Position Paper

Open joint letter to the European Commission concerning the Union Database

(23 February 2023) The co-signatory organisations wish to raise serious concerns about the operational design and launch planning of the Union Database (UDB) for tracing gaseous and liquid transport fuels, under the recast Renewable Energy Directive (RED II) and the associated Implementing Act for voluntary schemes.

We represent the industries of renewable gaseous fuels, including producers, transmission operators, suppliers and traders. On a general note, we welcome the objective of the UDB to facilitate cross-border trade and enhance liquidity in a pan-European renewable and low-carbon gas market. However, pending operational design issues should not adversely impact separate tradability of certificates from the underlying commodity, and system integrity. We are also concerned over the general lack of information and due notification to gas market participants, so that they are sufficiently prepared ahead of the launch of the UDB. This altogether makes the implementation plan of the UDB unrealistic and risks causing uncertainty and barriers in kick-starting a market in renewable and low-carbon gases.