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European Biogas Association

EBA

The European Biogas Association advocates for the recognition of biogases as sustainable energy sources.

Lobbying Activity

Meeting with Katri Kulmuni (Member of the European Parliament)

2 Dec 2025 · Biokaasut kiertoviljelyssä

Meeting with Christine Singer (Member of the European Parliament)

24 Nov 2025 · Event on Biogas

Response to Circular Economy Act

6 Nov 2025

The European Biogas Association (EBA) welcomes the European Commissions forthcoming proposal for a Circular Economy Act. Biogases systems exemplify the circular bioeconomy in action. Fully bio-based, they rely on sustainable biomass feedstocks such as sequential crops, agricultural residues, animal by-products, bio-waste, industrial organic waste, wastewater and sewage sludge. Their circularity is threefold. First, they convert biomass into renewable bioenergy used across key sectors industry, households, transport and agriculture each of which generates biomass that can be fed back to generate new biogases. In addition, both co-products contribute to closing resource loops: digestate acts as a nutrient-rich organic fertiliser that supports new biomass growth while biogenic carbon can be captured and utilised in a range of industrial applications or stored to generate carbon removals To fully unlock the potential of biogases systems, they must be recognised and supported as integrated solutions that go well beyond their function as renewable energy sources. Achieving this vision of biogases circular bioeconomy hubs requires unlocking four key pathways, to be embedded in the EU Bioeconomy Strategy and the forthcoming Circular Economy Act: 1. Steer the supply of sustainable feedstocks towards biogases systems 2. Facilitate the deployment of biogases across Europe 3. Support the adoption of digestate as a circular organic fertiliser 4. Recognise biogenic carbon as a strategic carbon capture technology and removals solution.
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Biogas Industry Urges EU Target of 100bcm by 2040

13 Oct 2025
Topic — Revision of EU energy security framework for gas and electricity systems.
Message — The association requests a binding EU target of 100 billion cubic meters of biogas by 2040, mandatory renewable gas quotas in supply portfolios, national mapping of feedstock potential, and expanded infrastructure standards covering distribution networks. They argue biogas strengthens energy security through decentralized European production.1234
Why — This would create a clear investment signal and secure long-term market demand for their industry.56
Impact — Fossil gas suppliers lose market share as domestic biogas replaces imported natural gas.78
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European Biogas Association urges technology-neutral approach to car emissions

7 Oct 2025
Topic — EU revision of CO2 emission standards for new cars and vans.
Message — The association requests formal recognition of CO2-neutral fuels like biomethane in emission standards. They advocate for a Carbon Correction Factor and a dedicated vehicle category for cars powered by certified CO2-neutral fuels.123
Why — This would give biomethane the same regulatory recognition as battery-electric vehicles and drive investment in renewable fuel production.45
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European Biogas Association urges simpler rules for renewable aid

6 Oct 2025
Topic — The Commission is revising rules that exempt certain State aid from prior notification and approval.
Message — The group requests removing restrictive feedstock lists and aid caps for small projects. They want rules to recognize co-products like organic fertilizers and captured carbon.12
Why — This would allow more biogas projects to qualify for support while reducing regulatory complexity.3
Impact — Established market players would lose the advantage they hold over innovative smaller firms.4
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European Biogas Association Urges Integration of Renewable Gases with Electrification

6 Oct 2025
Topic — EU action plan to accelerate electrification and shift energy demand from fossil fuels.
Message — The association requests explicit recognition of biogas and biomethane as key enablers of energy system integration. They want market frameworks that reward flexibility services and energy taxation aligned with dispatchable renewable energy value.123
Why — This would expand markets for their biogas and biomethane products across power, heat and transport sectors.45
Impact — Pure electrification providers face increased competition from hybrid renewable gas solutions.67
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European Biogas Association urges biomethane inclusion in EU heating strategy

6 Oct 2025
Topic — EU strategy to decarbonise heating and cooling in buildings, industry and households.
Message — The association requests that biomethane be included in the Heating and Cooling Strategy to decarbonise the gas grid and buildings. They advocate for policy instruments like green gas contracts and blending obligations to encourage market uptake. They also support hybrid heating systems that combine biomethane with renewable electricity.123
Why — This would create demand for their product and make biomethane cost-competitive with fossil fuels.45
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European Biogas Association urges simpler carbon removal certification for biogenic CO₂

19 Sept 2025
Topic — EU methodology for certifying permanent carbon removals from biogas and biomethane production.
Message — The association requests explicit recognition of biogas and biomethane in the definition of biogenic CO₂. They oppose the introduction of Do No Significant Harm principles, warning these would create over-complication with little environmental benefit. They demand full alignment with existing renewable energy rules without introducing new requirements or accounting methodologies.123
Why — This would reduce regulatory complexity and compliance costs while enabling growth of their sector.45
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European Biogas Association urges realistic rules for organic fertilisers

19 Sept 2025
Topic — The Commission is evaluating the relevance and efficiency of the Fertilising Products Regulation.
Message — The EBA recommends revising technical requirements to make nutrient thresholds achievable for digestate. They also call for simplified assessments to reduce administrative burdens on producers.123
Why — Lowering certification costs and simplifying rules would increase market uptake for biogas producers.45
Impact — Third-party certification bodies would see reduced demand for their auditing and analysis services.6
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Meeting with Christine Singer (Member of the European Parliament) and Industrieverband Körperpflege- und Waschmittel e.V.

16 Sept 2025 · Organisation of an event

EBA urges specific 2040 targets for biogenic carbon capture

12 Sept 2025
Topic — The Commission is amending the Climate Law to establish 2040 greenhouse gas reduction targets.
Message — The EBA urges the EU to endorse a 100 bcm biogases target for 2040. They recommend an EU-wide target for biogenic carbon capture and a sector-specific roadmap. They also call for a framework supporting carbon capture, utilisation, and storage.123
Why — These actions would establish biogases as a strategic asset and improve the business case.45
Impact — Fossil fuel producers lose as the EBA prioritises biogenic carbon over fossil alternatives.6
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European Biogas Association urges global recognition of renewable gas certificates

11 Sept 2025
Topic — This initiative defines the EU's global climate and energy strategy through 2029.
Message — The EBA recommends that the EU champion global harmonisation of corporate climate reporting. They urge the Commission to use diplomacy so renewable gases are credibly accounted for.12
Why — This would reduce investment risks and boost global demand for renewable gas products.34
Impact — Global accounting bodies lose control over their standards as the EU demands regulatory alignment.5
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European Biogas Association demands support for biogenic carbon capture

11 Sept 2025
Topic — The Commission is developing a legislative framework for CO2 transport and markets.
Message — The EBA requests a regulatory framework that prioritizes biogenic CO2 and establishes a traceability system. They advocate for infrastructure planning that includes small-scale producers using liquid transport.123
Why — This helps small producers overcome high transport costs and access markets more competitively.4
Impact — Fossil CO2 suppliers lose market share as biogenic alternatives receive policy priority and financial support.5
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European Biogas Association urges technology neutrality for corporate fleets

5 Sept 2025
Topic — The European Commission is proposing new rules to increase zero-emission vehicles in corporate fleets.
Message — The association requests a 'Well-to-Wheel' emission accounting approach to recognize biomethane as a zero-emission fuel. They advocate for financial incentives like grants and tax exemptions rather than rigid mandates.12
Why — This designation allows biogas producers to maintain relevance in a market shifting toward zero-emission targets.3
Impact — Electric vehicle manufacturers would lose their exclusive regulatory status as the sole zero-emission option.4
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Biogas industry urges dedicated funding for maritime and aviation fuels

4 Sept 2025
Topic — EU framework to increase public and private investment in sustainable transport fuels.
Message — The association requests dedicated funding for biogases like biomethane to decarbonize heavy transport. They propose reinvesting aviation and shipping emissions revenues into clean fuel production. Additionally, they call for faster permitting to accelerate project deployment.123
Why — These policies would reduce financial risks and increase the cost-competitiveness of biogas projects.45
Impact — Fossil fuel exporters would see reduced demand as the EU prioritizes indigenous energy.6
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Meeting with Ion Codescu (Head of Unit Environment) and European farmers and

3 Sept 2025 · Exchange of views on the Commission’s draft amendment of the Nitrates Directive on RENURE

Meeting with Dan Jørgensen (Commissioner) and

2 Sept 2025 · Water/ Energy Nexus Interaction of Water Efficiency policy and housing policies

European Biogas Association urges gas grid focus in EU package

5 Aug 2025
Topic — The consultation seeks views on accelerating the upgrade and expansion of European grids.
Message — The organization requests that renewable gases be integrated into all levels of infrastructure planning. They propose mapping production potential at a local level to optimize existing pipelines. They also suggest expanding the criteria for cross-border projects to include broader system benefits.123
Why — This approach ensures the long-term utility and value of existing gas infrastructure.4
Impact — Supporters of total electrification may see their policy priority and funding reduced.5
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European Biogas Association urges EU ports to prioritize bio-LNG

