Conditions for the 2025 Compensation Scheme Gaps 4th round

The compensation scheme for ‘Filing the gaps’ is intended for manufacturers, producers, suppliers and subcontractors of construction products and industry organisations that have an LCA drawn up and publish the LCA data in the form of an environmental declaration in the NMD. Specific conditions apply to start-ups and small businesses that need extra support to comply with the regulations (see conditions under B). Manufacturers and producers of innovative products that contribute to CO2 reduction in the Netherlands are also eligible for compensation under specific conditions (see conditions under C). Manufacturers and suppliers with large or complex projects that require extra attention before the data can be published in the NMD and producers who, due to new CPR rules, want to have an LCA carried out for inclusion in the NMD.

This scheme is intended exclusively for the owner of the data. The applicant is the legal entity registered with the NMD Foundation and receives an invoice from the NMD Foundation for the annual membership fee. Once the application has been made, it is no longer possible to change the name of the applicant. If the NMD Foundation decides to pay the fee, it will be paid out to the applicant.

The NMD Foundation periodically publishes a list of gaps, which is based on elements, product groups or specific products that are strategically important for a more complete and qualitative EPB calculation. As of 1 January 2025, the following products and groups will be eligible for compensation:

1. Products on the priority list of the ‘white spots in the NMD’.
2. Products within the National Approach to Bio-based Building (NABB) scheme.
3. Innovative products that contribute to CO2 reduction in the Netherlands.

The compensation scheme for Filling the gaps in the NMD is part of a long-term project. As long as there is budget available, it will be distributed on a first-come, first-served basis. This compensation scheme will end once the available budget has been exhausted.

Table 1

1. The applicant is the owner of the data to be published. The applicant is registered with the NMD Foundation and receives an annual invoice for the contribution to be paid. After the data has been published, it is no longer possible to change the name of the applicant. Any compensation will therefore be paid to the applicant by the NMD Foundation..
2. The applicant checks wether the product appears on the Filling the gaps list. View the Filling the Gaps list
3. The applicant shall publish the environmental declaration in the NMD by 1 November 2025 at the latest. The content of the environmental declaration must be new and may not have been published in the NMD before. If it turns out that the content of the environmental declarations concerns copies and/or clones, the applicant can only be considered for a reimbursement for one environmental declaration. Copies and/or clones are not eligible for compensation. Environmental declarations published after 1 November 2025 are excluded from participation and are not eligible for compensation under this scheme. Publication of the environmental declaration will take place based on the NMD Assessment method. The environmental declaration must be assessed according to the verification protocol. View the verification protocol
4. To publish the data in the NMD, the applicant must follow the procedure for inclsuion in the NMD. View the procedure
5. The applicant must complete the following steps:
   • Data owner data has been entered when registering your data in the NMD. If this has not yet been done, you can enter your billing details here::  https://milieudatabase.nl/nl/milieudata-lca/mijn-product-in-de-nmd/aanmelden-data/#40
   • A signed de-minimis declaration  must be uploaded in the application form.
   • Compensation applicants start-ups, new businesses and small entrepreneurs, innovative products and special projects must also send the application document with a brief summary of the intended project in addition to the above information. This can be done via theapplication form.
6. The maximum available budget for this compensation scheme in 2025 is €355,000 excluding VAT. This amount provides for the compensation of a maximum of 322 category 1 or category 2 environmental declarations.
7. The compensation is €1,100 excluding VAT per environmental declaration up to a maximum of €27,500 excluding VAT per applicant.
8. De vergoeding is € 1.100,- exclusief BTW per milieuverklaring tot een maximum van € 27.500,- exclusief BTW per aanvrager.
9. The NMD Foundation has a separate procedural regulation for special projects. Special projects must involve, for example, a large dataset and/or an adjusted input procedure. An applicant must meet the following conditions:
   • The applicant submits a proposal to the NMD Foundation describing why the applicant believes the project to be special. The proposal describes the purpose and expected output and outcome of the project.
   • The maximum reimbursement per applicant is €27,750 excluding VAT.
   • The compensation will be paid once the dates have been published in the NMD and the dates have been approved by the NMD Foundation.
10. If the situation so requires, the NMD Foundation may, in consultation with the applicant, choose to award the applicant a compensation of up to 40% of the total LCA costs, up to a maximum of €27,500 excluding VAT per applicant. The applicant is obliged to send an itemised invoice to the NMD Foundation, based on which the amount of the aforementioned compensation can be determined. This condition may also apply to special projects.  
11. Apllicants who have previously participated in the White Spots compensation scheme may participate again, provided that the following conditions are met:
    • Nieuwe milieuverklaring(en) wordt/worden gepubliceerd in de NM;
    • The product appears on the list published by the NMD Foundation;
    • The applicant complies with the state aid scheme as referred to in the de minimis regulation and
    • there is still sufficient budget available at the time of publication.
    • If an applicant has submitted a (preliminary) application in 2024 and has been granted an extension until 1 November 2025 to publish the data in the NMD, the NMD Foundation reserves the right to choose between processing the application under the 2024 round 3 scheme or the 2025 round 4 scheme.
12. Applications will be processed in the order in which they are published in the NMD. The date of publication is the date on which the environmental declaration was published in the NMD and the NMD has received a complete application.
13. If an applicant is part of an economic unit in which legal entities and companies are organisationally linked as referred to in Article 2:24a of the Dutch Civil Code, Article 2:24b of the Civil Code and Article 2:24c of the Civil Code, the maximum of €1,100 excluding VAT per environmental statement up to a maximum of €27,500 excluding VAT applies to the economic entity, regardless of which legal entity and/or company within the economic entity submitted the application.
14. Insofar as the granting of the compensation can be considered as an aid measure, the compensation is granted on the basis of de minimis Regulation No. 1407/2013 of the Commission of the European Communities of 18 December 2013 on the application of Articles 107 and 108 of the Treaty to de minimis aid (OJEU 2013 L352/1), or later European legislation replacing it, and only insofar as the conditions of that regulation are met. When submitting the request for compensation, the applicant submits a de minimis declaration stating all other de minimis aid received in the two preceding tax years and the current tax year. The total amount of de minimus support granted to one company per member state may not exceed €200,000 over a period of three tax years. If the applicant has ties to other companies such that these companies must be considered one company, the de minimus declaration applies to the entire company..
15. The application will be assessed after the environmental declarations have been published in the NMD and a complete application has been received by the NMD Foundation. If the application is incomplete, the applicant will be given the opportunity to submit the missing documents within a period specified by the NMD Foundation. If the missing documents are not submitted within the set period, the application will not be processed.
16. The NMD Foundation may engage experts to assess the content.
17. The application will be assessed within 13 weeks of the NMD Foundation receiving a complete application.
18. Once the assessment has been completed, the applicant will receive an assessment letter. This letter will indicate how the compensation will be paid out.
19. Applications from round 3 2024 that have been considered for extension have been given the opportunity to publish these dates by 1 November 2025 at the latest. If the dates have not been published in the NMD by 1 November 2025 at the latest, the application will not be considered further. The 2024 White Spots scheme (3rd round) applies to applications submitted in 2024.
20. The applicant is obliged to keep published data in the NMD for five years. If the applicant removes the published data from the NMD in any way within a period of five years, the NMD Foundation reserves the right to reclaim the compensation paid.
21. If, during the period after payment of the compensation but before the expiry of the five-year term, the applicant sells the published data or wishes to make changes to the published data, the applicant is obliged to contact the NMD Foundation.

