European Renewable Gas Registry
ERGaR
ERGaR aims at facilitating cross-border transfers of renewable gases in Europe.
ID: 567866635144-18
Lobbying Activity
22 Sept 2025
ERGaR welcomes the opportunity to comment on the draft Delegated Act (DA) and highlights several improvements needed to ensure clarity, consistency, and feasibility for operators of biogenic CO capture and permanent carbon removal projects. First, ERGaR stresses the importance of enabling biogenic CO to be traded as a commodity. Current requirements obliging operators to identify the final user of CO in advance risk undermining a Single Market for CO. Allowing certificates to be issued once compliant storage is confirmed, supported by strict anti-fraud measures, would foster market liquidity and flexibility. Second, the DA should address the risk of double counting between RED III and CRCF. It is unclear whether biogenic CO stored via CCS in biomethane or biofuel projects counts towards RED targets or can generate CRCF units. Operators need legal certainty that they can choose only one framework. Drawing on Delegated Regulation (EU) 2023/1185 for RFNBOs and RCFs, the DA should explicitly prevent CO from receiving credits under multiple regimes. Third, ERGaR calls for harmonisation of definitions, recommending alignment of biogenic CO with the existing RED definition to avoid inconsistencies across legislation. Fourth, the DA should improve mass balance tracking by using a registry or database, reducing administrative burden and fraud risks. ERGaR points to existing Commission and national experiences as evidence of feasibility. Fifth, ERGaR proposes to extend the activity period from 10 to 20 years, reflecting the length of typical financing, support programmes, and off-take agreements. A 10-year limit creates mismatches with investment structures and could undermine project bankability. Sixth, ERGaR strongly opposes the inclusion of capital stock emissions in lifecycle calculations. These are negligible, difficult to quantify, and excluded under other frameworks (RED III, RFNBO rules). Their inclusion would create disproportionate burdens and reduce comparability. If they remain, clear thresholds and standardised emission factors are needed. Finally, ERGaR calls for proportionate sustainability requirements for biogenic CO from small or waste-based sources. Full RED III sustainability and GHG criteria should not apply to very small-scale plants or residual streams. The DA should mirror REDs thresholds to avoid overregulation, while still ensuring environmental safeguards. ERGaR urges that the DA balances environmental integrity with practical feasibility. This requires avoiding disproportionate burdens, ensuring consistency with RED III, and providing legal clarity to investors. A clear, workable, and harmonised certification system will be key to scaling up permanent carbon removals and unlocking private investment.
Read full responseResponse to Revision of EU rules on Gas
8 Apr 2022
The European Renewable Gas Registry (ERGaR aisbl) welcomes the opportunity to give feedback on the European Commission's proposal. Please find our detailed feedback in the attached document.
Read full responseResponse to Revision of EU rules on Gas
8 Apr 2022
The European Renewable Gas Registry (ERGaR aisbl) welcomes the opportunity to give feedback on the European Commission's proposal. Please find our detailed feedback in the attached document.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
18 Sept 2020
ERGaR fully supports the goal enshrined in the European Green Deal to make Europe the first climate neutral continent before 2050. We also endorse the review of the 2030 Climate Target Plan, in its efforts to increase the 2030 level of ambition for renewable energy and the greenhouse gas emissions reduction target. ERGaR believes that the revision of the EU renewable energy rules, notably directive 2018/2001/EU (hereafter RED II), will help the EU in meeting its ambitious climate goals but also in fostering the growth of a relevant economic sector.
Our association supports Option 5 of the proposed Inception Impact Assessment, as we believe that a combination of the Options 2, 3, and 4 could best serve EU’s ambitious climate agenda. For ERGaR, the investment supporting non-regulatory measures are the most important in Option 2. We recommend extending the measures contained in the Recovery and Green Deal packages with respect to green hydrogen to other renewable gases, first of all biomethane. For example, the introduction of co-financing for complex projects by the EU.
ERGaR believes that the renewable gas industry can contribute to reducing GHG emissions and greening EU’s economy to substantially higher extent than foreseen in the NECPs. We actively support the possible upward review of the 32% target for renewable energy set at the EU level. We strongly suggest the introduction of a target for renewable gases. Member States should collectively ensure that the share of renewable gases in the Union's gross final consumption natural gas in 2030 will be at least 10 %. They should set national contributions to meet, collectively, the binding overall Union target set as part of their integrated national energy and climate plans. A separate target for low-carbon gases could be set additionally.
