Joint Industry Call: Removing barriers to the internal energy market by enabling Ireland’s participation in cross-border trade of renewable gas
Read the full joint statement here.
The co-signatories of this joint statement urge the European Commission to take immediate action to:
- Recognise Ireland as an integral part of the EU interconnected gas grid and associated mass balancing system;
- Enable cross-border trade of sustainable renewable gases from third countries, including the United Kingdom, within the Union Database (UDB).
Pursuant to Directive (EU) 2015/1535 (1), the Irish authorities notified the European Commission on 23 December 2025 of a proposed national Renewable Heat Obligation (RHO) scheme under the Renewable Heat Obligation Act (2025).
In its detailed opinion assessing the matter at stake, the European Commission stated that “no pipeline-based biomethane from the UK or continental Europe can be imported to Ireland nor it can eligibly count towards the Irish contribution to the RED target”, for as long as the United Kingdom does not participate to the Union Database (UDB) or meet the applicable sustainability requirements for renewable gaseous fuels. This interpretation is understood with respect to the UK’s status as a third country following Brexit and where European Regulation is no longer directly transposed. This may justify proportionate safeguards for traceability, certification and double-counting prevention in third countries. However, this should not justify a blanket exclusion of pipeline-based biomethane imports into Ireland where the sustainability and GHG characteristics aligned with the RED can be verified through recognised certification systems and, in the future, the Union Database.
The continued exclusion of third countries from the UDB, including the UK, has been an issue repeatedly raised by industry representatives and third-country governments. This is now operating as a direct barrier to the proper functioning of the EU single market. Its impact is particularly acute and disproportionate for Ireland, due to its unique geographic and infrastructural position, whereby Ireland’s gas interconnections transit through the UK, resulting in an indirect pipeline connection to continental Europe. As a consequence, Ireland is denied access to compliance and market mechanisms available to other Member States. This creates unjustified intra-EU trade restrictions and results in discriminatory treatment within the EU internal energy market.
To preserve the integrity of the EU renewable energy market, it is essential that all countries with physical interconnection to the EU gas grid should have access to the mass balancing system. Cross-border trade of renewable gases between EU countries and third country partners should also keep contributing to our decarbonisation goals. In this context, third countries should also be brought within the scope of the UDB before this tool becomes mandatory.
Download the full statement below.
