15 Targeted Amendments to the EU Methane Emissions Regulation to Safeguard Energy Security

IOGP Europe – together with 10 other EU-based and national energy associations – proposed 15 limited and targeted adjustments to the EU Methane Emissions Regulation’s (EUMR) importer requirements needed to safeguard Europe’s energy security. The proposed adjustments preserve the environmental ambition of the Regulation, while introducing common-sense and consistency.

 

Key amendments

Some of the key amendments include:

• Fixing the inconsistent timeline of the EUMR, whereby operators are required to comply with the EUMR importer requirements before the methodology and toolkit needed to do so are actually ready. The associations call for a conditional, time-bound delay until essential secondary legislation, Monitoring, Reporting and Verification (MRV) standards, relevant methodologies, verification protocols, minimum criteria for certification/traceability etc. are drafted, adopted, and operational so that all stakeholders – verifiers and competent authorities, accreditation bodies included – have time to develop, scale, and set up the necessary framework for compliance.
• Revising the producer- and country-level MRV equivalency criteria to preserve the ambition while grounding it in operational realities. At the country-level, no exporting country is currently deemed as equivalent to the EU standards – not even Norway, the UK and the US, which are often considered as world-leading in this area. At the producer-level, this can be done for example by recognising companies’ efforts to go from Level 4 to Level 5 of OGMP 2.0 (and not Level 5 only).
• Adjusting the penalty criteria to better reflect the physical and commercial realities of crude oil and gas markets such as commingling of molecules, crude grade constraints, and the resulting limitations in tracing molecules to specific producers. The upcoming “Recommendations on penalties” promised by the Commission, while most likely helpful, will not have the legal weight to supersede the penalty provisions in the Regulation.

“Enough time has been spent already talking about unrealistic compliance options – the work needs to start now, and it must take place in close collaboration with industry to preserve the EUMR’s ambition while avoiding de facto non-compliance and a risk to the EU’s energy supply,” said the representatives of the associations.

 

Main points

• On March 9, IOGP Europe together with FuelsEurope published the Wood Mackenzie study on the impacts of the EUMR importer requirements. The study shows that the requirements may cause a significant share of EU oil and gas imports to become non-compliant, and hence risk being deterred from the EU market, from 2027 onwards.
• On 13 April, a cross-sectoral coalition of more than 70 companies and associations, including IOGP Europe, sent a letter to the 27 EU Energy ministers calling for targeted amendments to the EUMR and a stop-the-clock.
• This call was also echoed by a group of MEPs in a letter on 10 April to the Commission President von der Leyen and Commissioner Jørgensen.
• And as an input to the Commission’s upcoming “Recommendations on Penalties”, together with industry partners on 10 April the association also issued a set of joint recommendations on penalties for the EUMR.

“Our proposed adjustments to the EUMR’s importer requirements preserve the text’s ambition while introducing common sense and consistency. If the requirements are not aligned with operational and commercial realities fast, the EU will head towards a self-inflicted, regulatory supply gap in 2027,” says François-Régis Mouton de Lostalot, IOGP Europe Managing Director.