further processing into MTJ
- iv.Hydrotreatment of Lipids from marginal/contaminated lands to produce HEFA
- v.Biomass Pyrolysis and Upgrading or co-processing to produce biokerosene and bio-heavy fuel oil
- vi.Biomethane from AD and Gasification and Methanation to produce biomethane for shipping or further processing into methanol (methanolysis) for shipping
- vii.E-Methanol production from CO2 and renewable H2 for shipping
This list provides key examples of value chains but the call remains fully open to other value chains. The primary requirement is that any proposed solution must be proven capable of reaching the pre-commercial TRL 8 stage by the end of the project.
Hydrogen Exclusion: It is explicitly noted in the call implementation rules that hydrogen production as an end-product is not in scope for this topic.Â
The call does not provide a shortcut to change, bypass, or influence existing RED regulations. The project is designed to implement compliant solutions, meaning projects must exclusively use feedstocks that are already explicitly listed as eligible in Annex IX of the Renewable Energy Directive. If your project develops a highly promising technological solution but faces regulatory blockades because current laws do not provide legal certainty to test this specific new innovation, the EU grant does not give you an automatic "free pass" to ignore those existing regulations. However, projects can utilize mechanisms known as "regulatory sandboxes". This involves collaborating directly with the responsible national regulatory authorities to negotiate temporary permission to test the innovation in a controlled, limited, and safe environment. Several EU countries already offer these regulatory sandbox mechanisms to researchers and suppliers.
The Pre-Commercial Procurement (PCP) Process
Yes, conducting an Open Market Consultation is a mandatory step for every EU-funded Pre-Commercial Procurement.
A minimum of two phases is required, typically starting with a feasibility study followed by validation/testing. However, if appropriate to speed up the project, procurers can choose to fast-track and condense development and testing into a single combined phase.
The overarching procurement need and common problem must be defined clearly from the very beginning so bidders understand the overall goal. However, specific technical requirements and award criteria can be detailed and refined stepwise as the project progresses through its different phases (e.g., from general security design to specific field-testing requirements).
The biomass itself is simply considered part of the industrial value chain being developed. Regarding the PCP procedure itself, it is exempted from standard EU public procurement directives. This grants buyers the freedom to design their own customized procedure (such as open or restricted). The main legal requirement is that they must publish a prior information notice and a contract notice.
Financials, Risk Management, and IPR
The EU provides a 100% funding rate for PCP actions. However, public buyers are free to add their own additional funds if they wish to conduct even more expensive testing outside the EU budget.
To ensure the project has a sizable impact, more than 50% of the total eligible project costs must be dedicated strictly to the actual procurement of the R&D services. The remainder covers related preparation, management, and testing activities.
To incentivize wide commercialization, the suppliers retain ownership of the IPR. In return, public buyers retain license-free rights to use the results for their own operations. Buyers also retain a “call-back right,” enabling them to demand the transfer of the IPR back to themselves or force the supplier to grant licenses to third parties if the supplier fails to commercialize the technology or in emergency situations.
Procurers can manage these risks by setting strict “performance indicators” (minimum quality, maximum cost, and timelines) that suppliers must meet at the end of each phase to advance to the next. Additionally, buyers are encouraged to use “value engineering.” This allows them to offer financial incentives—effectively sharing cost savings—with suppliers who deliver solutions that are faster, cheaper, or of higher quality than initially contracted.