24 Jul 2025
Topic — The European Union is developing a strategy for port competitiveness and energy transition.
Message — The EBA calls for including inland ports in all EU marine greening strategies. They request policy support to close infrastructure gaps for renewable gas refueling.12
Why — This enables the biogas industry to scale up supply using existing infrastructure.3
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Response to EU industrial maritime strategy

24 Jul 2025

The European Biogas Association (EBA) welcomes the Commissions Initiative for an EU Industrial Maritime Strategy to help the maritime industry transition to a decarbonised, digitised, and competitive sector based on zero-emissions and clean technologies. As outlined in the Commissions CfE document, the maritime industry plays a pivotal role in strengthening EU competitiveness and economic security. Yet, as recognised by the Commission, the maritime industry remains a hard to decarbonise sector that requires scalable and readily available sustainable solutions in order to meet the climate ambitions, while maintaining operational and cost efficiency. In addition to this, inland navigation and transportation play an equally important role in decarbonising the shipping industry and must be therefore included in the scope of all Union wide marine greening strategies. In this context, the uptake of sustainable renewable fuels, particularly biomethane and bio-LNG, is critical in advancing the decarbonisation of the maritime and inland waterway industry. Bio-LNG offers a readily available and cost-effective solution to reduce greenhouse gas emissions in the shipping sector by up to 93% (based on a Tank-to-Wake approach). Unlike many alternative fuels, bio-LNG can be used immediately in existing LNG-fueled vessels without modifications to marine engines, storage, transport, or bunkering infrastructure, allowing shipowners to reduce emissions without major investments in repurposing procedures. With 638 LNG-fueled vessels in operation globally in 2024 a 33% increase over the previous yearand a projected increase of LNG-fueled vessels and LNG carriers in operation and on order by over 2,000 vessels by 2028, bio-LNG is a ready-to-use, scalable option to defossilise the current and future LNG fleet while leveraging existing infrastructure. Overall, biomethane and bio-LNG are a perfect drop in fuel for LNG vessels and offer the potential for reaching carbon-negative emissions. This aligns with the Clean Industrial Deals ambitions to bolster energy security and affordability, while also ensuring industrial competitiveness and climate neutrality. In addition to this, the Net-Zero Industry Act recognises biomethane as being part of the strategic net-zero technologies pool, which the EU aims to bolster through increased manufacturing capacity, speedy and simplified permitting procedures and consumer-oriented support schemes. That said, cost competitiveness is at the forefront of bio-LNG, as it leverages existing LNG infrastructure for bunkering, storage, and distribution while avoiding high costs of infrastructure and technology repurposing.
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Biogas association urges inclusion of all digestate types

16 Jul 2025
Topic — Identifying waste streams with potential for the recovery of critical raw materials.
Message — The association requests that all types of digestate be recognized for their recovery potential. They also strongly urge the Commission to classify nitrogen as a critical raw material.12
Why — This would allow the biogas sector to valorize its by-products and support strategic resource autonomy.3
Impact — Non-EU fertilizer exporters could lose market share as Europe reduces reliance on external nutrient sources.4
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Meeting with Christine Singer (Member of the European Parliament)

14 Jul 2025 · Dinner proposal - Circular Economy of Biogas

Meeting with Agnese Dagile (Cabinet of Executive Vice-President Raffaele Fitto)

24 Jun 2025 · Accelerating the deployment of critical technologies in energy sector.

European Biogas Association urges prioritization of biogas in bioeconomy

23 Jun 2025
Topic — A consultation on creating a circular, climate-neutral, and competitive European bioeconomy strategy.
Message — The organization requests that the EU prioritize the allocation of biomass for biogas production. They want biogas recognized as a circular hub that provides renewable energy, organic fertilizers, and carbon capture solutions.12
Why — The proposals would secure feedstock supplies and create new profit opportunities for biogas producers.34
Impact — Synthetic fertilizer manufacturers may lose market share as the EU promotes bio-based organic alternatives.56
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Response to European Affordable Housing Plan

3 Jun 2025

The recognition of biomethane as a renewable energy source is central to ensuring that affordable and sustainable housing solutions can be delivered across Europe, particularly for vulnerable populations and lower- to middle-income households. This makes biomethane a flexible, readily available and cost-effective solution to cut CO emissions and accelerate the shift to a carbon-neutral building stock, together with building-renovation plans and renewable electricity. The EBA welcomes the Commissions Initiative for a European affordable housing plan as an opportunity to recognise energy flexibility and affordability within the buildings sector, thus enabling a just transition for citizens living in the EU. Given the Commissions Call for Evidence (CfE), EBA would like to outline the following actions to be taken into consideration ahead of the publication of the draft European affordable housing plan. As outlined in the Commissions CfE document, the Initiative will aim to deliver affordable heating options without requiring costly infrastructure transformations. Biomethane, a green natural gas energy resource, needs to be acknowledged as a readily available and decarbonised solution to the EUs energy system. In fact, it can be added to existing gas networks, storages and appliances, reducing upfront costs for households. To stimulate market demand for biomethane, market-based instruments like green gas contracts, blending obligations and biomethane purchase agreements must be incorporated and promoted to increase investment in housing and energy systems that are both cost-competitive and environmentally responsible. These mechanisms will make it easier for households to access renewable and affordable heating options, while aligning with the Commissions objective to deliver cost-competitive, low-emission heating. In the current context of peak demands and grid congestion, biomethane can play a pivotal role in supporting a more integrated, flexible, and resilient energy system, which is essential to delivering on the Commissions objective of affordable housing for all. Indeed, heating homes is different from other types of energy use it is seasonal and directly linked to weather conditions. Space heating mostly relies on fossil fuels, and during cold seasons, the demand can far exceed the capacity of the electricity grid. By integrating hybrid heating systems, which combine biomethane with renewable electric heating, housing providers can ensure that heating needs are always met without requiring prior grid reinforcements, while simultaneously reducing energy costs and enabling customers to select the most affordable decarbonised energy available. This flexibility is particularly important for vulnerable populations who may face higher energy bills due to fluctuating electricity prices. Ensuring that renovation strategies adopt a technology-neutral approach towards heating appliances allows for renewable gases like biomethane to complement electrification and protects consumers from price vulnerabilities. Lasty, despite its clear potential, biomethanes contribution to the defossilisation of buildings is still underacknowledged in EU legislation, hence putting barriers to future market access, despite its recognition in the Energy Performance of Building Directive. As the EU moves towards zero-emission buildings by 2030 and plans to phase out standalone fossil-fuel boilers by 2040, failure to account for renewable gases risks excluding valuable and cost-effective solutions. Without legal clarity and regulatory inclusion of biomethane consumption in buildings, consumers and suppliers will face uncertainty, hence undermining investment and deployment of renewable gas. The European affordable housing plan is an opportunity to recognise biomethane as a viable and affordable energy vector to increase energy efficiency and low-carbon solutions in the buildings sector.
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Meeting with Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra)

24 Apr 2025 · Presentation of the Offtakers Declaration on Sustainable Biomethane for Europe’s Green Transition

Meeting with Daniel Attard (Member of the European Parliament)

23 Apr 2025 · Industrial Action Plan for the Automotive Sector

Meeting with Yannis Maniatis (Member of the European Parliament)

14 Apr 2025 · Introductory Meeting

Meeting with Christine Singer (Member of the European Parliament)

26 Mar 2025 · Biogas

Meeting with Giorgio Gori (Member of the European Parliament)

25 Mar 2025 · Role of biogas in the transition

Response to European Water Resilience Strategy

4 Mar 2025

The European Biogas Association (EBA) welcomes the European Commissions initiative to develop a Water Resilience Strategy (WRS) including a Water Efficiency First principle. This strategy represents an important step toward securing the competitiveness of the water, energy and agricultural sectors. Due to its cross-sectoral scope, the WRS may involve complex trade-offs, making it essential to ensure that policy decisions do not result in higher energy consumption, increased greenhouse gas emissions or negative effects on food security or biodiversity. Biogases plants are closely connected to water in several ways. First, anaerobic digestion is an integrated step of urban and industrial wastewater treatment, helping to reduce sludge volumes while generating renewable energy. Second, all biogases plants, regardless of the feedstock used, require process water, for instance to adjust the dry matter content of the substrate mix before digestion or to cool down the process. Third, the co-product of anaerobic digestion, digestate, can be treated with specific technologies to produce clean water and its long-term application to soil can enhance water retention. Lastly, biogases producers are also often farmers, who rely heavily on water abstraction to sustain food production. EBA wishes to present two recommendations to increase the impact of the Water Resilience Strategy: 1. Recognise the water efficiency of biogases systems and encourage voluntary practices that promote water sobriety and circularity 2. Acknowledge digestate's role in contributing to water retention and propose a renewed approach to address water pollution. Find more information in our attached position paper.
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Meeting with Catherine Geslain-Laneelle (Director Agriculture and Rural Development)

