Position Papers

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 and MEPs: 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
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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...

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...

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...

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 (...

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.

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.

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...