Joint Paper on Recast Implementing Regulation (EU) 2022/996
Read the full Eurogas recommendations here.
The renewable gas industry welcomes the objectives of Implementing Regulation (EU) 2022/996 to strengthen the Union Database (UDB), improve traceability, and prevent fraud in renewable and low-carbon gases. At the same time, we stress that the rules must remain technically sound, operationally feasible, and compatible with the way EU gas markets and infrastructure function. We see strong common ground on preserving a workable mass-balance system, keeping realistic mass-balance periods and operational deadlines, enabling predictable third-country access, ensuring that sustainability proofs and gas volumes are linked without undermining market liquidity, and applying robust but proportionate auditing and fraud controls. Furthermore, we call for the recognition of all liquefaction pathways, including on-site liquefaction, grid liquefaction and equivalence liquefaction, to promote a level playing field and ensure the advantages of all models are harnessed to meet the growing demand for bio-LNG and e-LNG.
Renewable gases are central to the EU’s decarbonisation strategy for heating, industry, power, and transport. Their scale-up depends on a clear, stable regulatory framework that recognises the fungible nature of gas in interconnected networks, allows certified volumes to be traded efficiently across borders and sectors, and provides traceability that prevents fraud without creating disproportionate administrative burdens.
Implementing Regulation (EU) 2022/996 should therefore reflect the physical and commercial realities of gas networks, support investment in renewable gases, and maintain confidence in sustainability claims while avoiding barriers to trade and liquidity.
We believe that if the concerns that we mention are addressed, Implementing Regulation (EU) 2022/996 can strengthen trust in renewable gas markets without undermining liquidity, support investment in biomethane, e-methane, and RFNBOs, enable cross-border trade and third-country imports under clear, equivalent rules, and provide a robust but proportionate framework for auditing and fraud prevention.
If key issues remain unaddressed, the Regulation risks reducing the volume of certified renewable gas available on the market, increasing costs and administrative burdens disproportionately, and creating legal and commercial uncertainty for investors and traders. Hence, reducing the efficiency and affordability of the European energy market at a moment when it was crucial to secure improvements in both.
This paper sets out our shared concerns and concrete policy asks by topic, with a view to supporting a scalable, credible market for biomethane, e-methane, and RFNBOs.
Read the full article below.