25 Feb 2025 · Role of agriculture in biogas production

Response to Implementing Act on non-price criteria in renewable energy auctions

20 Feb 2025

EBA appreciates the European Commissions efforts to integrate sustainability and resilience into the auction system for renewable energy deployment. EBA particularly supports the general principles of Article 3, notably that non-price criteria should: Reflect the market maturity of the technologies addressed. Be designed by involving relevant interested market participants. Avoid creating insurmountable and unjustified entry barriers and disproportionate costs. However, adjustments are needed to ensure that biomethane projects are fairly evaluated and that compliance requirements are proportionate, particularly for smaller producers. 1. Ensure RED compliance is sufficient for carbon footprint assessment of biogases (Article 8) 2. Expand Circular Economy criteria to recognise additional circular dimensions (Article 9) 3. Introduce simplified compliance for SMEs in sustainability criteria (Articles 10-13) 4. Ensure energy system integration criteria are inclusive of gaseous systems (Article 15) 5. Expand resilience contribution criteria to incentivise local sourcing (Article 7)
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Response to List of net-zero technology final products and their main specific components

20 Feb 2025

Biogas and biomethane production facilities are inherently complex, relying on a wide range of specialised components. However, the Commissions current draft takes a simplistic approach to defining main specific components and final products in this sector. This creates a risk of limiting the positive effects of the NZIA on our manufacturing supply chain and, more broadly, on the EUs ability to strengthen its global leadership in biogas and biomethane technologies. We urge the Commission to revise its approach to ensure a more comprehensive and effective technological coverage. Please find attached our recommendations.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

This Delegated Act, which is a crucial step in ensuring the effective implementation of the Net Zero Industry Act (NZIA). The depth of the NZIAs impact on net-zero technology supply chains will largely depend on the definition of final products and specific components set out in this Act. Biogas and biomethane production facilities are inherently complex, relying on a wide range of specialised components. However, the Commissions current draft takes a simplistic approach to defining specific components in this sector. This creates a risk of limiting the positive effects of the NZIA on our manufacturing supply chain and, more broadly, on the EUs ability to strengthen its global leadership in biogas and biomethane technologies. We urge the Commission to revise its approach to ensure a more comprehensive and effective technological coverage. Recommendation 1: Biomethane and biogas as energy products should be added in the final products for the following technologies: Sustainable biogas and biomethane technologies Landfill gas technologies Sewage treatment plant gas technologies Recommendation 2: Additional specific components should be added in the categories of - sustainable biogas and biomethane technologies -landfill gas technologies -sewage treatment plant gas technologies -CCS technologies Please find attached our full feedback.
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Response to Implementing Act for guidelines on strategic projects

20 Feb 2025

The European Biogas Association (EBA) supports the issuance of guidelines for the implementation of certain selection criteria for net-zero strategic projects. Clear guidelines are essential for smooth implementation by national authorities and giving equal opportunities to project developers across EU countries. The EBA appreciates the European Commissions efforts in drafting the guidelines. Yet improvements are necessary to enhance clarity, accessibility, and consistency in the implementation of the Net-Zero Industry Act. This response should be read in conjunction with the EBAs answer to the draft Delegated Act on specific components. Please find attached our full comments.
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Meeting with Jens Geier (Member of the European Parliament)

4 Feb 2025 · Exchange on follow up initiatives of the Gasmarket Package

Meeting with Antonella Sberna (Member of the European Parliament)

29 Jan 2025 · Biogas e Biomethane: Soluzioni Green per la Competitività e la Sostenibilità dell'UE

Meeting with Li Andersson (Member of the European Parliament)

29 Jan 2025 · Biogas

Meeting with Raúl De La Hoz Quintano (Member of the European Parliament)

22 Jan 2025 · Introduction

Meeting with Martine Kemp (Member of the European Parliament)

22 Jan 2025 · Introduction Meeting

Meeting with Pilar Del Castillo Vera (Member of the European Parliament)

22 Jan 2025 · Energy

Meeting with Kris Van Dijck (Member of the European Parliament)

22 Jan 2025 · The role of biomethane in the transition towards climate-neutral and competitive industries

Meeting with Radan Kanev (Member of the European Parliament) and Gas Distributors for Sustainability

21 Jan 2025 · European Energy Forum dinner- Technology neutrality for an efficient energy system integration

Meeting with Aurelijus Veryga (Member of the European Parliament)

21 Jan 2025 · Biogas and Biomethane: Their Role in Achieving EU Climate Neutrality

Meeting with Silvia Sardone (Member of the European Parliament, Committee chair)

21 Jan 2025 · ENVI COMMITTEE

Meeting with Dario Tamburrano (Member of the European Parliament)

21 Jan 2025 · Priorità per la legislatura

Meeting with Aurel Ciobanu-Dordea (Director Environment) and

16 Jan 2025 · Contribution of the European Biogas Association to the development of environmental policy

Meeting with Fotini Ioannidou (Director Mobility and Transport)

15 Jan 2025 · Introducing the potential for EU policies of the biogases.

Meeting with Asger Christensen (Member of the European Parliament)

15 Jan 2025 · Biogas

Meeting with Annalisa Corrado (Member of the European Parliament) and Solar Heat Europe/ESTIF

15 Jan 2025 · Renewable Energy

Meeting with Kristian Vigenin (Member of the European Parliament)

14 Jan 2025 · Contribution of biogas and biomethane to the EU’s climate neutrality objective

Meeting with Benoit Cassart (Member of the European Parliament)

12 Dec 2024 · Prise de contact

Meeting with Elsi Katainen (Member of the European Parliament)

11 Dec 2024 · Ilmastopolitiikka

Meeting with Bruno Tobback (Member of the European Parliament)

10 Dec 2024 · The role of biomethane in the transition towards climate-neutral and competitive industries

Meeting with Sophia Kircher (Member of the European Parliament)

9 Dec 2024 · Vehicle emission targets

Meeting with Rosa Serrano Sierra (Member of the European Parliament) and Bolt

9 Dec 2024 · Priorities for European Commission 2024-2029

Meeting with Sander Smit (Member of the European Parliament) and TotalEnergies SE

6 Dec 2024 · ENVI

Meeting with Radan Kanev (Member of the European Parliament)

2 Dec 2024 · Clean energy

Meeting with Norbert Lins (Member of the European Parliament)

21 Nov 2024 · Biogas and biomethane in Europe

Meeting with Maria Grapini (Member of the European Parliament)

21 Nov 2024 · Renewable energy

Meeting with Nina Carberry (Member of the European Parliament)

20 Nov 2024 · EU Energy Policy

Meeting with Valérie Hayer (Member of the European Parliament)

20 Nov 2024 · Biogas

EBA Urges Tracking Exemptions and Delayed Deadlines

7 Nov 2024
Topic — This consultation addresses extending the Union Database scope for renewable and recycled fuels traceability.
Message — The association calls for extending the implementation deadline for gaseous fuels to twelve months. They also request exempting producers under 2 MW capacity. They propose increasing reporting windows for transaction data to three months.123
Why — The sector would avoid technical disruptions and reduce administrative costs for small operators.4
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Meeting with Eero Heinäluoma (Member of the European Parliament) and Westenergy Oy

15 Oct 2024 · Ajankohtaisaiheet

Meeting with Stefan Köhler (Member of the European Parliament)

15 Oct 2024 · Politischer Austausch

Meeting with André Rodrigues (Member of the European Parliament)

3 Oct 2024 · Apresentação do sector do biogas europeu

Meeting with Jeannette Baljeu (Member of the European Parliament)

24 Sept 2024 · Biogas and biomethane

Meeting with Grégory Allione (Member of the European Parliament)

23 Sept 2024 · Réunion European Biogas Association

Meeting with Isabella Tovaglieri (Member of the European Parliament)

5 Sept 2024 · Future of European biogas policies

Meeting with Barry Andrews (Member of the European Parliament)

5 Sept 2024 · Sustainability

Biogas industry urges clearer rules for zero-rating and subsidies

26 Jul 2024
Topic — This consultation updates monitoring and reporting rules for the EU Emissions Trading System.
Message — EBA requests defining the same gas grid as the interconnected European network. It demands an end to restrictions on using subsidized biomethane within the ETS. The group also calls for the recognition of negative emissions from non-fossil sources.123
Why — Harmonized rules would eliminate market distortions and provide regulatory certainty for biogas operators.45
Impact — Member States lose control over domestic subsidy schemes and carbon accounting across different regulations.6
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Biogas group seeks special recognition for biogenic carbon storage

