Position Papers

Letter and Position Paper
Urgent Need for Regulatory Clarity in MER to Safeguard EU Supply Security: Letter to Institutions
Read the full letter here.
Eurogas, along with 18 other organisations at the forefront of the energy transition, sent a joint letter to the European Commission and Council of the EU regarding the M...

Position Paper
Supporting the Development of CCUS Technologies in the NZIA DR on CO2 Injection Obligation
Read the full recommendations here.
Eurogas welcomes the publication for consultation of this Delegated Regulation, which supplements the rules under the Net Zero Industry Act (NZIA, Article 23) an...

Position Paper
REPowerEU: Delivering Energy Security and a Realistic Transition
Read the full position paper here.
As the European Commission prepares to update REPowerEU, it must reflect not only how far we’ve come – but how much of the original vision was based on assump...

Position Paper and Report
Navigating Towards 2040: The Critical Role of the LNG Industry in Achieving the EU’s Climate Targets
Read the full report here.
Liquefied Natural Gas (LNG) will continue to play a pivotal role as Europe accelerates its transition to a secure, competitive and climate-neutral energy system, accordin...

Position Paper
Enabling Renewable Gases in Buildings with Green Contracts
Read the full position paper here.
The revised Energy Performance of Buildings Directive (EPBD), together with the revised Energy Efficiency Directive (EED) are the foundation of the EU's plan to d...

Position Paper
Eurogas Recommendations on Gas Storage Regulation
Read the full paper here.
Eurogas recognises the critical role of gas storage in ensuring security of supply (SoS), particularly during times of crisis. However, the European energy landscape has s...

Position Paper
Eurogas Recommendations on Two Commission Communications for the Automotive Sector
Read the full recommendations here.
On 5 March 2025, the Commission published two Communications in the context of the Strategic Dialogue on the Future of the Automotive Industry: 'The Industrial A...

Letter and Position Paper
Open Letter to Transport Commissioner, MEPs, and Ministers: EU Funding for Heavy-Duty Fleet Renewal
Read the full letter here.
Eurogas published on 24 March 2025 a letter addressed to Commissioner Tzitzikostas and the Members of the European Parliament, in which we called on the European Union to...

Position Paper
Call for action: Urgent need to recognise third country exports of gaseous fuels under the Union Database
Read the full joint statement here.
Call for action: Urgent need to recognise third country exports of gaseous fuels under the Union Database
The co-signatories of this joint statement call for...

Position Paper
Action Plan for Affordable Energy Prices
Download the full document here.
Following the publication of the European Commission's Action Plan for Affordable Energy, which accompanies the Clean Industrial Deal, Eurogas shares its observatio...

Position Paper
Recommendations for a Competitive European Security of Supply Framework
The European Union's revision of its security of supply architecture will need to balance sustainability measures from the Green Deal, energy affordability concerns such as those stemming from the crisis, and energy security imperatives associated with the phase-out of Russian fossil fuel imports.
Eurogas welcomes this revision and proposes both overarching and gas-specific security of supply recommendations.

Position Paper
Recommendations on Scaling Up Industrial Carbon Management
Read the full recommendations here.
Industrial carbon management (ICM) technologies are crucial for achieving the EU’s climate neutrality target by 2050, enabling emissions reductions while ensur...

Position Paper
Recommendations on Ensuring EU Security of Affordable Supply in Light of the Methane Emissions Regulation
Download the full document here.
The European Union's Methane Emission Regulation (MER) represents an important step in aligning climate ambitions with global energy trade. Eurogas fully supports t...

Position Paper
Road Transport Sector calls for Technology-Neutral Review of the CO2 Emission Standards Regulations
The Road Transport Sector calls for Technology-Neutral Review of the CO2 Emission Standards Regulations and Incentives to Stimulate Uptake of Clean Vehicles by Fleet Owners.
Read the full statement...

Letter and Position Paper
Ms Von der Leyen, please do not include Measures which Endanger Europe’s Energy Security and Financial Stability in the Clean Industrial Deal
See the full joint letter.
Ms Von der Leyen, please do not include measures which endanger Europe's energy security and financial stability in the Clean Industrial Deal.
Eurogas, alongside a coali...

Position Paper
Eurogas urges European Commission to assess Storage Regulation’s impact on energy prices
Download the full document here.
In the context of the upcoming Clean Industry Deal and Affordable Energy Action plan, the costs and benefits of a possible extension of the Storage Regulation need...

Position Paper
Let Green Gas Count: GHG Protocol Should Fully Recognise Robust Market Instruments in End-Users’ Scope 1 Emissions Inventories
Read the joint letter here.
145 companies and associations globally call for clarity on the role of market instruments for renewable gases in the Greenhouse Gas (GHG) Protocol.
Following the wit...

Position Paper
Joint Statement: Reality Check for European Hydrogen Policy to Adjust the Course
Read the full joint statement here.
17 industries bringing together key stakeholders across the hydrogen value chain, welcome the EU’s commitment to developing a clean hydrogen market....

Position Paper
Eurogas response to the European Commission’s energy security fitness check consultation
See full response here.
In September 2024, the European Commission published a consultation on the fitness of Europe's energy security.
In summary, Eurogas' position is that:
The EU should...

Position Paper
Reducing, simplifying & streamlining reporting requirements under the EU Framework on Sustainable Finance
Eurogas views on reducing, simplifying and streamlining reporting requirements under the EU Framework on Sustainable Finance.
Read the full document here.
The European Framework on Sustainable F...

Position Paper, Report, and Study
STUDY | Ensuring Resilience in the European Energy Transition: Strategic Use of Gases to Meet EU Climate Ambitions
The success of Europe’s energy transition depends on balancing affordability, security, and sustainability.
Natural gas, renewable and low-carbon gases are uniquely positioned to deliver this, an...

Position Paper
Eurogas’ recommendations on the extension of scope of the Union Database (UDB) to raw materials used for fuel production
Download the full Eurogas assessment and recommendations.
In this paper, Eurogas provides an assessment of the draft Delegated Regulation extending the scope of the Union Database to raw materials...

Position Paper
Joint Statement: Towards EU Due Diligence Rules that Work for All
Download the full statement.
The European Green Deal is now moving into the implementation and transposition phases which present significant complexity and therefore uncertainty. The Corporate Sus...

Position Paper
Joint Energy Associations Group recommendations for the review of the commodities market under MiFID II
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The Joint Energy Associations Group (JEAG), composed of BDEW, EFET, Eurelectric and Eurogas, has prepared energy sector recommendations for the European Commission...