Voluntary Certification for RNG Projects: New Qualification Standards for Animal Waste

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Public and private financial incentives for the construction and operation of renewable natural gas (RNG) projects have accelerated the growth of the industry over the past several years. While much of the RNG industry’s focus recently (for good reason) has been on qualifying for federal tax credits under the Inflation Reduction Act or state tax credits under programs like California’s Low Carbon Fuel Standard, there has been less emphasis on the voluntary credit market for private parties. However, with the phase-out of many of these public tax credits, RNG project participants are taking a closer look at the voluntary market.

On October 20, 2025, the Center for Resource Solutions modified its Green-e® Renewable Fuels Standard to explicitly accommodate biomethane production from certain animal-waste operations. The new standards define “Concentrated Animal Feeding Operations” (CAFOs) under the newly-added Appendix A. Until this update, projects using animal waste feedstocks faced uncertainty under the voluntary certification regime because the standard primarily referenced organic waste streams like food waste, yard waste and municipal wastewater. With these new criteria in place, developers of RNG facilities that capture methane from manure lagoons or other animal-waste systems can now aim for Green-e® certification.

For project developers, investors, and other RNG project participants, this change creates measurable new opportunities. With animal-waste RNG now eligible, developers can tap into a broader feedstock base—accessing livestock operations, dairies, hog or poultry farms—to partner on biomethane projects and then certify under Green-e® to generate Renewable Fuel Certificates (RFCs) that carry third-party verification. This means additional revenue streams from voluntary markets, enhanced project marketability, and better off-take positioning for those seeking certified low-carbon fuel. Moreover, the inclusion of CAFO-based projects can make such developments more attractive to ESG-oriented investors who value not only carbon reductions but also traceability and independent verification of feedstock and emissions.

Certification under Green-e® now also means animal-waste-based RNG projects can benefit from enhanced reputational and risk-mitigation value. By complying with Appendix A, these projects demonstrate that they meet rigorous environmental and sustainability safeguards—such as community input, wildlife and water-quality protections—and strict feedstock definition for CAFOs. This third-party guardrail reduces investor risk around feedstock legitimacy or public-relations concerns (often associated with large animal operations) and allows developers to anchor a certification label in their marketing and contracting. In turn, investors may view certified RNG from animal waste as lower-risk and more bankable, especially when paired with offtake contracts or voluntary-buyer portfolios requiring certified credentials.

Although the future of financial incentives for RNG projects on the public side is a little more uncertain and subject to some growing pains in the near term, the development of the voluntary credit market for these projects is a welcome relief.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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