16 Jul 2024
Topic — The consultation defines requirements for considering carbon dioxide permanently chemically bound in products.
Message — The group requests a clear distinction between biogenic and fossil carbon sources. They also want biochar included as a form of permanent storage.12
Why — The sector would profit from their low-cost carbon being prioritized in regulations.3
Impact — Fossil fuel processors would face a competitive disadvantage under these proposed rules.4
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Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

4 Jul 2024 · Alternative Fuels - Biomethane and Biogas

Response to Commission Directive amending Annex III of the Nitrates Directive

16 May 2024

The European Biogas Association (EBA) welcomes the opportunity to provide feedback on the updated rules on the use of certain fertilising materials from livestock manure (RENURE). The Commission proposal to amend the Nitrates Directive (Council Directive 91/676/EEC) recognises the advancements in manure processing techniques, which have enabled the production of manure-derived fertilisers which are as environmentally safe as synthetic fertilisers. To address the lack of playing field between synthetic and organic fertilisers, promote on-farm circularity, and foster greater fertilizer autonomy, the Commission suggests granting Member States the authority to allow certain RENURE fertilisers above the limit of 170 kg of nitrogen per hectare per year. However, the Commission proposal diverges from the technology-neutral approach outlined in the initial study by the Joint Research Center (JRC) . Instead, the Commission proposal permits only three post-treatments and their respective end-products: ammonium salts (scrubbing salts), mineral concentrates and nitrogen-rich phosphate salts (struvite). Today, certain fertilisers derived from manure, including digestate from manure, not only exhibit equal or even lower nitrogen leaching levels than synthetic fertilisers, but also thanks to their valuable stable organic matter, enhance soil structure and water holding capacity, consequently minimising nutrient runoff. However, despite being as environmentally safe as their synthetic counterparts, these fertilizers face a hurdle: the discriminatory limit of 170 kg of nitrogen per hectare per year in Nitrate Vulnerable zones. This limit applies indistinctively to all nitrogen-based fertilisers derived from manure, unlike synthetic fertilisers. This prevents farmers from substituting carbon-intensive synthetic fertilisers by organic alternatives between 170 kg and the nitrogen requirement of each crop. As part of the targeted revision of the Nitrates Directive, EBA urges the European Commission to allow the safe use of all RENURE fertilisers above the limit of 170 kg of nitrogen per hectare per year, i.e. all fertilisers compliant with the criteria included in the Commission proposal, such as certain digestates. EBA wishes to propose several recommendations (outlined in the attached detailed feedback) aimed at enhancing the effectiveness of the directive, ensuring environmental protection while fostering the circular fertilisers market and reducing reliance on synthetic fertilisers in line with the objectives of the European Green Deal.
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Meeting with Caroline Nagtegaal (Member of the European Parliament) and International Road Transport Union Permanent Delegation to the EU and

16 Apr 2024 · Biomethane in road transport

European Biogas Association urges higher nitrogen limits for digestate

7 Mar 2024
Topic — The European Commission is evaluating rules protecting water from agricultural nitrate pollution.
Message — The EBA calls for allowing digestate use above the 170 kg/ha/year nitrogen limit. They request support for technologies that recover nutrients from manure and digestate.12
Why — This change would help biogas producers replace synthetic fertilizers with organic digestate.3
Impact — Manufacturers of carbon-intensive synthetic fertilizers would see reduced demand for their products.4
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Response to Guidance to facilitate the designation of renewables acceleration areas

22 Feb 2024

The European Biogas Association welcomes the opportunity to provide feedback on the European Commission initiative to provide guidance to Member States on designating renewables acceleration areas. By 21 February 2026, Member States are required to designate renewables acceleration areas for one or more types of renewable energy sources, in accordance with the revised Renewable Energy Directive (Directive (EU) 2023/2413). The European Commissions initiative will include practical advice on the initial steps, existing good practices and mapping tools that can help identify and designate renewables acceleration areas, targeting only wind and solar energy sources. However, Article 15c of the revised Renewable Energy Directive refers to various types of renewable energy sources. Based on this, EBA urges the European Commission to include biogas and biomethane in the guidance on designating renewable acceleration areas. Please find the extended version of EBA reply in attachment.
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Meeting with Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson)

20 Feb 2024 · State of play on biogas and biomethane production in Europe

Meeting with Beatrice Covassi (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and

15 Nov 2023 · Public Hearing - Soil Monitoring Law

Meeting with Maria Noichl (Member of the European Parliament, Rapporteur for opinion) and European Compost Network ECN e.V.

15 Nov 2023 · Soil health

Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

15 Nov 2023 · Soil Health Law

Meeting with Manuela Ripa (Member of the European Parliament, Shadow rapporteur)

7 Nov 2023 · Soil monitoring and resilience directive

Meeting with Bert-Jan Ruissen (Member of the European Parliament, Shadow rapporteur)

30 Oct 2023 · Soil Monitoring Law

European Biogas Association urges binding targets for soil health

2 Oct 2023
Topic — New EU law establishing a framework to monitor and restore healthy soil conditions.
Message — The association calls for binding soil targets and faster implementation of regeneration practices. They want the law to promote digestate application as a sustainable management tool.12
Why — Legally recognizing digestate would turn biogas byproducts into valuable, policy-supported agricultural fertilizers.3
Impact — Synthetic fertilizer producers may lose market share as policy shifts toward circular organic alternatives.4
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Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur)

29 Sept 2023 · Soil health Law

Meeting with Mohammed Chahim (Member of the European Parliament)

14 Sept 2023 · Bio gas

Meeting with Nils Torvalds (Member of the European Parliament)

13 Sept 2023 · Soil Monitoring Law

Meeting with Heléne Fritzon (Member of the European Parliament)

12 Sept 2023 · Möte med European Biogas Association

Meeting with Patrizia Toia (Member of the European Parliament, Shadow rapporteur)

12 Sept 2023 · Hydrogen and Gas Regulation

Response to Amendment of the EU ETS Monitoring and Reporting Regulation (MRR) in response to the ETS revision/Fit For 55

22 Aug 2023

The European Biogas Association welcomes the opportunity to provide feedback on the draft Implementing Regulation amending Commission Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions. Please find the full version of the reply in the attached file.
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Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson)

26 Jul 2023 · Role of biomethane in modelling

European Biogas Association urges alignment with Renewable Energy Directive

7 Jul 2023
Topic — Consultation on sustainability reporting standards for company disclosures on climate and environment.
Message — The EBA requests market-based accounting for Scope 1 and 3 emissions. Reporting should align with existing laws and include proofs of sustainability.123
Why — This preserves the market value and tradability of biomethane certificates.45
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Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson), Stefano Grassi (Cabinet of Commissioner Kadri Simson)

22 Jun 2023 · EBA Statistical Report 2022; new Biomethane Map; Biomethane Week 2023

Biogas industry urges EU to set binding production targets

25 May 2023
Topic — Proposed EU regulation to scale up domestic manufacturing of clean energy technologies.
Message — The organization recommends setting a binding biomethane production target. They also want to include production plants as strategic manufacturing projects. Finally, they seek recognition for biogenic carbon capture as a strategic technology.123
Why — This status provides priority permitting and better access to public financing.45
Impact — Fossil fuel suppliers lose market share as renewable gases replace industrial carbon.6
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Biogas Industry Urges Recognition of Biomethane in HDV Rules

19 May 2023
Topic — The Commission is reviewing CO2 emission standards for new lorries, buses, and coaches.
Message — The EBA requests a Carbon Correction Factor to recognize biomethane's decarbonization potential. They advocate for technology neutrality to keep internal combustion engines in use.12
Why — The biogas sector maintains its market position and protects investments in gas-powered vehicle technology.3
Impact — Electric vehicle manufacturers lose their exclusive policy advantage over other low-carbon transport technologies.4
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European Biogas Association calls for streamlined EU Taxonomy rules

2 May 2023
Topic — The consultation establishes sustainability criteria for economic activities under the EU Taxonomy Regulation.
Message — The organization requests a single manufacturing category for biogas to resolve inconsistencies and attract investment. They also advocate for including nitrogen recovery and removing restrictive feedstock thresholds for bio-waste treatment.123
Why — Clearer rules would help the sector attract green investments and meet REPowerEU production targets.45
Impact — Synthetic fertilizer manufacturers could face increased competition from sustainable alternatives like recovered nitrogen.6
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European Biogas Association urges clearer taxonomy for biomethane investments

2 May 2023
Topic — Establishing criteria for sustainable investments contributing to European Union environmental objectives.
Message — The group wants a single classification for biogas production regardless of how the gas is ultimately used. They also propose including nitrogen recovery in the circular economy rules to provide alternatives to expensive synthetic fertilizers.12
Why — Simplified rules and clearer categories would help the sector attract necessary green financing for growth.34
Impact — Synthetic fertilizer producers may lose market share to sustainable nutrient recovery alternatives.5
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and ExxonMobil Petroleum Chemical and

