Eurogas Position on the Revision of EU Sustainability Certification Rules under the Renewable Energy Directive (RED)
Read the full Eurogas recommendations here.
Certification of renewable and low-carbon gaseous fuels is a cornerstone for building a truly integrated and functioning European market. Under REPowerEU, the European Union has set ambitious objectives, including reaching 35 bcm of biomethane production by 2030 and scaling up the production and import of 20 million tonnes of renewable hydrogen, alongside the development of a robust framework for low-carbon hydrogen.
Despite these ambitions, deployment of these energy vectors has progressed more slowly than expected. Regulatory uncertainty, coupled with delays in operationalising key instruments such as the Union Database, continues to hinder market development both within the EU and with third-country partners. The revision of Implementing Regulation (EU) 2022/996 presents a critical opportunity to address these barriers.
Certification must be unlocked both rapidly and effectively. Ensuring that rules are clear, workable, and implemented without delay is essential to scale up investments, enable cross-border trade, and fully integrate renewable and low-carbon gases into the EU energy system. A fully operational and reliable certification system, supported by a well-functioning Union Database, will be instrumental in delivering on the EU’s decarbonisation objectives while safeguarding flexibility and security of supply.
Against this backdrop, Eurogas makes the following recommendations concerning the upcoming Implementing Regulation (EU) 2022/996 recast:
- Ensure that new audit rules do not create unnecessary burdens
- Recognise liquefaction by equivalence as a viable enabler for decarbonisation
- Enable hydrogen blending into the gas grid through an appropriate product group definition
- Ensure more frequent updates of electricity carbon intensity & feedstock Annex IV
- Clarify and strengthen mass balancing rules
- Ensure the recognition of third-country imports
- Harmonise conversion factors for high and low heating values between GOs and PoS
- Establish clear rules on retroactive cancellation of PoS
- Clarify the treatment of subsidised biomethane
- Integrate low-carbon fuels in the Union Database framework
- Clarify the definitions of “cancellation”, “annulment” of a transaction and “consumption” of a consignment
Download the recommendations below.