Definitions of biobased materials and building products Biobased materials (products) are materials (products) that are derived entirely or partially from biomass, i.e. from a material of biological origin, excluding material embedded in geological formations or fossilised material.

Biobased content: The biobased content in a construction product can be determined using EN 16640 or EN 16785-1. Both approaches (EN 16640 and EN 16785-1) are based on the same principle that the 14C content can be considered a tracer of recently produced biobased products. However, there are differences in the way the amount of 14C in a sample is used to express the amount of biobased (carbon). Therefore, when information about biobased (carbon) content is exchanged between companies, or from company to consumer, it is crucial to clarify what these differences are and which standards these statements are based on. The EN 16640 standard is less dependent on the moisture content of the product (water in wood, for example) and is therefore easier to apply to building products.

• EN 16640 – parts B and C Biobased carbon content

The amount of biobased carbon (= organic + inorganic) expressed as a fraction of the total amount of carbon in the sample.

European standard EN 16640 specifies the method for determining the biobased carbon content in biobased products using the 14C method.

• EN 16785-1 Biobased content

The amount of biobased C, H, N, O expressed as a fraction of the total mass of the sample. The approach used for carbon to determine the biobased content of a sample based on isotope measurements cannot be used for other elements, such as oxygen, nitrogen or hydrogen, because there are no ‘biobased marker’ isotopes for those elements. However, based on the chemical (reaction) formula and elemental composition of biobased and fossil raw materials, it is possible to calculate the biobased content of a product, taking all important elements into account.
This approach is specified in EN 16785-1, which determines the amount of carbon, oxygen, hydrogen and nitrogen from biomass in the biobased content. The elements oxygen, hydrogen and nitrogen in the product are considered to originate from biomass if they are bonded to carbon that has been obtained from biomass. The method includes validation of a manufacturer's declaration about the composition of the product, based on the evaluation of the combined experimental radiocarbon and elemental analysis results.

Biodiversity is a contraction of biological diversity. Biodiversity is the number, variety and variability of living organisms. This includes the variety within species (genetic diversity), between species (species diversity) and between ecosystems (ecosystem diversity).