25 Apr 2023 · Energy, environmental and digital challenges of our time

Meeting with Deirdre Clune (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and

29 Mar 2023 · Stakeholder Consultation on Urban Waste Water Treatment Directive

European Biogas Association urges flexible wastewater energy rules

13 Mar 2023
Topic — The European Commission is revising the Urban Wastewater Treatment Directive to protect human health and the environment.
Message — The EBA requests that energy rules allow plants to generate renewable energy both onsite and offsite. They also want new mandates to boost the market for fertilizers made from recovered sewage nutrients.12
Why — These measures would secure a larger market share for biogas technologies and increase production potential.34
Impact — Traditional mineral fertilizer producers would face increased competition from recycled organic nutrient alternatives.5
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

9 Mar 2023 · REPower EU

Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur)

22 Feb 2023 · Urban wastewater treatment

Meeting with Nils Torvalds (Member of the European Parliament)

12 Jan 2023 · methane

Meeting with Jens Gieseke (Member of the European Parliament)

15 Nov 2022 · Austausch zur Energiepolitik

European Biogas Association Urges Simpler Rules for Organic Fertilizers

24 Oct 2022
Topic — The draft regulation defines when animal by-products in fertilizers no longer require official controls.
Message — EBA requests aligning the regulation with existing fertilizer standards to remove redundant sanitation requirements. They seek recognition for alternative transformation parameters to facilitate the trade of digestate across the EU.12
Why — Streamlining these rules would reduce compliance costs and expand market access for biogas producers.34
Impact — Synthetic fertilizer manufacturers could face increased competition from more accessible organic digestate products.5
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans) and Gas Distributors for Sustainability

19 Sept 2022 · CO2 standards for trucks

Meeting with Barbara Thaler (Member of the European Parliament, Rapporteur for opinion) and TotalEnergies SE and

6 Sept 2022 · RED

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and Gas Distributors for Sustainability and

6 Sept 2022 · CO2 Standards for heavy duty vehicles

Meeting with Jerzy Buzek (Member of the European Parliament, Rapporteur) and Climate Action Network Europe and

19 May 2022 · Meeting on gas and hydrogen regulation

European Biogas Association urges recognition of biogenic CO2 removals

2 May 2022
Topic — The European Commission is proposing a regulatory framework for certifying carbon removals.
Message — The group seeks a certification mechanism covering biogenic CO2 storage and sustainable farming. They demand harmonization with existing energy laws to ensure the system remains practical. They also call for rules allowing certificate trading on voluntary carbon markets.123
Why — This would create new revenue streams for biogas producers by monetizing their carbon-capturing by-products.4
Impact — Fossil-fuel based manufacturers would face increased competition from newly incentivized recycled bio-based materials.5
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Meeting with Jens Geier (Member of the European Parliament, Rapporteur) and WindEurope and

28 Apr 2022 · Exchange on the gas market directive

European Biogas Association urges update to EU Nitrates Directive

26 Apr 2022
Topic — EU initiative to reduce nutrient pollution and stimulate recovered fertiliser markets.
Message — The association wants the Commission to update the Nitrates Directive to distinguish digestate from raw manure. They advocate for digestate as a sustainable alternative to energy-intensive chemical fertilisers.12
Why — Removing application limits on digestate would expand the market for biogas co-products.3
Impact — Producers of synthetic chemical fertilisers face reduced demand for fossil-fuel-based products.45
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

25 Apr 2022 · Keynote speech

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and Common Futures. Energy Transition Specialists B.V.

13 Apr 2022 · Biomethane potential in Europe

European Biogas Association urges binding EU biomethane targets and grid access reforms

12 Apr 2022
Topic — EU regulation on internal markets for renewable and natural gases and hydrogen.
Message — The association requests an EU target for 20% GHG intensity reduction in gas supply by 2030, EU-wide right to inject biomethane into networks, and cost-sharing rules for grid connections. They argue current proposals lack ambition needed to deliver 35 bcm biomethane production target.123
Why — This would accelerate biomethane market integration and reduce financial burdens on producers, particularly farmers.45
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European Biogas Association urges EU framework for rapid biomethane scale-up

12 Apr 2022
Topic — Revision of EU gas market rules to facilitate renewable and low-carbon gases.
Message — The association requests clear biomethane definitions, EU-wide grid connection rules, and cost-sharing with network operators. They propose a 20% GHG intensity reduction target for gas supply by 2030 and greater transparency in biomethane disclosure to consumers.1234
Why — This would reduce connection costs and financial burdens, enabling faster biomethane market integration.567
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

The EBA recommends that: 1. The EPBD takes stock of the different economic development levels, geographic characteristics, energy mix as well as the climate of Member States when introducing provisions to advance building sector defossilization. 2. Gas technologies should not be considered fossil since they can use renewable gas. The EU legislation should recognise the role of renewable gases such as biomethane and bioLPG in future-proof gas-based technologies. 3. Use of locally produced biomethane in heating should be incentivised to promote the local circular economy and social acceptance of the energy transition. 4. The development of “smart buildings” should be supported – this would contribute to the energy system optimisation by shifting demand between renewable gas and electricity in times of peak demand. 5. For an affordable and cost-effective energy transition of building heating, energy efficiency improvements through renovation wave should be combined with mixed technology approach where gas technologies complement electrification of heating. 6. The contribution of renewable gases to address the dual challenge of energy security and climate change should not be underestimated as the local production potential is substantial and large enough to meet a reduced demand in gas for heating. In this context, ruling out gas technologies from the buildings would be expensive, as they are renewable-gas ready, are often the most cost-effective, faster, and easier solution to retrofit. The European Biogas Association remains open to dialogue and collaboration to improve the Commission’s proposal and to share with the co-legislators the expertise and experience of our members.
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Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur) and Elengy

9 Mar 2022 · Austausch zur EU-Verkehrspolitik

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Arla Foods amba and Common Futures. Energy Transition Specialists B.V.

23 Feb 2022 · Biomethane

Response to Count your transport emissions: CountEmissions EU

11 Dec 2021

The EBA considers as important the development of a common framework to calculate and report transport-related greenhouse gas emissions. We acknowledge that the task is demanding and laborious. We do not ignore that the development of the PEF calculation method by the JRC took 10 years. One of the most determinant issues is how to use the calculation method. The discussions on how and where the method should be used should take place once the method has been developed. The assumptions of the calculation method should be comprehensive and technology-neutral and the method should be based on accurate data. Without this, the results of the calculation will not be precise and cannot be extrapolated, certainly not in legislative obligations. Another aspect to consider is the potential overlapping with other pieces of legislation already in place to limit CO2 emissions of fuels and vehicles: REDII for renewable energy (life-cycle; CO2 and other environmental impacts), Regulations of CO2 performance standards for vehicles (use phase; only CO2), ETS for maritime and road transport (use phase; only CO2), energy tax directive (production and use phases; CO2 and other environmental impacts). In order to have zero-emission in transport, overall control on the emissions over the whole life cycle of the product/service is needed. However, at present, there is no comprehensive management of transport emissions. The legislation is being developed and split between different Directorates-General of the European Commission. Please find attached the full feedback to this Initiative.
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Response to Revision of Alternative Fuels Infrastructure Directive

