Position Papers

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...
REMIT II should provide adequate implementation periods.
Position Paper

REMIT II should provide adequate implementation periods.

REMIT II introduces substantial changes to numerous REMIT provisions, for which adequate transitional periods should be foreseen. This would ensure proper implementation and compliance in the wake o...
Back-up disclosure channels would help enable energy firms manage risk effectively.
Position Paper

Back-up disclosure channels would help enable energy firms manage risk effectively.

Eurogas and cosignatories welcome that the disclosure of inside information through IIPs (Inside Information Platforms) will be regulated by the new REMIT II framework. IIPs are an essential infrast...
Biomethane imports should be automatically included in the Union Database
Position Paper

Biomethane imports should be automatically included in the Union Database

Eurogas and seven other industry organisations call on the European Commission to immediately and fully include biomethane and biomethane-based imports in the Union Database. Excluding the ce...
CCU/S technologies in NZIA are welcome, but we must also have a clear target for CO2 injection capacity.
Position Paper

CCU/S technologies in NZIA are welcome, but we must also have a clear target for CO2 injection capacity.

In line with prior calls, Eurogas and the European Energy Retailers association welcome the Net Zero Industry Act's acknowledgment of the CCS and CCU supply chain as net-zero technologies. This, tog...
We need an integrated systems perspective to fully harness flexibility in the Electricity Market Design.
Position Paper

We need an integrated systems perspective to fully harness flexibility in the Electricity Market Design.

The undersigned organisations include Eurogas, Cogen Europe, EBA, EUGINE, EUTurbines, and Hydrogen Europe and represent multiple energy carriers and integrated energy solutions. While demand...
We propose the Commission prolong the Energy Platform for one year while assessing its impact
Position Paper

We propose the Commission prolong the Energy Platform for one year while assessing its impact

In line with our position paper on the extension of AggregateEU, Eurogas has signed a joint letter directed to DG ENER along with six other associations calling on the Commission to not make emergen...
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