Circular construction means developing, using and reusing buildings, areas and infrastructure without unnecessarily depleting natural resources, polluting the living environment and damaging ecosystems. Building in a way that is economically responsible and contributes to the well-being of people and animals. Here and there, now and later.

Sustainable extraction (‘Renewable raw and construction materials’; Agrodome, April 2022): Biotic raw materials are in principle infinitely available because they grow back over and over again within a human timescale. This means that the biotic material is harvested and the plants or trees can start growing again in the same place. This can be done through natural processes (seeds present in nature, root suckers) or through human intervention by sowing, planting and managing (fertilising, etc.) crops.

NB: Artificial nutrients and pesticides that are applied are not renewable.

Sustainably managed forests are self-sustaining ecosystems from which timber and other products can be regularly harvested without affecting production, quantity or biodiversity. They are therefore in fact an inexhaustible resource.

In addition, the ‘Definitions of renewability and biobased’ are used for biobased products. . View here

In addition to the above conditions 1 to 19, the following criteria apply to biobased materials and building products:

A1. Applications for biobased products made in 2024 fall under the National Approach to Biobased Building (NABB). The NABB offers a reimbursement of €2,500 excluding VAT per LCA for a minimum of 70 biobased building products.

A2. To maximise the effectiveness of the regulation, it is necessary that the new environmental declarations actually fill in the gaps and reduce them. In other words, the new environmental declarations must meet the following criteria:

A3. The product must be sustainably sourced and the biobased content must be predominant. The final award is based on the List of Ingredients as stated in the LCA. The assessor can view this confidentially and without naming the ingredients and recipes, the EPD can report on the biobased content of the product.

a. Building materials with the following biobased content are eligible for the scheme:

1. Algae
2. Bamboo
3. Bio-asphalt
4. Biobased fire protection
5. Biobased paint
6. Bio-composite
7. Biofoam pearls
8. Biopolymer
9. tree resin
10. Cellulose
11. Composite
12. Grasses
13. Hair
14. Hemp
15. Wood fibre
16. Jute
17. Lime hemp
18. Cotton fibres
19. Coconut
20. Cork
21. Lignin
22. Glue
23. Bulrush
24. Miscanthus
25. Mycelium
26. Dandelion (rubber)
27. Oil and resin
28. Reed
29. Rice husk
30. Sorghum
31. Sheep's wool
32. Shells
33. Straw
34. Paint
35. Flax
36. Wood-Plastic Composites
37. Sawdust
38. Seaweed
39. Sunflower seed meal

b. Other natural fibres and other residual flows from agriculture, forestry and horticulture are also eligible, provided these products meet the criteria listed in point B2. Residual flows therefore include potato peelings, pineapple peelings, mango peelings, etc.

A4. For products that have been processed in such a way that it is not clear whether they have an organic content (such as organic resin, organic glue, organic paint), the organic content is determined according to EN 16785-1.

A5. If it concerns a biobased additive with a low volume percentage per product unit, the biobased content is considered to fulfil the condition that the additive must be more than 95% biobased.

A6. A maximum of 10 LCAs of category 1 environmental declarations of biobased building products (including wood) that improve the quality of existing category 2 environmental declarations are eligible for compensation.

A7. A maximum of 10 LCAs of category 1 environmental declarations of the following wood products are eligible for compensation:

• Complete prefabricated wooden construction kits with predominantly biobased materials
• Complete wooden homes or buildings with predominantly biobased materials

In addition to the above conditions mentioned under 1 to 22, the following criteria apply to start-ups/starters/SMEs.

B1. Applicants must submit a request substantiating that the applicant is a starter or small entrepreneur. The product must make a positive contribution to the climate, the reduction of CO2, or the Dutch circular construction economy. The application form can be downloaded via the link below.

B2. The compensation scheme for start-ups/starters/SMEs is a scheme for the following target groups:
a. starting (or start-up) manufacturers or suppliers
b. small or medium-sized manufacturers or suppliers

B3. It must be a construction product that makes a positive contribution to the Dutch circular construction economy.

B4. You have been registered with the chamber of commerce for a maximum of 5 years and/or you have a maximum of  250 employees.

B5. If you are an SME, you have an annual turnover of no more than €50 million or a balance sheet total of no more than €43 million.

B6. A maximum amount of €1,100 excluding VAT per environmental declaration applies to construction products that make a positive contribution to the Dutch circular construction economy, up to a maximum of €27,500 excluding VAT. The maximum reimbursement per applicant is therefore €27,500 excluding VAT.

In addition to the above conditions listed under 1 to 22 inclusive, the following criteria apply to innovative building products.

C1. Applicants must submit a request substantiating that the product is an innovative building product. The product must make a positive contribution to the climate, the reduction of CO2, or the Dutch circular construction economy. The application form can be downloaded via the attached link.

C2. For innovative building products that make a positive contribution to the Dutch circular construction economy, a maximum amount of €1,100 per environmental declaration applies. The maximum compensation per applicant is €27,500 excluding VAT.