16 Nov 2021

The European Biogas Association (EBA) has been an active member of the Commission’s Sustainable Transport Forum assisting in implementing and fostering the deployment of alternative fuels infrastructure. We have likewise supported the Alternative Fuels Infrastructure Directive as a technology-neutral piece of legislation helping the EU to reduce its oil dependence. However, over the past few years, the focus has been gradually shifted from all alternative clean fuels to electricity only which we truly regret, given that there are other fuels available in Europe, such as bio-CNG and bio-LNG that can help Europe to achieve zero or even negative levels of CO2 emissions. The artificial and unilateral support for e-mobility, through the biased tailpipe approach, can jeopardize the EU’s objectives to truly decrease the emissions of the transport sector and to get rid of third country dependence. Any life-cycle analysis of e-mobility can prove that it causes GHG emissions over the manufacturing of engines, well-to-tank (over 40% of the European electricity supply is still fossil) and in the recycling phase. A recent comparison of the JRC also shows that from all combinations of fuel/energy carriers and powertrains explored, biomethane represents one of the absolute lowest greenhouse gas intensive routes . Biomethane and other advanced biofuels are critical to meet the EU’s climate challenged and AFIR is needed in the transition from fossil to biofuels. Biomethane is available right here and now, across Europe, and its production levels can be easily scaled up to ensure ample future supply. It is also among the most affordable advanced biofuels and bio-CNG allows also citizens with low and middle income to have access to low-carbon mobility. We agree that the CNG and LNG infrastructure may be in some countries market-driven but in order to ensure the required uptake in all Member States to meet the EU’s climate objectives, the Regulation should still oblige Member States to fill gaps also in the main CNG networks. As bio-LNG will need to play an essential long-term role in maritime and heavy-duty road transport sector, it is important that the European Commission keeps reviewing the sufficiency of the core LNG network, also after 2025. EBA welcomes the provision in Recital 5: The use of fossil gaseous or liquid fuels is only possible if it is clearly embedded into that is in line with the long-term objective of climate neutrality in the Union, requiring increasing blending with or replacement by renewable fuels such as bio-methane, advanced biofuels or renewable and low-carbon synthetic gaseous and liquid fuels. Such decarbonization pathways should be included in the legal requirements of the Regulation. CNG and LNG infrastructure also serves the rapidly increasing share of bio-CNG and bio-LNG sales and Member States that are committed to reach at least 40% bio share in their transport gas mix by 2030 – leading to GHG savings of 55% - should be encouraged to continue developing the corresponding infrastructure in their long-term plans. However, these decarbonization pathways should be equally required when electricity, ammonia or hydrogen are deployed: in many Member States, the electricity supply is still mostly fossil with a very high carbon footprint while the transport gas mix is in several Member States, including the Nordic countries and the Netherlands, close to 100% renewable. Biomethane deployment can reach higher emissions savings than any electricity or hydrogen. For these reasons, also the Article 2 (Definitions) should make a difference between fossil and renewable electricity, hydrogen and ammonia. Fossil energy cannot lead to zero-emission mobility!
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Response to Revision of the Energy Tax Directive

15 Nov 2021

Reforming of the Energy Taxation Directive is essential to set up a European framework conducive to the fast uptake of renewable energies by European citizens, businesses and the public sector. A successful reform will provide strong positive price signals to shift to renewable energies, especially renewable gases, such as biomethane. By 2050, EU’s domestic biomethane supply of biomethane can alone serve 40% of the future gas consumption. Based on the proposal published by the European Commission in July 2021, the European Biogas Association wishes to put forward the following recommendations to the European Parliament and the Member States: 1. Set a level playing field in minimum taxation levels reflecting environmental performance of fuels and of electricity sources Some minimum taxation levels that are proposed are not consistent with the expressed goal to ground the taxation structure in environmental performance of fuels and electricity: a. “Sustainable food and feed crop biogas” in 2033 is taxed at the same level as fossil fuels. b. Electricity is taxed at the lowest level whatever its source and the GHG emissions of its production. Electricity generated by fossil fuels would have a minimum taxation level 35 times less than the sustainable biogas in 2023 and 71 less than fossil fuels. c. The minimum taxation level of “renewable fuels of non-biological origin” (RNFBO) is not associated with GHG emissions savings criteria. 2. Use categories of biogases, biofuels and RFNBOs that are based on the Renewable Energy Directive 2018/2001 and taxation minima consistent with their sustainability requirements Four biogas types are present in the proposal and definitions are neither clear, nor consistent with the Renewable Energy Directive 2018/2001 (“RED II”). Such proposal would bring legal confusion. 3. Give biohydrogen the lowest minimum taxation level, like for hydrogen of non-biological origin (RFNBO) We recommend setting a level playing field for all sources of green hydrogen, including biohydrogen from sustainable biomass. The legislators should coordinate their reform of the ETD and the RED II to ensure this integration in a legally consistent manner. 4. Ensure that Member States can still exempt sustainable renewable fuels from excise duty We recommend having tax exemptions of Article 16 applicable to biogas compliant with sustainability requirements of the RED II, and not just to “advanced biogas” (i.e. biogas made from feedstocks of Annex IX – Part A of the RED II), and to all end-uses of biogas. The ETD should give Member States flexibility to implement tax reductions or exemption for renewable energies, knowing the State Aid Rules already regulate this kind of measures to ensure they are compatible with the internal market. 5. Strive to agree on a new ETD because this revision is essential to send a positive price signal for renewable gases The on-going negotiations among Member States are an opportunity to set up urgently a taxation framework that reflects climate performance of renewable fuels and that will lead to a faster substitution of natural gas by renewable gases. We urge Members States to agree without delay on a new ETD because the text is essential for a positive price signal for renewable gases such as biogas. 6. Clarify the possibilities for Member States to adapt the structure of minimum tax levels The proposal of the Commission is ambiguous about the extent to which Member States can adapt the structure of minimum tax levels. This should be clarified. Please find our full recommendations in the attached document The European Biogas Association is the voice of renewable gas in Europe since 2009. The association counts today on a well-established network of over 200 national organisations, scientific institutes, and companies from Europe and beyond.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

Please find attached EBA's feedback.
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Response to FuelEU Maritime

8 Nov 2021

The European Biogas Association (EBA) warmly welcomes the European Commission’s ambitions to increase the share of renewable fuels in the maritime transport fuel mix, thereby strengthening the measures taken at the international level by IMO. The proposed Regulation rightfully establishes a level-playing field between different fuels by finally introducing a well-to-wake approach that ‘provides a more complete picture of the environmental performance of the various energy sources’ (Recital 16). This exemplary basis to calculate true GHG emissions should be immediately extended also to the road transport sector. Given that the Regulation proposes to calculate the GHG emissions on a well-to-wake basis, it is difficult to understand why electricity shall still have a zero-emission factor (Annex I). This is not technology neutral or in line with the current GHG balance of the European electricity supply: over 40% of the EU’s electricity is still sourced from fossil energy and thus far way from reaching zero GHG emissions, even more so if a full life-cycle approach is taken into account. Therefore, we call the EU institutions for correcting this biased element in the Annex distorting science-based emissions calculations: the emissions of electric maritime mobility must be likewise calculated on a well-to-wake basis. Bio-LNG is certainly the most viable fuel helping to decarbonize the maritime and heavy-duty road transport sectors. It can rely on production capacity of biomethane that is available and scalable today all over Europe (sustainable potential to replace 30-40% of natural gas consumption in Europe), it can be used in LNG engines without any modification – at the moment, 1/3 of the vessels use LNG as a fuel – and transported, stored and bunkered in ports utilising existing LNG infrastructure. Finally, it comes along with multiple benefits to our climate, environment and society reducing GHG emissions by up to about 92% compared with fossil LNG in the combustion cycle and improving air quality with virtually no SOx while dramatically limiting emissions of NOx. Bio-LNG has a long-term role to play in the European energy supply and the value of its production, increasing physical blending with fossil LNG and consumption should be acknowledged and supported by the EU institutions on a level-playing field with electricity and hydrogen. As the proposal states, it is important that there will be a basket of measures supporting the decarbonization of the shipping sector. Furthermore, the legislative framework must be coherent. It is of utmost importance that the revision of the RED including the Annex IX as well as the introduction of the implementing act on voluntary schemes will be designed suitable also for gaseous fuels. New sustainable biogas feedstock, such as sequential silage cropping, must be added to the Part A of Annex IX in order to avoid any capping of renewable gas potential in Europe. Tracking and tracing of biomethane should be tailor-made for gaseous fuels. RED III should propose in clear terms a Guarantee of Origin system resulting in certificates that could be traded separately from the physical gas molecules – across all member states of the EU – as soon as the renewable methane is either liquified or injected in a grid. Finally, also the European taxonomy under the Sustainable Finance framework should be supporting the cleanest fuels, like bio-LNG, in a technology-neutral manner, based on well-to-wake emissions. Finally, we request that MRV requirements for all energy carriers are commensurate with the administrative burden and scientific rigor reflected in the upcoming proposal on Methane fugitive emissions. For instance, if the said proposal introduces full lifecycle requirements for gaseous fuels, such requirements should also be introduced for liquid fuels.
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Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

Please find attached the feedback of EBA including links to supporting studies.
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Biogas industry urges EU to prioritise biogenic CO2 over fossil sources

7 Oct 2021
Topic — EU policy on carbon removal certification and sustainable carbon farming practices.
Message — The association requests preferential treatment for biogenic CO2 from biogas across EU legislation. They want urgent reforms to industrial emissions trading rules to credit CO2 avoidance, mandatory disclosure of CO2 origins in products, and financial support for innovation in biogenic CO2 technologies.1234
Why — This would create new revenue streams from CO2 capture and extend their circular economy business model.567
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and Guidehouse Netherlands B.V. and Gas for Climate

9 Sept 2021 · Progress made in the establishment of a European biomethane alliance and priorities

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and Gas Distributors for Sustainability and NGVA Europe

8 Mar 2021 · EU taxonomy, draft delegated act

Meeting with Henrik Hololei (Director-General Mobility and Transport) and Gas Distributors for Sustainability and NGVA Europe

4 Mar 2021 · Sustainable and Smart Mobility Strategy

Response to Proposal for a legislative act on methane leakage in the energy sector

