Position Papers

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...

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...

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...

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...

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...

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...

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...

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....

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...

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...

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...

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...

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...

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...

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...

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...

Position Paper
We need a binding biomethane target for 2030
Eurogas and 48 other organisations involved in the decarbonisation of the gas industry in Europe call on the European Union to include a binding 2030 target for the scaleup of biomethane in the Hydr...

Position Paper
What role should LNG play in Europe moving forward?
Critical points were raised during the CEER/CNMC 37th Madrid Forum presentation and during the follow up discussion with Eurogas on 14 July. Let's take a look at some of the takeaways from this disc...

Position Paper
NZIA should recognise CCU as a Strategic Net-Zero Technology
Carbon Capture and Utilisation (along with Storage) is of strategic importance to reach European net-zero objectives. The technologies will enable the supply of renewable fuels and other alternative...

Position Paper
NZIA should define Sustainable Alternative Fuels technologies as Strategic Net-Zero Technologies
Driven by EU policies, demand for Sustainable Alternative Fuels will rapidly rise in years to come, and – in the absence of a suitable domestic production capacity - supply shortages would force t...

Position Paper
European Auto and Fuel industries announce new working group for monitoring methodologies for CO2-neutral fuels
In order to achieve climate neutrality in Europe’s transport sector by 2050, stakeholders representing the automotive and fuels industries have expressed their support for the start of the work by...

Position Paper
Zero-Emission Buildings: renewable energy delivered through grids is key
Eurogas and the undersigned organisations support an ambitious and cost-efficient decarbonisation of the European building stock. We need to strive for smart, efficient, integrated, and increasingly...

Position Paper
JEAG Letter on REMIT II Trialogues
The Joint Energy Associations Group (JEAG) welcomes that the EU Commission (“EC”) has tabled its legislative proposal for a review of REMIT (Regulation on Wholesale Energy Market Integrity and T...