Policy Paper
01.12.2025

Eurogas Response: EU Taxonomy Climate Delegated Act Call for Evidence

Read the full paper here.

Eurogas calls for a more pragmatic, coherent and technology-neutral EU Taxonomy Climate Delegated Act to better support investment in Europe’s energy transition. While recognising the important role of the Taxonomy in guiding sustainable finance, Eurogas warns that several current technical screening criteria are overly complex, inconsistently aligned with existing EU legislation, and not always reflective of technological and economic realities. This risks slowing down investments that are needed to deliver system flexibility, security of supply and emissions reductions at scale.

In its response, Eurogas highlights the need for stronger alignment with existing EU energy legislation, including the Renewable Energy Directive, Energy Efficiency Directive and Industrial Emissions Directive, in order to reduce legal uncertainty and ensure a more coherent regulatory framework. It also calls for simplified DNSH and life-cycle assessment requirements, making better use of existing standards and providing clearer, more practical guidance on what is required to demonstrate compliance.

A further key concern relates to greenhouse gas emission thresholds, which Eurogas considers too strict or not achievable with current or near-term technologies without CCS. It therefore recommends revising thresholds to better reflect technological feasibility, market maturity and system adequacy, while also introducing grandfathering provisions to protect existing investments and ensure regulatory stability.

On bioenergy, Eurogas stresses the importance of full alignment with RED III sustainability criteria, warning that diverging requirements could undermine investment certainty. It also supports a more technology-neutral approach to biogas and biomethane, ensuring recognition across all end uses and value chains.

Finally, Eurogas underlines the importance of maintaining flexibility in how gas infrastructure is treated under the Taxonomy. This includes ensuring dual-purpose and hydrogen-ready networks remain eligible during the transition, alongside broader recognition of hydrogen storage and hydrogen-derived fuels, including transitional solutions such as blends, which are essential for system integration.

Overall, Eurogas is calling for a Taxonomy framework that is more practical, predictable and investment-friendly, one that supports a realistic and cost-effective pathway to decarbonisation without unintentionally constraining the technologies and infrastructure needed to deliver it.