26 Jan 2021

EBA welcomes the European Commission’s efforts to reduce methane emissions in order to achieve the required GHG emissions savings by 2030 and 2050. As the EU’s Methane Strategy indicates, anaerobic digestion (AD) plays a major role preventing these emissions from agriculture, waste management and also the energy sector. The biogas industry is therefore a large net reducer of methane emissions per se and methane emissions related to AD itself are minimal (according to voluntary or mandatory measurements made in several European countries), nevertheless they must be avoided. The OGMP initiative developed for the oil and gas industry is difficult to adapt to the biogas sector that includes mostly small farm-based plants (that are there to prevent methane emissions). We are in favour of a common initiative also in the biogas sector but it would need to be dedicated to the sector. We therefore suggest the following model for a European voluntary scheme, based on the existing national schemes, to minimise methane emission from biogas, reasonably adapted to the size of the plants (less obligations for smaller plants): • Step 1: Operators required to have a plant description with critical control points, which can serve as a check list in regular rounds on the critical points. • Step 2: Detection of leaks via in situ gas sensor or imaging technology across entire site (e.g. handheld, vehicle). • Step 3: Measurement and quantification. The measurement frequency should be established depending on the size of the plant. • Step 4: Short-term (2025) and long-term (2040) reduction targets aiming at driving down the emissions to a certain level set by the voluntary schemes. A central European body should be established to collect and aggregate data and set targets with linked certification schemes. However, before such scheme is established, the following preparatory work should be carried out: • EU funding allocated to a follow-up of the EvEmBi project to investigate BAT especially on quantitative measurements and to further synchronise the already existing (national) voluntary schemes (expected 2-3 years). • In the meantime, EBA will collect data from voluntary schemes around the EU and report to the Commission. Finally, we want to remind and underline the importance of AD helping to avoid emissions of several key emitting sectors (agriculture, waste management, energy) as stated in the EU Methane Strategy (2020) and the role of digestate in substitution of fertilizers produced from fossil resources. The biogas sector is still young and needs political support to realise the full potential of its environmental benefits. With regard to the policy options, we opt for 2.b: Sector coverage including upstream, midstream and downstream gas and oil (OGMP 2.0).
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Response to Climate change mitigation and adaptation taxonomy

14 Dec 2020

Compared to the initial TEG report, improvements were made, but unfortunately this taxonomy does not sufficiently support all solutions needed to reach carbon neutrality. Biogas and biomethane are key solutions for decarbonization with multiple positive externalities and needed to integrate intermittent renewables in the energy system. Even a zero-emission society will need a source for methane and biocarbon. Qualifying sustainable biogas/biomethane as a ‘transitional’ activity, excluded from RD&I, and thus treating it differently from other renewables is certainly not justified. The delegated act on taxonomy should include: • No additional requirements regarding the sustainability of bioenergy going beyond the current sustainability criteria as introduced by the RED II (and adopted by the EU’s ordinary legislative procedure) – currently under implementation in the Member States. o ‘Manufacture of biogas/biomethane’ from agricultural or forestry feedstocks is considered a ‘transitional activity’ even if it complies with sustainability criteria of RED II (2018/2001). This is not acceptable as biogas/biomethane are long-term decarbonization solutions in particular for “hard-to-abate” sectors where electrification is too expensive or unfeasible. o For biogas production used in transport, a gas-tight cover on the digestate storage is applied whatever the feedstocks used. This additional constraint on biogas/biofuel production for transport is incoherent and not practical, as biomethane installations injecting in the network do not know about the end-use. When it comes to the digestate storage, the taxonomy should refer to the RED II. o The threshold of GHG emissions savings from biomethane in heat production should be fully aligned with RED II (70% savings instead of 80% for installations starting operation from 01/01/2021 until 31/12/2025) o The co-digestion of waste and agricultural feedstock should not be limited. • A definition for ‘low-carbon gases’. The draft taxonomy qualifies conversion/retrofit of existing natural gas networks to 100% of hydrogen or other low carbon gases. At least all renewable gases (including biomethane) should be under the scope to support a truly sustainable transition of the gas sector. It should be explicitly mentioned that connecting biomethane plants to the gas network qualifies a sustainable activity. • No technology-biased approach qualifying only ‘zero-emission’ (tailpipe) vehicles and vessels sustainable as of 2025. The European electricity supply is – and will most probably remain for the next 10 years – to a large extent fossil and emissions related to the battery production must be considered. 100% electrification will thus not result in decreased CO2 emissions by 2030. On an LCA-basis, bio-CNG and bio-LNG can reduce emissions by more than 100% (JEC 2020) and biomethane plays a key role preventing the EU’s methane emissions in waste management and agriculture. In water transport, bio-LNG is clearly one of the few viable options that are available today. It can be used in existing LNG engines and transported, stored and bunkered in ports utilising existing LNG infrastructure. Bio-CNG and bio-LNG together with their infrastructure and vehicles/fleets/vessels should therefore clearly qualify for the ‘green’ category mitigating climate change. Public transport and fleets of public authorities running on biomethane should also be included, with reference to the CVD 2019/1161. • No restrictions on the use of renewable gas in heating of buildings as this is not coherent with the criteria on biogas production and jeopardizes the needs of the energy system (flexibility) and of different building types and climate zones. Therefore criteria on the manufacture of heating systems should only refer to ‘the top energy labelling classes’ and the Ecodesign Directive. Installation, maintenance and repair of heat pumps should take in gas and hybrid versions as the latter can also use renewable energy.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

In order to reach climate neutrality by 2050, the EU must massively deploy renewable energies across all sectors: in addition to renewable electricity supply, also hard-to-abate sectors that are difficult to electrify, such as certain heavy industries and transport sectors, must be gradually de-fossilised – however in the same way as fossil electricity, also fossil gas enables the development of its renewable counterpart and plays therefore an important role in the short- and mid-term. Not all renewable energy sources are already able to compete on a level-playing field against fossil energy, due to the relatively low carbon price in most EU countries and the ongoing subsidies flowing to high-carbon fossil energy sources. Moreover, positive externalities of biogas/biomethane in particular are not sufficiently internalized and it is difficult to do so in practice. Therefore, in addition to gradually removing fossil fuels subsidies and the necessary (rapid) increase of the EU’s carbon price, state aid for renewable energy is still required for many renewable energy sources over the next years. When these support systems for renewable energy sources are designed, it must be kept in mind that not one size fits all: bioenergy requires operating aid and particularly biogas is unique also in terms of versatility and positive socio-environmental externalities. It can significantly reduce the EU’s methane emissions in agricultural and waste management sectors while producing renewable gas and/or power to fuel energy, transport and industrial sectors. Biogas upgraded to biomethane can make use of the existing gas infrastructure and appliances without any limitations. The sector creates thousands of sustainable jobs, also in rural areas supporting rural development and innovation. The secondary product, digestate, can be applied as a bio-fertiliser helping to make farming practices more sustainable. Biogas production fully contributes to a resource-efficient circular economy, also along the food value chain. All these benefits must be kept in mind when support systems are designed. Moreover, biogas and biomethane are dispatchable energies that help to better integrate intermittent renewables in the system. Biogas and biomethane are thus complementary to wind and solar which require back-up and therefore, these may not be compared on a simple LCOE basis. Technology-specific tendering and subsidy schemes are necessary. The EU taxonomy (the draft delegated act) fails to understand the synergies between different policies and sectors, putting forward a very limited, technology-biased approach that favours electricity and hydrogen. These energy carriers, when produced from renewable sources, are not sufficiently available today or in the short-term, probably not even in the long-term for all sectors. All sustainable and renewable fuels and technologies, based on life-cycle emissions, should be allowed to contribute to emissions savings according to a model based on sector integration. Therefore, we would be against the proposal asking Member States to identify the contribution to environmental protection based on the EU Taxonomy. When it comes to sustainability of bioenergy, the Guidelines should be aligned with the sustainability criteria in the Renewable Energy Directive. Europe needs a stable policy framework including State Aid Guidelines that are aligned with all cross-sectoral EU strategies and the existing legal framework like the Renewable Energy Directive and the possible schemes that its revision may put forward to reach targets or quotas on demand or supply of renewable energy.
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Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