Our association fully supports the development of a robust certification system as outlined in the Energy System Integration and Hydrogen strategies. In particular, we are convinced that the European natural gas network is key to deliver renewable gases to European consumers through the use of a mass balancing system. By applying the mass balance system, the gas consignment transferred cross-border can be counted towards meeting national renewable energy targets in the country of consumption.
To highlight the relevance of the interconnected European natural gas network as a single logistical facility for mass balancing, we propose to add to the recital 123 of the RED II the following paragraph:
“The interconnected European natural gas network (consisting of the transmission and distribution systems operated on the territory of European Union, EFTA and the European Economic Community member states) is recognised as a single logistical facility for the purpose of mass balancing injected and withdrawn renewable gas consignments. By applying the mass balancing methodology, the renewable gas consignment transferred cross-border can be counted towards meeting national renewable energy targets in the country of consumption.”
The above proposal reflects the fact that associated greenhouse gas emissions and meeting the sustainability criteria can be best documented by means of the mass balancing methodology.
Finally, we believe that reviewing the EU renewable energy rules would be a crucial opportunity to strengthen the system of Guarantee of Origin as outlined in article 19 of RED II. We fully welcome the extension of the European standard CEN-EN 16325 to other energy carriers, as announced in RED II.
We would be pleased to discuss this contribution further which we hope you will find useful.
Read full responseResponse to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)
24 Jul 2020
ERGaR fully welcomes the initiative of the European Commission to revise the Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions (hereafter MRR). It is an opportunity to introduce additional tools to incentivise and accelerate decarbonisation of the ETS sectors in a cost-efficient manner in line with the EU Green Deal principles.
Nevertheless, we may suggest to further elaborate key points of the proposal to fully reflect a needed resilient and cost-effective system:
1. ERGaR agrees with the biomass emission factor of zero as suggested in Article 38.b of the proposal. However, we want to point out that biomethane production may also result in negative emission values. In case installations can proof negative emissions, the additional efforts should be rewarded by receiving the negative emission factor.
2. ERGaR supports the proposed Article 39 to determine the biomass fraction of natural gas received from a gas network. However, we strongly recommend that one single methodology should be proposed by the regulation. Not only will it allow the development of common rules for the Members States, but it will prevent market distortions. Therefore, we propose to use the methodology as defined in Article 39.4 which determines the biomass fraction using purchase records of biogas of equivalent content. Accordingly, the second methodology based on the average gas grid biomass fraction should be fully disregarded.
3. ERGaR agrees that the biomass fraction for injected biomethane into a gas network should be based on purchase agreements along with proof of compliance with the sustainability criteria. However, we suggest to thoroughly define the term “purchase records”, especially referring to designated certificates that will ensure the proof of sustainability of biogas and the avoidance of any double counting (of incentive at production level and/or of volume at consumption level). Accordingly, we think that the revision of the MRR should be firmly in line with the implementation of the Articles 25-30 of the Renewable Energy Directive (EU) 2018/2001 (hereafter RED II) by using the mass balance system.
It is expected that the new Union database, outlined in the RED II and currently under development at DG ENER, will apply the mass balance methodology for all applications of biomethane distributed through the European natural gas network. This Union database could be the relevant instrument to apply for mass balancing in relation to the EU ETS. Furthermore, ERGaR has developed a scheme (ERGaR RED MB) for mass balancing of sustainable biomethane consignments distributed along the European natural gas network. Information and data gathered according to the ERGaR RED MB scheme may support the role of the Union database.
4. ERGaR wants to point out the need for an effective monitoring and reporting of greenhouse gas emissions particularly for biomethane on national level. ERGaR registries may offer to perform the data provision referring to mass balanced biomethane consignments since they register the relevant information on cross-border exchanges via ERGaR and document corresponding national production and consumption.
Please find our full feedback enclosed.
Thank you very much in advance for your consideration.
Sincerely yours,
ERGaR
Read full response