Position Papers

Eurogas response to the European Commission’s energy security fitness check consultation
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...
Reducing, simplifying & streamlining reporting requirements under the EU Framework on Sustainable Finance
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...
STUDY | Ensuring Resilience in the European Energy Transition: Strategic Use of Gases to Meet EU Climate Ambitions
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...
Eurogas’ recommendations on the extension of scope of the Union Database (UDB) to raw materials used for fuel production
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...
Joint Statement: Towards EU Due Diligence Rules that Work for All
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...
Joint Energy Associations Group recommendations for the review of the commodities market under MiFID II
Position Paper

Joint Energy Associations Group recommendations for the review of the commodities market under MiFID II

Download the full position paper. The Joint Energy Associations Group (JEAG), composed of BDEW, EFET, Eurelectric and Eurogas, has prepared energy sector recommendations for the European Commission...
Efficient ESMA level 2 measures are needed to achieve EMIR 3.0 goals for resilient markets
Position Paper

Efficient ESMA level 2 measures are needed to achieve EMIR 3.0 goals for resilient markets

Download the full paper here. The Joint Energy Associations Group (BDEW, Energy Traders Europe, Eurelectric, Eurogas) welcomes the improvements endorsed by the EU legislators to the clearing thresh...
Eurogas’ recommendations on the low-carbon fuels delegated regulation
Position Paper

Eurogas’ recommendations on the low-carbon fuels delegated regulation

In this paper, Eurogas provides an assessment of the low-carbon fuels delegated regulation, highlighting elements that it welcomes, providing recommendations on what should be improved, identifying ch...
Joint Statement on the Low-Carbon Fuels Certification Draft Delegated Act
Position Paper

Joint Statement on the Low-Carbon Fuels Certification Draft Delegated Act

Download the full joint letter below. The co-signatories of this letter welcome the intention of the European Commission to define the necessary elements for the certification of low-carbon fuels (...
Joint Statement: Technology Openness in CO2 Emission Standards
Position Paper

Joint Statement: Technology Openness in CO2 Emission Standards

The Network for Sustainable Mobility* takes note of the emerging political debate on the decarbonisation of road transport and recognises with concern that the lack of technology openness in both regulations for light and heavy-duty vehicles severely constrains the choice of viable technologies to meet the CO2 reduction targets.
Renewable Gas Tracking Systems – Value of Biomethane Certificates
Position Paper and Report

Renewable Gas Tracking Systems – Value of Biomethane Certificates

Eurogas, in collaboration with EBA, ERGaR, and RNGC, has commissioned a report from S&P Global Commodity Insights to support revisions of the Greenhouse Gas Protocol. The report highlights the well-regulated biomethane markets in Europe and the US, demonstrating their role in reducing GHG emissions and supporting new production capacity. Key findings include the importance of RNG certification and tracking systems, the regulatory frameworks driving decarbonization, and the significant CO2 reductions achieved. Learn more by reading the full report.
The Joint Energy Associations Group (JEAG) responds to public consultation on REMIT Implementing Regulation revision.
Position Paper

The Joint Energy Associations Group (JEAG) responds to public consultation on REMIT Implementing Regulation revision.

The Joint Energy Association Group (JEAG) has submitted its response to the public consultation by the Agency for the Cooperation of Energy Regulators (ACER) on the revision of the REMIT Implementing...
Greening Corporate Fleets should embrace Sustainable Alternative Fuels including Biomethane
Position Paper

Greening Corporate Fleets should embrace Sustainable Alternative Fuels including Biomethane

Eurogas strongly encourages the European Commission to consider the role of all sustainable alternative fuels to decarbonise the road transport sector. In addition, the EC should focus on fostering th...
Industry publishes joint recommendations for Low-Carbon Fuels Certification
Position Paper

Industry publishes joint recommendations for Low-Carbon Fuels Certification

Eurogas has published a joint statement on the Low-Carbon Fuels Certification Delegated Act. The co-signatories of this letter welcome the intention of the European Commission to define the necessary...
Eurogas’ guiding principles on low-carbon fuels.
Position Paper

Eurogas’ guiding principles on low-carbon fuels.

Low-carbon fuels are defined in the Gas Directive (in its most recent version, yet to be formally approved) Art. 2 and include e.g. low-carbon hydrogen (and its derivatives), i.e. hydrogen produced fr...
REMIT II Implementation should ensure Proportionality, a Tailor-Made Approach to Energy Markets and Stakeholder Consultation.
Position Paper

REMIT II Implementation should ensure Proportionality, a Tailor-Made Approach to Energy Markets and Stakeholder Consultation.

Eurogas welcomes the revision of REMIT as a necessary step to reflect the evolving energy market and further increase transparency. Over the last decade, REMIT has provided a robust legal framework, w...
Eurogas supports the Commission’s investigation into State Aid for Biomethane.
Position Paper

Eurogas supports the Commission’s investigation into State Aid for Biomethane.

Eurogas supports the Commission’s investigation on state aid for biomethane as a means to guarantee fair competition and trade of renewable gases. On 5 March, the European Commission published in...
Weights and Dimensions should incentivise both zero-emission and alternatively-fuelled vehicles.
Position Paper

Weights and Dimensions should incentivise both zero-emission and alternatively-fuelled vehicles.

Eurogas welcomes the Commission’s proposal to review the Weights and Dimensions Directive (WDD), which sets out the maximum weights and dimensions for heavy-duty vehicles (HDVs) to circulate on EU...
Eurogas & 45 other organisations call for urgent action allowing imports of biomethane and biomethane-based fuels under the UDB.
Position Paper

Eurogas & 45 other organisations call for urgent action allowing imports of biomethane and biomethane-based fuels under the UDB.

The signatories call for immediate action of the European Commission to ensure the full recognition of imported biomethane and biomethane-based fuels in the Union Database. As conveyed in Nov...
National neutrality charges will fragment the EU market and are against the Union’s spirit of solidarity.
Position Paper

National neutrality charges will fragment the EU market and are against the Union’s spirit of solidarity.

Eurogas notes with concern recent initiatives by Member States to introduce charges at cross-border points to recover the costs incurred for the emergency storage filling of 2022. Allocating...
The GHG Protocol Update should include Market-Based Accounting.
Position Paper

The GHG Protocol Update should include Market-Based Accounting.

Eurogas and 17 other organisations call on the GHG Protocol Secretariat to include market-based accounting and the recognition of low-carbon fuels certificates in Scope 1 of its GHG Protocol Update....
Eurogas Statement: US LNG exports to Europe contribute to security of supply, the energy transition and both economies.
Position Paper

Eurogas Statement: US LNG exports to Europe contribute to security of supply, the energy transition and both economies.

Europe is committed to phase out its dependency on Russian gas in the wake of Russia's invasion of Ukraine, and has tied this shift to its 2050 climate goals. In achieving both, imports of US LNG ha...
EMIR 3 trialogues: Adopt changes to the clearing threshold calculation without delay.
Position Paper

EMIR 3 trialogues: Adopt changes to the clearing threshold calculation without delay.

Eurogas and its cosignatories of the Joint Energy Associations Group (BDEW, EFET, Eurelectric, and IOGP) endorse the changes agreed by all three EU institutions to the clearing threshold calculation...
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