EBA welcomes the efforts of the European Commission to revise the existing legislation to achieve the required 90% emissions reduction in the transport sector by 2050. To make this necessary green transition in the transport sector, the EC must understand the interlinkages between different sectors and tap into all available sustainable options, as in most other EU legislation: AFID, RED II and FQD (gaseous fuels will likely be included in the scope.) These Directives pursue technology neutrality which is sorely needed to ensure a fast, safe and affordable transition. However, alternative fuels cannot be deployed if the vehicle manufacturers are required to focus unilaterally on e-cars. Unfortunately, this inception IA gives the impression that this technology biased approach will be further strengthened. The release of fossil CO2 has a cumulative effect and must be prevented. Relying on electricity only presents major drawbacks: - Electricity production is, to a large extent, still fossil based and all projections show that this will still be the case in the coming next years. The choice of 100% electrification will thus not result in decreased CO2 emissions by 2030. - a too high dependence on a single technology and supply sources creates high risks: need to produce and recycle an enormous quantity of batteries, this without full clarity on its impact on environment, costs and European industry. - The current CO2 emission standards force car manufacturers to focus only on electric vehicles, which puts in danger the efforts of various Member States to reduce their transport emissions by advanced biofuels. Alternative renewable fuels such as bio-CNG (and bio-LNG) are already available and affordable. They can reduce emissions by more than 100% (JEC 2020), improve air quality by reducing NOx emissions and particulate matter. NGVs are produced in Europe and cause less noise pollution than conventional petrol or diesel cars and have often a much longer range than electric ones. The share of bio-CNG in the transport gas mix is continuously increasing in Europe being currently at 17%. In all the Nordic countries and the Netherlands, the share is well above 50%. Additionally, bio-CNG and bio-LNG can rely on the existing infrastructure without massive investments – as in the case of e-mobility. Finally, renewable methane can also support electrification: the use of methane enables large scale deployment of renewable electricity since power-to-gas provides a cost-efficient solution to store excess electricity in the form of renewable methane. The potential of sustainable biomethane production is enormous: a minimum of 1000-1200 TWh by 2050 (according to several recent studies). In 2030, 40% biomethane will be easily available to power the entire NGV fleet which is currently estimated at over 13 million vehicles. This will already result in an overall GHG emissions reduction of 55%. With supportive legislation, the share could be further ramped up. The EU must realise, and translate into its legislation, the close link between vehicle and fuel legislation. EBA understands that an LCA approach to vehicles may not be realistic before 2030, but this must be the ultimate aim. In the meanwhile, we urge the European Commission to incorporate a voluntary crediting system, or any other possible tool like recognising biomethane as a non-CO2 contributor - on equal footing with electric mobility - as only biogenic CO2 is emitted, in the European legislation. If this is not done at this stage, low carbon fuels’ contribution to the CO2 emission reduction will be lost and citizens with low and middle income lose their access to low-carbon mobility. Thus, we urge the EC to create a level-playing field between all low-carbon fuels and technologies. Relying on the CO2 emissions reduction only at tailpipe level – without making a difference between fossil and biogenic CO2 - is not sufficient to ensure the shift to carbon neutral mobility.
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European Biogas Association demands binding renewable gas targets

21 Sept 2020
Topic — Review of the Renewable Energy Directive to meet 2030 climate goals.
Message — The association calls for a binding 11% renewable gas target by 2030 and specific capacity goals. They also seek simplified trading rules and the removal of transport sector multipliers.123
Why — Harmonized trading rules and binding targets would resolve regulatory uncertainty and boost demand.45
Impact — Battery producers would face new ethical sourcing, durability, and recycling performance requirements.6
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Response to Sustainable and Smart Mobility Strategy

10 Jul 2020

EBA calls the European Commission to finally adopt a technology-neutrality approach on transport fuels if it really wants to speed up the decarbonization. For truly a sustainable transport sector in Europe all technologies will need to play a role. Transport is in fact the only sector which is not decarbonizing but shows even an increase in the GHG emissions on a yearly basis since 2014. The deployment of electric vehicles and related infrastructure is crucial but will not be enough to decarbonise all sectors of transport, including heavy-duty and maritime, and in a fast and cost-effective way. The need for further actions to reduce emissions in the transport sector must be addressed without delay. Biomethane is available as of today and can contribute to speed up transport decarbonization in the coming years and make sure its economic benefits remain in the EU. The advantages of renewable gas are backed by a significant scale-up potential. A recent study from CERRE estimates the EU could produce 124 bcm (approximately 1211 TWh) renewable methane. In transport, this potential can be tapped with already available technologies: Biomethane is already being used in gas vehicles in Europe. The share of renewable energy in transport in the EU was 8.6% in 2018 whilst the share of biomethane in gas fuelled cars accounted for 17%. Also, the fuelling infrastructure is growing: according to NGVA Europe, there were in 2019 50% more LNG stations in Europe compared to 2018, while LNG powered heavy-duty vehicle registrations nearly tripled in 2018- 2019. Also, the number of CNG stations grew by more than 300 units in 2018-2019 resulting in 3732 stations at the end of 2019. However, only e-mobility benefits for targeted legislative support, such as super-credits under the article 5 of Regulation (EU) 2019/631. Important to mention that alternative fossil fuels such as CNG, LNG and LPG have environmental benefits compared to conventional fuels such as low NOx emissions and they enable the gradual transition to their renewable counterparts. In comparison with petrol and diesel, natural gas generates already a GHG emission reduction that can go above 23%. GHG emissions of natural gas vehicles become close to zero, or even negative, when considering biomethane pathways. Also with bioLPG it is possible to achieve CO2 reductions of up to 80% compared to conventional LPG, dependent on the feedstock used. Recently, Spain has recognized the positive effects of biomethane and has set the CO2 contribution of biomethane fuelled cars to “0” in a Tank-to-Wheel (TtW) approach. This is in line with the initiatives implemented in other countries, such as Sweden, which recognizes the great potential of biomethane in the transport sector. The use of renewable gases has large additional environmental benefits. Apart from the substantial improvement of air quality by lowering NOx emissions and particulate matter, renewable gas provides a bridge to a circular economy, one of the top priorities of the European Green Deal. As biomethane is embedded in the society, it can help cities and municipalities to establish a local and circular bioeconomy in by integrating waste management and local renewable energy production. In the light of the COVID-19 situation, it is more important than ever to have local and resilient value chains. Furthermore, biomethane is a corner stone towards agro-ecology by increasing biodiversity, soil health, food security and promoting resource efficiency and minimizing mineral fertilizer. It further stimulates rural economy development and provides localized green jobs. This production process provides the lowest greenhouse gas emissions when measuring lifecycle emissions of vehicles and fuels compared to any currently known energy source in the automotive industry. Biomethane can thus contribute to a significant reduction of greenhouse gas emissions, particularly in sectors that are outside the EU ETS, such as transport and agriculture.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

12 Jun 2020 · Role of biogas in climate neutral energy sector

Response to Evaluation of the Alternative Fuels Infrastructure Directive

20 Mar 2019

Using biomethane for transport improves air quality and can lead to carbon neutrality (when 80% of the gas mix is renewable). Renewable methane is already produced in increasing volumes in most European countries; the technology is mature and biomethane profits also from the existing natural gas infrastructure in Europe. Biomethane can therefore play a crucial role already in the short term in transport sectors such as shipping and trucking that cannot be easily electrified. The legislation at EU level is necessary to accelerate the switch to alternative fuels EU-wide. However, the Members States’ implementation at national level, including planning and coordination on biomethane’s infrastructure, has not been sufficient. The measures introduced are not concrete enough to be effective and the national plans should not focus on individual fuels; all alternative fuels are needed to decarbonise the transport sector. Binding targets, set at the EU level, for filling stations per each alternative fuel would be necessary. We expect the binding mandate for advanced biofuels in the new Renewable Energy Directive to create demand for gas-driven vehicles and it is important that it is supported by sufficient filling infrastructure for both CNG and LNG. Additionally, it would be important that the life-cycle emissions of fuels would be always considered in all legislation, also when future CO2 standards for vehicles are set. The tailpipe approach does not acknowledge the climate benefits of renewable fuels.
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Response to Prolongation of State aid rules reformed under the State aid modernisation package that expire by the end of 2020

7 Mar 2019

The new sustainability criteria on biomass fuels was introduced by the Renewable Energy Directive (EU) 2018/2001. These criteria and the upcoming delegated act on high and low iLUC biofuels should be followed when deciding on the continuation of the operating aid to biofuels. The old approach making the difference simply between advanced biofuels and ‘food-based biofuels’ should not be applied any longer.
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Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

16 Nov 2016 · sustainability policy on bioenergy

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

9 Nov 2016 · future development of renewable gas

Meeting with Dominique Ristori (Director-General Energy) and WindEurope and

21 Jun 2016 · European renewables industry

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

15 Dec 2015 · Biogas

Meeting with Jyrki Katainen (Vice-President) and European Compost Network ECN e.V. and

16 Nov 2015 · Circular Economy

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

19 May 2015 · Circular Economy

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

9 Jan 2015 · STATE OF PLAY AND OUTLOOK OF THE EUROPEAN BIOGAS SECTOR, COMMISSION PRIORITIES IN ENERGY AND CLIMATE POLICY

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

9 Jan 2015 · Le rôle du biogaz dans l'union énergétique